Comparative education research is complicated by the difficulty of identifying comparable units across contexts. This paper considers the advantages and limitations of a functional equivalence approach to comparative education. The functional equivalence approach allows us to meaningfully compare the operations that serve each function in the full curriculum value chain of design, application, and updating. We use a theory-based list of common processes in each phase to develop a survey for experts from nine countries, then code their responses to derive ten key common functions. The functional equivalence approach allows us to aggregate some operations that serve the same functions, so our set of functional equivalents is slightly shorter than the theory-based list of processes. In comparing across contexts, we find easily identifiable functional equivalents, functional equivalents that manifest through very different operations, functional equivalents carried out by a wide variety of actors and institutions, similar operations that are not functionally equivalent, and functional equivalents that are not consistently present in all contexts. The functional equivalence approach helps identify comparable operations despite contextual diversity.