November 3, 2021

Submitting to EC Consultation

We recently developed Proca to interface with the feedback mechanism for the European Commission (EC). This was used successfully by a coalition of groups who wanted to encourage their members, supporters and the wider public to respond to a Feedback Mechanism about regulation of genetically modified plants based on new genomic techniques (which you can see here). We are happy to have contributed to democracy by making it easier for campaigners and the public to have their views heard.

Improving Democracy

One of the stated ambitions of the current Commission is Better Regulation. One of their objectives “Involving citizens, businesses and stakeholders in the decision-making process”. One part of this is through citizen consultations, to gather feedback before drafting new laws. 

Unfortunately, the EC system has a rather cumbersome implementation which makes taking part difficult for “normal” citizen. It requires people to create an email account, verify the email, then reload the page to submit their comment, which takes a few minutes. This means that in practice, most consultations only get responses from lobbyists and very engaged citizens, often within the EU bubble, and most consultations have a low amount of participation. There was recently a report by the European Court of Auditors about the Commission’s public consultation work, which said that outreach activities fell short. 

The ‘Feedback Mechanism’ comes at an initial stage in the legislative development and asks for a single comment from individual members of the public, stakeholders, experts, etc. Later on in the process is a Public Consultation (you can read more about the different steps on the EC’s website here). Occasionally, some consultations have received a huge number of responses, such as the one about forest regulation or the consultation on summertime. When there is lots of big democratic participation, it is almost always due to a broad network of Non-Governmental Organisations and campaigners who are organising and mobilising citizens. We believe this is vital to our democracy and we are proud of our work to support them.

We are pro-democracy and think that participation in political processes should be as open as possible, and therefore created a tool to simplify the process and allow people to submit a comment to the EC feedback mechanism using a simple comment box. We are pleased that our tool enabled a huge number of people to participate in the feedback than would usually do so. There were over 60,000 responses, which is many times higher than a typical one.


Our development of an interface with the feedback mechanism for the European Commission (EC), as part of Proca is an expansion of the different actions available on the platform which we are happy to have.

Proca is a digital action toolkit and works by giving each organisation a widget which they can embed anywhere on their website, meaning the action can happen where they want them to. It is designed for coalitions, making it easy for multiple organisations to take part in a campaign together. You can read more here.


Our platform functions as an equivalent to the European Commissions official platform, as there is no additional verification in their platform that we bypass and our submissions are fully in line with their rules for suitable feedback.

The main functional difference is that the individual respondent does not need to verify their email address when submitting through Proca, as we handle submission behind the scenes. Email verification is not something that is required by the EC’s rules, nor is it a meaningful security step. Removing this step therefore makes it easier for people to respond. We do still run a ‘deduplication’ process on our submissions to ensure that there is only one submission per email address,

Each organisation could choose how they encouraged responses and how their widget worked. Many pre-filled the ‘comment’ field to suggest a message for an individual user to submit, which users were free to edit. Some organisations left the field blank and suggested some points that could be made on the webpage.

Interfacing with the European Commission’s Platform

We hope that the European Commission will recognise that more participation in public feedback processes and consultations is a good thing and develop an API which we could integrate with Proca to facilitate greater participation in them.