May 29, 2026

  Blog

EA to MCA Migration: Your Four-Point Compliance Checklist

My Atlas / Blog

1,414 wordsTime to read: 8 min
Steven Kelley by
Steven Kelley

Steve Kelley works with organizations to optimize their Microsoft licensing agreements and protect them from future licensing liabilities. Before joining Directions... more

Microsoft no longer wants midsize enterprises on the Enterprise Agreement (EA). The de facto floor for an EA renewal has been creeping upward for years, and customers in the 2,500-to-10,000 user band. Microsoft has decided this group is too small to command the direct account management it reserves for its largest accounts and too operationally complex to fit a SaaS-only playbook. Microsoft is steering these customers toward the Microsoft Customer Agreement (MCA) purchased through a Cloud Solution Provider (CSP). For these customers, the move is not optional. An EA renewal may not be an option any longer and there’s likely no rep to whom to talk. (How far up-market this push extends in Microsoft FY27 is the next question.)

Many CSPs are doing their best to accommodate these EA transitions. However, Microsoft is guiding these customers into a channel it has not equipped to properly handle these migrations. There is no formal certification program for CSPs taking on EA migration work, no required training curriculum, no qualification standard, and no SKU parity between what’s available in the channel customers are leaving and the channel they are entering.

Clearly, Microsoft is trying to pull Software Assurance off life-support, but the CSP subscription alternatives are financially untenable. The institutional knowledge that the legacy Large Account Reseller (LAR) channel accumulated over 20-plus years of EA work doesn’t carry over into the latest pureplay CSP newcomers, and Microsoft has shown no urgency to close either the knowledge gap or the program gap with appropriate transition SKU tooling.

What Microsoft Built, and What It Didn’t

The MCA-through-CSP channel was designed for cloud-first customers buying SaaS subscriptions. For that population, it works adequately. For midsize enterprises with mixed estates — factory floor terminals running Windows by device, retail point-of-sale kiosks licensed for Microsoft 365 Apps per device and Office Standard LTSC licensing, Windows file and print servers covered by Software Assurance (SA), on-premises SQL Server with SA-enabled new version rights, Remote Desktop Services device CALs and the like — the channel has structural gaps that midsize customers will discover only after they sign.

Most CSPs cannot transact Software Assurance without side partnerships with resellers that sell Open Value or Microsoft Products and Services Agreement (MPSA)-type arrangements where SA and perpetual license-only purchases are still buying options. Per-device Microsoft 365 Apps for Enterprise, a SKU that legitimately exists for shared-device populations under the EA, does not exist in the CSP price list. From-SA pricing and step-up SKUs, both of which most midsize EA customers rely on, have no CSP equivalent. There is no annual true-up to reconcile usage uptick, and the order return window is five days.

These are not edge cases. They are the daily operational reality of the customers Microsoft is pushing into the channel.

In other partner ecosystems, such as Azure Expert Managed Service Provider (MSP), the Solutions Partner program, the AI Cloud Partner, Microsoft invests in partner enablement, technical certification, and ongoing assessment. For EA-to-CSP migration, there is no equivalent license knowledge certification. The work is being done, and the customers are being signed, but Microsoft has built no apparatus to ensure the quotes are accurate and compliant.

What This Looks Like in Practice

A recent advisory engagement involving a multinational client with thousands of users illustrates the consequences. The customer’s expiring EA was actually an EA-Subscription (EA-S), a less common cousin to the EA where even SA line items are purchased as ‘leased’ licenses, so no underlying perpetual licenses exist. Multiple quotes received by the customer from global systems integrators marketing themselves as EA-to-CSP specialists revealed two distinct flavors of compliance exposure, each traceable to a structural gap Microsoft has not closed.

In one approach, a CSP proposed continuing the customer’s SA line items through an Open Value agreement layered alongside the new CSP subscriptions, at a cost of roughly $982,000 in annual SA. But the proposal was non-compliant. EA-S is a rental construct in which no perpetual base licenses are ever acquired, so SA-only continuation is not a viable option. There were no base licenses to attach SA to, and Open Value could not manufacture them retroactively. Five material Teams line items were also omitted entirely, as if inconvenient or unavailable.

