Today’s information systems are often large and complex, affecting many people within and beyond the organization. Participation in this context is increasingly challenging because of the complexity of involving all who might be affected by a new information system. As a result, systems of representation, in which individuals are chosen to represent others, are often put in place to manage the participation process. Research has considered particular challenges of “representative participation” (Mumford, 1983); however, there is little empirical research comprehensively examining these systems of representation. Who participates in these systems, how are they structured and how is this representative work undertaken? Most importantly, what are the impacts of these decisions on the representation systems that are built and on the participation that flows from them? The purpose of our research is to explore the structuring of systems of representation in IS development and implementation. Building on the work of Land and Hirschheim (1983) and Mumford (1983), and drawing on Habermas’ deliberative democracy (1998), this research explores the system of representation employed in a large Electronic Health Record implementation as empirical evidence. Healthcare is a critical context for studying information systems implementation because of its uniqueness and complexity (Chiasson and Davidson, 2004; LeRouge et al., 2007), and therefore serves as an important environment for this research. Our contributions, drawn from this Electronic Health Record project, include an understanding of three fundamental tasks for developing systems of representation: defining the constituency, selecting representatives, and determining how the representation relationship will be carried out. We demonstrate that systems of representation can be classified by different meanings of “represent.” These types – “represent as spokesperson,” “represent as example” and “represent as symbol” – differ in the purpose of representation, in who is involved and in how representation is undertaken. Most importantly, these types of systems differ in their participatory potential. The findings highlight the opportunities and challenges inherent in the construction and implementation of systems of representation. The paper concludes by exploring the implications of these findings for practitioners and researchers, suggesting that representation should be more than simply appointing representatives, and offering mechanisms for participation and influence. We call on researchers to view these systems of representation in more fine-grained ways to better understand what their complexities mean for contemporary system development and implementation.