Bat low impact class licences and registered consultants

The bat low impact class licence exists because most bat roosts found on development sites are small, ordinary and predictable, and putting each of them through a bespoke European protected species licence application wastes everyone's time. Under a class licence, a consultant Natural England has registered can register a qualifying site and proceed on the licence conditions, without waiting for an individual determination. The trade is control for speed: the conditions are fixed, the scope is narrow, and the registered consultant carries the compliance burden personally.

What the class licence covers

All English bat work that would otherwise breach the Conservation of Habitats and Species Regulations 2017 needs a licence, and a licensed ecologist is legally required for the survey work and any mitigation licence. Regulation 55 of those Regulations is the derogation power, and the three tests still apply under a class licence: an overriding public interest purpose, no satisfactory alternative, and no detriment to the maintenance of the species at favourable conservation status.

What changes is the process. Instead of a site-specific method statement assessed by a licensing officer, the licence sets standard conditions for low impact situations, and the registered consultant certifies that the site meets them. Planning permission is still needed first, because the licensing authority will not authorise works that have no lawful basis to proceed.

Survey effort does not shrink. You still need the roost characterisation from a bat survey, carried out to the current Bat Conservation Trust good practice guidelines, before you can show the site qualifies.

Roost types and species inside the scope

The scope is set by roost significance rather than by convenience. Broadly, the licence is aimed at day roosts, night roosts, feeding perches and small numbers of individuals of the commoner species, in buildings and structures rather than in significant natural features.

Sites drop out of scope where the roost is a maternity site or a hibernation site, where the species is one of the rarer Annex II species, where the number of roosts or bats on the site exceeds the licence limits, or where the site lies within or close to a Special Area of Conservation designated for bats. The precise species list, roost categories and numerical caps sit in the licence document itself and its conditions have been revised more than once, so read the current version rather than a version you worked to three years ago.

One judgement call recurs. A roost that looks like a day roost in July may be a maternity roost the following May, and a single emergence survey in the wrong month will not distinguish them. Where the evidence is thin, the honest answer is more survey effort, not a registration that assumes the best case.

Who can register as a consultant

Registration is personal. Natural England assesses the individual, not the firm, and expects a bat survey licence held for a reasonable period, a record of mitigation work on comparable roost types, and referees who can speak to the applicant's handling of licensed work. Registered status runs for a defined period and is renewable.

The obligations that come with it are the part applicants underestimate. A registered consultant is accountable for the accuracy of every site registration submitted, for the mitigation being built as described, and for the returns. Natural England can audit, suspend and remove registration, and a suspension has immediate consequences for every live site in that consultant's name.

If you are a developer rather than an ecologist, the practical question at appointment is simple: is the named person on the registration the person who will actually visit the site during works. Ask it before you appoint. Our professional directory is the route to reviewers who can check draft documents, and the same principle applies there, in that the named individual matters more than the letterhead.

Registering a site and starting work

The registration submission is short compared with a bespoke application, but it is not a formality. It typically requires the site details, the roost characterisation and survey dates, the species and roost types present, the works proposed, the mitigation and compensation specification, and a declaration that the site meets the licence conditions.

1. Complete survey to good practice guidelines and characterise every roost.
2. Confirm against the current licence conditions that the site qualifies.
3. Design the mitigation, including timing, exclusion method, replacement roost provision and supervision arrangements.
4. Submit the site registration and wait for Natural England's confirmation.
5. Carry out the works under the licence conditions, with the supervision the registration specifies.

Confirmation of a site registration is usually a matter of days rather than the several weeks a bespoke licence determination takes. That gap is the whole commercial point of the route.

Records, returns and audit

Class licence work carries a reporting duty. The consultant keeps records of what was found, what was done, when, by whom and with what outcome, and submits returns to Natural England within the period the licence specifies. Replacement roost provision, whether bat boxes, access tiles or a dedicated void, has to be recorded as built rather than as designed.

Poor record keeping is the most common cause of trouble. Natural England's audits look at the paper trail first, because that is what exists after the scaffold has come down. A file with no dated photographs of the exclusion, no record of who supervised the soffit removal and no as-built note on the replacement roost is indefensible if anything is questioned later.

When a bespoke licence is still needed

A bespoke European protected species mitigation licence remains the route where a maternity or hibernation roost is affected, where a rarer species is present, where the roost sits in a tree of high value or an underground feature, where impacts exceed the class licence caps, or where the mitigation involves anything the standard conditions do not contemplate.

There is a temptation to slice a scheme into phases so that each phase looks low impact. Do not. The assessment is of the site and the project, and a registration that understates the roost is a licensing offence rather than a clever programme decision. Where the Protected Species Survey work shows a borderline case, the defensible answer is the bespoke route with a proper method statement.

What it does to a programme

On a converted barn or a re-roofing project, the class licence route can take several weeks out of the critical path, and it removes the risk of a determination landing after the contractor has demobilised. It does nothing about survey seasons. Emergence and re-entry surveys still run from May to September, with the strongest evidence between May and August, and no licence route shortens that window.

So the sequencing advice for a developer is unchanged. Commission the Preliminary Ecological Appraisal and the preliminary roost assessment in the winter, book the emergence surveys for the following summer, and treat the licence, class or bespoke, as the last few weeks of the process rather than the first thing to worry about. Missing a survey season costs a year. Choosing the wrong licence route costs a month.

This is general guidance, not legal advice. Licence conditions change, and the position on any particular roost should be confirmed by the licensed ecologist responsible for the work. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval, and for protected species work a suitably licensed ecologist is legally required rather than optional.