The concept of Theory of Change (ToC) is well established in the evaluation literature, underpinning substantial research and practice eff orts. However, its ability to facilitate learning has been increasingly debated. The objective of this paper is to identify, characterize, and evaluate concerns over the use of ToCs based on a review of relevant studies. Seven concerns are found: distinguishing ToCs from other evaluation approaches, conceptual vagueness, under-developed ToCs, undercontribution to theoretical knowledge, uncertainty in stakeholder engagement, neglecting context, and overlooking complexity. Priority areas for improvement include integrating context and complexity throughout the ToC process, contributing theoretical knowledge, and engaging stakeholders as appropriate.