Involving civil society – in particular affected stakeholders – is often seen as a solution to democratic deficits. High expectations ride on the promise of participation in new modes of governance at the EU, such as the Open Method of Coordination (OMC). But its results have been modest, and it is unclear who should participate where, and how. Corinna Wolff offers a consistent framework to assess participation from the perspective of democratic legitimacy, conceptualising it as functional representation. She reviews recent theories of representation, develops them into a tool to deal with complex governance settings, then applies this framework to functional representation at the European Commission in EU social policy. The results indicate that far from being a panacea, functional representation raises fundamental questions about the possibilities for democratic European governance.