Summary
A European managed hosting provider received a formal Microsoft SPLA self-assessment letter, requiring it to review its licensing position under its hosting agreement, evidence it, and correct any shortfall within a requested 45-day window. The estate ran on Hyper-V across multiple clusters, roughly 50 virtual machines, and carried a System Center question the provider had answered incorrectly after an earlier conversation. The provider engaged SAMexpert to lead the defence: licensing analysis, remediation planning, and the response to Microsoft.
The position was rebuilt from the actual running estate rather than raw inventory, Windows Server reporting was evidenced on an actual-consumption basis, the System Center question was resolved with a formal written opinion, and the one shortfall was isolated and corrected. The apparent exposure came down to a defined, two-month true-up, with an over-stated user count removed in the provider's favour at the same time.
The engagement closed in roughly three months end to end, on a non-binding timeline that never escalated. Corrective reporting was routed through the provider's existing reseller, and a short, high-level closing response was prepared for Microsoft.
Anonymity guarantee
We must never give our clients away to the wrath of Microsoft. To protect them and their business, the client referenced here has been kept anonymous. Everything else is 100% a true story.
A formal letter, and exposure that looked open-ended
A Microsoft SPLA self-assessment asks the provider to review its own licensing position, evidence it, and correct any shortfall within a stated window, with the implication that anything left unresolved becomes an audit. A hosting provider reports to Microsoft every month for everything it runs on behalf of its own clients, so the letter covers the whole estate until the licensable position is established.
Several things widened the surface area. The estate ran exclusively on Hyper-V across multiple clusters, segmented by hardware rather than by service, with the provider's own self-hosted application and its hosted IaaS workloads sharing those clusters, which blurred the line between what fell inside the hosting agreement and what did not. A mixed SQL Server estate needed each instance attributed correctly. Two virtual machines were short of Remote Desktop Services Subscriber Access Licences and Office for end-client users, and sat alongside an Active Directory user count that was overstating exposure in the other direction.
Most contentious was System Center. The provider managed its Windows servers with System Center Virtual Machine Manager in agentless mode, and had come away from an earlier conversation believing that agentless management removed a licensing liability.
Rebuilding the position from the running estate
Rather than respond from raw inventory or from the worst-case reading of the letter, SAMexpert rebuilt the position from what was actually running. Twelve months of reporting history was reviewed and a full PowerShell inventory was collected across every Hyper-V host, re-engineered mid-engagement to work around a Microsoft-side security change that had disrupted data collection. The licensable figure came down to running Windows Server virtual machines only.
The provider's own operating pattern evidenced genuine consumption: running-machine snapshots every 10 minutes, and dynamic machine movement disabled outside planned maintenance. Both support actual-consumption reporting under the agreement.
An Effective Licence Position report set out the realistic range across three remediation scenarios before any decision was taken.
Resolving the System Center question in writing
The agentless-management question was answered with a formal written opinion and a supporting evidence dossier rather than an assertion. SAMexpert established that agentless System Center management did not remove the liability the provider believed it removed, and set out the reasoning in full.
Because the conclusion reversed the position the provider had taken from the earlier conversation, the rationale was communicated carefully, with one caveat flagged at the same time: a host whose configuration may have changed and should be re-scanned. The provider confirmed the position was clear and accepted it.
Correcting what needed correcting
With the position rebuilt, the shortfall was confirmed and corrected: Remote Desktop Services Subscriber Access Licences and Office for end-client users on two virtual machines. The over-stated Active Directory user count was stripped out at the same time. SQL Server was attributed instance by instance, separating customer-owned licences, a customer-declared instance, and those reported under the hosting agreement. The provider's own self-hosted application was confirmed out of scope as self-hosting, with a recommendation to separate it from the hosted workloads onto distinct hardware over time.
The response to Microsoft
Rather than wait for the next scheduled submission, the provider corrected the two affected months immediately through its existing reseller and reported accurately from then on. It had already sent a holding acknowledgement, and followed with a short, high-level closing response confirming the self-assessment was complete and that minor reporting inconsistencies were being corrected. No itemised figures, and no account of the historical correction in the communication itself. The window was non-binding throughout, and nothing escalated.
The outcome
Element | Result |
|---|---|
Apparent exposure | Reduced from an open-ended self-assessment to a defined, two-month true-up. |
Windows Server | Rebuilt from the running estate and evidenced on an actual-consumption basis, counting running virtual machines only. |
System Center question | The provider's earlier reading replaced with a formal, evidenced written opinion, which the provider accepted. |
Subscriber Access Licences | Remote Desktop Services and Office corrected on the affected machines, and an over-stated user count removed in the provider's favour. |
Remediation route | Corrective reporting through the existing reseller, plus accurate reporting from the following month, with no wait for the next cycle. |
Response to Microsoft | A short, high-level closing response confirming completion without over-disclosing. |
Microsoft timeline | Non-binding throughout. Acknowledged, held once, and never escalated. |
Engagement duration | Roughly three months from kick-off to formal closure. |
What this leaves the provider with
The self-assessment was defended and closed with one small, well-understood correction. The rest of the value is in what remains afterwards.
A Windows Server position rebuilt from genuine consumption rather than raw inventory. A formal, evidenced opinion on the System Center question, retained on file for the life of the agreement. A clear separation of in-scope hosting from out-of-scope self-hosting, with a practical path to keep it that way. And a line of communication with Microsoft that closed the matter without over-disclosing.
If you have received a Microsoft SPLA self-assessment letter, are facing an audit, or want an independent view of your licensing position, get in touch. We don't sell Microsoft licences or cloud services, so our advice is always independent.