Bat class licences and which consultant can use one
A class licence removes weeks from a bat mitigation programme, but only a consultant personally registered by Natural England can use one. Here is how to check and what it covers.
If your conversion or demolition will affect a bat roost, the works need a licence from Natural England, and only a suitably licensed ecologist can obtain or act under one. Where the impact is low and the species are common, that licence can be a class licence rather than a bespoke application, which removes several weeks from the programme. The catch is that a class licence can only be used by a consultant Natural England has registered to use it, and registration is personal to that individual rather than held by the firm.
Self-builders usually discover this at the point the quotes come in and two of the three ecologists cannot do the job.
Why a class licence exists alongside bespoke licences
Bats are European protected species. Damaging or destroying a roost, or deliberately disturbing bats, is an offence under the Conservation of Habitats and Species Regulations 2017 and the Wildlife and Countryside Act 1981, whether or not bats are present on the day the roof comes off.
The bespoke route is a mitigation licence application to Natural England, made after planning permission is granted, setting out the survey findings, the impact, the mitigation and the compensation. Natural England has to be satisfied of three things before granting it: that the works are for a purpose the regulations permit, that there is no satisfactory alternative, and that the action will not be detrimental to maintaining the favourable conservation status of the species.
A class licence works differently. Natural England issues the licence once, sets its conditions and its scope, and then registers individual consultants to act under it. The registered consultant registers each site, carries out the works under the licence conditions, and reports afterwards. There is no site-by-site application to determine, which is where the time saving comes from.
A Protected Species Survey and any licence that follows it legally require a suitably licensed ecologist. An AI-drafted report can structure the submission and set out the policy context, and it cannot replace the survey, the licence or the professional judgement behind either.
Who can be registered to use one
Registration is granted to a named individual who can demonstrate to Natural England that they have the experience to work without site-by-site oversight. In practice that means a record of bat work rather than a qualification alone.
What Natural England looks for runs along these lines:
- A current survey-level licence for bats, held for a period, with evidence of survey work carried out under it
- Experience of mitigation licence work, usually a number of licensed schemes either as named ecologist or under supervision
- Familiarity with the roost types and species the class licence covers
- Professional references, and membership of a body with a code of conduct and a disciplinary process
A junior ecologist cannot be registered, and nor can a firm. Where a consultancy says it holds the class licence, what that normally means is that one or more of its staff are registered, and the person who will actually attend your site may not be among them. Ask who, by name.
What the class licence covers
The low impact route is deliberately narrow, and the scope is set by the licence document itself rather than by the consultant's judgement. The limits usually run across four dimensions.
| Limit | What it means in practice |
|---|---|
| Species | A defined list of commoner species, which excludes the rarer Annex II species |
| Roost type | Day roosts, feeding perches and transitional or occasional roosts, not maternity or hibernation sites |
| Numbers | A small number of bats, counted at the peak survey figure |
| Impact | Loss or modification of a small roost with proportionate mitigation available on site |
A typical qualifying case is a single common pipistrelle day roost under a ridge tile on a bungalow being re-roofed, where a bat box and a retained access gap deal with the impact. A loft with a maternity colony of brown long-eared bats is not a qualifying case, regardless of how helpful the mitigation sounds.
The survey work that establishes which case you are in comes first. A preliminary roost assessment can be done at any time of year, while emergence and re-entry surveys run from May to September with the best results between May and August, and that seasonality is the single biggest programme risk on a small conversion. The Bat Survey page sets out the survey sequence, and a wider Preliminary Ecological Appraisal will pick up whether anything else on the site needs attention at the same time.
Where a bespoke licence is unavoidable
Four situations take you out of the class licence and into a bespoke application.
- A rarer species is present, particularly those listed as requiring special measures, where the class licence does not apply at all.
- The roost is a maternity site or a hibernation site, or the survey cannot rule either out.
- The number of bats, or the scale of roost loss, exceeds the licence limits.
- The mitigation needed goes beyond what the licence conditions permit, for example a purpose-built bat house or a long-term monitoring commitment.
