EU administrative law as a disciplinary field emerged and developed very much anchored in comparative administrative law. In this respect, legal scholarship has both mirrored and further enhanced the work of Court of Justice. The normative project to establish administrative law beyond the state was grounded on a state-matrix of general principles developed on the basis of functional comparison. While this approach led the first academic constructions of EU administrative law to ignore the specificities of the EU administrative institutions, those initial efforts have shaped the foundations of EU administrative law. They fed the scholarly efforts to give effect to an “utopia” (Chiti, 2007) of an integrated administration constitutionally framed by general principles and fundamental rights. The paper is essentially a diagnosis, examining the functions that comparative administrative law performed in different stages of EU administrative law and its current limits as a legal discipline.