EU Inclusion Policies Rest on Individual Commitment, Study Finds

A new study of the European Union’s institutional communication reveals a striking paradox: while the EU has built one of the world’s most extensive frameworks for diversity, equity and inclusion (DEI) in public communication, the daily practice of inclusive messaging depends largely on the discretionary commitment of individual professionals rather than formal organizational structures. Researchers from Sapienza University of Rome, the University of Tuscia, and the University of Beira Interior published their findings in Frontiers in Communication, identifying what they term “entrusted inclusion” — a condition where inclusive practice is sustained day to day by personal dedication rather than being secured by roles, procedures, and evaluation metrics.

The research team, led by Lucia D’Ambrosi, combined documentary analysis of European policy frameworks and communication guidelines issued between 2018 and 2026 with twenty semi-structured interviews conducted in 2026 with communication officers, policy officials, and external practitioners working for European institutions at the central level. Interview data were analyzed through reflexive thematic analysis, a method that allows researchers to identify patterns of meaning while remaining reflexive about their own interpretive assumptions.

The study traces three distinct phases in the evolution of EU DEI communication policy. Between 2018 and 2019, institutions established gender-sensitive language as an explicit commitment, introducing guidelines on gender-neutral terminology and the countering of stereotypes. The second phase, from 2020 to 2025, saw the launch of the Union of Equality agenda under the von der Leyen Commission, which formally articulated diversity, equity, and inclusion as an integrated framework combining gender mainstreaming with intersectionality as a horizontal principle. The current cycle, spanning 2026 to 2030, marks a more structural shift, with DEI being integrated into organizational processes, evaluation mechanisms, and professional training, while artificial intelligence is explicitly identified as a vehicle for gender bias requiring mandatory impact assessments.

Despite this increasingly articulated policy architecture, the researchers found that the documents analyzed do not specify who is accountable for putting inclusive communication into practice. The frameworks remain largely prescriptive and text-centred, with limited attention to the organizational conditions under which institutional communication is actually produced — the clearance procedures, the tools employed, and the hierarchical dynamics that shape final output. This gap between declared policy and structural practice is what the researchers conceptualize as the space where “communicative clashes” emerge.

Communicative clashes, as defined by the research team, are the breaking points at which institutional communication aimed at inclusion comes into conflict with its own production processes, forms of representation, or reception dynamics, generating effects that are unforeseen or even contrary to the initial intention. These include tokenism, diversity washing, intersectional algorithmic bias, over-blocking in automated moderation, and forms of discursive marginalization. The concept is distinct from simple communication failure; it names structural tensions between inclusive intent and the organizational and technological conditions of its production.

Three dynamics compound the fragility of entrusted inclusion. First, the validation chain — understood by professionals as a safeguard of quality — is reported to dilute inclusive intent. The more strategically important a message, the further it moves from communication professionals towards management levels that may lack the specific cultural knowledge the message requires. One interviewee described the resulting hybrid product as “a sort of Frankenstein’s monster,” assembled from disparate contributions without a coherent vision. Second, the feminization of the DEI field concentrates inclusion work in roles with limited decision-making authority, reproducing the very gendered asymmetries the policies are meant to address. The sample of twenty interviewees included fourteen women and six men, a pattern consistent with interviewees’ accounts of their units. Third, external backlash produces divergent institutional responses, ranging from resistance to adaptation and formal retreat.

The study also identifies a significant blind spot in the institutions’ approach to artificial intelligence. Internal rules governing AI use in institutional communication are oriented to data protection and factual accuracy but remain silent on the representational quality of generated content. AI-assisted content passes through standard review and approval chains without a dedicated checkpoint for representational bias, gender stereotypes, or other distortions that generative systems may produce or amplify. Institutions prefer proprietary or in-house developed tools, such as GPT@EC, and ban AI-generated imagery in external communications to show real people. Yet the review processes through which all content passes were designed to catch factual errors, tone problems, or oversights — not to check whether an AI-generated text or image reproduces stereotypes or excludes someone.

The researchers are careful to note the limitations of their approach. The study analyses professional accounts and institutional documents rather than communication outputs or audience responses, meaning its claims concern how inclusion is produced and perceived inside the institutions, not the properties of published content. The sample provides more substantial empirical evidence for the European Commission than for the Council and the Parliament, and it primarily reflects the perspectives of professionals already involved in DEI-related roles. The behavior of senior validators is reconstructed largely from the accounts of professionals who work below them in the hierarchy.

The findings carry significant implications for how inclusive communication is understood and implemented. The researchers argue that the remedy for entrusted inclusion lies not in strengthening declarations but in allocating inclusive responsibility to roles, procedures, and evaluation criteria. Without such structural embedding, inclusive practice remains vulnerable to changes in personnel and leadership. The study’s conceptualization of communicative clashing — the ongoing collision of inclusive intent with the conditions of production, control, and mediation — offers a framework for understanding why well-intentioned policies can produce outcomes that run counter to their original aims, and points toward the organizational reforms needed to close the gap between policy mainstreaming and structural practice.

Subject of Research: Diversity, equity and inclusion in EU institutional communication

Article Title: Diversity, equity and inclusion in EU public communication. Between policy mainstreaming and communicative clashes

Article References: D’Ambrosi, L., Radano, G., Taverna, V., & Oliveira, E. (2026). Diversity, equity and inclusion in EU public communication. Between policy mainstreaming and communicative clashes. Frontiers in Communication, 11, Article 1950049. https://doi.org/10.3389/fcomm.2026.1950049

Image Credits: AI Generated

DOI: 10.3389/fcomm.2026.1950049

Keywords: EU policy, diversity and inclusion, institutional communication, artificial intelligence, organizational culture, public communication, Diversity, equity, inclusion, public, communication, Between