Sixty-nine consultations, and none of them where you were looking
Between 1 June and 15 August 2026, twelve EU regulatory authorities opened or ran at least 69 public consultations. Not one of them appears on the Commission's Have Your Say portal, which is where most public affairs teams do their consultation monitoring. Of the fourteen authorities whose alerting we could verify, exactly one lets you subscribe by email to new consultations. That is the European Banking Authority, and the box is called Consultations.
Method
The perimeter is the sixteen EU decentralised regulatory authorities tracked in Dixit, from ECHA and EFSA to AMLA and the Single Resolution Board. The period runs from 1 June to 15 August 2026, and every consultation counted was open on at least one day inside it. The source is each authority's own consultation pages, feeds and news listings, read by hand on 17 August 2026, then checked against Have Your Say. Twelve authorities could be enumerated exactly and produced the 69. EFSA and EASA publish consultations we could confirm but not count, their listings rendering only in a browser, and ECHA and ACER blocked automated reading entirely. The figure is a floor.
One delegated act, three authorities, three websites
On 1 July 2026, the European Banking Authority, ESMA and EIOPA each opened a consultation on selected KPIs under the Taxonomy Disclosures Delegated Act. Same delegated act, same Article 8 of the Taxonomy Regulation, same closing date of 12 August 2026. Three separate websites, three separate submission processes, and between them a single email alert you can tick.
A bank, an asset manager and an insurer with the same taxonomy exposure therefore had to watch three sites for six weeks to see the whole file. The EBA's own listing page made that harder rather than easier: for discussion papers it prints only the deadline, so its taxonomy item appears as "12 Aug 2026" with no trace of the 1 July opening. Anyone reading that page sees a closing date and assumes nothing was missed, when a six week window has in fact been running.
EIOPA has the mirror-image defect in its feed, which timestamps each item with the date the outcome was published rather than the date the consultation opened. Its 8 July 2026 entry on the valuation of liabilities arising from derivatives refers to a consultation that ran from 9 December 2025 to 20 March 2026. A monitoring rule built on that feed misdates a file by up to seven months, silently.
Volume is asymmetric, so a fixed cadence fails in both directions
The 69 are not spread evenly. The European Medicines Agency alone accounts for at least 33. The EBA follows with 15, EIOPA with 7, AMLA with 6, ESMA with 4, ENISA with 2, the Single Resolution Board with 1, the EU Drugs Agency with 1. Four authorities ran none at all.
No authority is stable over time either. ESMA opened nothing between 1 July and 17 August 2026, and nothing between 9 October 2025 and 19 February 2026, a four month gap. The Single Resolution Board planned exactly two public consultations for all of 2026, both in the first quarter, and announced both a year ahead in a December PDF: better foresight than any alert offers, and invisible to every one of them.
So a weekly check tuned to the EMA is wasted effort at the SRB, and a quarterly check tuned to the SRB misses four EBA consultations that opened and closed inside the quarter. Note too that the newest authority is among the busiest: AMLA, operational only since late 2025, had six consultations touching this window, four of them still open on 17 August, all on binding technical standards under the anti money laundering package.
What closes tends to disappear
Retrieval is where the gap becomes structural rather than annoying. The EU Agency for Railways lists 13 consultations with an unusually good filter set: year, status, opening and closing dates, all sortable. Every one of the 13 is closed and the most recent closed on 17 June 2022. Its consultation feed is genuinely consultation-specific, and every item in it is timestamped October or November 2022, from a site migration. Anyone who subscribed then has received nothing since, and no way to tell silence from breakage.
ACER's legacy archive is worse, because it is confidently wrong: it still advertises a 2021 consultations calendar and lists two 2021 references as open. The EMA keeps expired consultations under the label "Consultation open", including items whose deadlines passed on 15 June, 30 June and 31 July 2026. EFSA moved its closed consultations and the contributions received onto a platform that neither renders without JavaScript nor gets indexed, so the fastest route to a closed EFSA consultation is a search engine. The EBA archive has neither a date filter nor a status filter.
