
MCS Technical Supervisor: requirements and who can hold it
The redeveloped MCS scheme puts a named Technical Supervisor on every certificate. The evidence MCS expects, what they answer for, and who can hold it.
Batteries have no permitted development class of their own. When a home battery needs planning permission, and what to capture at survey.
The question comes up on almost every battery retrofit, usually at the wrong moment: after the quote is out, sometimes after the equipment is on the van. "You're not going to need planning permission for this, are you?" And for most jobs the honest answer is no, nothing gets submitted, and nothing ever comes of it. But the legal position behind that answer is thinner than it is for the panels on the roof or the heat pump on the wall, and the gap between the two is exactly where a small number of jobs go wrong.
Here's what the rules actually say, where a battery job can still turn into a householder planning application, and what to capture at survey so it never surprises you.
For a typical retrofit, meaning a battery inside the house, in the garage, or on an outside wall alongside the existing installation, planning permission isn't on the job. Nothing gets submitted to the council and the install proceeds on the schedule you quoted.
The position is genuinely that simple for the great majority of domestic battery work. What's worth understanding is why it's simple, because the reason isn't "batteries have a permitted development right like solar panels do". They don't. That difference matters on the jobs that sit at the edge.
England's permitted development rights for microgeneration live in Part 14 of Schedule 2 to the Town and Country Planning (General Permitted Development) (England) Order 2015. Read that Part and the pattern is consistent: every technology gets an explicit class.
Solar on a house or block of flats is Class A. Stand-alone solar in the garden is Class B. Ground source heat pumps, Class C. Water source heat pumps, Class D. Flues for biomass and combined heat and power, Classes E and F. Air source heat pumps, Class G, with the whole noise apparatus behind it that decides whether a heat pump job is permitted development at all. Wind, Classes H and I. Solar canopies over non-domestic parking, Class OA.
Battery storage appears nowhere in that list. When the order was amended for air source heat pumps in 2025 and for solar in 2026, no battery class joined them. The Planning Portal's solar guidance, which is the practical companion to those classes, covers panels and equipment and makes no mention of batteries either.
So the reason a battery retrofit usually needs no application isn't that the order grants one. It's that most batteries never get near the things planning permission exists to control. A unit in a cupboard or a garage changes nothing about the external appearance of the property. Planning's business is what a property looks like and how land is used from the outside; a battery inside the building does neither.
That logic carries a battery mounted on the outside wall of the house in most retrofit situations. It also has a limit, and the limit is the freestanding unit in the garden.
A battery cabinet standing on a pad in the garden isn't covered by the renewables Part of the order at all. If a permitted development right covers it, it's Class E of Part 1: the general right for buildings and enclosures within the curtilage of a dwellinghouse for a purpose incidental to the enjoyment of the dwelling.
Class E is the right that covers garden sheds and outbuildings, and it comes with limits, all of which apply to a battery cabinet:
Most domestic battery cabinets sit under a metre tall, in a side return or by a back wall, and clear every one of those limits. But the limits are what turns a "no application" job into a householder one: a customer who wants the battery next to the front boundary line, an oversized enclosure spec from a commercial-scale system that has crept into a domestic quote, or a listed property where the whole question changes shape. When a Class E limit is breached, the route is a householder planning application, with the fee and the wait that come with it, and that's a conversation you want to have at survey, not at install.
There's also an honest caveat to carry: the order never spells out that a battery is an "enclosure" under Class E. It's the only general right that reaches one, and in the ordinary run of jobs that's how they're treated. But because there's no explicit battery class, the clean habit on anything unusual (a large cabinet, a boundary position, designated land) is one pre-application enquiry to the local planning authority before you quote. The Planning Portal's own advice on the adjacent solar classes is the same in spirit: discuss with the local authority whether the limits and conditions will be met.
Two other regimes get folded into "do we need permission for this" by customers, and they're worth separating in the quote conversation, because they have different timelines and different owners.
The grid side isn't planning permission. A battery changes what the installation exports, and on larger systems the DNO application is the real consenting process: G98 versus G99 decides which form the job takes, and a G99 application for a solar-plus-storage system is where connection conditions land. Where the network is constrained, export limitation under G100 can keep a bigger battery job connected without reinforcement. None of that has anything to do with the council, and a customer who has waited on a DNO response will sometimes assume the planning answer is equally slow. It usually isn't.
Certification isn't planning permission either. Whether the job needs MCS is about the scheme, the consumer protection behind it and grant eligibility, not about the council's development control. A battery retrofit that needs no planning application still needs its installation certificates, and the commissioning notification on a grid-connected system is a real deadline with its own consequences for missing it.
Getting these three straight in one paragraph at quote stage is also cheap differentiation: it tells the customer you run the whole consenting picture, not just the panel on the roof.
Everything above is the position in England. Wales and Scotland run their own permitted development orders with their own classes and limits, and neither mirrors the English order class for class. If you install across borders, the answer for the same battery on the same kind of house can differ, so check with the local planning authority before quoting the job there.
The install businesses that never get surprised by this are the ones that treat the battery position as a survey question, not an install-day decision:
That's a handful of fields on a site survey, and it turns a potential mid-job stoppage into a priced contingency. It's the same discipline as capturing the DNO works-required status or the response to a further-information request on the grid side: one record per job, with the decision evidence attached, rather than a reconstruction from memory when the customer asks why the date moved.
This is where the tooling earns its keep. A job management system that understands battery installs lets you build those siting questions into a survey fieldset, attach the LPA's pre-app response if you got one, and keep the planning position on the same project record as the quote and the schedule, so the answer to "do we need permission for this" is a lookup, not a phone call to whoever surveyed it in March. The same record feeds the rest of the job's costing and margin, which is where a surprise householder application hurts most, and it's the difference between running compliance as a routine and running it as a series of discoveries.
If your team is still finding out where each job stands by phone, book a demo and we'll show you how install businesses keep the survey answers, the consenting positions and the certificates on one project record from quote to commissioning.
Sources: The Town and Country Planning (General Permitted Development) (England) Order 2015, Schedule 2, Part 14 (renewable energy classes); Schedule 2, Part 1, Class E (buildings etc incidental to the enjoyment of a dwellinghouse); Planning Portal: Solar panels. Order text as revised (amendments applied to 27 August 2026); confirm against the current text and the local planning authority for each job.
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