Bat licences: who holds one and what it allows

If your project touches a building with bats in it, the question of who holds a bat licence and what it allows decides your programme. Two different licences exist. A survey licence lets an ecologist look for bats using methods that would otherwise be an offence. A mitigation licence lets works proceed that would otherwise damage a roost. They are issued separately, they are held by different people at different stages, and a mitigation licence is normally granted only after planning permission is in place.

Self-builders discover that sequence late, and it is the single most common cause of a build slipping by a year.

Why a licensed surveyor is required at all

All bat species in the UK are protected. The Conservation of Habitats and Species Regulations 2017 make it an offence to deliberately capture, injure or kill a bat, to deliberately disturb one, or to damage or destroy a breeding site or resting place. The Wildlife and Countryside Act 1981 adds protection against intentional or reckless disturbance and against obstructing access to a roost.

The offences are drawn widely enough that ordinary survey work engages them. Entering a roost, handling a bat, shining a light into a crevice or using an endoscope in a roosting space are all capable of constituting disturbance, so the ecologist doing that work has to be licensed for it.

Note that the roost is protected whether or not bats are present at the time. A roof void used seasonally is still a resting place in December.

Survey licences and mitigation licences compared

A survey licence, issued by the statutory nature conservation body, permits an ecologist to use defined techniques for survey and conservation purposes. It is personal to the ecologist and is issued at levels reflecting the techniques permitted, from basic roost inspection up to handling and trapping. It does not permit any works to the building.

A mitigation licence permits the development works themselves. It is applied for once a scheme is settled, it names the site, the methods, the timing and the compensation, and it is granted only where three tests are met: the work is for a permitted purpose, there is no satisfactory alternative, and the action will not be detrimental to the maintenance of the population at favourable conservation status.

The licensing body will normally expect planning permission to be in place before it grants a mitigation licence, because the no satisfactory alternative test cannot be assessed against a scheme that might still change. So the order is survey, then application, then permission, then licence, then works. It does not compress.

Class licences and registered consultants

Alongside individual licences there are class licences. A class licence sets out the permitted activities in advance and allows registered consultants who meet defined experience criteria to act under it by registering a site rather than applying for a bespoke licence.

For bats the relevant class licences cover survey and conservation work, and low impact development sites where the roost type and the numbers involved fall within stated limits. Registering a site under a low impact class licence is faster than a bespoke application, often by several weeks, and the difference matters when a build programme is waiting.

The limits are real. A maternity roost, a hibernation site or a species of higher conservation concern will take the project outside the class licence and into a bespoke application. Ask the ecologist early whether the site is likely to qualify, because the answer changes your programme by a month or more.

What an unlicensed surveyor may lawfully do

More than people assume, which is why the first stage of survey work often costs less than expected.

A preliminary roost assessment involves an external inspection of the building, an internal inspection of accessible spaces without entering or disturbing a roost, and a search for field signs. Dusk emergence and dawn re-entry surveys are carried out from outside the building, watching the elevations, and require no licence. A desk study of local records is unlicensed work.

What an unlicensed person must not do is enter a roost, handle a bat, use an endoscope in a roosting feature, obstruct access to a roost or carry out works that damage one.

The assessment itself still has to be competent, and councils expect ecological reporting to follow recognised professional guidance. That first stage usually sits inside a Preliminary Ecological Appraisal, and setting its scope properly matters, which is the subject of writing a brief for a specialist planning report.

Evidence to ask a consultant for

Before appointing, ask for five things and keep the replies on file.

1. The licence or class licence registration number, and the level or scope it covers.
2. Confirmation of professional body membership at an appropriate grade.
3. Two recent examples of comparable sites, with the outcome of the licence application.
4. Professional indemnity insurance details.
5. A written scope stating the number of survey visits proposed, the months they will fall in and what happens if bats are found.

The fifth is the one that protects you. A quotation for a single survey visit on a building with obvious bat potential is not a saving, because the guidance will require more visits and you will pay for a second mobilisation.

Checking a specialist before appointment follows the same pattern across disciplines, as set out in reviewing a specialist report you did not commission.

Timing a licence application against a build programme

Work backwards from the season.

Preliminary roost assessments can be done at any time of year. Emergence and re-entry surveys are seasonal, falling broadly between May and September with the most informative period earlier in that window, and the number of visits depends on how suitable the building looks. A building with high potential needs more visits than one with low potential, spread across the season.

Then allow for the application. Preparing the licence application, the method statement and the compensation design takes the ecologist several weeks, and the licensing body has its own determination period. A bespoke application takes longer than a class licence registration.

A realistic sequence for a barn conversion: assessment in March, emergence surveys May to July, planning application submitted July, permission in the autumn, licence application in the winter, works starting the following spring with timing restrictions attached. Attempting to shortcut any step usually costs more than the delay it avoids.

The Bat Survey work and any resulting Protected Species Survey must be carried out by a suitably licensed ecologist. That is a legal requirement, not a preference, and an AI-assisted draft can only ever be a starting point for that professional rather than a substitute for the survey or the licence.

Offences and who commits them

The person who carries out the work commits the offence. So, in many cases, does anyone who causes or permits it, which can extend to the landowner, the developer and the contractor.

The offences are criminal and carry a fine and, in serious cases, imprisonment. Insurers do not cover them. A demolition contractor who removes a roof knowing bats are present has a personal exposure, which is why competent contractors ask to see the licence and the method statement before they start.

There is also a planning consequence. A local planning authority must have regard to the licensing tests before granting permission where a protected species is likely to be affected, so an application without adequate survey information can simply stall.

Where you need a reviewer to check ecological work before it goes in, the professional directory is the route to a sign-off.

This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval. For specialist technical reports, qualified professional input may be required.