Summary
Microsoft’s December 2025 Product Terms update introduces three changes:
Updated Terms of Use reference for Bing Grounding in Copilot Studio
Dragon Copilot Nursing licence general availability
Windows 365 Reserve general availability
The changes apply to both MCA and EA/EAS programmes, effective 1 December 2025.
Power Platform: Bing Grounding Terms of Use URL Update
Microsoft updated the Terms of Use URL for “Grounding with Bing Search” and “Grounding with Bing Custom Search” within Copilot Studio, changing from the non-enterprise TOU to the enterprise-specific terms.
Caching Rights: The Key Difference
The enterprise TOU grants something the non-enterprise terms explicitly prohibit: the right to cache Bing search results.
Under the non-enterprise TOU, Section 4(b)(o) flatly bans caching, listing among prohibited activities: “Copy, store, cache, archive, or create a database of Output.”
The enterprise TOU carves out an exception in Section 3(c): “Customer may copy, store, cache or archive Bing Services Output solely (1) to the extent permitted by copyright law and (2) as an integrated part of its own work product, so long as the work product is not created for the purpose of or intended for use as a substitute for the Services or the Bing Services Output.”
Practical Implications of Caching Rights
Microsoft didn’t explain the change. The Product Terms simply updated the URL. But the caching difference has potential practical implications for Copilot Studio deployments:
Response latency and performance: If you’re building a Copilot Studio agent that gets the same questions repeatedly (e.g., “What’s your returns policy?”), under the non-enterprise terms you’d have to hit Bing every single time. Under enterprise terms, you could cache search results to deliver faster responses.
Cost management: Every Bing API call costs money. If agents handle high volumes of similar queries, caching could substantially reduce consumption charges.
Offline or degraded-network scenarios: An enterprise might want agents that can still function (with cached data) when Bing connectivity is temporarily unavailable.
Audit and compliance: Some organisations need to retain what data sources informed AI outputs. Under non-enterprise terms, you technically shouldn’t keep that data. Under enterprise terms, you can retain it as part of your own work product.
Whether any of these drove the change, or whether this is simply legal housekeeping to point enterprise customers at the correct terms, remains unclear.
Dragon Copilot: Nursing Licence Now Generally Available
Microsoft has added the Dragon Copilot Nursing licence to the Product Terms, supporting the general availability of Dragon Copilot for Nursing in the United States from December 2025.
Dragon Copilot is Microsoft’s AI-powered clinical documentation assistant. It listens to patient-clinician conversations and generates clinical notes automatically. The product launched in March 2025, consolidating two Nuance technologies Microsoft acquired in its $19.7 billion acquisition: Dragon Medical One (speech recognition) and DAX Copilot (ambient clinical intelligence).
Dragon Copilot is completely separate from Microsoft 365 Copilot. It has its own licensing model, purchase channels, and doesn’t require Microsoft 365 licences - only Microsoft Entra ID for authentication.
Licence Types
According to Microsoft’s licensing guidance, Dragon Copilot offers role-specific licence types:
For physicians, there are two options: |
|---|
Physician Per User: A flat monthly fee covering all features - frontend speech, ambient recording, and AI note generation. One licence assigned to one named clinician. Predictable monthly costs regardless of usage volume. Physician Flex: A hybrid model. The subscription covers frontend speech capabilities only. Ambient recording and AI note generation are billed separately through Azure consumption at $0.01 per unit. The main cost driver is ambient structured notes at 300 units ($3.00) per use. A clinician documenting 20 patient encounters daily would generate roughly $1,200 per month in consumption charges on top of the Flex subscription fee. |
For nurses, there is currently one option: |
|---|
Nursing Per User: A licence type for nursing workflows, including ambient flowsheet capture. Unlike the physician licences, there is no Flex option for nursing - only the Per User model is available. Microsoft hasn’t published subscription prices for any of these licence types. When CNBC asked about pricing at the March 2025 launch, Microsoft declined to share costs. |
Nursing Capabilities
According to Microsoft’s October 2025 announcement, over 25% of a nurse’s shift is consumed by documentation and administrative tasks, contributing to the 65% of nurses reporting high stress and burnout levels.
