Shared objectives, fragmented efforts: Non-state actor advocacy and the politics of coalition-building in EU AI Governance

The regulation of artificial intelligence in the EU has mobilised a wide range of non-state actors, including digital rights groups, non-profit organisations and grassroots movements. In theory, these actors have a considerable overlap in their objectives, structural position and normative commitments, especially regarding their calls for democratic oversight and their concerns about the dominance of big tech corporations from the United States. Yet, despite their sustained efforts over the last three years, their impact in Brussels has remained limited at best. In this paper, I argue that this limited impact of non-state actors is not primarily due to a lack of access, but to their fragmented advocacy and lack of coalition-building. Drawing on theories of coalition building from the field of social movement studies, I show that strategic disagreements, divergent framings and lack of coordination have prevented non-state actors from forming a cohesive advocacy coalition that would be able to counterbalance more unified (US) industry interests effectively. Empirically, the paper combines a qualitative analysis of consultation submissions, policy documents as well as advocacy and campaign materials with elite interviews and process tracing of key moments in the AI Act negotiations. The findings contribute to debates on the role of non-state actors in EU digital governance and underscore the importance of coalition coherence for effective policy impact in Brussels.