We welcome the European Commissions initiative to introduce the Digital Omnibus package and would like to express our appreciation for the Commissions efforts to simplify the EU digital regulatory framework and ensure the effective and innovation-friendly implementation of the Artificial Intelligence Act (AI Act).
SDG
Spitzenverband Digitale Gesundheitsversorgung e.V.
Industry association · Germany · EU Transparency Register 041077193145-51
2
positions filed
in the 665 files tracked
2
legislative files
of 665 tracked
2
with a full position paper
attached to a submission
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.
Who they are
Among the 1106 non-governmental organisations on this site, they rank #686 by legislative files engaged, a count of participation, not a measure of influence.
0.6
declared lobbying FTE
self-declared
€25K+
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2024
in the register since
Declares membership of
- Deutsche Gesellschaft für Innere Medizin e.V.
- DIN Deutsches Institut für Normung e. V.
- Beirat gematik
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Non-governmental organisations
- Head office
- Berlin, Germany
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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Their record over time
Spitzenverband Digitale Gesundheitsversorgung e.V. filed 2 positions between 13 Mar 2026 and 3 Aug 2026, across 2 of the 665 legislative files tracked here, attaching a full position paper 2 times.
What they argued
SVDGV Statement: Ensuring Legal Certainty and Proportionality in the Classification of Software and AI-Based Medical Devices (MDR Reform, Annex VIII, Rule 11) The German Digital Healthcare Association (SVDGV) welcomes the Commission's proposal (COM(2025) 1023 final) to simplify the MDR and align software risk classification with actual patient risk. We raise two concerns: 1.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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Everything on this page comes from Spitzenverband Digitale Gesundheitsversorgung e.V.’s own submissions to the European Commission. We have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.
Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.