A bespoke application takes time to prepare and time to determine, and it cannot be submitted until planning permission is in place. Build that into the programme from the first survey rather than discovering it after permission. The sequence, the evidence and the usual delays are set out in more detail in the protected species mitigation licence explained.
Natural England has also developed additional accreditation and earned recognition arrangements for experienced bat consultants over recent years. Those arrangements change, so confirm the current position on gov.uk rather than relying on what was true for a project two years ago.
Checking a consultant's registration
Ask three questions before appointing, and ask for the answers in writing.
Which class licence do you propose to work under, and what is its reference. Are you personally registered to use it, and what is your registration detail. Will you be the ecologist attending the site and signing the records, or will that be a colleague.
A consultant who is registered will answer all three in a sentence each. If the answers are vague, or if the firm offers a general statement about holding licences, go back and ask again. You are the one who will be prosecuted alongside the contractor if works proceed unlawfully, and a letter from the ecologist is the only comfort you will have.
Where the scheme is sensitive and you want the report checked independently, the professional directory is the route for a review and sign-off by a suitably qualified reviewer.
Record keeping and reporting duties
Working under a class licence carries administrative duties, and they fall on the consultant rather than on you. Knowing what they are helps you spot when the work is not being done properly.
The registered consultant has to register the site with Natural England before works, usually with a notification period before any activity on site. The licence conditions specify what has to be recorded during the works: the date, the method, the supervision, the bats encountered, the mitigation installed. A return goes to Natural England afterwards, and annual returns cover the consultant's use of the licence across all their sites.
What this means for you is a short checklist at the end of the job: the site registration reference, the works record, the photographs of installed mitigation, and the return reference. Keep them with the planning documents, because a planning condition requiring the mitigation to be implemented will be discharged against exactly this evidence.
Questions to ask before you appoint
Beyond registration, four questions tell you whether the appointment will work.
- What survey work does the proposal include, in which months, and what happens to my programme if the result is a maternity roost.
- Is the fee fixed for the surveys only, or does it include the licence work and the supervision on site.
- Who attends on the day the roof is opened, and what is the call-out arrangement if a bat is found.
- What will you need from my builder, and when.
The last one is the question nobody asks. Licensed works usually require the contractor to work under the ecologist's supervision for defined operations, with hand-stripping of a roof area rather than mechanical removal, and that has a cost and a programme consequence the builder needs to price before the contract is signed.
Browse the PlanScope report types to see which ecology reports your project is likely to need, and treat the draft as the starting point for your licensed ecologist rather than a substitute for them.
For specialist technical reports, qualified professional input may be required. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.
Frequently asked questions
What is a bat class licence?
A licence Natural England issues once, with fixed conditions and a defined scope, which registered consultants can then use on individual low impact sites. The consultant registers each site rather than making a site-by-site licence application, which removes the determination period from the programme. The scope is set by the licence document, not by the consultant.
Can my ecologist's firm hold the class licence?
No. Registration is personal to a named individual who has satisfied Natural England about their bat experience. A consultancy saying it holds the licence usually means one or more staff are registered, and the ecologist attending your site may not be among them. Ask who by name and get the answer in writing.
When is a bespoke mitigation licence needed instead?
Where a rarer species is present, where the roost is a maternity or hibernation site or those cannot be ruled out, where the numbers or scale of roost loss exceed the class licence limits, or where the mitigation goes beyond the licence conditions. A bespoke application cannot be submitted until planning permission is in place.
When can bat surveys be carried out?
A preliminary roost assessment can be done at any time of year. Emergence and re-entry surveys run from May to September, with the best results between May and August. That seasonality is usually the biggest programme risk on a small conversion, so commission the preliminary assessment early enough to leave a survey season available.
Do I need planning permission before applying for a licence?
For a bespoke mitigation licence, yes. Natural England expects the planning permission to be in place, with the bat mitigation secured, before it will grant the licence. The class licence route works differently because the licence already exists and the consultant registers the site, but the planning position still has to be resolved.
What records should I keep after licensed works?
The site registration reference, the works record kept by the consultant, photographs of the installed mitigation and the return reference submitted to Natural England. Keep them with the planning documents, because a condition requiring the mitigation to be implemented will be discharged against exactly that evidence.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.