The EU’s foreign and security policy is often criticised for being undemocratic. The article addresses this contention from the perspective of deliberative democracy. The focus is on the procedural qualities of the second pillar decision-making processes as it is not only the quality of the outcomes that determine the democratic legitimacy of policy-making, but also the way decisions have come about. Against five criteria, the EU’s second pillar procedure is assessed for its putative lack of democratic qualities. The evaluation shows that decision-making is dominated by secrecy and unelected officials who act extensively on behalf of national ministers without proper accountability mechanisms available. Whereas there are conditions conducive to deliberation, they are basically found outside the formal settings and among unelected officials. There are no institutionalised rules where the responsible politicians are obligated to justify policy choices in front of the citizens. Hence the second pillar is only likely to enhance elite deliberation.
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