In the classic understanding of human rights obligations, the state is considered the primary duty-bearer. Governments, however, are increasingly handing over their function of delivering health services to NGOs. This article argues that because of these new and increasing responsibilities, NGOs should also be seen as duty-bearers required to uphold rights through their services, activities, and principles of operation. Translating human rights norms into practical, measurable activities remains a challenge. We worked with organizations delivering HIV-related services to prisoners and injecting drug users in Malawi and Pakistan. The aim was to develop a simple, practical framework of activities and indicators to provide accountability standards against which NGOs could be held accountable for progressively realizing the rights of their clients.