Checking a bat licence holder before you hire them

A bat licence belongs to a person, not to a company. That single fact is the reason this check is worth ten minutes before you instruct anyone. The consultancy's website may say "licensed ecologists"; the individual sent to your site on a July evening is either named on a licence or is not, and if they are not, the work they do inside a roost is unlawful.

For a self-builder or a small developer, the consequence lands on your programme rather than theirs. A survey carried out without the right licence can be challenged, a mitigation licence application can be refused as inadequate, and bat work is seasonal, so a mistake found in September costs you until the following May.

Which licences exist and what each permits

Bats are protected under the Conservation of Habitats and Species Regulations 2017 and the Wildlife and Countryside Act 1981. Offences include deliberate capture or disturbance and damage to or destruction of a breeding site or resting place, whether or not a bat is present at the time.

Three categories of authorisation matter to a development project.

A survey licence permits activities that would otherwise be offences while surveying: entering a roost, handling bats, using an endoscope, or disturbing bats to establish what is there. A walkover assessment from outside a building does not need one. A dusk emergence survey usually does not involve handling, but internal inspection of a roost does.

A mitigation licence permits the works themselves where a roost will be damaged or destroyed. It is issued after planning permission and against a method statement. The three tests are that the work serves overriding public interest or public health and safety reasons, that there is no satisfactory alternative, and that the favourable conservation status of the species is maintained.

A class licence lets a registered consultant carry out defined categories of work without a bespoke application each time. The registration is specific to a named individual and to a class of work, and the low impact class licence for bats is the one most often relevant to a barn conversion or a roof strip.

How a class licence differs from a bespoke licence

The difference is who decides, and how quickly.

A consultant will sometimes tell you a scheme can proceed under a class licence when the survey results put it outside the class. Ask which class, and ask why your case fits it. The answer should reference species, roost type and numbers, not convenience.

Where registration can be verified

Ask for three things in writing before you appoint: the individual's full name as it appears on the licence, the licence or registration number, and the expiry date. Then check rather than assume.

1. Take the licence number and the person's name, and confirm the registration with Natural England, which administers licensing in England.
2. Ask for a copy of the class licence registration document or the survey licence itself, not a logo on a letterhead.
3. Check professional membership separately through the relevant institute's register, since chartered or full membership is evidence of assessed competence rather than of licensing.
4. Ask who will actually attend the site visits, and get the licensed person named in the appointment.

Point four is the one that gets skipped. A licensed principal ecologist quoting the work, with unlicensed staff doing the survey, is a familiar arrangement and a poor one where the activity needs a licence.

Questions to ask about previous licence applications

Competence shows in the paperwork more than in the fieldwork. Useful questions, and the answers you want to hear:

• How many mitigation licence applications have you submitted in the last two years, and were any returned for further information
• What roost types have you worked on that match mine, such as a maternity roost in a barn or a crevice roost under lead flashing
• Which surveys do you consider necessary for my building, and what is your reasoning under the current good practice guidelines
• Who writes your method statements, and who supervises the works on site

A consultant who answers the third question by listing the survey visits without explaining the reasoning is quoting a template. The survey effort should follow from the building's features and the assessed likelihood of roosting, and our note on whether a survey is still valid covers the shelf life question that follows.

Why licence returns matter

Class licences and bespoke licences both carry reporting obligations. Returns are how the regulator knows what happened, and a consultant with a poor returns record is a risk to your next application.

You are entitled to ask whether previous returns were submitted on time and whether any licence has been refused, suspended or withdrawn. The question is uncomfortable to ask and easy to answer for anyone with nothing to hide.

What happens if the ecologist is not licensed

Two separate problems arise. The first is legal: activities requiring a licence, carried out without one, are offences under the regulations, and liability does not stay with the consultant alone where a developer instructed the work.

The second is practical. Natural England can decline to accept survey data gathered unlawfully or by an unlicensed person, which means repeating the survey in the next available season. On a barn with a suspected maternity roost, that is a year.

If you discover the problem mid-project, stop the activity that requires the licence, take advice, and be straightforward with the local planning authority about the position. A Protected Species Survey has to be capable of supporting a licence application, and a survey that cannot is worse than no survey at all, because the planning file now records the roost without the evidence to deal with it.

Recording the check in your project file

Keep a short record: the name, the licence or registration number, the expiry date, the date you verified it, how you verified it, and the appointment document naming that person. Add the survey visit dates and who attended each one.

That file does two jobs. It answers a case officer who asks who carried out the survey, and it protects you if the consultancy changes staff mid-project.

As an illustrative example, a stone barn conversion with droppings on a beam and gaps under the ridge tiles is likely to need a preliminary roost assessment, then emergence and re-entry surveys in the season, then either a class licence registration check or a bespoke licence application before the roof is touched. The check at the start of that sequence costs nothing. The check missed at the start costs a season.

Bat work is an area where a suitably licensed ecologist is legally required, and no drafted document changes that. A bat survey has to be carried out and signed by that person, and PlanScope's draft reporting is a starting point for them rather than a substitute. Reviewers who can sign off drafted reports can be found through the professional directory.

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.