Court of Auditors: widespread delay in low emission zones

The Court of Accounts of Castilla-La Mancha has publicized the final joint audit report, conducted with the Court of Auditors and the regional external control bodies (OCEX), regarding the establishment of low-emission zones (ZBE) in municipalities. The resolution, dated September 30, 2026, and signed by president Fernando Andújar Hernández, is published in the Official Gazette of Castilla-La Mancha (DOCM) no. 193, dated October 7, 2026, under reference 2026/7152. The report concludes that the implementation of ZBEs in the community is “clearly insufficient” and shows a “generalized failure” to meet the legal obligation.

The reference framework is Article 14.3 of Law 7/2021, of May 20, on Climate Change and Energy Transition (LCCTE), which required municipalities with more than 50,000 inhabitants to have a ZBE by January 1, 2023, and Royal Decree 1052/2022, of December 27, which regulates its minimum requirements. The audit, coordinated with the Court of Auditors and regional external control bodies, covers the six obligated municipalities in the region—Albacete, Ciudad Real, Cuenca, Guadalajara, Talavera de la Reina, and Toledo—and uses March 31, 2025, as the reference date.

The work, which was a horizontal compliance and operational audit, examined ordinances, technical projects, procurement, and measurement systems, and relied on external sources such as the National Subsidy Database, the Public Sector Procurement Platform, and the official provincial bulletins. The auditor responsible for the report is María Victoria Galán Mora.

Only Guadalajara had an operational zone, and it was overdue

As of March 31, 2025, only Guadalajara had implemented a ZBE, although it did so after the legal deadline. The city councils of Toledo, Cuenca, Albacete, Ciudad Real, and Talavera de la Reina did not have a ZBE in effect and were in preliminary stages of drafting or processing.

The report notes an “insufficient integration” of the ZBE into sustainable urban mobility plans, delays in regulatory processing, prolonged moratoria, and deficiencies in control and monitoring systems. The reasons cited by the city councils—procedural, technical, financial, or legal—“do not exempt” them from complying with the legal obligation.

The situation in Guadalajara has been altered by judgments no. 178/2026 and 179/2026, dated April 15, from the High Court of Justice of Castilla-La Mancha, which declared the regulatory ordinance of its ZBE null and void as no prior and current SUMP (Sustainable Urban Mobility Plan) contemplating it had been proven.

PRTR Financing and justification risks

The financing of Guadalajara’s LEZ was mainly based on external resources: 3,930,211.91 euros from the Recovery, Transformation and Resilience Plan (PRTR), 1,652,568.74 euros from agreements with the Junta de Comunidades de Castilla-La Mancha, and 88,335.00 euros from the PIMA-CC program. The report warns of a “high dependency” and risks associated with the fulfillment of milestones and justification obligations, as well as possible non-subsidizable cost overruns.

Within the framework of orders TMA/892/2021 and TMA/354/2022, funded by the PRTR, municipalities without an LEZ received:

• Albacete: 11,633,754.92 euros.
• Toledo: 3,185,910 euros.
• Talavera de la Reina: 2,426,481 euros.
• Ciudad Real: 2,045,000 euros.
• Cuenca: 321,687.36 euros.

The control body notes a “lack of correspondence” between the funding obtained and the degree of execution achieved, with a “relevant risk of inefficiency” in the use of public funds.

Contracting without regulatory coverage and reimbursement in Cuenca

The city councils channeled the implementation through public procurement, in several cases without the ordinance having been approved. The awards amount to 3,575,919 euros in Ciudad Real, 3,436,550 euros in Toledo —with an incurred cost of only 50,000 euros—, 2,382,538 euros in Albacete, and 2,332,326 euros in Talavera de la Reina.

In Cuenca, the lack of execution and justification of a PIMA-CC 2021 grant led to a partial reimbursement procedure resolved on February 18, 2025, by the General Directorate of Circular Economy and Agenda 2030: return of the 50,000 euro advance plus 6,615.58 euros in late payment interest and loss of the remaining 50% of the aid.

Subsequent events and uneven progress

The report records progress after March 31, 2025. Albacete initially approved its ordinance on April 21, 2026; Ciudad Real approved its SUMP on November 28, 2025, and published the ordinance on December 30, 2025; Cuenca definitively approved it on November 24, 2025, with access restrictions starting January 1, 2026. In Toledo, the Plenary rejected the initial approval of the ordinance on November 21, 2025.

The report includes four recommendations: promote the approval and operation of the zones, strengthen the monitoring and evaluation of air quality —with express mention of Talavera de la Reina—, complete the technical project for Cuenca, and ensure in Guadalajara the prior integration of the LEZ into a SUMP.

The publication of the report exposes the city councils to a double front: accelerating the processing of zones that are still incomplete and justifying to the granting administrations European grants already received, the non-compliance of which may lead to repayments. The delay directly affects urban air quality and public health in the six audited cities.

Source: Official Gazette of Castilla-La Mancha, no. 193, October 7, 2026, section I (General Provisions), page 34230 (official reference: 2026/7152).