Key debates in administrative law often play out within the contours of “accountability” to such an extent that accountability has been described as administrative law's “central obsession” (Metzger 2015, 130). The salience of accountability is particularly high in comparative administrative law since accountability can serve as one of the transcendent principles underpinning “universalist” approaches to comparative study (Jackson 2012; Choudry 1999). However, as with many central concepts in comparative law, the overuse of the term may risk diluting its analytical utility and thus obscure more than elucidate. This danger has prompted pleas to “save” the concept “from friends and advocates” (Dubnick 2002, 1).This chapter suggests that the concept of accountability is normatively and analytically useful in comparative administrative law, provided that there is clarity as to the level of abstraction at which the term is used. The essay proposes a three-tier approach to the concept of accountability - accountability as a political ideal (“level 1 accountability”), as a specific set of normative commitments (“level 2 accountability”), and as an empirical phenomenon (“level 3 accountability”). It argues that the usefulness (and contestability) of comparative approaches will vary as one moves from one tier to the next. The essay further discusses case studies from the United States, the United Kingdom, and France that illustrate specific institutional manifestations of accountability. The chapter concludes by presenting certain key challenges to accountability that implicate different tiers of accountability
