Comparative research on climate change adaptation policy struggles with robust conceptualization and measurement of adaptation policy. Using a policy mixes approach to address this challenge, we characterize adaptation policy based on a general model of how governments govern issues of societal interest. We argue that this approach allows for context-sensitive measurement of adaptation policy, while being both comparable and parsimonious. This approach is tested in a study of adaptation policies adopted by 125 local governments located in Canada, France, Germany, the Netherlands, and the UK. Using a systematic data collection protocol, a total of 3328 adaptation policies were identified from local council archives between the periods of January 2010 and May 2017. Results of this analysis suggest that there is structured variation emerging in how local governments govern climate change adaptation, which justifies calls for comparative adaptation research to use measurements that capture the totality of adaptation policies being adopted by governments rather than focusing on specific types of adaptation policy. We conclude with a discussion of key issues for further developing of this approach.