To what extent is accountability key to realising rights? In struggles over access to water, conflicts between market- and rights-based frameworks imply distinct strategies of accountability. The former implies consumers holding service providers to account. In this understanding, citizens are consumers and accountability is exercised through the implied contract, mediated by the market, between customer and water utility, even if the state remains responsible for regulating private service providers to ensure they meet the needs of the poor. Rights-based frameworks assume that accountability claims will be pursued through and mediated by the state. This confers upon the state the power to both respect and deny rights, the consequences of which are explored below.