Digital Transformation Policies for Sustainable Tourism: A Comparative Policy Analysis of the European Union and Albania

This study analyzes how digital transformation and environmental sustainability are articulated as a common policy agenda known as the “twin transition” in the tourism sector, comparing the European Union (EU) as a mature regulatory and financing framework with Albania as an EU candidate country undergoing rapid but uneven digitalization. Adopting a qualitative comparative policy analysis, the study applies qualitative document analysis to a purposively selected core corpus of official EU strategic and legislative documents, EU-Albania accession negotiation documents, and Albanian national strategies. Documents were selected on the basis of official status, thematic relevance, and recency, and were compared within a structured comparative framework of seven policy dimensions, using the EU’s own accession requirements as the benchmark for comparability. Particular attention is paid to the positioning of artificial intelligence within each framework: while EU policy discourse treats AI as embodied within a green digital agenda, despite the lack of a clearly specified mechanism, the most visible AI initiatives in Albania have focused on general public administration, not on specific sustainability applications for tourism. The analysis identifies a gap highlighted in official documents in the accession negotiation process: the lack of tourism data infrastructure in Albania. The study argues that AI should be conceptualized not as an automatic result of digitalization, but as a potential mediating mechanism, conditioned by the existence of this data infrastructure, a condition that remains empirically untested. The paper concludes with concrete policy implications for the current phase of accession negotiations and identifies empirical testing of this mediating mechanism as a priority for future research.