When the mandate is missing, the state becomes the delivery guy
- Ott Sarv
- 4 hours ago
- 4 min read
In many countries, the hardest part of building national digital rails is not technology. It is the business model. When ministries disagree over who is allowed to deliver a capability that everyone will depend on, the only thing that still moves is procurement. A platform ships, adoption begins, and only later does everyone notice that the platform has quietly become the procedure.
That is how governments end up operating wallets and national data exchange platforms, even when the policy instinct is that the state should define rules, supervise, and avoid being the delivery actor. The state is not choosing to be the delivery guy. It is being pushed into delivery because nobody else is legally enabled to be compellable, especially under incident pressure and public scrutiny.
The postal lesson: designation beats ownership
The postal world solved a similar coordination problem through the Universal Postal Union (UPU). The important design is not ownership. It is designation. Governments set the obligations and a delivery institution is designated to meet them, under shared rules and operational discipline.
The UPU defines designated operators as national postal operators tasked by their government to fulfil treaty obligations. The UPU states it has 192 member countries, which is why this model looks close to universal in practice.
Modern postal delivery also shows something digital programmes often underestimate: even where the outcome is physical delivery, the system increasingly relies on structured electronic data exchange governed inside the service regime. You can see that direction in the Universal Postal Convention. The lesson for digital is straightforward: neutrality and interoperability do not appear because an operator is state-owned or because a vendor is competent. They appear because a mandate makes the operator compellable and supervision is able to enforce it.
The category mistake that turns delivery into a turf war
Operator fights become unwinnable when basic categories collapse. Infrastructure, services, and legally bounded functions are not procurement labels. They decide where decision rights sit, what can be delegated, and where remedy must reach.
Term, linked once | What it is in practice | Why it changes the operator choice |
Shared cross-domain foundations reused across many services | DPI can be operator-neutral, but governance must be compellable or the operator becomes the rulemaker by default | |
A public-facing outcome in a specific domain | DPS is where political accountability concentrates, so governments centralise delivery when mandates are unclear | |
A legally bounded act inside an authorised procedure that can produce legal effect | If DPF decision rights are not allocated, any operator model becomes unsafe because nobody can compel correction, suspension, or evidence production | |
Reusable artefacts such as software and specifications | DPG can accelerate build, but it cannot substitute for authority, mandate, or remedy, and treating it as governance creates drift |
Once you see this split, the wallet and data exchange debate becomes less emotional. A wallet may be user-controlled exchange at the edge, but the system around it still has national reliance consequences: onboarding, relying party eligibility, incident response, suspension, evidence, and dispute handling. Those are mandate questions before they are software questions.
This is why the Seven Layer Model for Digital Public Infrastructure matters. The model is a discipline that prevents downstream delivery artefacts from substituting for upstream authority, institutional mandate, and oversight and remedy.
The EU example, read as a business model
The EU framework is useful here because it normalises operator-neutrality while still placing a public obligation on states to ensure availability. Regulation (EU) 2024/1183 on EUR-Lex establishes the European digital identity framework and anchors the EU Digital Identity Wallet obligation in law. The same framework sits on top of the amended Regulation (EU) No 910/2014.
The practical takeaway is not that governments must run everything. The takeaway is that an open market only works when supervision can actually compel evidence, corrective action, and continuity under stress. Where that compellability is missing, governments drift into operating because they cannot outsource accountability for failure.
The real reason governments end up operating
When mandates are unclear, contracts become the substitute governance instrument. That tends to fail in exactly the moments that define trust.
Neutrality fails when the operator has incentives to gatekeep or bundle. Crisis compellability fails when suspension and recovery depend on escalation goodwill rather than enforceable duty. Remedy fails when evidence is proprietary, fragmented, or inaccessible to independent oversight.
In that environment, the state becomes the delivery actor not because it should be, but because it is the only actor the political system believes it can compel.
A way out when ministries are fighting and nobody owns mandate
When ministries contest ownership and internal capability is thin, two common choices both fail predictably. A single ministry-run platform invites bypass and duplication. An open market without enforceable supervision invites self-asserted compliance and platform capture.
The highest-probability path is staged: establish compellability first, then open the market.
Phase | What happens | Who delivers | What changes politically |
Stabilise compellability | Centre of government allocates decision rights once, defines enforceable obligations, and creates supervisory powers that can compel evidence and corrective action | One baseline operator is designated under a mandate instrument, often a postal operator or another utility | The ministry fight loses oxygen because delivery is no longer a prize; compliance with obligations becomes the focal point, aligned with the designated operator logic |
Open the market safely | Licensing or recognition rules admit additional providers, with portability and interoperability as entry conditions | Multiple providers compete, including the baseline operator as one provider among others | Competition becomes possible without creating an unavoidable gatekeeper, because exit and continuity are engineered from the start |
This is the digital equivalent of what the UPU achieved in post: mandate first, interoperable delivery under supervision next. A modern digital mandate must also cover evidence, incident response, portability, and non-discrimination, because those are the control points where platforms become sovereign by default.
The moment the mandate is clear, the operator choice becomes less ideological. A postal operator can be a strong baseline utility when designated properly. Market vendors can compete when supervision is real. Ministries can stop fighting over delivery when decision rights are allocated and enforced upstream. That is the same structural logic the Seven Layer Model is trying to protect.
