Who Speaks Like Citizens? Investigating Citizen-Interest Group Congruence in Stakeholder Feedback to European Commission Consultations

The widening gap between policy and citizens' immediate concerns has intensified calls for more inclusive and participatory policymaking. While public consultations can serve as venues for increasing input legitimacy and bridging this democratic deficit, little is known about the conditions under which citizen and interest group feedback align in consultations. Exploring citizen-interest group policy congruence provides insights into the circumstances under which interest groups best represent citizen interests and into the nature of the citizens who participate in public consultations. Drawing on the literature of interest representation and lobbying, as well as research on stakeholder participation and diversity in consultations, I expect that citizen-interest group congruence will be higher on issues of public salience, issues that are less complex, and with non-business actors. To test these hypotheses, I analyze 150,410 citizen-interest group dyads based on 13,918 stakeholder submissions to 267 public consultations between 2016-2021. Using GloVe word embeddings to calculate cosine similarities between citizen and interest group consultation responses, the results show that interest group type is a stronger predictor of citizen-interest group congruence compared to consultation-level factors such as salience and complexity. Public authorities, trade unions, consumer organisations, and environmental organisations demonstrate significantly more congruence with citizen submissions compared to business groups. Furthermore, in a subsample of 48,920 citizen-nonbusiness group dyads across 229 consultations, the results show that complexity and salience are not strong predictors of congruence between citizens and nonbusiness actors, but some consultation topics (Regional policy, Environment, Banking and financial services) have a positive impact on congruence.