From Show to Substance: How Public Affairs Gets Its Bite Back

By Stefan Borst, Senior Partner Advocacy Strategy

We’ve all been there: the LinkedIn post goes viral, the panel is packed with stakeholders, the photos look great – and nothing in the annex changes.

Welcome to the squeaky-clean world of “hands-off” lobbying. A place where performance scores higher than impact. An in these digital times it sometimes feels like our craft lost its bite.

Do not get me wrong, visibility is crucially important – as a tool in certain moments. Public Affairs departments also have to justify their existence from time to time with a little show. But without a clear plan for how to change a law that might affect your operational business, those flashy moments are essentially a waste of money and time.

The real ROI is measured in votes and text. Everything else is either useful to promote this goal or merely decoration.

There are, of course, campaigns where visibility is the outcome: licence to operate, reputational signalling, showing alignment with a political priority. That’s fine – as long as you are honest with yourself about which game you are playing and don’t confuse one with the other.

Where influence actually lives

EU policy is engineered through early, structured steps: initiatives, roadmaps, inception impact assessments, consultations, impact assessments, drafts (green and white papers for the nostalgics among us). If you’re late, you’re loud. If you’re early, you’re useful – and might even achieve success almost unnoticed.

The Commission’s own Better Regulation toolbox is a treasure trove to understand where officials need and welcome credible help. So, compile numbers that make sense, draft text that survives inter-service comments and spend some time coming up with practicable ways a piece of legislation might function and be enforced in real life.

And then remember: it’s not just the Commission. Council working parties, permanent representations and political groups in the Parliament are not stage props in this story – they are co-authors. Sure, media and public sentiment are not “just show” either; they set the political guardrails within which your beautifully crafted option is even thinkable. But guardrails don’t care about details. And details are where you can make a difference. 

To prove the point

• Automotive – Euro 7: The final deal tightened rules for buses and trucks and introduced the first brake particle cap for cars but largely kept passenger-car tailpipe limits and stretched timelines. The media moments were dramatic, but the outcome hinged on annex language, durability factors and Council/EP maneuvering. Translation: work on your tables and your trilogue lines at least as much as on LinkedIn posts, talking points and panel appearances.

• Chemicals – PFAS restriction: ECHA’s PFAS process attracted 5,600+ comments. What moves decisions here? High-grade socio-economic analysis (SEAC), enforceability advice (Enforcement Forum), precise derogation text – and Member States who can defend those choices at home. A sweeping advocacy campaign won’t survive without numbers, substitutes and timelines that regulators and capitals can defend.

• Energy – Renewable hydrogen (RFNBO): The delegated act set “additionality” and correlation rules, including a monthly match that tightens to hourly from 2030 and a 36-month rule linking new renewables to electrolysers. Those details came from heavy technical feedback, not podium talks. If your memo modelled operational feasibility and could reassure both the desk officer and a sceptical capital, you mattered.

• Tech – AI Act & DMA: The AI Act’s obligations for general-purpose models and the code-of-practice pathway were honed through painstaking drafting and political triangulation between Parliament, Council and Commission. And in 2024–2025, DMA probes and first fines showed that enforcement hinges on specific areas of compliance, not grand statements. Viable texts beat viral threads by a long shot.

If you overlay these files with what follows, a pattern emerges: those who mapped real decision makers (including in Council), picked their timing, brought workable text and used “show” moments in a targeted fashion are the ones whose fingerprints are now baked into annexes, recitals and guidance.

How to break the ‘show first’ habit

Everyone who has operated an office in Brussels knows: a little bit of show – especially for the internal hierarchy – is not only helpful, but necessary. Yet a great Public Affairs leader knows how to combine the internal battle for attention and budget with external action in the trenches of legislation. The trick is to use “show” as leverage to win resources for “substance”. Here are some steps that may be helpful for the latter.

1.     Map decision makers first, then look at audiences

Make sure you really know – not only procedurally, but in reality – who ultimately influences the decision you need. This group of people will be small. In many files, that list looks something like: a handful of desk officers and heads of unit, a rapporteur and a couple of shadows, one or two Council working parties and a few key Member States holding the pen. That’s your primary universe.

