Among the few things scholars can agree about Thomas Bilney (1495–1531), the enigmatic figure at the heart of early English evangelicalism, is that he embraced Luther’s teaching of justification by faith. This consensus is based chiefly on two of Bilney’s statements on justification in a 1527 letter to Cuthbert Tunstall, then Bishop of London. By putting these statements in the broader context of Bilney’s extant writings, this essay aims to show that while Bilney used some of the same language and concepts as Luther, the way he developed and understood those concepts was fundamentally distinct. In his views of the law, the reception of grace, and of the nature of justification, Bilney’s soteriology differed markedly from that of the German reformer. In his distinctive development of evangelical soteriology, Bilney illustrates the experimental nature of early evangelicalism and the dangers of seeking prematurely to pigeonhole its proponents with anachronistic confessional labels.