The European Commission’s expert group system has been criticized as closed, elitist and dominated by vested interest. This paper examines how the Commission has responded to external demands to ‘democratize’ their expert group system by posing the question: has there been significant reform of their expert groups or is the Commission resistant to change? The research applies Boswell’s (2008) organizational action theory typology on how organizations respond to external challenges (Full Adaptation, Evasion, Institutional Decoupling and Reinterpretation) by examining the Commission’s response to four key themes relating to expert groups: openness, transparency, epistemic diversity and effectiveness. The research is based on semi-structured interviews with Commission Officials, statistical analysis of information within the Commission’s Online Register of Expert Groups and an examination of primary Commission documents. The aim is to assess how the Commission responds to external challenges and what their response means for the legitimacy of EU policymaking.