The obsequiousness epidemic: three phrases we should banish from position papers

Every trade association in Brussels employs someone whose entire job is disagreeing with the European institutions without ever using the word "disagree."

Read enough position papers and you learn to recognise the tell: "we support the Commission's ambition on X," followed by ten pages explaining why X, as drafted, would be a disaster. The agreement is theatre. Everyone in the room knows it. And still the theatre continues, dossier after dossier, because somewhere along the way Brussels decided that saying what you actually think is bad manners.

It isn't manners. It's a failure of nerve, and it costs more than it saves.

Start with the reflex itself. Public affairs people hedge because the institutions are the regulator, the gatekeeper, and — for anyone hoping to be in the room next time — the audience whose good opinion matters more than winning this particular fight. If you’re working on a trade or competition file, the Commission has quasi-judicial powers. And in many cases, they’re also a lobbyist’s dream future employer.

Disagreeing plainly feels like a relationship risk. So the public affairs industry has built an entire dialect around avoiding it: frame the objection as a question about "implementation," recast disagreement as a concern about "legal certainty," volunteer to "work constructively" on whatever emerges from trilogue however hideous that turns out to be. None of it is dishonest exactly. It's evasive in a way that's been normalised to the point where nobody notices it happening.

The trouble is that regulators are not, in fact, mind readers.

A Commission official reading "we agree with the objectives" has limited reason to discount it as ritual softening, particularly when every other submission on the file uses the identical formula. The framing makes the actual argument harder to find and easier to ignore, and it’s far easier for the file to move forward on the assumption that industry broadly accepts the direction of travel.

If you think an approach is wrong and saying so is a relationship risk, then frankly it’s probably not much of a relationship to begin with anyway. But failing to say so, then discovering three years later that everyone treated your silence as consent, makes it considerably worse.

"Legal certainty" deserves particular scrutiny

This phrase is most often used to smuggle an objection past a reader who's stopped listening for one.

Nobody actually wants certainty in the abstract. A ban is certain. Liquidation is certain. What the phrase is doing is dressing up "we want a specific, favourable answer" as a neutral concern about regulatory process, because asking for a favourable answer sounds like special pleading, whereas asking for "certainty" sounds like good governance. It's a more respectable-sounding way of saying the same thing, which is precisely the problem: it obscures rather than clarifies what's actually being asked for, at the exact moment clarity would serve best.

And then there's the sign-off that closes almost every submission: "we stand ready to work constructively with the co-legislators." This one is nearly content-free. It commits to nothing, endorses nothing, and objects to nothing. It's simply a placeholder deployed by people who don't yet know what the final text will look like and don't want to be on record either way. If you have a view on which version of a given article should prevail, put it in amendment form. If you don't have one yet, say that, or say nothing.

A sentence that reads as cooperative regardless of outcome is a hedge, not a position, and it wastes everyone’s time.

None of this is a case that euphemism single-handedly produces bad legislation — that's a harder claim, and one that would need dossier-level evidence to support properly. The claim here is narrower and, I think, harder to dispute: this style of communication makes the industry's actual arguments less legible to the people meant to be persuaded by them, at exactly the moment legibility matters most.

A submission that spends its opening agreeing with a Commission position it goes on to eviscerate is asking a policy official, mid-triage, to do the work of locating the real argument themselves .

The institutions can handle direct disagreement. They deal with it from Member States, from Parliament committees, and from each other, constantly. What they seem less used to is direct disagreement dressed as anything other than direct disagreement. Brussels needs public affairs people willing to write down what they actually think, and let the institutions respond to it.