The transient response of a proton exchange membrane fuel cell (PEMFC) supplied with pure hydrogen and oxygen was investigated by load step measurements assisted by electrochemical impedance spectroscopy and chronoamperometry. Using an in-house designed resistance board, the uncontrolled response in both cell voltage and current upon step changes in a resistive load was observed. The PEMFC was found to respond quickly and reproducibly to load changes. The transient PEMFC response was limited by a cathodic charge transfer process with a potential-dependent response time. For load steps to high-current densitities, a second transient process with a constant response time was observed. This transient was offset from the charge transfer transient by a temporarily stable plateau. Results from chronoamperometry indicated that the second transient could be related to a diffusion process. Transient paths were plotted in the V–i diagram, matching a predicted pattern with overshooting cell voltage and current during a load step.