Does Accountability Require Agency? Comment on Responsibility and Accountability in the Algorithmic Society

In their intriguing paper Responsibility and Accountability in an Algorithmic Society (2025) the authors argue that the debate on how to deal with responsibility related issues with algorithmic agents requires a distinction between responsibility and accountability. In this comment to their paper, it is argued that while the notion of accountability as understood by the authors brings some significant benefits it also is ambiguous in an important way. Accountability could be understood as being purely instrumental with regard to general morally desirable consequences or it could be understood as necessarily containing an element of scaffolding for the agent who is held to account. The comment develops the options and discusses the consequences of choosing either of them.