Since the Adaptation Fund (AF) became operational in 2007, there has been a vivid discussion about equity and efficiency in how resources (predicted to be scarce) are governed and allocated. One complicating factor is that allocation is often discussed between countries rather than between sub-national causes and groups, and while this approach follows from the UNFCCC context, it is problematic because it ignores the fact that vulnerability is a locally contextualized phenomenon. This paper empirically analyses the portrayal of vulnerability and adaptation benefits in project proposals approved by the AF, and thereby comments on the normative principles of equity and efficiency when allocating funds to developing countries and their vulnerable communities. It does this by evaluating actual decisions made by the AF, which has been operating for some time. We qualitatively analyse all proposals approved as of December 2012 by the Fund's Board. First, we compare the ways that ‘particular vulnerability’ is justified or not, especially in light of the minimal guidance available. Second, we compare project proponent's statements (or lack thereof) on economic, social, and environmental benefits arising from the suggested projects, and who they would accrue to. Lessons learned with regard to allocation will also be important for the development of the Green Climate Fund, considering that resources are likely to be scarce for some time in comparison with predicted funding needs.