Other · Germany · EU Transparency Register 244298340978-40
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Among the 1106 non-governmental organisations on this site, they rank #22 by legislative files engaged, a count of participation, not a measure of influence.
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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GISAD i.G. filed 31 positions between 4 Sept 2020 and 3 Nov 2022, across 28 of the 665 legislative files tracked here, attaching a full position paper 29 times.
> > Challenges: Gisad welcomes the European Commission’s initiative to improve the Directive on the overall efficiency of buildings. From the perspective of an overall digital strategy, the digital regulation of technical building systems is at the forefront.
Filed in German · English published by the European Commission
Gisad (Global Institute for Structure relevance, Anonymity and Decentralisation i.G.) is a non-profit institution in the process of being set up. From the point of view of Europe’s citizens, Gisad wants to develop a digital society system that can compete in systems. As early as 2017, Gisad defined in its policy programme the idea of an indicator of the structural importance of society.
Filed in German · English published by the European Commission
Gisad (Global Institute for Structure relevance, Anonymity and Decentralisation i.G.) is a non-profit institution in the process of being set up. From the point of view of Europe’s citizens, Gisad wants to develop a digital society system that can compete in systems. As early as 2017, Gisad defined in its policy programme the idea of an indicator of the structural importance of society.
Gisad welcomes the European Commission’s initiative to regulate the exchange of data by law in order to ensure respect for copyright, citizens’ sovereignty and optimal exploitation by industry. However, already in the EU’s opinion on the impact assessment of this initiative, it is clear that it is likely that it will not be possible to meet the partially contradictory objectives.
Filed in German · English published by the European Commission
Gisad’s opinion is subject to the proviso that it is part of an overall digital concept (multiple use of the same infrastructure at no extra cost). Gisad has defined three objectives on which a Digital Marshall Plan should focus: 1. The optimal processing and easy exploitation of digital data, while preserving diversity and involving all those involved in the value added in a merit-based manner. 2.
Filed in German · English published by the European Commission
Gisad’s opinion is subject to the condition that it is part of a digital whole, concept (multiple use of the same infrastructure at no extra cost). Gisad has defined three objectives on which a Marshall Plan should focus: 1. Optimal processing and easy use of digital data, while preserving diversity and suffering. ensure that all those involved in the creation of value are involved in a fair manner. 2.
Filed in German · English published by the European Commission
>>Challenges: GISAD welcomes the EU Commission's intention for a cyber resilience law. However, it is doubted that even option 5 will achieve the desired purpose. Politicians always want to regulate something after the fact, when a wrong development has been identified.
>>Challenges: GISAD welcomes the initiative to promote repair and reuse. An EU D-S to preserve democracy in the digital society must provide access for every citizen. However, many citizens do not have the financial means or still use an old, non-Internet enabled mobile phone only to make phone calls. This GISAD statement only refers to devices that are suitable for communicating via the internet.
>>Challenges: GISAD welcomes the initiative better protection for passengers. However, it is unlikely that only a legal framework can achieve the challenges in terms of optimal flexibility of travel and integration of all private and public mobility providers. GISAD has already commented on modular mobility http://gisad.eu/en-eu-initiative-multimodal-digital-mobility-services/ .
>>Challenges: GISAD welcomes the EU strategy on standard essential patents to promote digital transformation. The problems are significant and not yet fully recognised by the EU Commission. While the public sector cur-rently has no way of examining patents that are structurally relevant to society, democracy-hostile compe-tition not only has the opportunity to identify the potential of democracy-preserving patents…
I think it is the wrong way to soften data protection regulations more and more and at the same time to complicate the handling for the user for legal compliance. I refer to the GISAD statement on the Digital Euro at https://ec.europa.eu/info/law/better-regulation/have-your-say/initia- tives/13392-A-digital-euro-for-the-EU_en
>>Challenges: GISAD welcomes the EU Commission's initiative to strengthen the cross-border activities of associations. As digitalisation of society is advancing strongly, legislation should be timely and proactive in preserving digital democracy. Democracy is significantly threatened by the current digital concepts depicted in platforms.
>>Challenges: GISAD welcomes the EU Commission's initiative to promote the cross-border activities of associations. However, GISAD rejects the principle of limiting the activity to the EU territory. In the context of digital transformations, geographical borders will play an increasingly minor role. What remains are the borders of language areas and values.
>>Challenges: GISAD welcomes the intention of the EU Commission to develop and standardise ESG ratings. Already in 2017, GISAD proposed in its policy statement at https://gisad.eu/wp-content/uploads/2021/08/taking-the-economy-and-society-into-the-digital-transformation.pdf to introduce a key figure on societal structural relevance.
>>Challenges: GISAD welcomes the European Commission's initiative to strengthen victims' rights in criminal cases. GISAD has already taken an extensive position on child abuse at http://gisad.eu/en-eu-initiative-combating-child-sexual-abuse-review-of-eu-rules/ .
