By mid-2026, it is very likely that there will be no clear idea of the situation in Madrid Low Emission Zone, a traffic restriction area comprising the entire municipality of Madrid and in effect since January 1, 2025, after a transitional period that began in September 2021. With the changes introduced in the Sustainable Mobility Ordinance by the new Ordinance 2/2026, approved last March 24, strictly speaking, it can no longer be called a LEZ, but rather a “fake” LEZ, which only retains its name but not the essence of what was intended with this urban motorized mobility regulation figure for environmental and social sustainability reasons.
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The Madrid City Council, after two years of moratorium granted to all vehicles without the DGT environmental badge (vehicles with environmental classification A) domiciled in Madrid in the General Vehicle Registry (RGV) and registered in the Mechanical Traction Vehicle Tax (IVTM) Register of the Madrid City Council since at least 01/01/2022 and continuously, has not extended this moratorium for a third year. Instead, it has authorized these vehicles to access, circulate, and park in Madrid LEZ sine die and without limitations, except in specific situations where nitrogen dioxide concentrations recorded at the city’s air quality monitoring stations exceed the legal limit values. This is the change introduced by the new Transitional Provision 7 of the Ordinance, in whose title and development the term “temporary” is paradoxically used to refer to an express authorization, without a deadline and without other conditions than those previously mentioned.
Furthermore, Transitional Provision 7 adds another clarification: the rest of the vehicles with environmental classification A may also circulate under the same circumstances without any domicile or registration requirement, “provided they are not ‘passenger car’ type automobiles with classification 10 by construction criteria, classified in categories 00 Unspecified, 02 Family, and 33 Off-road by usage criteria.”
This means that, except for passenger cars with environmental classification A with a third row of seats or increased capacity, off-road vehicles and those not classified in any other class by RGV usage criteria, all the most polluting vehicles from the other 68 categories, both from Madrid and non-Madrid residents passing through Madrid, can circulate. In practice, this allows all types of vehicles to circulate through the now fake Madrid LEZ, regardless of their pollutant and greenhouse gas emissions. The new Ordinance has stripped the LEZ covering the entire road network of the municipality of Madrid of its regulatory essence for sustainable mobility.
In view of the modification introduced by Transitional Provision 7, the previous system of exceptions to circulation restrictions in Madrid LEZ, which was included in article 21.4 of the Ordinance, was deliberately emptied, as almost nothing can now be excepted, and consequently, the new wording of 21.4 is dedicated to discussing serious traffic offenses (to whom?), instead of exceptions.
Therefore, the implications for the circulation of vehicles without the DGT environmental badge resulting from the recent rejection by the Supreme Court of the cassation appeal filed by the Madrid City Council against the TSJM ruling 405/2024, which annulled the articles of the Sustainable Mobility Ordinance 10/2021 related to the low emission zones of the municipality of Madrid, are irrelevant, except for what may refer to the retroactivity or not of the sanctions imposed since the operation of the former Madrid LEZ, with possible consequences for the local Madrid Treasury.
Paradoxically, the modification of the Sustainable Mobility Ordinance regarding LEZ is justified by the need to reinforce the general purpose of protecting human health and the environment and to adapt to the state regulations approved after the previous reform of the Ordinance in September 2021, particularly Royal Decree 1052/2022, which regulates low emission zones, in development of article 14.3.a) of Law 7/2021 on climate change and energy transition. This is expressed in the document of the report on the prior public consultation of the Ordinance modification (section 2.2) and in the preamble of Ordinance 2/2026 itself (points 30, 31, 36, 65). RD 1052/2022 has the status of “basic legislation on environmental protection,” which is the exclusive competence of the General State Administration (AGE), according to article 149.1.23ª of the 1978 Constitution.
The “relaxation” of circulation and parking restrictions for vehicles in Madrid LEZ, imposed by Transitional Provision 7 of the Sustainable Mobility Ordinance, paves the way for the holding of the Madrid Formula 1 Grand Prix on the LEZ streets next September. The urban (or semi-urban) circuit Madring, under construction since July 2025, occupies city roads in Madrid; specifically Francisco Umbral street, Avenida del Sena, Vía Dublín, and Glorieta de Edimburgo. The circuit’s paving is expected to be completed throughout this May, which represents progress in the development of this project promoted by the Community of Madrid, the Madrid City Council itself, and IFEMA.
F1 single-seaters do not have the DGT environmental badge but will circulate through Madrid LEZ, blending, according to their characteristics, into the broad range of class A vehicles that can circulate through this fake LEZ. However, this contradicts the purpose of Madrid LEZ according to the Sustainable Mobility Ordinance itself (Art. 21.2), coinciding with the purposes of RD 1052/2022 regulating LEZ (Art. 1.2). Clearly, F1 cars are not the type of vehicle that RD 1052/2022 identifies in its article 5.3 as possible exceptions to access, circulation, and parking restrictions, because they do not correspond, as they should, to “duly justified cases,” nor do they guarantee compliance with the LEZ objectives (Art. 3 of RD 1052/2022).
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On the other hand, if we try to find the fit of these racing cars in the express circulation authorizations of Transitional Provision 7, it would seem coherent to identify them, according to the RGV, as automobiles with classification 10 (passenger car type) by construction criteria and category 00 (unspecified) by usage criteria. There is no more precise classification to fit them into, with the RGV in such circumstances instructing the application of category 00. In such a case, without the DGT environmental badge, not domiciled in Madrid in the RGV nor registered in the IVTM of the Madrid City Council, they should be excluded from the transitional regime of the Sustainable Mobility Ordinance and, consequently, prohibited from circulating through Madrid LEZ.
However, one might consider the possibility that, despite this implicit prohibition, F1 cars might ultimately circulate on urban roads, violating the circulation restrictions of Madrid LEZ, which “constitutes a serious traffic offense,” according to article 21.4 of the Sustainable Mobility Ordinance in its new wording.
The serious traffic offense is typified and sanctioned with a fine of 200 euros, according to the Traffic, Motor Vehicle Circulation, and Road Safety Law, an amount that is laughable when talking about such a lucrative activity as Formula 1. Moreover, under this circumstance, it would not be coherent to suppose that the municipal authorities of Madrid would promote and, according to their powers, authorize the holding of an event starring teams that they would later have to sanction for contravening the municipal regulation itself.
If the changes introduced in the Sustainable Mobility Ordinance aim to adapt it to RD 1052/2022, regulating LEZ, the resulting Ordinance should not contradict but confirm, even reinforce, the general regulation established by RD 1052/2022, given its status as basic legislation on environmental protection. The F1 competition on the streets of Madrid LEZ violates article 5 of the Royal Decree (“Restriction of access, circulation, and parking of vehicles and environmental classification”), even when filtered through the current Madrid ordinance.
It should not be forgotten, moreover, that the Madrid City Council received subsidies from NextGenerationEU funds through the Aid Program for municipalities for the implementation of low emission zones and the digital and sustainable transformation of urban transport (included in Component 1 of the Recovery, Transformation, and Resilience Plan of the Government of Spain), in its two calls (2021 and 2022), for a total amount of more than 214 million euros.
The step back taken by the municipality of Madrid in the sustainability of its mobility with Transitional Provision 7 of the Ordinance now questions, at least in part, its legitimacy as a beneficiary of these aids. The holding of the Formula 1 Grand Prix on the LEZ roads, however fake it may be, corroborates this.
By the way, what will happen to the Madrid LEZ informational signs installed at all entrances to Madrid and at the accesses from the M30 to the capital’s road network? They have become completely outdated.
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