The underpotential deposition (upd) of a Cu shell on a non-Pt nanoparticle core followed by galvanic displacement of the Cu template shell to form core–shell electrocatalyst materials is one means by which the Pt-based mass activity targets required for commercialization of PEM fuel cells may be reached. In situ EXAFS measurements were conducted at both the Au L3 and the Cu K absorption edges during deposition of Cu onto a carbon-supported Au electrocatalyst to study the initial stages of formation of such a core–shell electrocatalyst. The Au L3 EXAFS data obtained in 0.5 mol dm–3 H2SO4 show that the shape of the Au core is potential dependent, from a flattened to a round spherical shape as the Cu upd potential is approached. Following the addition of 2 mmol dm–3 Cu, the structure was also measured as a function of the applied potential. At +0.2 V vs Hg/Hg2SO4, the Cu2+ species was found to be a hydrated octahedron. As the potential was made more negative, single-crystal studies predict an ordered bilayer of sulfate anions and partially discharged Cu ions, followed by a complete/uniform layer of Cu atoms. In contrast, the model obtained by fitting the Au L3 and Cu K EXAFS data corresponds first to partially discharged Cu ions deposited at the defect sites in the outer shell of the Au nanoparticles at −0.42 V, followed by the growth of clusters of Cu atoms at −0.51 V. The absence of a uniform/complete Cu shell, even at the most negative potentials investigated, has implications for the structure, and the activity and/or stability, of the core–shell catalyst that would be subsequently formed following galvanic displacement of the Cu shell.