> > Challenges: Gisad welcomes the European Commission’s initiative to harmonise instant payments. Legislation should already take account of the new possibilities offered by the introduction of an EU-D-S. Cash is still used in many cases today because it is simple and safe and because it can be bought anonymously. In principle, cash can be replaced by digital means of payment if these conditions are met.
Filed in German · English published by the European Commission
Challenges: GISAD welcomes the EU Commission's initiative to regulate access to vehicle data. Appropriate is option 3, to impose legal requirements in addition to prescribing a list of the data. The customer can remain largely anonymous if the state of the art is exhausted. For example, 1,000 IP addresses can be made available per user, which are used randomly, as described in patent application DE102017005550 (A1).
>>Challenges: GISAD welcomes the European Commission's initiative to tackle child sexual abuse. However, GISAD has already argued extensively at https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12618-Regulation-enabling-temporary-continuation-of-specific-child-protection-measures-by-certain-communications-services- that new legislation will not be sufficient and may even counterproductively…
Gisad’s aim is to accompany the preparation of a holistic Marshall Plan, as called for by the President of the European Commission, Ursula von der Leyen. A digital approach adapted to citizens’ rights and diversity must be at the heart of the Marshall Plan.
Filed in German · English published by the European Commission
> > Challenges from the perspective of a European Digital System (EU-D-S): Gisad welcomes the European Commission’s initiative to create a fair and competitive digital economy. The Commission refers to G20 and OECD level initiatives to achieve a world-wide digital release. A separate EU tax makes sense only if it supports the specific objectives of the EU.
Filed in German · English published by the European Commission
Gisad welcomes the European Commission’s initiative on tax avoidance. Digitalisation has increased tax avoidance. Global digital companies are based in one tax-free country and generate value creation in another country. This opinion only takes into account the situation of digital companies that generate their turnover using the internet.
Filed in German · English published by the European Commission
>>Challenges: GISAD welcomes the initiative to improve the quality of corporate reporting. GISAD has already comment-ed on https://gisad.eu/eu-initiative-nachhaltige-unternehmensfuehrung/ and https://gisad.eu/de-eu-initiative-ein-moderner-eu-rahmen-fuer-die-unternehmensbesteuerung/ in this context. In the context of digitalisation, business models are becoming increasingly complex and opaque to inves-tors.
>>Challenges: GISAD welcomes the initiative of the EU Commission to standardize photovoltaic modules, inverters and systems. GISAD does not see it as its task to deal with the details of legal regulations. GISAD develops general principles and recommendations from the perspective of an EU Marshall Plan, which should be into account taken in the legislation. GISAD negates 1. “no action” or 2.
Gisad welcomes the European Commission’s initiative to offer capital market products that are transparent in risk, understandable in the use of capital and directly beneficial to citizens. To this end, it is necessary to establish generally binding standards that guarantee the quality of the products created by the capital of the companies.
Filed in German · English published by the European Commission
>>Challenges: GISAD welcomes the EU Commission's initiative to establish a space-based system for secure communications. Even though the threat environment is constantly changing, there are some basic prerequisites for sustainably increasing cyber security. GISAD believes that promoting individual components such as a space-based system is the wrong way to go.
GISAD welcomes the European Commission’s initiative to increase transparency in political advertising and communication. GISAD does not see it as its task to express its views on the harmonisation and simplification of legislation.
Filed in German · English published by the European Commission
Challenges: GISAD welcomes the Commission's initiative to modernise digital company law. The European digital society will be successful if the EU offers a unique selling proposition and a competitive advantage over other economies. The European Commission has several steering options at its disposal, such as tax breaks, subsidies or guarantees, to strengthen a common single market.
Challenges: In the various European countries there is a different speed of enforcement of eGovernment. These dif-ferences are related to general security concerns in digitalisation. Many citizens do not have so often to contact authorities for that digitalisation of public infrastructure can offer them a real advantage.
>>Challenges: GISAD welcomes the European strategy against abusive litigation. The issue is a top priority for GISAD. The EU Commission have evidence that companies seeking to promote a civil liberties-friendly internet, are being severely hampered. Only then is it plausible that Europe has completely lost the B2C internet market to foreign gatekeepers.
>>Challenges: GISAD welcomes the ex-post evaluation of the European Regional Development Fund and Cohesion Fund. As GISAD itself did not participate in the funds, only indications can be given which should be taken into account in the evaluation in the context of the future orientation. The COVID-19 pandemic is forcing many companies and regional policy to rethink.
> > Challenges: Gisad welcomes the European Commission’s initiative to simplify elections for mobile citizens. In a digital concept, there must be no fundamental distinction between local, European and European Parliament elections. In order to avoid double elections, every citizen should be free to choose a main place of residence in the EU, regardless of the EU country in which he/she is born.
Filed in German · English published by the European Commission
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