Side by side
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.
Company · Germany
Industry association · Belgium
Declared costs: €600K+ a year · in the register since 2010
Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries · Commission Implementing Decision on standard contractual clauses between controllers and processors located in the EU
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
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.
Viega Group · filed 7 Dec 2020 · source
On the Commission Implementation Decision: No feedback On the Annex: Section II, Clause 1, Module One, paragraph 1.7: The onwards transfer under sub-paragraph iii is not in line with the GDPR: Appropriate measures are concluded in Articles 45 to 50 and an agreement is not part of this.
Business Software Alliance (BSA) · filed 10 Dec 2020 · source
BSA | The Software Alliance (“BSA”), the leading advocate for the global software industry, welcomes the opportunity to provide feedback on the European Commission’s draft new standard contractual clauses (“SCCs”) for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679. We respectfully submit the comments attached in response to the Commission’s consultation on the New SCCs.
Viega Group · filed 26 Nov 2020 · source
On the Commission Implementation Decision: Article 3 should define how the evaluation of practical application is conducted. At least one method and a minimum sample size, if appropriate, should be defined. On the Annex: Clause 2 (a): States it is prohibited to modify the Clauses. However, options are to be chosen and clause 5 could be excluded what would be an modification. Options could be defined in an Annex.
Business Software Alliance (BSA) · filed 10 Dec 2020 · source
BSA | The Software Alliance (“BSA”), the leading advocate for the global software industry, welcomes the opportunity to provide feedback on the European Commission’s draft new standard contractual clauses (“Article 28 SCCs”) on the matters referred to in Article 28(3) and (4) of Regulation (EU) 2016/679.
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