The COVID-19 pandemic resulted in mitigation efforts that put women at increased risk of gender-based violence. Stay-at-home requirements increased abuse at home. Early in the pandemic Spain and Argentina issued policies to address such violence at home. This policy analysis uses the ‘What’s the problem represented to be’ approach to shed light on the different assumptions, intentions and problem framings in both governments’ policy responses. Drawing on published policy documents we found both disparities and similarities in the way that gender-based violence is represented as a problem. Four key findings emerged; (1) gender-based violence is not clearly defined in the policies and the terminology has a partially (de)gendered discourse while focusing on female ‘victims’ of violence; (2) the role of men as perpetrators is ‘silenced’; (3) the problem construction weighs exclusively on the aftermath of the violence, and; (4) both countries address violence against LGBTI+ in different ways. Our recommendations are for policymakers to reconsider the focus of their policies in these respects to reduce the harm that naming and framing of gender-based violence can inflict. We recommend attention to the root causes of gender-based violence to result in a more holistic and sustainable approach in policy development.