The European Commission’s social investment strategy, which holds that social policy expenditure should be at least partially channelled towards investment into people’s capacities, has been severely criticised. Some scholars have even categorised social investment as an outright neoliberal reform. However, the actual content of the reform imperative has been neglected in the discussion. Through qualitative content analyses divided into privatisation, marketisation and liberalisation, this article examines the (non)-neoliberal policy instruments embedded in the European Social Investment Package. For privatisation, the policy documents were found to propose universal benefits and services, but at the same time propounded benefits that targeted low-income groups and ‘make work pay’. Marketisation stressed competition and market-based financial tools as well as managerial instruments for public administration, but evaded any reference to non-competition-based means, such as social insurance. Liberalisation addressed existing barriers to labour mobility, reinforced individual rights to equal opportunity and responsibilities and restored the role of institutions to advance social investment. Consequently, we argue that inherent ambivalence hinders any assessment of these policies as neoliberal, but they cannot be categorised as in opposition to it either.