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When Consultants Come to Town: How the European Commission Justifies the Involvement of Private Contractors in Online Public Consultations.

Andreea Năstase and Elissaveta Radulova
p. 191-214

Abstract

Against the background of increased reliance on private contractors in European regulatory governance, this article explores how the European Commission justifies the hiring of external consultants for policy formulation purposes, particularly for organizing and analyzing the results of consultations with stakeholders and the general public. We focus on Jean-Claude Juncker’s term of office (2014-2019), a period marked by the multiplication and systematization of public consultation opportunities across the policy cycle due to the introduction of the so-called Better Regulation Agenda. The article presents and tests a novel typology of legitimation claims regarding the involvement of external consultants in regulatory policymaking, focusing on both the official institutional discourse of the European Commission and its existing administrative practice. We find that consultants are legitimized using procedural arguments. They are expected to implement the Better Regulation methodology for public consultations in an accurate and cost-effective manner, but not to innovate, adapt, or optimize the process. In other words, the purpose of hiring consultants is not to bring in external expertise unavailable in-house but rather to replace European Commission civil servants with cheaper private sector workers. In the long run, this carries the risk of eroding institutional memory and public knowledge and capabilities.

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Introduction

1Reliance on consultancy services and private contractors is a common feature of regulatory governance in Europe. For various jurisdictions, the process of contracting out is “associated with efficiency, flexibility, and expertise” (Freeman & Minow, 2009). As Dooling and Potter (2023) show, contractors perform manifold functions in the rulemaking process. These range from purely administrative tasks such as scheduling conference rooms, to substantively impactful work, such as assisting in the drafting of what will ultimately become binding regulatory text.

  • 1 We view consultants as contract-based actors who sell their knowledge and expertise to different cl (...)
  • 2 The global industry of management consulting was estimated at $900 billion in 2020-2021 (Statista, (...)

2The outsourcing of public administration tasks to private contractors is not a new phenomenon (see, for example, Howlett & Migone, 2013; Seabrooke & Sending, 2022). New, however, is the trend to employ consultants1 across the board in all sectors of government (Ylönen & Kuusela, 2019). Furthermore, while the consultancy costs reach ever-higher peaks2, paradoxically, the number of newly hired civil servants may rise as well (May 2023).

3The logic behind the consultancy services market is relatively straightforward. As Seabrooke and Sending (2022, p. 459) note, “when the benefits of acquiring external knowledge outweigh the costs of producing it internally, public administrations outsource the tasks”. More and more scholars demonstrate, however, that these alleged benefits may become (major) shortcomings over the long-term, thus revealing the Janus Face of outsourcing. For example, the continuous involvement of contractors in various critical functions “infantilizes” public authorities (Mazzucato & Collington, 2023) and limits the ability to govern by reducing the capacity for innovation (Dooling & Potter, 2023). Furthermore, increased reliance on consultants can decrease the democratic quality of rulemaking because consultants do not typically factor-in normative political debates about fairness, equality, or solidarity in their advisory reports, and prioritize technocratic arguments over values (Ylönen & Kuusela, 2019, p. 253). The term ‘consultocracy’, coined by Hood and Jackson (1991), captures well these growing concerns about the power and influence of consultants in public administration and, especially, their potentially negative effects on democracy, transparency, and accountability of decision-making in the public sector (for a comprehensive review, see Raudla et al., 2024).

4These multiple misgivings about the impact of consultants on the functioning of democratic political systems represent the starting point for our study. Specifically, we aim to take stock of how the involvement of consultants is discussed (i.e., discursively constructed) and legitimized (i.e., rendered politically acceptable) in public administration. Implicit in this set of questions is the assumption that democratically functioning public authorities must explain and be held accountable for their choices (in this case, outsourcing some of their work to private parties). Moreover, in light of the potential shortcomings outlined above, the usual functional justifications for using consultants (i.e., time and resource efficiencies) seem insufficient and unsatisfactory, if not outright superficial. Therefore, we aim to map out the theoretically conceivable and in-practice-used arguments that account for consultants’ involvement. Through this research effort, we will reflect on the adequacy of public authorities in providing legitimate justifications if/when they outsource.

5The jury is still out when it comes to balancing the benefits and shortcomings of involving external contractors in public policy-making. It is therefore important to consider the rhetorical justifications and (normative) arguments for using consultancy services in public policy processes. This subject is gaining attention in the scholarly community (see Galwa & Vogel, 2023; Nikolova et al., 2009; Seidenschnur et al., 2022), but it remains underexplored and necessitates the collection of empirical evidence from different jurisdictions. This study aims to contribute to the debate by examining the European Union (EU) as a case study.

6The EU is a political system that is often accused of having a democratic deficit (Follesdal & Hix, 2006; Kohler-Koch & Rittberger, 2007; Holzhacker, 2007) and it is therefore investing particular effort in legitimizing its governance processes. As a part of this long-term and ongoing effort, initially labelled “Good Governance” and currently, “Better Regulation”, the European Commission (EC) has issued procedural guidelines to all its services on how to incorporate good governance practices and improve overall institutional legitimacy. Jean Claude Juncker’s Commission (2014-2019) was particularly committed to these objectives and made the so-called Better Regulation Agenda (BR Agenda) a flagship initiative during its term in office. The BR Agenda is an all-encompassing project aimed at reforming regulatory rule-making and at rendering the EU law-making process more evidence-based, transparent, and open to public participation (see Listorti et al., 2020; Papadopoulos et al., 2024; Radaelli, 2018). The BR Agenda created an infrastructure of procedural internal rules that is still in place today and was amended in non-essential ways in 2021 and 2023.

7Because of the centrality of democratic legitimacy considerations in the BR Agenda, we assume chances were higher during the Juncker Commission (as opposed to other times in the EC’s recent history) to give serious consideration to the legitimacy of employing external contractors for EU policy formulation. In other words, the Juncker Commission represents the most likely case of explicit and systematic justification (legitimation) of outsourcing. This article therefore focuses on the legitimacy claims put forward by this Commission.