Then think about how you can reach them. This is where the audience approach comes in. Decision makers do not live in isolation. They may be part of one or several groups (audiences) where the sentiment may influence them: party families, business federations, NGOs, national media, their own governments or constituencies.

Map the decision makers first. Then use audiences – and yes, sometimes public “show” – to shift the environment around them.

2.     Know your timing

A good advocacy tactic must move in lockstep with the legislative process, otherwise it’s theatre. Use tools to stay on top of developments – there are plenty of those out there – and translate the big picture into a simple internal timeline:

• When is the inception impact assessment?

• When are key Council working party discussions?

• When is the rapporteur drafting?

• When does your worst-case scenario become “locked”?

If you can’t point to the decision point your activity aims to influence, you’re probably doing content marketing, not Public Affairs.

3.     Use a dashboard

Track your dossiers, quantify their priority and measure wins: a recital narrowed, a threshold adjusted, a compliance duty clarified. Be sure to keep an overview of all quality interactions (desk-officer work sessions, accepted submissions, questions from a capital, etc.). It is nice to quantify your reach and visibility. It is much better to know what impact your work is creating. Also: use this dashboard as a weapon in your internal politics. CEOs and Comms teams love numbers – so give them better numbers. Show, over a year, how three boring text changes beat a hundred thousand impressions when it comes to risk avoided, cost saved or opportunity created. That is how you win the internal battle for budget. 

4.     Practice realism

Your CEO may want to abolish all red tape, but it is your job to transform that desire into something realistic. So, understand what your operational business really needs. Then understand how policy needs to change to achieve that. That is your optimal scenario. Then look at what politics is about to do – which likely will provide you with a worst-case scenario (yes, I am exaggerating… slightly). Now pair policy plans with economics, involve legal and ops to produce feasibility notes and start drafting texts that people can actually paste into annexes, recitals or guidance. Draft and draw compromise lines before you need them.Realism also means accepting that Member States and political groups have red lines. If your “perfect” text boils down to “wishful thinking informed by the marketing department” it will be dead on arrival. Better to understand that early and design the best politically feasible version of reality than to die the hero’s death on the hill of unrealism. 

5.     Choose your tools smartly

Early stages: technical coalitions and workable options. Late stages: political breadth and cover. In between: targeted national work, especially where key capitals are holding the pen. Be explicit about what a panel, op-ed or campaign is supposed to be for (e.g. road-testing a compromise line, signalling cross-sector support, creating air cover for a Member State change of position) and cancel it if it isn’t tied to an identified decision point. Media and flashy events are not evil. They are just expensive tools. Use them when they help move a specific person at a specific moment – not to comfort yourself that “something is happening.” 

6.     Close the loop

Six to twelve months after adoption, check implementation fidelity – did your elegant sentence survive contact with reality? Did the way Member States transpose and enforce the rules remotely match what you briefed your board on? Feed the lesson into guidance, delegated acts and the next round of legislation. Policy is a revolving game that never really ends. If you treat adoption as the end point, you are leaving a lot of influence – and a lot of business risk – on the table.

What do you get for all this effort?

If you implement at least some of these steps, your calendar will get lighter and your advocacy will hit the mark more often. Trade one viral LinkedIn post for three lines that decide actual behaviour in the market. And enjoy the results of making a difference instead of just creating noise (don’t get me wrong, flashy events are fun, too. Networking does matter. But that is for another post).

If you want a quick test before you or someone suggests the next “big moment”, try these questions: 

1. Which specific decision maker(s) should this move?

2. At which specific decision point in the process?

3. In what specific way should they behave differently afterwards?

If you can’t answer all three, you are not doing advocacy, you are conducting theatre.

Public Affairs isn’t broken – but at the moment it feels a bit digitally distracted. Brussels still rewards most those who bring the right goods to the right room at the right time. Let’s choose substance over show.