This report offers a comparative perspective on the right to housing through the legal systems of Finland, Scotland, France, and South Africa. The report engages with arguments in Irish political discourse over legal protection of the right to housing and offers a comparative perspective on the principled and practical concerns raised by proponents and opponents of a right to housing. The comparative analysis highlights a wide variety of structural and institutional means by which the right can be guaranteed; there is no ‘one size fits all’ model.