REPUBLISHED

10 unanswered points about the “Blue Borgo” project

Erblin Vukaj · Originally published: 4 March 2026

On Tuesday, Gener 2 published a text entitled “10 facts about the legal and administrative status of the project in Velipojë”, claiming that the Blue Borgo project complies with the law and that debate over the property claims is based on “misinformation”.

But official documents obtained by Citizens.al from institutions, along with reporting on the ground, show that many issues around the project remain unanswered. Here are ten of them.

We should note that our newsroom approached the company for comment on at least two occasions, but had received no response by the time this article was published.

1. Were the works carried out a year ago lawful?

In March 2025, residents of Rrjoll clashed with the group of workers who had begun developing the Blue Borgo project. The situation escalated after police intervened, while residents publicly alleged that Gener 2 was trying to take their land.

The company responded with a six-line statement. It confirmed that development of the project had begun, but rejected the allegations, insisting that everything complied with the law.

Records show that Gener 2 obtained an execution licence for the project (NZ.4586/34) on 16 September 2025. The building-permit decision, meanwhile, was signed on 8 August 2025, and the permit was formally issued by the Territorial Development Agency (AZHT) only on 15 January 2026 (Building Permit No. 360/1).

This means that the preliminary works in 2025 preceded full completion of the legal procedures.

2. Has ownership status been fully verified?

Gener 2 says it entered into contractual relations with “the party recorded as holding the ownership rights” and that it has infringed no one’s rights.

“[…] the project has relied solely on final decisions, certified at every level of the judiciary,” one of its responses stated.

Gener 2 has not, however, provided a summary of these decisions, the underlying ownership title, the chain of property transfers or the documents demonstrating the legal certainty of the transactions.

In the building permit’s site plan, Gener 2 appears as a designer alongside Stefano Boeri’s architectural firm, while another company owned by the Ulaj family, ABA Blue Borgo, appears as the developer. This suggests that the third party is itself an Ulaj enterprise.

In a project of this scale, transparency over ownership is essential to the investment’s credibility.

3. What is the Shkodër Prosecutor’s Office investigating?

According to Gener 2, there is not a single suspension order preventing the project from continuing.

“The property and the relevant process have undergone the necessary stages of review under the applicable framework, and on this basis no legal obstacle to the normal continuation of works has been identified,” the company states.

But the Shkodër Prosecutor’s Office confirmed to Citizens.al that criminal proceedings have been opened in the matter, based on material referred by the Special Prosecution Office (SPAK). Proceeding No. 390/2025 was referred by SPAK on 21 March 2025 following a complaint by residents alleging that property titles had been forged.

Although the investigation is still ongoing, the existence of criminal proceedings shows that some aspects of the project remain under examination by the judicial authorities.

4. Why is the issued permit not displayed at the construction site?

After the clashes and residents’ reports, a sign was placed beside the Shëngjin–Velipojë road. Although it described the project, it was not accompanied by the issued, signed permit from the National Council of Territory and Water (KKTU).

The sign states that the investment is estimated at around 26.8 billion lek (€280 million), that the works are expected to last five years, or 60 months, and when Gener 2 obtained its execution licence.

The sign provides no information on cadastral locations, 3D views of the project, the layout of the structures to be built, the topographic map, technical indicators for adjoining property plots, property setbacks, building density, the site-coverage ratio or other details.

5. How well informed was the local community?

The company says the project was presented at public consultations and that there were no objections.

According to the National Environment Agency (AKM), a consultation on the project was held in September 2024 as part of the Environmental Impact Assessment (EIA) procedures.

The consultation is recorded in the non-technical summary of the environmental report, which presents the project as a tourist development “with a manageable environmental impact”.

But local residents have publicly stated that they learned about the project only when work began on the ground.

This creates a contradiction between the official narrative and the local community’s understanding, while public institutions have offered no further clarification.

6. How was the project exempted from the infrastructure impact tax?

Shkodër Municipality confirmed to Citizens.al that the project is recorded as exempt from payment of the infrastructure impact tax.

Yet neither the specific administrative act granting this exemption to Blue Borgo nor the detailed legal basis justifying it has been made public so far.

Under the local tax schedule, the infrastructure impact tax for a tourist investment of this scale in Velipojë is around 3% of the investment’s value.

Using the publicly cited project value of around €280 million as a reference, the potential infrastructure impact tax would therefore amount to around €8.4 million.

Until the document justifying the exemption is published, it remains unclear how, and on what basis, a tax liability of this size was waived.

7. Does the project meet the “brand name” criterion for tax exemption?

The law on local taxes provides a specific infrastructure-tax exemption for five-star accommodation facilities with special status, but only if they are operated by an international hotel “brand name”.

So far, neither Gener 2’s public communications nor the documents released by institutions have named an international hotel brand that will operate the Blue Borgo resort.

In the absence of this element, the question remains whether the project actually met the legal conditions for exemption from the infrastructure tax.

8. Why is the project not listed as a strategic investment?

The Albanian Investment Development Agency (AIDA) twice confirmed to Citizens.al that no Strategic Investment Committee decision appears on record for the Blue Borgo project.

This means the project does not hold formal strategic-investor status, a status often used to justify tax incentives or expedited procedures.

In this context, it remains unclear what other legal mechanism underpins the infrastructure-tax exemption.

9. Does the project affect a protected area?

The area where Blue Borgo is being built was part of the Buna River–Velipojë Protected Landscape, specifically sub-zone 1b, which was subject to the second level of environmental protection. This category was intended to preserve biodiversity and the natural landscape, allowing only economic and tourism activities that did not undermine the conservation objectives.

However, amendments to the Law on Protected Areas adopted in 2024, when the project was also conceived, introduced the concept of “tourism of excellence”, allowing high-standard tourist accommodation facilities to be built even within protected areas.

Organizations such as the Centre for the Conservation and Protection of the Natural Environment in Albania (PPNEA) have warned that this approach could open the way to intensive tourism development in areas previously intended mainly for conservation.

Gener 2 itself has not addressed this aspect and has not clearly specified what measures it has planned to reduce the impact on the area’s environment.

In this sense, the conflict in Rrjoll concerns more than a single resort. It is also part of a broader debate: whether protected areas should remain spaces where nature conservation takes priority or become tourism-development zones.

10. If the documents are so clear, why not publish them all?

In its public response, Gener 2 says it is ready to make the relevant documentation available.

Yet despite Citizens.al’s emailed requests, the investor has so far held no press conference and published no complete file containing the infrastructure-tax exemption act, proof of a partnership with an international hotel “brand name”, the list of conditions imposed by the National Territorial Council (KKT), and documents proving that those conditions have been met.

Until these documents are made public, Blue Borgo will remain not only a major tourism investment, but also a story with many open questions.