8Interestingly, and somewhat counterintuitively, given its ambition to bring the EU closer to its citizens, the BR Agenda has also significantly increased opportunities for the EC’s Directorate Generals (DGs) to hire consultants by raising the requirements for policy-specific expertise and research in the development of EU legislation. Indeed, an internal EC review estimated that external contractors provide services amounting to between €10 million and €37 million annually under the BR Agenda (Commission, 2019b, p. 40). However, this figure seems low compared to external assessments. For instance, a special report by the European Court of Auditors (ECA) found that, between 2017-2019, the EC signed contracts with external consultants worth a total value of €2.7 billion. Of this amount, €594 million was allocated to the categories of “studies” and “evaluation”, which can be considered the most relevant for preparing legislation and policymaking (European Court of Auditors, 2022, pp. 8–9). Furthermore, a 2022 report on the EC’s use of consultants to prepare legislation, commissioned by the European Parliament, found that, between 2014-2021 a total of €1.1 billion (almost 18% of the total expenditure on consultants) could be attributed to policymaking support services (Centre for Strategy & Evaluation Services, 2022, pp. 7-8). In sum, significant budgetary streams have been channeled toward external contractors within the EU governance system, raising the normative expectation that the EC somehow justifies its widespread use of consultants.

9Against this background, our research aims to take stock of the arguments and justifications given concretely in the context of the deployment of consultants in the processes of Open Public Consultations (OPCs). To be clear, we aim neither to evaluate the legitimacy of the consultants employed by the EC nor to gauge whether their involvement actually renders the public consultations they support more or less legitimate. Rather, we are interested in legitimacy claims, i.e., in the way the involvement of consultants in EU policy-making is rhetorically justified to align with the standards of democratic legitimacy.

10Although consultants are much more frequently involved in evaluation and impact assessment work, we chose to focus on OPCs for two reasons. First, we expect the pressure to rhetorically justify the presence of consultants to be greatest with regard to OPCs, precisely because this is the policymaking stage where they are least likely to be present. OPCs are meant to create a direct line of communication between European citizens on the one hand, and EU decision-makers on the other. Their aim is to boost citizen engagement and participatory democracy more generally (Kohler-Koch & Quittkat, 2013; Quittkat, 2011) and thereby strengthen the EC’s democratic credentials. However, through outsourcing, a third party (i.e., the consultant) is inserted into what is otherwise supposed to be a direct relationship. This poses a challenge in terms of democratic legitimacy, especially as consultants often operate outside of the public’s scrutiny, on the periphery of formal procedures, and under unclear accountability relationships. This means that, from a normative standpoint, their use requires a more reasoned justification that likely goes beyond addressing internal capacity shortages.

  • 3 Shorter periods for stakeholder feedback (4 weeks) are available for roadmaps, impact assessments, (...)

11A second reason to choose OPCs as a case study is the availability of empirical data. The BR Agenda led to an increase in public consultation opportunities across the policy cycle by requiring 12-week OPCs during both policy initiation (to assess the scope, priorities, and added-value of EU action for new initiatives) and policy evaluation (to assess how the policy worked on the ground)3. The use of consultations during the Juncker Commission escalated to the point that external stakeholders reported fatigue due to the demands of constant participation (Commission, 2019b, p. 16). This guarantees the availability of data to be examined in this study.

12In summary, we follow a three-step case selection process, narrowing down each time based on the case expected to be most likely to provide robust legitimation and proper argumentation about outsourcing practices. First, we choose the EU as a political system that continuously engages in explicitly legitimizing its governance actions. Second, we choose the processes within the BR Agenda during the term of the Juncker Commission (2014-2019). This period saw particular fortification of good governance principles in policy-making practices, and therefore possibly also gave rise to increased legitimation claims regarding outsourcing practices under the general umbrella of improved transparency. Thirdly, from all aspects of the BR Agenda, we zoom in on the consultation processes under the OPCs because, by design, they are most likely to improve openness, transparency, accountability, and participation in EU governance. We consider each of these levels to be the most likely to exhibit robust justifications for outsourcing practices. In other words, if the legitimation of involving consultants is not adequate in the case of EU’s OPCs during the Juncker Commission’s term in office, chances are it will hardly be adequate elsewhere in the EU, with all the normative and ethical consequences thereof.

13Conceptually and analytically, the main research question is addressed by developing and testing a novel typology of legitimation claims regarding the involvement of consultants in regulatory policymaking. Starting from the well-known distinction between input, output, and throughput democratic legitimacy (see Schmidt, 2013), we consider how public consultations are valued under each of these legitimation strands and, consequently, the added value that consultants might bring to the process. Based on this, we distil three ideal types – the political strategist, the policy expert, and the process expert – which reflect the different ways in which the involvement of external contractors in public consultations might be considered democratically legitimate. Armed with these conceptually-derived expectations the article then tests them focusing first on the official institutional discourse, as reflected in EC policy documents and guidelines (by means of qualitative content analysis). In a second step, we focus on the existing administrative practice (by means of interviews), exploring two Directorate Generals (DGs) within the EC, which have demonstrated a relatively high use of consultants for OPCs during Juncker’s term of office.

14In summary, this study aims to take stock of the rhetorical justifications put forward by the EC as to why and how consultants could be involved in the European public policymaking process (legitimacy claims) and to explore the normative preconceptions and de facto justifications of outsourcing. Through this effort, we aim to reveal how a controversial phenomenon – the employment of external (private) actors in public policymaking – is justified and legitimized by a public institution that itself aims to increase and justify its legitimacy (especially during the Juncker Commission’s term in office).

15The article proceeds as follows. Section 1 provides an overview of the OPCs undertaken during the Juncker Commission (2014-2019) and maps the use of consultants in this context. The aim here is to delineate the scope of our object of study – consultants’ involvement in OPCs – using descriptive statistics. Section 2 presents the analytical framework and our methodological approach. Section 3 takes stock of the European Commission’s official discourse regarding the legitimacy of public consultations and the potential role of consultants therein. In Section 4, we show how consultants are in practice brought in to deal with OPCs, what their tasks are, and what they are expected to deliver. We also map a series of contradictions that OPCs raise in terms of practical implementation and elucidate, on this basis, what outsourcing reveals about the actual state-of-play in this otherwise most inclusive and participatory step of the EC’s policy-formulation stage. Conclusions follow.

Open public consultations and external contractors during the Juncker Commission

16The EC – a remote, unelected executive with wide-reaching powers – has long relied on participatory governance to address accusations of “democratic deficit”, which have plagued the EU since the early 1990s, and to which it has been especially vulnerable (see Greenwood, 2017; Kohler-Koch, 2010; Saurugger, 2008 among others). Consulting with citizens and organized interests is an important part of this effort. Art. 11 of the Treaty on the European Union (TEU) requires EU institutions to “maintain an open, transparent, and regular dialogue with representative associations and civil society” and specifically instructs the Commission to “carry out broad consultations with parties concerned in order to ensure that the Union's actions are coherent and transparent”.

  • 4 However, the EC does not accept anonymous contributions to OPCs.

