The issue of gaps between ICT policy design and their outcomes is the subject of debate in academic research on information systems in developing countries. This paper extends the design-actuality gaps (Heeks, 2002) framework to provide a theoretical foundation for the evaluation and analyses of the gaps between government policy design and actual outcomes of the implementation of these policies. The design-actuality framework has traditionally been used in understanding success, failure and local improvisations of information systems in developing countries (Pozzebon and Heck, 2006; Gerhan and Mutula, 2007, Best and Kumar, 2008). This framework has also been used to explain success and failure of specific government projects (Gichoya, Hepworth, and Dawson, 2006). This research extends the framework to develop a theoretical foundation for government ICT policies evaluation and analysis.