How the Bologna Process Governs Without Law: A Para-Comitological Perspective on European Higher Education

This article proposes a para-comitological interpretation of the Bologna Process, arguing that its governance architecture is committee-centred and functionally comparable to EU comitology while remaining legally distinct. Although the Bologna Process is formally intergovernmental and non binding, it has developed a stable and highly structured coordination system based on permanent and semi-permanent bodies, proceduralised working methods and iterative policy cycles. While existing literature has analysed the Bologna Process mainly through the lenses of soft law, Europeanisation and experimentalist governance, limited attention has been paid to the implications of its committee based architecture as a governance model in its own right. Drawing on a qualitative analysis of institutional documents – including ministerial communiqués, the Rules of Procedure of the Bologna Follow-Up Group (BFUG), mandates of working groups and documents relating to the Bologna Secretariat – this article reconstructs the operational structure of the process and compares it functionally with EU comitology under Article 291 of the Treaty on the Functioning of the European Union (TFEU). Rather than claiming legal equivalence, comitology is used as an analytical benchmark to identify similarities in governance practices, including delegated technical work, reliance on expertise, procedural continuity and structured follow-up mechanisms. The concept of para-comitology is introduced to capture these dynamics. The article argues that the Bologna Process represents a mature form of institutionalised soft governance, offering a useful perspective for analysing coordination mechanisms in policy areas characterised by limited formal competences and raising broader questions about legitimacy, accountability and governance beyond hard law in European integration.