As is well understood, traditional political representation by political parties in a Parliament is not available at the EU level in the same way as in its member states. As a consequence of this fundamental barrier to democratic politics, the EU has not seen the development of the intermediary structures that allow for representative government, such as the media and political parties, in the same ways as they evolved in member states. In this context, functional representation has been perceived by some as a potential equivalent to electoral representation, offering a source of legitimacy-generation that can compensate for the lack of legitimacy generated through the standard model of representative democracy at the EU level. This contribution looks at how civil society organizations cooperate supra-nationally, under the head of European umbrella organizations, in order to discuss in how far they can compensate for the lack of more traditional forms of democratic representation at the EU level. To do so, it uses fresh qualitative data from three kinds of organizations representing different kinds of interests: agricultural, environmental and anti-poverty groups. The findings show that at present, the capacity and/or willingness of civil society actors to cooperate under the head of European umbrella organisations, and to represent a European rather than a national interest, is limited.