Microsoft Customer Attestation Enforcement: Partner Impact, and Recommended Actions

Microsoft is introducing major changes to how Microsoft partners confirm that their customers have accepted the Microsoft Customer Agreement (MCA). The objective is to standardize the attestation process, ensure traceability of customer consent, and align compliance expectations globally.

These updates have direct operational and technical implications for partners who transact through Partner Center or use the Partner Center APIs. This article summarizes the new enforcement model, associated technical changes, and practical guidance discussed during our recent “Microsoft Attestation Deadlines – Act Before Jan 2026” webinar.

Background: The evolution of customer attestation

Since the MCA’s introduction, partners have recorded customer consent using several Partner Center methods:

• Partner Center UI: manual attestation by the partner on behalf of the customer.
• Bulk Attestation Tool: CSV-based utility for batch confirmation.
• Partner Center APIs: programmatic interface for automated attestation.
• Direct customer acceptance: through the Microsoft 365 Admin Center.

The first two options, manual and bulk, often produced inconsistent data: incomplete signer information, limited audit trails, and region-specific variations that complicated compliance reviews.

To resolve this, Microsoft introduced the Enhanced Attestation API, a single, auditable framework enforcing explicit customer acceptance, standardized identifiers, timestamps, and status reporting.

Unlike manual or bulk approaches, solutions already integrated with Partner Center APIs, such as Work 365, are well positioned to comply quickly. Work 365’s API-based model is already working towards mirroring Microsoft’s new approach: automatically synchronizing acceptance records, validating agreement status, and maintaining an end-to-end audit trail within the partner’s CRM and billing system.

Key enforcement deadlines

After January 5, attestation becomes an API-only workflow; manual acceptance in Partner Center will be disabled.

Technical objectives behind the change

Microsoft’s goals:

1. Explicit customer consent — Partners can no longer attest on behalf of customers without them viewing the agreement.
2. Data integrity and traceability — Each acceptance receives a unique Attestation ID tied to the customer and timestamp.
3. Automation and scalability — API-driven acceptance eliminates regional manual variations and ensures consistent telemetry across CSP transactions.

Partners must ensure every customer record includes a valid Attestation ID synchronized with Partner Center via API.

Current vs. future process flows

Partner-asked queries

Recommended partner actions

1. Audit existing customers for pre-April 2023 attestations.
2. Migrate from manual/bulk tools to the Enhanced API.
3. Implement or update API integrations to capture Attestation ID, signer details, and timestamp.
4. Separate the Microsoft agreement from partner contracts, bundled acceptance no longer compliant.
5. Prepare for audit requests by mapping Work 365 agreement records to Partner Center IDs.

How Work 365 supports the transition

Work 365 integrates directly with Partner Center APIs and will support the Enhanced Attestation API ahead of the January 5 deadline.
Partners can:

• Generate and track attestation links with expiry dates.
• Sync acceptance data bi-directionally with Partner Center.
• Manage Microsoft and custom agreements in one system.
• Maintain an audit-ready history for compliance and reporting.

Strategic implications

Microsoft’s enforcement of API-based attestations represents more than a compliance update, it’s a systemic realignment of how partner operations function.

1. Ensure compliance is verifiable, not assumed.
2. Eliminate reliance on manual, partner-initiated processes that can’t scale or be audited.

For partners, this marks a major inflection point:

• Manual workflows and one-off tools are no longer sustainable.
• Microsoft’s API-first model assumes partners have integrated systems capable of automating customer data, agreements, and provisioning.
• Those without such systems will be limited to direct customer attestation only, losing operational flexibility and efficiency.

This is where Work 365 becomes foundational. By integrating directly with Partner Center APIs, Work 365 enables:

• Continuous compliance — every attestation, subscription, and billing event synced in real-time.
• Operational scalability — one unified process across customer agreements, billing, and provisioning.
• Audit readiness — a complete system of record for partner transactions and customer consent.

What is Work 365?

Work 365 is the leading billing and subscription automation platform for Microsoft Cloud Solution Providers (CSPs). Built natively on the Microsoft Power Platform, it connects directly with Partner Center to streamline every operational workflow, from customer provisioning and subscription management to billing, invoicing, payments, and compliance.

Partners use Work 365 to automate and unify their CSP business operations, replacing manual processes and siloed tools with one connected system that keeps Microsoft and partner data in sync. The solution provides:

• Automated billing and invoicing for license-based, usage-based, and one-time services.

• Direct Partner Center integration, ensuring all subscriptions, agreements, and transactions stay compliant with Microsoft requirements.

• Advanced contract and pricing flexibility to support NCE, multi-region, and multi-currency scenarios.

• Audit-ready records for revenue, provisioning, and customer attestations — critical for upcoming enforcement changes.

In short, Work 365 enables partners to scale their CSP business with confidence, maintaining continuous compliance and operational efficiency while aligning directly with Microsoft’s API-first, automation-driven model.

Conclusion

Microsoft is tightening compliance, but partners who modernize their systems will gain operational leverage. Those who don’t risk being left with manual processes that limit growth.

This transition to API-based attestations marks a definitive shift in the CSP program. It enforces a uniform compliance standard and requires every partner to modernize their attestation workflow.  Partners should treat this as a system migration project, not a policy reminder. Completing the move now ensures uninterrupted transactions when legacy interfaces retire on January 5, 2026.

Watch the full discussion here or reach out to our experts for more information!