17For the past 30 years, the EC has developed an extensive “consultation regime” (Kohler-Koch & Finke, 2007) that currently incorporates several different instruments, from relatively exclusivist (e.g., one-to-one meetings with stakeholders and expert groups) to open formats (e.g., European Citizens’ Conferences and online forums), allowing a variety of actors to participate (for a classification of consultation instruments used by the EC, see Kohler-Koch & Quittkat, 2013, p. 63). OPCs represent the most inclusive tool in this consultation regime. Conducted online, they have a very wide reach. In principle, any European citizen can make a submission, irrespective of their actual knowledge of or interest in the subject of the respective OPC4. Even before Juncker’s term of office, the EC regularly used OPCs for any new regulatory measures necessitating an Impact Assessment – meaning, new measures likely to have significant economic, social, or environmental consequences (EC, 2009).

18Although OPCs have been successful in attracting a larger and more varied pool of respondents, thus increasing participatory policymaking beyond the usual circle of Brussels insiders (Beyers & Arras, 2021; Binderkrantz et al., 2021; European Court of Auditors, 2019; Lindgren & Persson, 2018; Quittkat, 2011; Quittkat & Kotzian, 2011), in practice they have failed to be truly inclusive. OPCs remain dominated by stakeholders from “old” – particularly Northern – member states (Quittkat, 2011) and by business representatives (Binderkrantz et al., 2021; Marxsen, 2015; Quittkat, 2011; Rasmussen & Carroll, 2014). Discrepancies in participation interest have been explained, inter alia, through policy distributional effects (Rasmussen & Carroll, 2014) and issue salience (Rasmussen et al., 2014; Røed & Wøien Hansen, 2018). Despite its documented flaws, it is interesting to note that those who actually use the EC’s consultation regime do not find it biased in favor of Brussels insiders (Bunea, 2017).

19We have comparatively fewer insights about what happens after the open consultations close (but see Chalmers, 2014; Lei, 2024; Rasmussen & Toshkov, 2013 for exceptions). This is where our article makes a contribution. We start by investigating the reports5 the EC produces after OPCs conclude. These reports have often been criticized for being purely descriptive and giving no indication of how the input received from stakeholders and citizens will be assessed or will inform policy-making activity (see e.g. Kohler-Koch & Quittkat, 2013; Quittkat, 2011). However, they do shed some light on the EC’s use of external contractors. Using the online platform “Have Your Say”6, where OPCs were centralized during the Juncker Commission, we systematically reviewed all OPCs7 that were launched and closed between November 1, 2014, and August 1, 2019. A total of 440 consultation procedures were studied. Only 249 (or 57%) of these procedures had consultation reports available online. Of these, the vast majority (82%) were produced ‘in-house’ (i.e., by the respective Directorate Generals (DGs) that launched the consultation procedure), while 46 reports (or 18%) were authored by external contractors – primarily consultancies (58%), but also universities (5%), or consortia of consultancies with some university participation (37%). We coded an OPC report as outsourced only when authorship was explicitly attributed to an external party. OPC reports with no authorship information were coded as internally produced by EC staff. However, it is possible that a consultant might have written them anyway or helped to write them (the BR Guidelines do not provide clear information on the attribution of authorship for such documents).

20With these limitations in mind, our data does show that, while outsourcing the execution and analysis of OPCs to external contractors is not a mainstream practice, it is also not uncommon. Furthermore, it casts some doubt on what might be considered the obvious explanation for the employment of contractors, namely, internal capacity shortages within the EC. For instance, most outsourced reports were for OPCs with 100-200 responses (n=14), followed by OPCs with 200-400 responses (n=9), and, finally, OPCs with less than 100 responses (n=8). None of these categories represents an uncommonly high response rate. By comparison, we found only seven outsourced reports in the higher range, i.e., OPCs with more than 1, 000 responses (see Figure 1). Furthermore, most outsourced reports (n=37) pertained to OPCs that predominantly used closed, multiple-choice questions, meaning that the collected data was not especially difficult to analyze (see Figure 2).

Figure 1: Share of in-house and outsourced reports per number of submissions (N=249)

Figure 1: Share of in-house and outsourced reports per number of submissions (N=249)

Source: The authors

Figure 2: Share of in-house and outsourced reports per format of the consultation document (N=249)

Figure 2: Share of in-house and outsourced reports per format of the consultation document (N=249)

Source: The authors

21Regarding the workload of the DGs that led the OPCs, the data shows that those with the most outsourcing were indeed among the busiest groups during this period (see Figure 3). But this is not a straightforward correlation. For instance, we found that the Directorate General for Environment (DG ENV) had the highest number of outsourced OPC reports (n=10, as opposed to four reports produced in-house), yet it had the least amount of consultation work (i.e., 31 OPCs, both with and without published consultation report). It lagged behind the Directorate General for Internal Market, Industry, Entrepreneurship and SMEs (DG GROW), which was the busiest during the Juncker Commission with 46 OPCs overall but only two outsourced reports (of the 30 OPC reports we could trace for this DG).

Figure 3: Share of in-house to outsourced open public consultations per Commission Directorate General (N=249)

Figure 3: Share of in-house to outsourced open public consultations per Commission Directorate General (N=249)

Source: The authors

22The lack of an obvious explanation for contracting out motivates the more in-depth investigation proposed here of the justifications used by the Commission to hire consultants in connection with OPCs. This is what the next section aims to explore.

Analytical Framework – exploring the legitimacy of (open) public consultations

23In this section, we draw on normative theoretical literature to map existing claims about the contribution of public consultations to the democratic legitimacy of public bureaucracies. Based on these claims, we deduce the Commission’s potential expectations regarding the value of public consultations, and, consequently, how it might legitimize the hiring of consultants for OPCs. This section offers a framework to guide the subsequent empirical analysis in Sections 3 and 4.

24Proponents of public consultations and stakeholder engagement present these types of practices as somewhat of a panacea for the ills of modern governance. The OECD (2018), for instance, shows that consultation can enhance both input and output legitimacy. In terms of input legitimacy, public consultations supplement traditional representational democratic practices. Public bureaucracies are not elected and are not subject to the discipline of the vote, but they are still expected to be receptive to the demands and preferences of policy stakeholders and the general public. Public consultations enable the articulation and transmission of these demands and therefore enable bureaucracies to be responsive. In this optic, consultations contribute to the development of more responsive policies (see e.g. Fung, 2015; Papadopoulos & Warin, 2007; Rimkutė & van der Voet, 2024).

