The use of English as lingua franca in mainland Europe’s higher education and research sectors has rapidly expanded over the past several decades. Despite these expansions, critics claim that there is a conspicuous absence of European Union (EU) language policy concerned with the use of English as a “contact” language in education and research contexts. This study attempts to assess these claims by conducting a comparative analysis of English as a lingua franca discourse in the policy declarations and communications of two EU actors with remits for higher education and research – the European Higher Education Area (EHEA) and the European Research Area (ERA). Using methods that draw on critical discourse analysis and corpus linguistics, I compiled specialised corpora consisting of the policy documents published by the EHEA and the ERA over the past twenty years. I then used the corpus analysis tool Sketch Engine and a reference corpus of general EU discourse to assess how often and in what ways language policy was considered. The analysis reveals intra-institutional conflicts in how language is conceptualised between policy actors and across policy portfolios in the EU. The findings also confirm the absence of explicit discourse on the use of English in academic and research contexts over the institutional lifetimes of two actors with remits for these sectors. The study highlights the persistence of a “top-down/bottom-up” conceptual gap at the heart of EU language policymaking regarding English as a lingua franca in European higher education and research.