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I'd argue that flat structures don't exist outside of tiny companies, only clearly delineated and obfuscated structures, none of which are flat after 20 people or so. So when a medium-sized or larger company says they are "flat", it means they are struggling to understand their own organization.

Of course, differing degrees of stratification are still possible. The "Spotify model" decouples team leadership and cuts down a bit on stratification by distributing authority. But even then the model is not at all flat when you zoom out. And the smaller degree of stratification comes at the cost of incurring extra overhead resolving decisions amongst multiple stakeholders who have all been empowered over certain limited aspects of different teams/projects/services.

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