Whether you can see who else responded splits the field in two. The EBA and ESMA publish named individual responses on the consultation page, respondent by respondent. EIOPA, the SRB and AMLA do not: AMLA's closed consultations carry one line, "The consultation is closed. Results will follow." That asymmetry decides whether you can read the other side's arguments before writing your own, which is the most valuable thing a closed consultation contains.
What this changes for you
Three things you probably cannot say to your management today. How many consultations closed this quarter at the authorities with binding power over your sector, because no page anywhere aggregates them. Whether your organisation responded to the right ones, since the consultations you never saw leave no trace in your records. And what your peers argued the last time the same file came round, because half of those responses were never published and the other half sit behind an archive with no date filter.
The cost is not the missed consultation as such. It is that agency-level rulemaking is where the technical detail lands: the reporting format, the scoring methodology, the bioequivalence guidance, the threshold that decides whether your product is in scope. By the time that detail reaches a Commission act on Have Your Say, it was settled months earlier in a consultation you were not watching.
The limits of this count
A fair objection first: nobody monitors sixteen authorities, and 69 is an aggregate across a set no single team needs to follow. True, and the count is not a workload claim but a dispersion claim, which survives the objection. A financial services practitioner needs the EBA, ESMA, EIOPA, the SRB and AMLA: five sites, five alerting regimes, one email subscription between them, and the taxonomy file alone spanned three of them in six weeks.
The rest of the limits are ours. The 69 is a floor: the four authorities missing from it are not authorities without consultations. The count says nothing about the stakes of a consultation, only that it existed and was open. And each authority defines a consultation differently: the EMA's calls for scientific data are counted here because they solicit comment on a draft, which is a defensible line and not the only one.
What to do with it
List the authorities with binding power over your sector, open each one's consultation page, and record three things: the URL, what alerting exists, whether an archive exists. One afternoon, once a year, and it is the only way to know the shape of your own blind spot.
Subscribe to everything that exists and write down what does not: the EBA's consultations email box, the EMA's and EIOPA's consultation feeds, EASA's per channel feed URLs, which work but are not listed on its own RSS index page. For every authority with no mechanism, put a fortnightly reminder in the calendar to open the page by hand.
Never plan a response from a listing date. Open the consultation's own page and read the opening date there, because the listings hide it and the feeds sometimes carry the wrong one.
Archive every consultation you respond to on the day you file it: title, authority, opening and closing dates, your submission and the link. Their archives will not do it for you, and several stop working entirely.
When a delegated act touches more than one sector, check all three European Supervisory Authorities rather than the one you usually read. On the Commission side of the same problem, our study of which directorates-general publish the most consultations and which draw the most input covers 1 000 initiatives from June 2023 to May 2026, and the same reflex applies there: searching what has already closed is what tells you where a file is going.
Questions and answers
Are EU agency consultations published on Have Your Say?
No. Have Your Say publishes Commission initiatives: calls for evidence, Commission public consultations, draft delegated and implementing acts, evaluations, archived back to November 2018. The Better Regulation Toolbox treats EU decentralised agencies as stakeholders to be consulted, not as publishers on the portal. Every agency consultation in this count ran on the agency's own site.
Which EU authorities let you subscribe to new consultations?
Of the fourteen we could verify, one offers an email subscription with a consultations category: the European Banking Authority. Three publish a feed carrying consultations specifically: the EMA, EIOPA and EASA. A fourth feed, at the EU Agency for Railways, has published nothing since November 2022. Everyone else mixes consultations into general news, or offers nothing.
How long do EU agency consultations stay open?
From four weeks to three months, depending on the authority and the instrument: three months at AMLA on draft technical standards, six weeks at the EBA on its taxonomy discussion paper, four weeks at the EU Drugs Agency on its 2030 strategy. There is no common minimum comparable to the Commission's twelve week standard, which is why a monthly cadence can miss a whole consultation.
Where do you find a closed EU agency consultation and the responses to it?
It depends entirely on the authority. ESMA offers a date range filter over 515 items with named responses per consultation. The EBA publishes named respondents but has no date filter. EIOPA has a status filter but resolves comments inside final report PDFs. AMLA publishes nothing yet, and EFSA's contributions sit on a platform search engines cannot index. Assume nothing is retrievable and keep your own record.
Sources
Counts and dates verified on 17 August 2026 on each authority's own pages.
