Countries are struggling to develop data exchange infrastructures needed to reap the benefits of e-government. Understanding the development of infrastructures can only be achieved by combining insights from institutional, technical and process perspectives. This paper contributes by analysing data exchange infrastructures in the Netherlands and Estonia from an integral perspective. The institutional design framework of Koppenjan and Groenewegen is used to analyse the developments in both countries. The analysis shows that the starting points, cultures, path dependencies and institutional structure result in different governance models for data exchange infrastructures. Estonia has a single – centrally governed – data-exchange infrastructure that is used by public and private parties for all kinds of data exchanges (including citizen-to-business and business-to-business). In contrast, the institutional structure in the Netherlands demands a strict demarcation between public and private infrastructures, resulting in several data exchange infrastructures. While there are examples of sharing infrastructure components across various levels of the Dutch government, public infrastructures cannot be used for business-to-business or citizen-to-business data exchange due to the potential for market distortion by government. Both the centrally governed Estonian model and the decentrally governed Dutch model have pros and cons on multiple levels.