Abstract This essay considers two problems in the justification of cost‐benefit analysis. First, it argues that because cost‐benefit analysis values policies, variation in imputed “values of life” are not, in theory, cause for concern. Second, it argues that the current framework of justification, which focuses on the moral justification of the formal theory of cost‐benefit analysis, is inadequate because it ignores (1) the institutional context in which cost‐benefit analyses occur, (2) the comparative nature of the justification, and (3) the fact that justification might be indirect rather than direct.