Abstract Since Cassini arrived at Saturn in 2004, its moon Titan has been thoroughly mapped by the RADAR instrument at 2-cm wavelength, in both active and passive modes. Some regions on Titan, including Xanadu and various bright hummocky bright terrains, contain surfaces that are among the most radar-bright encountered in the Solar System. This high brightness has been generally attributed to volume scattering processes in the inhomogeneous, low-loss medium expected for a cold, icy satellite surface. We can test this assumption now that the emissivity has been obtained from the concurrent radiometric measurements for nearly all the surface, with unprecedented accuracy (Janssen et al., and the Cassini RADAR Team [2009]. Icarus 200, 222–239). Kirchhoff’s law of thermal radiation relates the radar and radiometric properties in a way that has never been fully exploited. In this paper we examine here how this law may be applied in this case to better understand the nature of Titan’s radar-bright regions. We develop a quantitative model that, when compared to the observational data, allows us to conclude that either the reflective characteristics of the putative volume scattering subsurface must be highly constrained, or, more likely, organized structure on or in the surface is present that enhances the backscatter.