Tallinn Prepares Independent Financial Analysis of Lasnamäe Pool Project
Tallinn has not yet conducted a legal analysis on whether its planned payment of up to €20 million for a swimming pool concession in Lasnamäe complies with EU state aid rules, and is now preparing a tender for an independent financial review.
Tiit Terik, head of Tallinn's city administration, confirmed that the city has not carried out a separate legal analysis of whether the planned payment of up to €20 million to the concessionaire building a swimming pool in Lasnamäe complies with Article 55 of the EU's General Block Exemption Regulation (GBER) on state aid. The city's Property Department, together with its financial service, is now drafting terms of reference to commission an independent financial analysis of the project.
Before any aid is paid out, the analysis will verify its amount, eligible costs, the project's operating profit, and other conditions for granting state aid. A final calculation of operating profit and the funding gap has not yet been made, since actual construction costs and the concessionaire's economic model are not yet available.
Terik explained that the estimated concession value of €111.248 million and the GBER threshold of €110 million for sports infrastructure are not directly comparable figures. The concession value includes the concessionaire's possible revenue over 50 years plus the city's payment of up to €20 million, while the GBER threshold applies to actual investment costs, which will become known once a bidder's proposal is submitted.
Pool, not hotel
The city stressed that its aid is intended solely for building the pool and its supporting infrastructure, not the hotel or spa also included in the project. The cost calculation separates expenses for the pool, the sports building, and shared building areas, with payments made in construction stages based on invoices and acceptance reports. If necessary, separate accounting will be required for subsidized and non-subsidized activities.
A clause added to the draft contract on September 15 states that the concessionaire must comply with state aid rules and return any excessive or unlawfully granted aid — an obligation that already exists under law but was added to the contract for clarity.
The contract sets a priority order for pool access: municipal schools for swimming lessons come first, followed by children's and youth training groups and city-supported sports clubs, then other users. The city emphasized that its financial obligation is limited to the €20 million construction aid, and it is not taking on additional commitments for daily pool use or funding swimming training.
The deadline for bids in the international public tender expires in October, with the city planning to sign the concession agreement by January 1, 2027. The winning bidder must complete construction and obtain an operating permit within 34 months, with the new pool expected to open to residents by the end of 2029. This marks the city's third attempt to find an investor for the project, which was first proposed back in 2017.
