We appreciate the initiative to review the Cyber Security Act in the light of current geopolitical challenges, innovation leaps and clarity with regards to partially complimentary frameworks. We in particular support the strenghthening of the role of ENISA.
VBG
VÖB / German Association of Public Banks, Director IT Security
Industry association · Germany
2
positions filed
in the 326 files tracked
2
legislative files
of 326 tracked
2
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
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Their record over time
VÖB / German Association of Public Banks, Director IT Security filed 2 positions between 11 Apr 2025 and 5 May 2026, across 2 of the 326 legislative files tracked here, attaching a full position paper 2 times.
2025 · 1 filed2026 · 1 filed
What they argued
We appreciate the further elaboration of the CRA through the technical description provided. From the perspective of financial institutions, which are already subject to a lex specialis framework under DORA, many of the outlined requirements naturally apply, given the already very high security standards fulfilled by the financial sector.
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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.
- DIGITALEUROPE · 2 files in common
- Enel SpA · 2 files in common
- ITI - Information Technology Industry Council · 2 files in common
- Microsoft Corporation · 2 files in common
- UNIFE · 2 files in common
Showing 5 of 20.
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