Dragon Copilot for Nursing aims to reduce that documentation burden by capturing clinical observations as nurses work.
Nurses speak naturally during patient care, describing observations and actions as they go. Dragon Copilot captures the audio, interprets the clinical content, and structures it into flowsheet documentation mapped to the hospital’s specific schemas. Before anything enters the medical record, the nurse reviews the generated documentation and approves it for filing to the EHR.
The product also integrates with Epic Rover mobile application and provides access to clinical reference content from CDC, FDA, Medline Plus, Merck manuals, and UpToDate.
Regional Availability
According to Microsoft’s healthcare page:
For physicians: | For nurses: |
|---|---|
United States, Canada, United Kingdom, Ireland, France, Germany, and Austria. | United States only. Healthcare organisations outside the US will need to wait for Microsoft to expand nursing availability to their regions. |
Product Terms Requirements
The Product Terms impose strict requirements around Healthcare Intended Uses. Dragon Copilot is not a general-purpose transcription tool. Microsoft restricts it to qualified healthcare professionals who have been trained on the product and hold whatever certifications their jurisdiction requires.
The provider of record must review all AI-generated content for accuracy and completeness before finalising documentation. Not optional. The AI drafts; the clinician validates. Nothing enters the medical record without human approval.
All Dragon Copilot outputs require clinician review and approval. Patient consent and compliance remain the customer’s responsibility.
Customers bear sole responsibility for obtaining patient consents and maintaining evidence of authorisations. If a patient objects to ambient recording, that’s on the healthcare organisation to handle, not Microsoft.
There’s also a competitive use restriction: customers may not use Dragon Copilot or its data to create, train, or improve competing products.
Windows 365 Reserve: Business Continuity Cloud PCs
Microsoft has added Windows 365 Reserve to the Product Terms, following its move to general availability in November 2025.
Reserve addresses a specific scenario: users who primarily work on physical PCs but need temporary Cloud PC access during disruptions. Each licence provides up to 10 days of Cloud PC access per year, provisioned on demand when needed.
The 10-day annual allocation is designed for genuine emergency use rather than regular remote work. Days are consumed only while the Cloud PC is provisioned, so organisations can preserve unused days for future incidents. Reserve differs fundamentally from Windows 365 Enterprise or Frontline, which provide persistent or rotating Cloud PC access for users whose primary work environment is the Cloud PC itself.
Windows 365 Reserve differs from Windows 365 Enterprise and Frontline. Each licence provides up to 10 days of Cloud PC access per year, intended for emergency or temporary use rather than regular remote work.
The Tech Community preview announcement positions Reserve for device failure, theft, delivery delays, ransomware incidents, and testing scenarios. When a user’s primary PC becomes unavailable, administrators provision a pre-configured Cloud PC through Intune, the user accesses it via Windows App or web browser, and when they return to their primary device, the Cloud PC is deprovisioned to preserve remaining days for future use.
For organisations currently maintaining pools of loaner laptops for business continuity, Reserve offers an alternative worth costing out. Loaner pools require hardware procurement, storage, maintenance, imaging, and physical distribution logistics. Reserve eliminates the hardware overhead but introduces per-user licensing costs and dependency on network connectivity.
The licensing prerequisites mirror Windows 365 Enterprise:
Windows 10/11 Enterprise or Education
Microsoft Intune
Microsoft Entra ID P1
These are included in Microsoft 365 F3, E3, G3, E5, G5, A3, A5, Business Premium, and Student Use Benefit bundles. Learn more.
Microsoft doesn’t publish Reserve pricing. The product page directs customers to contact the sales team for pricing.
Also in the Windows 365 Product Terms update: Microsoft expanded the License Prerequisites table for Microsoft Entra Internet Access and Microsoft Entra Private Access to include Microsoft 365 G3 and Enterprise Mobility & Security G3. Government customers with G3 licences can now meet the prerequisites for these Zero Trust network access features when using them with Windows 365.
If you need help with Microsoft licensing, get in touch. We don’t sell Microsoft licences or cloud services, so our advice is independent.