In order to encourage investment in telecommunication networks, governments have been encouraged to adopt a regulatory state model, with an independent regulatory authority that is subject to a system of appeals and to parliamentary oversight, providing different forms of accountability. The European Commission has pursued this through a sequence of reforms, with governments of member states delegating powers to regulatory authorities, whose independence has been reinforced by directives and network governance. The model has originally been developed in the USA, where there are complex checks and balances, with procedures laid down in the Administrative Procedures Act, with rigorous lobbying before decisions, later subject to litigation. In Africa, the absence of institutional endowments has led to heads of state retaining much more power, delegating only limited functions to regulatory authority that is very rarely believed to be independent. Consequently, operators have lobbied and done deals with the head of state, leaving the regulatory authority for show.