We report a model of the cathode catalyst layer (CCL) impedance, which includes impedances due to oxygen transport in the Nafion film covering Pt/C agglomerates, and due to oxygen transport through the CCL depth. In the case of small cell current density, analytical solutions for the CCL impedance Z ccl are derived; for larger currents, we analyze numerical solution for Z ccl . The characteristic frequencies of the oxygen transport through the Nafion film and through the CCL depth are close to each other, and the contribution of the Nafion film impedance Z N to Z ccl is small up to the current densities 100 mA cm −2 . This makes it difficult reliable determination of Z N from experimental spectra of a standard 10 μm-thick CCL. However, with the decrease in the CCL thickness, the relative contribution of Z N to Z ccl increases. It gives us a chance to determine Z N by fitting the models of this work to measured spectra of a low-loaded MEA with a thin CCL. An example of fitting the model to a synthetic numerical impedance is given. Polymer electrolyte membrane fuel cells are ready to take their place in the spectrum of electrochemical sources powering the future society. Still, however, a lot needs to be done to improve stability and reduce the cost of these cells. Development of simple and robust ex situ characterization techniques for the fuel cell research and applications (cars, home appliances etc.) is an urgent task.It is generally accepted that the impedance technique gives much more information on a PEM fuel cell, than the DC methods.