This paper examines the development of the EU's LEADER Initiative for integrated rural development. It is argued that the policy process, specific to the LEADER Initiative, has to be understood in terms of the development of a 'policy community' in Brussels and beyond, engaged in policy developments informed by a clear 'integrationist' philosophy. The paper goes on to examine the administrative arrangements created within Spain to implement the EU's LEADER Initiative for integrated rural development. The intention of the scheme's initiators in Brussels was that, in order to facilitate 'grass-roots', local development initiatives, the regional and provincial levels of administration would not be involved in the programme and that administration would take place through one national agency (IRYDA in the case of Spain). A questionnaire survey and a series of in-depth interviews with appropriate officials at the European, national, regional and local (CEDER) levels revealed that, in several of the Spanish regions (autonomous communities), there has been a considerable degree of involvement in the Initiative but that such intervention varies quite widely. It is argued that it was inevitable that some Spanish regions (e.g. the Basque Country) would seek 'hands on' involvement in the scheme because of their suspicion of any centralised, national level of administration. Other regions with little experience of rural development (e.g. Extremadura) have been very closely involved with IRYDA throughout, whereas in Andalusia, where rural development plans were already significantly advanced before the adoption of LEADER, the regional authority appears to have had a minimal involvement. It is clear that officials in IRYDA have not followed the intentions of Brussels and, in their relationship to the regional authorities, have been extremely flexible in their implementation of LEADER 1. However, at the European level, LEADER 2 is now under way and contains a requirement that regional levels of administration be involved in the programme. It is argued that these findings support the view that policy implementation may be seen as part of the policy process, whereby the realities of implementation force changes in the nature of policy itself in ways not originally envisaged by the instigators.