25In terms of output legitimacy, consultations enable stakeholders and citizens to transmit policy-useful information to public bureaucracies. This information is usually based on external technical expertise that public bureaucracies might not otherwise have access to. It helps them develop an evidence-based understanding of policy problems and proposed solutions. Public consultations help public bureaucracies develop more effective policies, which are more fit-for-purpose and perform better on technical criteria such as feasibility, impact, and cost effectiveness (Meijer et al., 2013; Woods, 2015).

26By contrast, other authors (Beyers & Arras, 2021; Schmidt, 2013; Schmidt & Wood, 2019) interpret consultations from the perspective of throughput legitimacy. Consulting with stakeholders and the general public makes the policy-making process within public bureaucracies more open and inclusive. Openness and inclusiveness are two core elements that feed into the composite concept of throughput legitimacy, along with transparency and accountability (see Schmidt, 2013). From this perspective, what matters is that public consultations help enact a policy development process that is democratically legitimate in itself. Hence, consultations contribute to policies that are correctly developed, but not necessarily responsive or effective.

27Each of the three different strands of democratic legitimation outlined above points to a slightly different valuation that the Commission might have about OPCs and, subsequently, about the role of external contractors in this process (see Table 1).

Table 1: Legitimacy standards for open public consultations and the role of external contractors

Table 1: Legitimacy standards for open public consultations and the role of external contractors

Source: The authors

28We assume that contractors can play three different roles, which we have constructed here as ideal-types. First, if public consultations are valued primarily for their benefits in terms of input legitimacy, then contractors would be legitimized as political strategists. In this role, they would help the EC gather preferences, opinions, and views from stakeholders and citizens, weigh their relative significance, and interpret the results in terms of the political acceptability of the proposed measures. At the very least, we would expect the EC to look for consultants who have an in-depth knowledge of the stakeholder environment in a given policy area and an understanding of the issues that are likely to cause conflict or elicit divergent preferences.

29Second, if public consultations are valued primarily for their benefits in terms of output legitimacy, then contractors would be legitimized as technical and policy experts. In this role, they would help the EC gather policy evidence from stakeholders and citizens and process it in terms of the scientific soundness, relevance, and implications for the technical feasibility, impact, cost effectiveness etc., of the respective policies. This is the quintessential model of evidence-based policy-making. Here, we would expect the EC to look for consultants who have technical expertise in a given policy field, are familiar with existing regulatory regimes, and who are able to discern if the information received though public consultation represents sound and useful policy evidence or not.

30Finally, if public consultations are valued primarily for their benefits in terms of throughput legitimacy, then contractors would be legitimized as process/procedure experts. In this role, they would help the EC organize public consultations that are open, inclusive, and fair. We expect the EC to look for consultants who have knowledge and experience with consultative practices, who know how to organize engagement with stakeholders and citizens in a manner that is fruitful, and who at the very least are familiar with the relevant quality standards that are enshrined in the BR guidelines relating to deadlines, lengths and content of questionnaires and reports, modalities of advertising the OPC etc.

31Of course, the three roles outlined above are not mutually exclusive categories. Although there are some well-known trade-offs between different democratic legitimacy standards – for example, sometimes the policy solution that is the most responsive to stakeholder demands is not the most technically sound or cost-effective – there is no reason to think that we cannot have policies that tick all three boxes successfully (i.e., they are responsive, effective, and developed in a procedurally sound manner). Correspondingly, it may be that external contractors are legitimized by appealing to all the roles discussed here (e.g., they help the EC with its political strategizing, and also with the technical and procedural aspects of policy development). Therefore, our research inquiry seeks to establish whether the EC evokes these three roles equally in relation to external consultants and OPCs. If not, we will identify which roles are emphasized, which ones are played down, and why.

32Methodologically, we rely on a combination of documentary analysis and semi-structured expert interviews. On the one hand, we analyze the official discourse promoted by the Commission around democratic legitimacy and public consultations as derived from the BR Agenda introduced and implemented during the Juncker Commission. This part of the analysis relies on primary sources, such as official policy documents like the BR Agenda and its implementing guidelines.

33On the other hand, we use semi-structured interviews to explore administrative practices surrounding the use of consultants for OPCs. The aim is to verify whether the legitimation “on paper” takes place de facto and corroborates the conceptually-derived expectations outlined in this section. We focus on the two DGs that our survey identified as frequent “outsourcers”, namely DG ENV (out of 14 documented OPC reports, 10 were outsourced) and the Directorate-General for Mobility and Transport (DG MOVE) (out of 22 documented OPC reports, eight were outsourced).

34We carried out nine interviews with consultants who had repeatedly worked on OPCs in both DG ENV and DG MOVE (six consultants from four different consultancies), and with Commission officials who had handled OPCs and provided internal guidance on BR guidelines in DG ENV and DG MOVE (two officials in DG ENV and one in DG MOVE). All interviews were carried out between May and June 2020, recorded, transcribed, and analyzed with the help of specialized software (ATLAS-ti). Data from interviews is anonymized – we identify interviewees by numbers instead of names and by their organizational affiliation (i.e., either ‘Consultant’ or ‘Commission Official’). For an overview of the interview protocol, please see the Annex.

The democratic legitimacy of Open Public Consultations in the European Commission’s public consultations acquis

35In this section, we take stock of the official discourse of the EC regarding the legitimacy of public consultations as a key instrument of the BR framework. To put things into perspective, we do not look only at the legitimacy claims during the term of the Juncker Commission, but review three consecutive periods in the EC’s public consultation acquis: firstly, the initial reform package outlined in the 2001 White Paper on European Governance; secondly, the Better Regulation Agenda introduced by the Juncker Commission (with consultation guidelines issued in 2015 and revised in 2017); and, thirdly, the revised Better Regulation guidelines issued by the first von der Leyen Commission in 2021.

  • 8 Full copies of the coding tables are available upon request.

36We performed a content analysis on the guideline documents accompanying the Better Regulation (or previously the Good Governance) leading strategy relating to each of these three distinct periods in the EC’s consultation regime. Guideline documents were chosen because they are very detailed, specifying the function, but also the methodology of consultation. Thus, they represent the most revealing source of information on the legitimation strategy applied by the EC to the instrument of public consultations. Concretely, the public consultations guidelines from 2002, 2015, 2017, and 2021 (i.e., Commission 2002, 2015, 2017, 2021) were screened for all references to consulting the public, stakeholders, or citizens. We then classified them according to the three analytical dimensions explained in Table 1 (i.e., the functions of preference-gathering, evidence-gathering, and procedure enhancement). Coding was performed at the sentence level, and often, several codes were attributed to the same sentence because several functions were enumerated. We also performed a targeted search using the keywords: "contractors", "external", and "outsourcing" (root words used were: *contract*; *extern* and *outsource*) to ascertain whether external contractors were in any way mentioned, and if so, which legitimacy standard was invoked. Our findings are summarized in Table 2 below8.

