In March 2020, ICNIRP (the International Commission for Non-Ionizing Radiation Protection) published a set of guidelines for limiting exposure to electromagnetic fields (100 kHz to 300 GHz). ICNIRP claims this publication’s view on EMF and health, a view usually termed “the thermal-only paradigm”, is consistent with current scientific understanding. We investigated the literature referenced in ICNIRP 2020 to assess if the variation in authors and research groups behind it meets the fundamental requirement of constituting a broad scientific base and thus a view consistent with current scientific understanding, a requirement that such an important set of guidelines is expected to satisfy. To assess if this requirement has been met, we investigated the span of authors and research groups of the referenced literature of the ICNIRP 2020 Guidelines and annexes. Our analysis shows that ICNIRP 2020 itself, and in practice all its referenced supporting literature stem from a network of co-authors with just 17 researchers at its core, most of them affiliated with ICNIRP and/or the IEEE, and some of them being ICNIRP 2020 authors themselves. Moreover, literature reviews presented by ICNIRP 2020 as being from independent committees, are in fact products of this same informal network of collaborating authors, all committees having ICNIRP 2020 authors as members. This shows that the ICNIRP 2020 Guidelines fail to meet fundamental scientific quality requirements and are therefore not suited as the basis on which to set RF EMF exposure limits for the protection of human health. With its thermal-only view, ICNIRP contrasts with the majority of research findings, and would therefore need a particularly solid scientific foundation. Our analysis demonstrates the contrary to be the case. Hence, the ICNIRP 2020 Guidelines cannot offer a basis for good governance.