Since its inception, GLOBALGAP has transformed from an informal grouping of retailers into a highly elaborate regulatory organization. This chapter critically examines GLOBALGAP’s development. It argues that, through an iterative process of legitimation, actual and anticipated interactions with state, market and civil society actors led GLOBALGAP to develop structures, practices and processes that sought to enhance representation and participation of structurally weaker parties such as smallholders, whilst also addressing concerns relating to the exclusionary effect of its standards. It traces how, as non-state regulatory organizations emerge and develop, they respond to actual and anticipated governance interactions to build, maintain and repair their legitimacy. Crucially, early institutionalization confers power upon particular actors, crystallizes an organization’s identity and lays foundations for the achievement of its goals. Consequently, the enduring nature of early institutionalization can temper the potential for governance interactions to advance democracy, justice and fairness within non-state regulatory organizations.