To understand the development and implementation of adaptation policy, studies need to apply a multi-level framework that takes into account interaction between the different levels and how this is shaped by the political system. This study shows that focusing only on national adaptation policy development obscures the complexity of how adaptation policy may emergence as a result of interaction across multiple scales. Drawing upon upon a survey of policy literature and semi-structured interviews in case studies at national, regional and local levels in the UK and Sweden, the study shows that national policy development cannot be assumed to result in policy development and implementation at the local level. At the same time, national policies may also develop and be shaped by initiatives and political pressure from regional and lower levels. Policy development at sub-national levels may also take place with support from structures beyond the state, such as the European Union.