On November 26, a new state requirement for low-emission zones (LEZ) will come into force: city councils must prove that they actually function and that the restrictions provided for in their ordinances have effective consequences. The Government wants to close the door to models that are limited to defining an urban perimeter, installing signage, or sending notices to drivers without applying the corresponding penalty regime.
The obligation is set out in the Royal Decree 953/2026, of 4 November, published in the Official State Gazette (BOE) on the past 6 November. The regulation amends Article 10.3 of Royal Decree 1052/2022, which governs low-emission zones, and incorporates new conditions to demonstrate their correct implementation. Municipalities will have to send the supporting documentation both to the competent body on air quality of the Ministry for Ecological Transition and to the regional environmental authority.
The consequence of not doing so is clear: while the competent administrations do not receive that documentation, the LEZ will not be considered correctly implemented, as expressly stated in the new wording.
The reform thus introduces a difference between having a zone approved on paper and demonstrating that its restrictions are applied in practice. The change, however, does not mean that all municipalities must begin issuing fines the same day nor does it introduce a general prohibition for vehicles with environmental labels B or C. Access, driving, and parking conditions continue to depend on the municipal regulations of each zone.
Five tests to prove the functioning of LEZs
The new wording of Article 10.3 establishes five elements that local entities must prove to the competent administrations.
1. The first is the existence of current municipal regulations governing the low-emission zone. City councils must submit the corresponding ordinance within one month of its entry into force.
2. The second requirement directly affects the restrictions that vehicles must comply with. Municipalities will have to provide documentation proving that the prohibitions or access, circulation and parking limitations provided for based on the pollution potential of each vehicle have effectively come into force. Therefore, it will not be enough for the restrictions to appear in an ordinance or in an implementation schedule if they are still not being applied.
3. Third, local administrations must demonstrate that they have an effective access-control, monitoring and tracking system. The requirement is intended to ensure that the restrictions can be verified in practice and that municipalities have tools to identify the vehicles that enter the regulated areas and to check whether they meet the established conditions.
4. The fourth element introduces an obligation to connect with the state information systems. ZBEs must be integrated with the National Traffic and Mobility Access Point of the Directorate General of Traffic (DGT). This integration seeks to facilitate the availability and coordination of information about low-emission zones and the conditions that govern traffic within them.
5. The fifth requirement constitutes one of the main changes of the reform: town councils will have to demonstrate the effective application of the penalty regime. The text expressly excludes any transitional system of warnings that may have been contemplated previously. Therefore, it will not be sufficient to inform drivers that they have accessed a restricted area improperly if the municipality is still not applying the penalties provided for.
The intention of the Executive is to prevent municipal moratoriums from indefinitely prolonging the real application of the restrictions. A ZBE must have mechanisms to enforce its own rules and not limit itself to warning those who do not comply.
What changes for drivers and what restrictions remain in force
The entry into force of the decree may generate doubts among drivers, especially among those who use vehicles with environmental badges B and C. However, the reform does not establish a new national ban on circulation for these categories nor does it set a uniform schedule of restrictions for the entire territory. The scope of the limitations continues to depend on each municipal ordinance. It is the city councils that determine which vehicles may access, drive on, or park in their respective areas, as well as the times, the exceptions, and the conditions for obtaining authorizations.
That is why, on 26 November, it does not mean that all cities will automatically activate new fines or modify the access conditions. The date marks the entry into force of the new national requirements to prove the effective implementation of the ZBE. The specific application of the restrictions and the sanctioning regime will depend on the regulation in force in each municipality. To check whether a vehicle can enter a given area, the reference must always be the official information of the corresponding city council and its current ordinance. The driver should consult, in particular, the affected perimeter, the included streets, the environmental badges allowed, the days and times of application, and the possible exceptions.
It is also advisable to check whether special authorizations exist for residents, traders, service vehicles, or people with reduced mobility, as well as whether any prior procedure is necessary to benefit from them. The conditions can vary considerably between municipalities, so it is not enough to know the restrictions of the city of origin.
The Government seeks to end moratoriums without effective implementation
The regulatory amendment responds to the Executive’s concern about the differences between the formal implementation of low-emission zones and their real operation. The Ministry for Ecological Transition had already pointed to the existence of excessively prolonged sanctioning moratoriums and of zones in which the restrictions were not applied effectively. The new framework aims to reinforce compliance with municipal obligations and prevent ZBE from being reduced to an administrative delimitation without real capacity to condition the circulation of the most polluting vehicles.
The reform also maintains the information and monitoring obligations that already fell on local entities. These include communicating the delimitation and area of the zone, the measures adopted, their implementation schedule, and the results of the mandatory monitoring indicators. The documentation must allow the competent administrations to verify not only that municipal regulation exists, but also that the instruments provided to reduce emissions are in operation.
The fundamental change is that the Government requires moving from declared ZBE to effective ZBE. City councils will have to demonstrate that their restrictions are applied, that access is controlled, and that infringements have consequences. For drivers, meanwhile, the rule continues to be consulting municipal regulations: the new decree toughens the obligations of the administrations, but does not convert local restrictions into a general prohibition for certain environmental labels.