Table 2: Legitimation of public consultations and use of consultants in EC official discourse between 2002 – 2021

Table 2: Legitimation of public consultations and use of consultants in EC official discourse between 2002 – 2021

Source: The authors

37Findings show that the earliest consultation guidelines (from 2002) emphasized the input legitimacy aspects and portrayed public consultations as a viewpoint-gathering exercise. This is by far the most frequently invoked purpose of consultations (seven references), with procedure enhancement as a secondary purpose (five references). There is only one reference to the value of public consultations in relation to policy outcomes, and interestingly, the word ‘evidence’ is not mentioned once in the entire document.

38From 2015 onward, official rhetoric references ‘evidence-based’ policy-making more frequently, although it continues to be the least emphasized aspect of consultations until the von der Leyen guidelines. By 2017, the most reiterated legitimacy standard is the procedural one (16 references), with the EC stressing the importance of consultations for a robust policy-making process, but also devoting more attention to quality standards for organizing and running consultations. The preference-gathering function also appears frequently (13 references for the input legitimacy standard). Officials are instructed to seek a broad range of views and report on them neutrally, but they are also warned against the non-representative nature of some stakeholders.

39Finally, in 2021, the leading emphasis is on the procedure-enhancing and polity-affirming aspects of consultations (throughout legitimacy, 12 references), while the other two aspects of input and output legitimacy are visible and present but secondary (withsix and seven references, respectively).

40The first mention of contractors appears in the 2017 BR guidelines. However, in both the 2017 and in the more recent 2021 versions, contractors are seldom mentioned, and only adjacent to other issues. The general impression is that contractors are used for evidence-gathering and analysis (they deliver “studies” to the EC). It is unclear whether these studies regularly incorporate stakeholder or public consultations and, if they do, whether their purpose is (primarily) technocratic evidence gathering. The 2017 BR guidelines do mention that “external consultants can support or conduct the consultation work”, which confirms their involvement; however, no further details are provided.

41All in all, the EC’s consultation guidelines remain cryptic about external contractors. There are no rules or recommendations as to when, how, and for what purpose EC officials might resort to using contractors. Nor are there any justifications with regard to why this use is appropriate or legitimate. This indicates that, at a discursive level, the EC does not explicitly account for the involvement of contractors in any way.

Contractors and Open Public Consultations in the European Commission’s internal administrative practice: the cases of DG ENV and DG MOVE

42In this section, we draw on interview data to map legitimation arguments regarding OPCs and the involvement of external consultants therein. Rather than focusing on the official institutional discourse, as in the previous section, the analysis now moves to the work floor of the EC as it unpacks the internal administrative practices engendered by consultants’ involvement with OPCs. We zoom in on DG ENV and DG MOVE, which in Section 1 were identified as frequent “outsourcers” during the term of the Juncker Commission (2014-2019). Drawing on the analytical model presented in Section 2, we proceed in two steps: firstly, we show how those involved in the practical policy process (both EC officials and consultants) discuss the legitimacy of OPCs (i.e., as preference-gathering, evidence-gathering, or procedure-enhancing exercises); secondly, we show how consultants are brought in to deal with OPCs and how the legitimacy of their respective roles is articulated (i.e., as political strategists, technical experts, or procedure experts).

Open Public Consultations: unresolved contradictions and shaky legitimacy

43A general trend of widespread misgivings about the usefulness of OPCs exists among EC staff and consultants. Most of the consultants we interviewed expressed doubts, characterizing OPCs as “an obligatory exercise but not meaningful” (Consultant #6), “quite constrained”, and lacking “added value” (Consultant #1), a “mandated process” not designed “for research requirements” (Consultant #3), and providing “very limited” information for policy evaluation (Consultant #2).

44In terms of their potential to accurately gather stakeholders’ and citizens’ policy preferences (i.e., the input legitimacy standard), OPCs were frequently criticized for their failure to yield relevant input and their biased patterns of participation. Interviewees point to the fact that, despite a general understanding that OPCs should be accessible to the general public, the questionnaires continue to use overly technical language (Consultant #1, Commission Official #1). This is particularly evident with open questions, which can and do often attract irrelevant or factually incorrect responses (Consultants #1, #2, #3):

“You have to publish the report, you have to write a nice, long report, it can get challenging because in the open questions people write a lot of nonsense. They don’t know the issue, they don’t know what they’re talking about, and they don’t understand the question.” (Consultant #3)

45Furthermore, participation in OPCs can be very unequal. Interviewees have reported cases where the vast majority of responses came from only two or three Member States (Consultants #2, #3), or from representatives of specific industries (Consultant #6), or from respondents who self-select because they are interested in and have the necessary expertise to meaningfully engage with the OPC (Consultants #2, #3). As one interviewee remarked, “[…] there’s no way the information we get is statistically representative of anything’’ (Consultant #1).

46Finally, a particular problem is posed by the so-called ‘campaigns’, i.e., waves of OPC responses that are coordinated by one actor (e.g., a trade association or an NGO). The coordinating actors alert those in their network and/or their members to answer the questionnaire in a specific way and often provide model answers that can be uploaded with minimal changes. These campaigns generate a large number of similar, if not identical, OPC responses. In practice, it can be challenging to identify and separate them, especially if they are in different languages (Consultants #1 and #4).

47In terms of their potential to gather policy-relevant evidence from stakeholders and citizens (i.e., the output legitimacy standard), OPCs do not fare any better. Their inferiority is particularly highlighted by comparison with more limited, targeted consultations that consultants often organize with private stakeholders and national public authorities of the Member States. The latter were characterized as “fundamentally important” (Consultant #1) and much more likely to inform the EC’s thinking (Consultant #4). One interviewee explained:

“They’re night and day – the open public consultation is an afterthought, the targeted consultation is your source of information in every study I’ve worked on, with a few exceptions […] most of the time, the targeted consultation, that’s your big chance – that’s your resource phase, to survey the right people, interview the right people, get the information, these people really know how the policy works on the ground.” (Consultant #3)

48In the context of the broader evaluation studies that contractors deliver to the EC, OPCs are clearly the least relevant element. Instruments such as targeted stakeholder consultations or even desk research are seen as much more appropriate because they conform to the evidence-based analysis logic that underscores these exercises. OPCs do not. As such, they are difficult to reconcile with the final product that consultants are expected to deliver.

