The present paper aims at an analysis of the coherence of the European Union’s policy output in the field of Access and Benefit-Sharing, in the nexus between the Convention on Biological Diversity, the World Intellectual Property Organization and the Agreement on Trade-related Aspects of Intellectual Property Rights. As some preliminary data suggests, during 2006, the EU approach to ABS was fundamentally reorganized. The paper sets out to test whether such a reorganization can be found at the level of policy coherence. Statistical analysis suggests, that with one of two measures for policy coherence, a rupture around 2006 can be observed.