There is currently a variety of models of prison health accountability across the WHO European Region. The WHO Regional Office for Europe recommends that leadership should come from health ministries if health equity between prisons and the outside community is to be achieved. Most importantly, a whole-of-government approach is required to improve the quality of health services in prisons. This policy brief describes the governance and organizational models for prison health adopted by three European countries – Finland, Portugal and England. Each of these has a different arrangement in place, either under the Ministry of Health or under the Ministry of Justice working in partnership with the Ministry of Health. Those that have undergone a change in governance model have done so at different moments and adopted a different approach to implementing the change. Each of the three countries is considered separately, then similarities and differences between them are highlighted. Finally, recommendations are given for countries considering making a transition in the governance model that will improve the health services provided and the health status of people in prison.