49In other words, OPCs may not be scientific, they might not even represent research per se, but they still need to be integrated into evidence-based policy evaluations. A clear compromise must be made, yet there is no satisfactory way to achieve it. One consultant recounted an occasion when he used OPC data for an evaluation report and noted that “it came with asterisks and there were a lot footnotes at every moment” (Consultant #2). Another consultant explained that “what you get from analyzing the OPC is […] some numbers which you can stick in a report, to justify some of the other things you get from other sources.” (Consultant #1). At most, OPCs offer an opportunity to pick up on information or views that have not been anticipated and/or contradict research results significantly (Consultant #2, #3) – although none of the consultants interviewed could name a concrete example of when an OPC had surprised them.

50In summary, OPCs are perceived as underperforming when assessed against both input and output legitimacy standards. On the one hand, as preference-gathering exercises, they fail because their results cannot be considered statistically representative, even in the rare cases where they attract a high response rate. This seems to diminish their value in mapping, what one interviewee called “the political atmosphere around the topic” (Commission Official #3). This is particularly problematic because there is an understanding this is what OPCs are actually supposed to do. As interviewees observed, OPCs ought to “provide information on the importance of the issue for people” (Consultant #4), “they are only for the public” (Consultant #1), and they can offer “illustrations of different opinions and political feelings” (Commission Official #3). Ironically, the so-called ‘campaigns’, which are meant precisely to send political signals to the EC regarding the strong opinions of particular (stakeholder) groups, are downplayed by the practice of isolating and reporting on them separately.

51On the other hand, as evidence-gathering exercises, OPCs also fail because many responses are irrelevant or factually incorrect. The stakeholders who do have the expertise are consulted separately. As one interviewee noted, “most of the responses [to the public consultation] come from those affected by it, so the trading bodies, the companies, etc., and most of those we’ve already spoken to in an interview if they’re really important.” (Consultant #1).

52If OPCs perform poorly as both preference-gathering and evidence-gathering tools, then what is left is their symbolic significance. Despite its many flaws, this policy instrument remains relevant because it demonstrates the Commission’s commitment to transparency and openness as a policy-maker. According to the throughput legitimacy standard, the value of OPCs lies in their process-enhancing nature (see Table 1), and this is indeed the basis on which multiple interviewees have defended this policy instrument:

“[…] the biggest value I see in the public constitution is, it's the right thing to do, to give people a chance to comment […] I think that’s irreplaceable value.” (Consultant #2)

“I can see the importance of actually doing it, because the Commission needs to be seen to be transparent and open, and therefore giving everyone an opportunity to respond.” (Consultant #1)

“Even if there are not that many replies I think the fact that there is a possibility to keep comments is of value as such. For the sake of transparency, it serves some purpose, even if the number of replies is not that high”. (Commission Official #3)

“Yes, it is useful to the extent that it allows to inform citizens that the Commission looks into the directive, it looks into the possibilities, it looks into if it works or it doesn't work, it takes […] the opportunity for everyone to present their views”. (Commission Official #1)

The legitimation of consultants in relation to Open Public Consultations

53If the practice of OPCs is legitimized on procedural grounds, what does that mean for the legitimation of consultants who work with OPC processes? To answer this question, we must first take a step back and explain how consultants become involved in the BR process in the first place.

54The use of external contractors is connected to the increased need for administrative support that the BR Agenda has created. As mentioned before, the BR Agenda resulted in an increase of public consultation moments throughout the policy cycle, as well as more demands for research and evidence-based evaluation. This led to greater work pressures within the EC’s own bureaucracy and created an opportunity to contract out certain tasks to third parties (Commission Official #3).

55Consultants are generally brought into the process through framework contracts, which essentially represent a public procurement tender that pre-selects external contractors to provide translation, event management, documentation, and analytical services. Framework contracts create a group of vetted contractors, which the EC can use to temporarily supplement its administrative capacity, both quantitatively and qualitatively (e.g., coverage of languages or specialization in a particular policy subject/domain). As one interviewee explained:

“There is one main reason in using a framework contract and that's that it is simply faster [...] These are companies shortlisted as a result of an open call, so you do not have to check again the selection or technical criteria – this was already done in the preceding open call” (Commission Official #3).

56Framework contracts create a relatively small inner circle of pre-selected contractors who are subsequently offered work on an exclusive basis. Consultants interviewed (Consultants #1, #3, and #4) confirmed that most of the public consultation work they had done for the EC came through closed calls received in the context of framework contracts.

57As a rule, such calls are usually for evaluation or impact assessment studies, sometimes both executed back-to-back. Here, the OPC is just one component of a broader work package that typically involves primary research and restricted (targeted) consultations with stakeholders and representatives of public authorities in EU Member States (Consultants #3, #4, #6, Commission Official #2). This is confirmed by our descriptive statistics data, where a majority of the outsourced OPC reports (34 out of 46) pertain to some kind of evaluation exercise, whether of individual legislative acts, broader regulatory regimes, or other types of policy instruments. By contrast, only four contracted OPC reports were linked to new legislative proposals. In conclusion, it is exceptional for the EC to put out an open call for OPC work or for the call (open or restricted) to ask for OPC work exclusively.

58Once contracts are awarded, contractors enter into a close working relationship with the EC desk officer responsible for the respective policy dossier. They will be their main point of contact (Commission Officials #1, #2, #3) although consultants will also participate in inter-service meetings with representatives of other DGs in the case of more complex dossiers (Consultant #1). There is a lot of back-and-forth in relation to the OPC questionnaire, which is a jointly created output. Sometimes the consultancy writes the initial draft (Consultants #3, #4, #6), and other times the EC does (Consultant #1 and Commission Official #1). However, the EC always assumes ultimate responsibility for its content (Commission Official #1). Over time, the Secretariat General has evolved into the central quality check for OPCs, including the questionnaires. This can cause delays, especially in politically sensitive files: “They can be very particular about certain types of wording” (Consultant #3). Contractors are expected to work fast (10 to 14 days) to deliver the OPC reports, which creates significant work pressure (Consultants #1, #2, #3, #4).

59To come back to the initial question regarding the legitimation of consultants, what the strict control over questionnaires and the tight delivery deadlines demonstrate is that, when it comes to OPCs, consultants are valued strictly as a labor-saving solution for EC staff. Their involvement is legitimized by their process expertise – all of the consultants we interviewed confirmed that they were expected to be familiar with the BR guidelines. Some consultants also mentioned that research expertise is a bonus, particularly for OPCs with many open questions and/or those likely to have a high response rate, because “there are professional ways to analyze qualitative text using software and things like that, and the Commission doesn’t have the capacity to do that internally” (Consultant #3). These findings correlate with the EC’s own internal review of the BR Agenda. The review found that EC officials who supported the involvement of consultants cited limited internal capacity and the need for specific, methodological expertise as arguments (Commission 2019b, p. 24).

