www.ec.europa.eu/haveyoursay

                                                                   

Platform URL: https://ec.europa.eu/info/law/better-regulation/have-your-say_en

The COCOO-“Have Your Say” Doctrine: A Strategic Model for Proactive Policy Warfare

This doctrine establishes the protocol for interrogating the European Commission’s “Have your say” portal. This is not a feedback form; it is the EU’s primary battleground for shaping future legislation and policy. We will weaponize this platform to preemptively influence lawmaking, build coalitions, conduct high-level competitor intelligence, and generate the strategic opportunities that are the cornerstone of COCOO’s mission. This platform is the engine for our USP origination, our Challenge Discretion doctrine, and our WPI (Public Interest) narrative campaigns.

1. Core Principles of Interrogation

Our use of the “Have your say” portal is governed by the most proactive principles of the COCOO framework. We do not react to laws; we shape them before they are written.

  • Preemptive Strike Capability: The portal’s “Call for evidence” stage is our primary target.1 It allows us to intervene at the very inception of a new policy, long before the text is solidified. By submitting evidence and framing the problem early, we can shape the entire legislative trajectory in our favour, a core tenet of our proactive doctrine.
  • The USP Generation Engine: Every “Call for evidence” is a publicly declared problem that the Commission is seeking to solve. This is a direct invitation for a COCOO Unsolicited Proposal (USP).3 We will analyze these problems and propose COCOO-led solutions, offering our services as mediators, consultants, or managers of implementation frameworks directly to the Commission or to the industries that will be affected.
  • Open-Source Competitor Intelligence: The public nature of submissions is a goldmine.2 By analyzing the feedback provided by our competitors (e.g., major corporations like Google, Apple, or industry associations) on closed consultations, we gain unparalleled insight into their strategic fears, lobbying priorities, and internal thinking. This is a critical input for our Competitor Analysis.1
  • The WPI (Public Interest) High Ground: This platform is where the narrative battle for the “public interest” is fought. We will use our submissions to frame our objectives in the language of EU policy—sustainability, consumer welfare, market efficiency—and to deconstruct the self-serving arguments of our opponents, seizing the WPI high ground.6

2. Weaponizing the Platform’s Arsenal: Capabilities and Search Rules

Mastery of the portal’s filtering system is essential. It allows us to surgically target the initiatives that matter most to COCOO’s mission.

  • Official Search Rules & Functionality: The “Have your say” portal is a structured database of legislative and policy initiatives. The rules for interrogation are based on its powerful filtering capabilities 1:
Filter Function & Strategic Importance
Keywords A free-text search across initiative titles and descriptions. Useful for broad initial scans (e.g., searching for “supply chain” or “due diligence”).
Topic Our primary filter for sectoral focus. Allows us to isolate initiatives in critical areas like Competition, Single market, Banking and financial services, or Environment.
Stage The most critical strategic filter. Allows us to track and intervene at every point in the policy lifecycle: In preparation, Call for evidence, Public consultation, Draft act, and Commission adoption.
Feedback status Our action trigger. Allows us to filter for initiatives that are Open for feedback, Upcoming, or Closed. We will focus on “Open” and “Upcoming” for proactive engagement.
Type of act Tells us the legal weight of the initiative. We can filter by Legislative proposals, Delegated regulation, Implementing acts, or Communication, allowing us to prioritize our efforts on legally binding acts.

3. Strategic Interrogation: The Questions We Ask

We interrogate this platform to find the future conflicts and opportunities we can shape today.

  • For USP Origination & Preemptive Influence:

    • “Which initiatives in the Topic: ‘Banking and financial services’ are currently at the Stage: ‘Call for evidence’? What systemic risks are they trying to address that COCOO could offer a USP to solve?”
    • “The Commission has an upcoming consultation on the “. What are the key questions in the ‘Call for evidence’ document? How can we frame our submission to benefit our clients in the automotive sector?” 6
    • “Is the Commission planning a new Delegated act in the Topic: ‘Digital’ that could impact Big Tech firms like Meta or Amazon? What is the feedback period?” 1

  • For Competitor & Stakeholder Intelligence:

