If the transnational counter-terrorism order is to have any claim to legitimacy, it must enact a meaningful commitment to accountability. This chapter illustrates how such a commitment is largely absent from transnational counter-terrorism, showing that the accountability is frustrated by the institutional dominance of the Security Council and the informality of the institutional infrastructure. While the Office of the Ombudsperson and the UN Special Rapporteur on the promotion and protection of human rights and fundamental freedoms while countering terrorism undertake important accountability work, they are structurally and materially limited in their ability to hold the order to account. The chapter argues that meaningful accountability may not be possible in transnational counter-terrorism, because the order operates precisely in the way its promoters, hegemons, and institutions want it to.