The article uses the First Learning Wave (FLW) of the Global Fund’s National Strategy Application (NSA) to examine how ‘accountability’ is described both in the strategic priorities set, and in the mechanisms for assessing achievement against them, in the three National Strategic Plans that were developed for the FLW/NSA (Kenya, Malawi and Rwanda). A three-level framework for accountability is described and used to analyze the experience of the countries in the First Learning Wave of the Global Fund. It addresses two questions: how responsive were the National Strategic Plans (NSP) for AIDS to the notion of accountability, and how did the NSA modality assess accountability. We find that while relatively strong institutional and coordination frameworks are described in these new NSPs, and assessed by the Global Fund, accountability per se is not recognized as an explicit element in strategic planning; rather, it seems to be considered an implicit aspect of ‘coordination,’ ‘financial management,’ monitoring and evaluation, and ‘participation.’ We suggest that accountability frameworks need to be made explicit in NSPs as do processes for managing them. Moreover, assessment frameworks need to make explicit assessments of these provisions.