    • “In the Closed consultation on the EU Cybersecurity Act, which major technology firms and industry associations submitted feedback? Download their submissions. What are their stated positions, and what do they reveal about their strategic vulnerabilities?” 1
    • “Who were the key stakeholders that contributed to the evaluation of the EU rules on medical devices? This helps us map the political landscape of the sector.” 2

  • For Challenge Discretion & WPI Framing:

    • “The Commission is proposing a new Legislative proposal on ‘Industrial Decarbonisation’. How can we frame our submission to argue that their proposed approach creates an unfair ENTRYBARRIER for smaller firms, contrary to the public interest in a competitive market?” 3
    • “Does the ‘Consultation Strategy’ for the upcoming ‘Action Plan on the implementation of the European Pillar of Social Rights’ adequately consider the impact on business competitiveness? If not, we must submit feedback challenging the methodology.” 1

4. The COCOO-“Have Your Say” Strategic Playbook: A Model for Action

The following playbooks provide standardized workflows for using this platform to generate strategic influence and opportunities.

Playbook A: The “Early Strike” (USP Engine)

  • Objective: To identify emerging policy initiatives at their earliest stage and use them to generate high-value Unsolicited Proposals.
  • Execution:
    1. Set Up Monitoring: On a weekly basis, access the “Have your say” initiatives page.
    2. Filter for Opportunity: Apply the following filters: Feedback status: “Open” OR “Upcoming” AND Stage: “Call for evidence”.
    3. Select by Topic: Further filter by a strategic Topic for COCOO, such as Competition or Single market.
    4. Analyze the Problem: Review the resulting initiatives. For each one, download the “Call for evidence” document. This document explicitly states the problem the Commission is trying to solve.
    5. Develop the COCOO Solution: For any identified problem where COCOO has expertise, draft a USP. Example: The Commission issues a call for evidence on “Sustainable Corporate Governance.” COCOO develops a USP for a new, mediated framework that helps companies comply with future due diligence requirements, and submits this as part of its feedback.
  • Strategic Outcome: This playbook transforms COCOO from a reactive legal entity into a proactive policy partner. We are not waiting for laws to be passed; we are offering to help write the solutions, positioning COCOO to win contracts for their implementation.

Playbook B: The “Adversary’s Mind-Map” Audit

  • Objective: To build a detailed intelligence dossier on the lobbying positions and strategic priorities of our key corporate adversaries.
  • Execution:
    1. Identify a Closed Consultation: Select a recently Closed consultation in a sector of strategic importance. Example: The consultation on the “Review of the Merger Guidelines.” 6
    2. Access Submissions: Navigate to the initiative’s page and find the section containing the published feedback from stakeholders.
    3. Harvest Competitor Data: Systematically search for and download the submissions made by our key corporate targets (e.g., Microsoft, Siemens), their law firms (e.g., Mayer Brown), and their industry associations.
    4. Analyze and Deconstruct: Analyze these documents to understand their red lines, their preferred policy outcomes, and the arguments they use to support their positions.
  • Strategic Outcome: This provides an unparalleled, open-source intelligence view into our adversaries’ strategic thinking. When we next face them in a MATOIPO case or a regulatory challenge, we will already know their playbook.

Playbook C: The “Targeted Influence” Campaign

  • Objective: To execute a focused campaign to influence a specific, high-stakes legislative proposal.
  • Execution:
    1. Identify the Target Initiative: Using Playbook A, identify a key upcoming Legislative proposal or Delegated act.
    2. Build the Evidence: Use the full COCOO intelligence arsenal (Violation Tracker, Eurostat, etc.) to gather hard, quantitative data that supports our desired policy outcome.
    3. Frame the Narrative: Use the WPI principles to frame our argument. The submission should not read as self-interested, but as a good-faith effort to improve the law for the benefit of all Europeans.
    4. Draft and Submit: Draft a formal, evidence-based submission in response to the Public consultation or Draft act feedback period.
    5. Amplify (Optional): Coordinate the submission with a targeted media campaign via the EC.presscorner to ensure our position is heard beyond the confines of the portal.7
  • Strategic Outcome: This playbook operationalizes our lobbying strategy. It provides a structured method for directly influencing the text of EU law, creating a more favourable regulatory environment for COCOO and its clients.

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