60The legitimation claims presented above align with what we identified in Section 2 as the procedure expert role of consultants (i.e., their involvement is justified because they help the EC fulfil OPC quality standards which are relevant from a throughput legitimacy perspective). It also aligns with the valuation of OPCs as a throughput legitimacy enhancing exercise, as demonstrated in the previous sub-section. However, it is important to note that knowledge of and adherence to BR guidelines is all that is required – consultants are not expected to innovate, adapt, or optimize the OPC process, but simply to implement the existing institutionally approved methodology. The EC does not seek people with specific expertise in participatory governance or consultative practices. In other words, it does not use consultants for the sake of making OPCs better, by for example, improving their design or effectiveness. The cost-cutting rationale, rather than the ambition to perfect a democratic participation instrument, remains the key consideration and very much limits what consultants-as-procedure-experts are expected to deliver. Indeed, the consultants we interviewed perceived their own added value in relation to OPCs as simply offering solid service in a cost-effective manner, especially for understaffed DGs (Consultants #1, #3, #4, and #6).

61Having said this, it should be noted that, outside the strict scope of OPCs, the EC does require more of its consultants. They are expected to have technical expertise in their policy domain, knowledge of the main stakeholders active in the respective domain, and experience in organizing events for those stakeholders. In fact, consultancies tend to specialize in one or several policy domains precisely because of these requirements. For instance, it is commonplace for consultants to propose a list of stakeholders to be included in targeted consultations, which the EC can edit as they see fit (Consultants #1 and #5). One interviewee even explained that knowledge of the stakeholder environment is “our job” and “one reason the Commission is looking for consultancies” (Consultant #6).

62Therefore, consultants also play the other roles outlined in Section 2, namely technical expert and, to a limited degree, political strategist (insofar as a degree of political savvy is expected in relation to the stakeholders active in their policy domain). However – and this is key – these roles are activated in relation to other aspects of the work packages that the EC outsources to them. Neither policy expertise nor political perceptiveness are particularly required when it comes to OPCs.

Conclusion: the limited usefulness of Open Public Consultations and the (missing) legitimation of contractors’ involvement on the European Commission’s work floor

63In this study we set out to take stock of the arguments and justifications provided by the EC when deploying consultants during the EU policy formulation stage. Even though we chose to scrutinize OPCs as the most likely case of sound justification and focused on the Juncker Commission period (2014-2019), which set high ambitions for itself in terms of good governance and better regulation, our findings show that, overall, the EC did little to articulate a legitimation narrative for its use of external contractors.

64The analysis was executed at two levels: first, we took stock of the official discourse through a content analysis of official policy documents dealing with public consultations and the BR Agenda. Second, we zoomed in on administrative practice though a number of expert interviews with consultants and EC officials in DG ENV and DG MOVE.

65In terms of official discourse, we found that, in the BR Agenda, procedural/throughput legitimacy considerations are the most emphasized in relation to public consultations. OPCs are seen as rendering the policy-making process more transparent and inclusive by giving all interested parties a chance to be heard. Input legitimacy also appears frequently, although less often than procedural aspects. In these instances, the Commission highlights the value of OPCs in bringing to the fore a broad range of views. By comparison, the value of OPCs for output legitimacy – informing evidence-based policy-making – is the least emphasized aspect. Importantly, the official BR guidelines barely mention the use of contractors in relation to OPCs and have nothing to say on how or why such actors might be employed or held accountable by the EC. This indicates that the EC lacks an explicit strategy for using consultants in relation to OPC work and for minimizing the risks associated with outsourcing in the first place.

66In terms of administrative practice, we found that, when consultants are brought in, it is rarely just for OPCs. Rather, they generally conduct policy evaluations, which include consultations as a mandated component. Both consultants and EC officials have – at best – mixed experiences with OPCs and do not value them for providing different stakeholder and citizen views or policy evidence. The ‘saving grace’ of OPCs is their symbolic value – they help the EC to demonstrate its commitment to transparency and openness as a policymaker. Therefore, the views of those who work with OPCs – EC officials and consultants alike – correspond broadly to the official discourse, which also highlights the value of OPCs as a procedure-enhancing instrument. As for the role of consultants in these processes, neither policy expertise nor political perceptiveness are particularly required. Rather, what is required – and how their presence is justified from a democratic legitimacy perspective – is the ability to execute OPCs in accordance with the BR guidelines and in a cost-effective manner. Although the expectation to know and follow the BR guidelines demonstrates some attention to how consultants might impact on the procedural legitimacy of OPCs, it is the economic rationale that takes priority. Consultants are seen (and see themselves) primarily as a cost-cutting measure.

67What are the implications of our findings for democratic legitimacy? The EC is an evidence-based policymaker that, lacking the option to abandon OPCs altogether, uses them purely for procedural legitimation. These OPCs must be executed correctly, regardless of their actual usefulness. Their correct execution becomes in itself the source of democratic legitimacy. The focus is not on the responses collected through the OPCs, the way the Commission deals with these responses, or how they substantively feed into policy formulation. Rather, it is about doing the OPCs in a procedurally accurate manner. This suggests that the Commission values form over function and significantly marginalizes the participatory democratic goals inherent in the introduction of OPCs as an instrument of good governance.

68As to the role of the external contractors, of the three ideal-types defined in Section 2, it is the third role (i.e., the process/ procedure expert) that fits most closely to the work they do in connection to OPCs. However, the primacy of cost-cutting considerations means that, for the EC, consultancies most resemble what Dooling and Potter (2023) have labeled ‘regulatory body shops’ in the US context: “Body shops are companies that supply the government with laborers (“bodies”) to work in government offices, side-by-side with government employees, and often to perform exactly the same tasks as government employees” (Clark, 2011, cited in Dooling & Potter, 2023, p. 4). This is interesting because it suggests that, at least when it comes to OPCs, the EC is not actually looking for external expertise that it lacks in-house but rather looking to replace its existing workers with cheaper ones. If EC officials and consultants become completely interchangeable for certain well-defined tasks, this could explain why the EC does not appear to be interested in articulating a legitimation narrative for its use of consultants beyond the rather thin veneer of cost-cutting economic efficiency.