Had the customer signed, they would have paid nearly a million dollars for a benefit they could not legally exercise and would have entered the new term carrying a missing license component that a future Microsoft audit would value at approximately $3.9 million to cure.

In a second approach, a CSP regurgitated the customer’s existing EA-S bill of materials verbatim, attached CSP prices, and called it a quote. Among the line items was Microsoft 365 Apps for Enterprise By Device, which was the part name the customer had been using under their EA-S for shared worker kiosks. However, that SKU does not exist in the CSP price list even though it was parroted back on the quote. CSP allows Microsoft 365 Apps for Enterprise on a per-user basis only. Because the customer’s user population was roughly three times their kiosk device count, a per-user purchase sized to the device count would have left them short by thousands of user licenses, with an annual licensing shortfall exceeding $2.6 million once user provisioning outran the licenses ordered by device. The CSP return window is five days. After that, the order is final.

A third quote, from a legacy LAR-CSP, caught both issues, identified that SA could not be carried forward from an EA-S, flagged that per-device Microsoft 365 Apps for Enterprise has no CSP equivalent, and proposed a compliant, if more expensive, alternative structure. The LAR caught what the CSPs missed because the LAR channel still carries the institutional knowledge.

Unfortunately, LARs with this kind of expertise are becoming harder to find. Microsoft has systematically reduced LAR margins and incentives over the past several years, accelerating consolidation in a channel it once invested heavily in building. The knowledge exists, but the organizations that carry it are fewer in number and harder to access than they were a decade ago.

Your Four-Point Compliance Checklist

If your organization is in the midsize band and approaching an EA renewal that Microsoft will not offer, run the following checklist against every CSP quote you receive. A CSP that cannot answer all four in writing is not equipped to migrate your agreement.

On-premises servers and CALs. Inventory your Windows Server, SQL Server, Exchange Server, SharePoint Server, and Remote Desktop Services (RDS) deployments still running on-premises, and identify which are covered by SA. Pureplay CSPs cannot typically transact SA in-house. If you have a meaningful on-premises footprint, your CSP must partner with a LAR or you will need a parallel MPSA or Open Value Subscription. Keeping servers on a standalone Server and Cloud Enrollment (SCE) is also an option (often, not a great one). The quote should identify this explicitly.

Per-device licensing for shared workstations. Identify factory floor terminals, retail point-of-sale kiosks, call center hot-desks, or any other shared device population currently licensed by device. CSP offers Microsoft 365 Apps for Enterprise per user only. Confirm in writing how your CSP intends to handle this and what the cost differential looks like under per-user assumptions.

From-SA pricing and step-ups in your current EA. Review your EA Customer Price Sheet (CPS) and identify every line item priced with From-SA discounts or acquired via step-up. None of these constructs exist in CSP. Your CSP quote should explicitly identify replacement SKUs and acknowledge the price delta.

True-up posture and license position confidence. Assess how confident you are in your current license position. CSP has no annual true-up. There is no structured opportunity to clean up usage drift, and the order return window is five days. Your Software Asset Management (SAM) processes for license reconciliation and reporting must adapt. For midsize enterprises with on-premises sprawl, license position uncertainty is the default — commission a third-party software asset management review before you sign to consolidate, optimize and cross-check, not after.

What to Do Before You Sign

Treat the migration quote itself as a checklist .Ask every CSP candidate to respond to the four items listed above in writing, line by line, before any commercial discussion. A CSP that cannot answer them in detail is not equipped to migrate your agreement.

Remember: The audit exposure, the operational disruption, and the cost of curing problems introduced by the reseller all fall on you, not Microsoft and not the CSP. The onus has always been on the customer and the agreement says so explicitly.

Steve Kelley works with organizations to optimize their Microsoft licensing agreements and protect them from future licensing liabilities. Before joining Directions on Microsoft, Steven spent eleven years as president and CEO... more