Drawing on the cost of living surveys conducted by the Jesuit Centre for Theological Reflection (JCTR), a prominent local non-state actor, this paper suggests that the scale and depth of urban poverty in Zambia is under-estimated by official poverty lines. The paper argues that basing the food poverty line on a national average cost for food underestimates urban poverty and is likely to overestimate rural poverty. This is because of the significant disparity between cost of food in rural and urban areas, which is largely driven by the methods of accessing food items. The paper also argues that the threshold for the upper poverty line is too meagre for any urban area in Zambia, especially when taking the cost of housing into consideration. ~~Since policy choices are largely influenced by the definition of a problem, accurate definition and measurement of poverty is critical for the design and implementation of specific poverty reducing actions.