The involvement of civil society has been identified as key in ensuring ethical and equitable approaches towards the governance of AI by a variety of state and non-state actors. Civil society carries the potential to hold organisations and institutions accountable, to advocate for marginalised voices to be heard, to spearhead ethically sound applications of AI, and to mediate between a variety of different perspectives. Despite proclaimed ambitions and visible potentials, civil society actors face great challenges in actively engaging in the governance of AI. Based upon a survey of the involvement of civil society actors in the making of the German National Artificial Intelligence Strategy this discussion paper identifies and contextualises key challenges that hinder civil society’s fruitful participation in the governance of AI in Germany. These hurdles include existing structural challenges commonly faced by civil society actors, such as a notorious lack of financial and human resources, as well as broader questions of governance, such as interministerial competition, and a lack foresight in the design of participatory processes. Additional challenges related to technology governance, such as a lack of expertise not only in civil society but also among ministries and industry, are amplified within the rapidly evolving field of AI. Leveraging the potential of civil society’s involvement requires reevaluation of the relationship between civil society, state, and economic actors.