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Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.

Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.

UK
UP KRITIS

NGO · Germany

3
files engaged
of 583 tracked
3
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
BDI
Bundesverband der Deutschen Industrie e.V.

Industry association · Germany

56
files engaged
of 583 tracked
68
positions filed
in those 583 files
20.6
declared FTE
self-declared
15
EP accreditations
as declared to the register

Declared costs: €4M+ a year · in the register since 2008

Files both filed on (3)

Amending the NIS 2 Directive as regards simplification measures and alignment with the Cybersecurity Act 2 · A high common level of cybersecurity · Resilience of critical entities

Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.

What each said, in their own words

Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.

Amending the NIS 2 Directive as regards simplification measures and alignment with the Cybersecurity Act 2

UP KRITIS · filed 1 Apr 2026 · source

The business representatives of the German KRITIS Implementation Partnership (UP KRITIS), a public-private partnership between operators of critical infrastructures and the relevant authorities with more than 1000 member organizations in Germany, want to give feedback to the 4 main topics in the revision of the Cyber Security Act (CSA2) in the attached position paper 1. Expanded ENISA Mandate 2.

Bundesverband der Deutschen Industrie e.V. · filed 20 Apr 2026 · source

German industry welcomes the European Commissions aim to significantly strengthen Europes cyber-resilience and to create a level playing field for essential and important entities across the European Union. Cyber and IT security are the basis for a long-term secure digital transformation of the state, economy and society.

Bundesverband der Deutschen Industrie e.V. · filed 24 Apr 2026 · source

The ever-increasing cybersecurity threat landscape requires both regulators, industry and operators of critical infrastructures to adopt risk-adequate cybersecurity measures. Such concrete measures should be supported by a lean regulatory framework that outlines requirements and provides companies with the necessary support framework.

Bundesverband der Deutschen Industrie e.V. · filed 25 Apr 2026 · source

The ever-increasing cybersecurity threat landscape requires both regulators, industry and operators of critical infrastructures to adopt risk-adequate cybersecurity measures. Such concrete measures should be supported by a lean regulatory framework that outlines requirements and provides companies with the necessary support framework.

A high common level of cybersecurity

Bundesverband der Deutschen Industrie e.V. · filed 10 Aug 2020 · source

German industry welcomes the European Commission’s aim to significantly strengthen Europe's cyber-resilience and to create a level playing field for operators of essential services (OES) across the European Union. Cyber and IT security are the basis for a long-term secure digital transformation of the state, economy and society.

Bundesverband der Deutschen Industrie e.V. · filed 16 Mar 2021 · source

German industry welcomes the European Commission’s aim to significantly strengthen Europe's cyber-resilience and to create a level playing field for essential and important entities across the European Union. Cyber and IT security are the basis for a long-term secure digital transformation of the state, economy and society.

UP KRITIS · filed 18 Mar 2021 · source

The members of UP KRITIS (Public Private Partnership of the German Critical Infrastructure Managers) welcomed the revision of the NIS Directive 2.0. With a view to increasing network and information security in the European internal market in an effective and cost-effective manner, we would like to draw attention to the following possible improvements to the Commission’s legislative proposal of 16.12.2020 and ask it…

Filed in German · English published by the European Commission

Resilience of critical entities

UP KRITIS · filed 31 Mar 2021 · source

UP KRITIS is a private-public partnership of operators of essential services (OES) and public authorities. This statement is the result of the business representatives (OES) in UP KRITIS , who welcome the EU project but give some points to consider. 1.

Bundesverband der Deutschen Industrie e.V. · filed 7 Apr 2021 · source

As the voice of German industry, BDI highly appreciates the opportunity to provide feedback on the European Commission’s proposal for a Directive on the Resilience of Critical Entities (COM(2020) 829). German industry welcomes the European Commission’s aim to strengthen the resilience of critical entities in the Member States and to further level the playing field for critical entities across the European Union.

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