69It should be noted that our analysis, and therefore our findings, are limited to the term of office of the Juncker Commission. Although consultants continue to represent an important part of its ecosystem, the EC has changed since Juncker left office. Notably, the von der Leyen I and II Commissions have proved less eager to pursue the type of large-scale internal governance reforms that comprised the BR Agenda. Finally, we reflect on the long-term risks associated with the involvement of consultants in public administration. Firstly, the presence of consultants seems to simply reinforce the EC’s already existing inclination to treat OPCs as largely depoliticized, purely procedural exercises. Much of this has to do with the way OPCs are awkwardly folded into much broader policy evaluation exercises, which consultants are in charge of, and which prioritize evidence-based, technocratic analysis to the detriment of normative considerations. This reality is in line with concerns expressed in specialized literature (e.g., Raudla et al., 2024) that reliance on consultants diminishes the democratic qualities of rulemaking.

70Secondly, the EC appears aligned with a broader trend of institutionalisation of outsourcing practices, which were previously viewed as a temporary solution and a ‘fire-fighting’ exercise (see Zaman et al., 2023, p. 461). In particular, the widespread use of framework contracts indicates that temporary (administrative) service-provision has been normalized, and the EC now depends on this model of outsourcing. In the long run, these tendencies may lead to the risks identified by Ylönen and Kuusela (2019): loss of institutional memory, privatization, and monopolization of public knowledge.

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Appendix

Interviews

Consultant #1 - 18 May 2020 - Consultant and Owner of Consultancy Company, London, the United Kingdom

Consultant #2 - 28 May 2020 – Consultant at a Consultancy Company, New York, the United States of America

Consultant #3 - 1 June 2020 – Consultant, Founder of Consultancy Company, Brussels, Belgium

Consultant #4 - 1 June 2020 – Consultant, Founder of Consultancy Company, Brussels, Belgium

Consultant #5 - 25 June 2020 – Consultant at a Consultancy Company, Berlin, Germany

Consultant #6 - 25 June 2020 – Consultant at a Consultancy Company, Berlin, Germany

Commission Official #1 - 22 May 2020 - Commission Official, DG for Environment, European Commission, Brussels, Belgium

Commission Official #2 - 26 May 2020 – Commission Official, Deputy Head of Unit, DG for Mobility and Transport, European Commission, Brussels

Commission Official #3 - 4 June 2020 - Commission Official, DG for Environment, European Commission, Brussels, Belgium

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Notes

1 We view consultants as contract-based actors who sell their knowledge and expertise to different clients, among whom public sector organizations (see Fincham et al., 2008; Ylönen & Kuusela, 2019, p. 243). In this article, the terms ‘consultant’ and ‘contractor’ are used interchangeably (although, in principle, the latter denotes a broader category than the former, the only kind of contractors covered in the research project are those who would fit the definition of a ‘consultant’).

2 The global industry of management consulting was estimated at $900 billion in 2020-2021 (Statista, 2022).

3 Shorter periods for stakeholder feedback (4 weeks) are available for roadmaps, impact assessments, and implemented and delegated acts. Furthermore, stakeholders have eight weeks to give feedback on proposals after they have been adopted by the College of Commissioners, and can always submit suggestions to simplify legislation and reduce regulatory burden via the “Lighten the load” platform (https://ec.europa.eu/info/law/better-regulation/lighten-load_en) (Commission, 2019a).

4 However, the EC does not accept anonymous contributions to OPCs.

5 The EC reports the results of OPCs in factual summary reports and synopsis reports. The first are published relatively shortly after the consultations close and provide basic statistical information regarding the received responses (number of participants, types of stakeholder groups etc.), while the latter are published later and are meant to show a more detailed overview of the contributions received, as well as how these inputs are taken into account by the EC. Our analysis focuses only on synopsis reports.

6 The section from the “Have Your Say” platform (https://ec.europa.eu/info/law/better-regulation/have-your-say_en) devoted to Online Public Consultations (https://ec.europa.eu/info/consultations_en)

7 Although online tools are available for all the different stakeholder feedback moments along the BR cycle, the EC seems to consider only the 12-week exercises as online public consultations per se, because these are the ones that must be carried out through online questionnaires (Commission 2017) and are included in a dedicated consultation database at: https://ec.europa.eu/info/consultations_en. Therefore, these are also the consultations that we took into account for this research project.

8 Full copies of the coding tables are available upon request.

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List of illustrations

Title Figure 1: Share of in-house and outsourced reports per number of submissions (N=249)
Credits Source: The authors
URL http://journals.openedition.org/irpp/docannexe/image/5269/img-1.png
File image/png, 7.5k
Title Figure 2: Share of in-house and outsourced reports per format of the consultation document (N=249)
Credits Source: The authors
URL http://journals.openedition.org/irpp/docannexe/image/5269/img-2.png
File image/png, 5.3k
Title Figure 3: Share of in-house to outsourced open public consultations per Commission Directorate General (N=249)
Credits Source: The authors
URL http://journals.openedition.org/irpp/docannexe/image/5269/img-3.png
File image/png, 18k
Title Table 1: Legitimacy standards for open public consultations and the role of external contractors
Credits Source: The authors
URL http://journals.openedition.org/irpp/docannexe/image/5269/img-4.png
File image/png, 94k
Title Table 2: Legitimation of public consultations and use of consultants in EC official discourse between 2002 – 2021
Credits Source: The authors
URL http://journals.openedition.org/irpp/docannexe/image/5269/img-5.png
File image/png, 116k
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References

Bibliographical reference

Andreea Năstase and Elissaveta Radulova, When Consultants Come to Town: How the European Commission Justifies the Involvement of Private Contractors in Online Public Consultations.International Review of Public Policy, 7:2 | 2025, 191-214.

Electronic reference

Andreea Năstase and Elissaveta Radulova, When Consultants Come to Town: How the European Commission Justifies the Involvement of Private Contractors in Online Public Consultations.International Review of Public Policy [Online], 7:2 | 2025, Online since 01 July 2025, connection on 13 January 2026. URL: http://journals.openedition.org/irpp/5269; DOI: https://doi.org/10.4000/14mnk

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About the authors

Andreea Năstase

Faculty of Arts and Social Sciences, Maastricht University
a.nastase@maastrichtuniversity.nl

Elissaveta Radulova

Faculty of Arts and Social Sciences, Maastricht University
e.radulova@maastrichtuniversity.nl

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Copyright

CC-BY-4.0

The text only may be used under licence CC BY 4.0. All other elements (illustrations, imported files) may be subject to specific use terms.

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