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A rights-based approach (RBA) emerged in the arena of international development in the middle of the 1990s and is still one of the latest development discourses. Although a critical part of the RBA is to increase people's agency in fulfilling their rights, the RBA of development NGOs has not been comprehensively reviewed from the viewpoint of agency. Hence, by primarily reviewing existing empirical research, this article inquires what sociological notions of agency can be drawn from such empirical evidence and how those notions inform NGO practice. Given the likely implementation difficulties entailed by the western-conceptualized RBA, local expressions of rights need to be adopted as or adapted to the RBA. However, such expressions also need to be elevated, and people's agency needs to be heightened to the extent that they can purposefully employ such improved expressions as workable negotiation strategies with duty-bearers. Finally, the heterogeneity in people's exercise of agency should be given due attention.