This paper examines characteristics of the content of comment letters (CLs) written by European constituents and sent to the European Financial Reporting Advisory Group (EFRAG) and International Accounting Standards Board (IASB) to influence the development of International Financial Reporting Standards (IFRS). Following a multi-issue, multi-period approach, the study presented here involves a manual content analysis to compare the scope (i.e., organisation-specificity), form (i.e., completeness and level of detail), and tone (i.e., level of support) of the content of 892 pairs of CLs sent to EFRAG and the IASB between 2008 and 2016. Overall, the findings illuminate the participatory practices of European constituents in a cross-organisational setting, thereby challenging the common assumption that they send almost only highly similar or identical CLs to EFRAG and the IASB, as well as elucidate EFRAG's intermediary role in setting international accounting standards.