2004

In February 2004, two months prior to The Punisher's theatrical debut, Lions Gate Entertainment announced the studio's intent to follow the anti-hero film with a sequel. Avi Arad, chairman and CEO of Marvel Studios, expressed his interest in developing the franchise, saying that the second film would "become the fifth Marvel property to become a sequel." In March 2004, the director of the first film, Jonathan Hensleigh, said that he was interested in working with Thomas Jane again for The Punisher 2. In April 2004, Thomas Jane said that the villain for The Punisher 2 would be Jigsaw. In October 2004, Thomas Jane confirmed that the sequel was still in development. In November 2004, Jane said that the studio was interested in making a sequel based on successful DVD sales of The Punisher and was developing the preliminary budget for the follow-up.

2005

In March 2005, Marvel Entertainment announced its film slate for the future and included Lions Gate Entertainment's The Punisher 2 for a 2006 release. In April 2005, Lions Gate Entertainment's CEO Jon Feltheimer confirmed at LGF's 2005 fiscal 3Q analyst call that the studio had completed its deal to develop Punisher 2. In June 2005, Avi Arad indicated the sequel would be among the "handful of Marvel films" to carry the R rating. Prior to July 2005, Avi Arad revealed that the script was being rewritten and that the sequel would start filming within the year. In July 2005, Thomas Jane said that he had put on 12 pounds of muscle in preparation for the sequel and was hoping to make the film in time of fall 2006.

2006

In March 2006, Punisher 2 was announced to be produced in Louisiana. The film was listed in the domestic charter under Louisiana's Secretary of State. In August 2006, Marvel Entertainment revealed a new film slate that included The Punisher 2 on its partial list with production still to be determined. Thomas Jane said that the writer was halfway through a draft and that he believed filming would begin by February 2007. Jane confirmed that the villain Jigsaw, first announced in April 2004, would be in the film. Jane also said that director Jonathan Hensleigh would not be returning to direct the sequel. In addition, Lions Gate Entertainment, amidst the studios returning to New Orleans following Hurricane Katrina, announced that the Punisher 2 would begin filming within the year. In October 2006, Thomas Jane said the script was due in a couple of weeks, and that it would be "darker, bloodier and more unfriendly than the first one". In December 2006, the screenplay was being rewritten by screenwriter Stuart Beattie.

2007

It was announced that Kurt Sutter, a writer for The Shield, was involved with the script for Punisher 2. In an interview with Kurt Sutter he said that he had an enjoyable time writing the script for the sequel and that it was going to be very true to the character. In a separate interview Thomas Jane revealed that a new script had been turned in and everyone was hoping it would work out, as the lack of a good script had been holding up production. He further stated that if everything goes as planned then filming should begin in June or July. In a letter to Ain't it Cool News Jane stated that he has pulled out of the movie saying "What I won't do is spend months of my life sweating over a movie that I just don't believe in. I've always loved the Marvel guys, and wish them well. Meanwhile, I'll continue to search for a film that one day might stand with all those films that the fans have asked me to watch."

In May 2007, director John Dahl was in talks to direct the movie, but decided to not helm the film. In June it was announced that Lexi Alexander would then take over the role as director as a result. On July 21st it was announced that Northern Irish born actor Ray Stevenson would play the Punisher in the sequel to the 2004 film. Filming is slated to begin in October of 2007 in Montreal. In August, a working title for the film, Punisher: Welcome Back Frank was announced. On August 28th, Lionsgate announced that the new working name for Punisher 2 would be Punisher: War Zone. Paddy Considine was considered for the role of Jigsaw in the film but the offer was retracted. In mid-September, director Lexi Alexander announced cast members joining Ray Stevenson with Dash Mihok as Detective Martin Soap, Colin Salmon as Agent Paul Budiansky and Doug Hutchison as Loony Bin Jim. It was announced on September 25th via The Hollywood Reporter, that Dominic West will star as the main antagonist Jigsaw and Wayne Knight will play The Punisher's armorer Microchip. Filming occurred from October 22 until December 14 in Montreal. Principal photography for Punisher: War Zone was completed on December 27.

The film was set for September 11, 2008 release, but was pushed back 3 months to December 5, 2008.