Stakeholders of democracy promotion frequently criticise the European Union (EU) for the lack of sensitivity to country-specific contexts. This critique concerns both the concept of democracy and the means through which democracy’s development ought to be supported from the outside. In this paper, we examine the validity of this claim by providing evidence of the substance of “democracy” in the EU's democracy promotion. To do that, we ask: Is the EU’s concept of democracy sensitive to contextual factors in third countries, and if so, how? To answer this question, we build on Merkel’s (2004) analytical concept of embedded democracy and trace the substance of the Union’s understanding of democracy taking into consideration additional norms. Methodologically, we build on quantitative text analyses to study the EU’s progress reports published between 2004 and 2019 addressing countries of the European neighbourhood in its broader understanding (i.e., countries in the Eastern and Southern neighbourhood, the Western Balkans, and Turkey). With this article, we contribute to the understanding of EU democracy promotion in third countries, as well as the role of time- and country-varying contextual factors in EU democracy promotion.