Bat licence classes and what each one allows

Bat licence classes from Natural England split into two families that people constantly confuse. A survey licence lets an ecologist disturb bats to find out what is there. A mitigation licence lets a developer damage or destroy a roost as part of a scheme that already has planning permission. Holding the first does not entitle anyone to do the second, and a report written by a survey licence holder does not carry a development through the licensing stage.

All bat species in the UK are European protected species under the Conservation of Habitats and Species Regulations 2017, and they are also protected by the Wildlife and Countryside Act 1981. Both statutes create offences that apply whether or not anyone knew bats were present.

Survey licences and mitigation licences

A survey licence permits activities that would otherwise be offences when carried out for survey, research or education: entering a roost, inspecting with an endoscope, handling bats, and at higher tiers capturing them by harp trap or mist net and attaching radio tags.

A mitigation licence, generally called a European protected species licence, permits damage to or destruction of a breeding site or resting place, and disturbance of the animals, so that development can proceed. Natural England can only issue one where three tests are met: there is an imperative reason of overriding public interest or a public health and safety purpose, there is no satisfactory alternative, and the action will not be detrimental to the maintenance of the population at favourable conservation status.

Those three tests are the reason a mitigation licence application comes after planning permission rather than before. The planning decision supplies the evidence for the first two tests, and Natural England will expect the permission and the relevant conditions to be in place.

The class licence system and registration

Alongside bespoke individual licences, Natural England operates class licences. A class licence authorises a defined set of activities in defined circumstances, and instead of applying for a licence each time, a suitably experienced ecologist registers to use it and then works within its conditions.

For bats, the class licence route covers survey work at several levels and covers low impact development situations where the roost affected is of a defined type and small conservation significance. The registered person carries the obligations: they must keep records, submit returns and stay within the scope of the class.

Licence codes and class names are revised periodically, and classes are occasionally withdrawn or replaced. Check the current register of class licences on gov.uk rather than quoting a code from an older report, because a registration that has lapsed or a class that has been replaced is a real problem at the point of works.

The practical benefit of the class licence route is time. A bespoke licence application takes weeks to determine. A registered ecologist operating under a class licence can often proceed on notification.

What each level permits in the field

Survey licences are tiered by the risk the method poses to the animal.

The lowest tier covers roost inspection and disturbance in the course of survey, including endoscope use and the handling that inspection sometimes requires. Most consultancy bat work sits here.

Higher tiers add capture methods. Harp trapping and mist netting need specific training because the risk of injury is real and the handling burden during a busy night is substantial. Higher still, radio tagging for roost finding is a specialist activity that requires evidence of supervised experience with the technique.

A preliminary roost assessment needs no licence at all, because it involves external and internal inspection without disturbance to bats. That is why a preliminary assessment can be done at any time of year and is the right first step on almost every building. A Bat Survey that follows the Bat Conservation Trust good practice guidelines will set out which activities were carried out under which licence.

Emergence and re-entry surveys sit in the May to September window, with the middle of that period giving the most reliable results, and hibernation surveys sit in the winter months. Programme accordingly.

Evidence of experience needed to progress

Progression through the tiers is by demonstrated experience rather than by examination. Applicants provide a record of survey nights, handling experience and the methods used, supported by referees who already hold the relevant level.

What that means for anyone commissioning work is that a licence number is a floor rather than a ceiling. Two ecologists at the same level can have very different depth: one with three hundred emergence surveys across barn, church and tree roosts, another with the minimum record required to register.

Ask for the licence level, the number of years held, and two examples of comparable projects. A Protected Species Survey and any mitigation licence require a suitably licensed ecologist, and a PlanScope draft is a starting point for that professional rather than a substitute for their judgment.

How a licence should appear on a submitted report

Reviewers should expect the licence details to appear on the face of the report, not buried in an appendix. That means the surveyor's name, the licence or registration number, the level, and the expiry date. Where several surveyors attended, each should be listed with their own details and the nights they attended.

Three checks a reviewer can make quickly:

• Was the licence valid on every survey date, including the earliest one
• Did the methods used fall inside the scope of the level held
• Were the survey dates within the season the guidelines specify, and if not, is the limitation stated

A report that reports handling or trapping without naming a licence holder for that activity is not one to sign off. Our note on signing off an AI-assisted draft covers the broader question of what a reviewer takes on.

Fitting a licence into the programme

Sequencing is the part clients get wrong, and it costs months.

1. Preliminary roost assessment, at any time of year, to establish whether bats are a constraint.
2. Emergence and re-entry surveys in season, usually needing two or three visits depending on the roost potential found.
3. Report, mitigation design and planning application, with the ecological evidence submitted rather than deferred to a condition.
4. Planning permission granted, with any ecological conditions discharged as required by the licensing process.
5. Mitigation licence application to Natural England, or registration under a class licence where the situation qualifies.
6. Works carried out under the licence, with the named ecologist present as the method statement requires.

Natural England publishes target determination periods for licence applications, and those targets change. Check the current figure and add contingency, because an incomplete application restarts the clock.

What an applicant should ask their ecologist

Five questions worth asking before you appoint:

• Which licence do you hold, at what level, and when does it expire
• Will you personally attend, or will the work be delegated, and to whom
• Is this situation likely to qualify for a class licence or will it need a bespoke application
• What is your view on the survey season and what does that do to my programme
• What will the mitigation look like, and what does it cost to build and to monitor

Answers to those five tell you more than any credential. Reviewers listed in the professional directory can also review a survey report before it is submitted, which is worth doing where the roost is significant and the programme is tight.

For specialist technical reports, qualified professional input may be required. Browse the full report index to see which reports carry a professional required label.

PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.