
SAP Audit and Compliance Obligations in RISE Contracts: A Playbook for IT Leaders
How do SAP’s audit rights and compliance checks work for RISE customers? In short, moving to RISE with SAP (SAP’s bundled subscription offering for S/4HANA in the cloud) does not eliminate SAP’s license audits or compliance obligations – it changes their form.
SAP retains robust audit rights in RISE contracts, meaning it can still check that you’re using the software within agreed-upon terms.
Because SAP hosts the system under RISE, it has greater visibility into usage (e.g., user counts, activated modules, document creations) than in traditional on-premise setups.
RISE customers will be asked to address any overuse of licenses just as on-premise customers are, typically by adjusting subscriptions or paying for the excess. The bottom line is that RISE transforms SAP’s licensing model but does not shift the responsibility to customers to remain compliant.
This playbook explains the audit clauses to expect in a RISE contract, the unique compliance risks associated with RISE, and how to proactively manage and negotiate these obligations for CIOs, sourcing professionals, and IT leaders.
We compare RISE vs. on-premise audit terms, outline common licensing pitfalls (from unclear metrics to indirect use), and provide actionable guidance – from negotiating fair audit terms to setting up internal compliance monitoring and recognizing the red flags of an impending SAP audit.
The goal is to help you avoid surprises (“true-up shock”) and maintain control over your SAP licensing in the cloud.
In summary, RISE customers should treat license compliance as an ongoing discipline. Fewer metric types and a subscription model simplify compliance in some ways, but vigilance is still required to ensure you don’t exceed your contracted usage.
SAP’s Audit Rights in RISE Contracts – The Problem Statement
Even under RISE’s cloud-based model, SAP retains broad audit rights similar to those in traditional license agreements. The RISE contract’s audit clause typically grants SAP the right to perform license compliance audits on your usage of the cloud service.
This means SAP can require you to run usage measurement programs or provide system access/records to SAP auditors on request, to verify you haven’t exceeded your licensed quantities.
In practice, SAP’s dedicated license compliance team still periodically initiates audits (often on a ~1-2 year cycle) for RISE customers just as they do for on-premise customers.
These clauses are typically written in RISE contracts to state that SAP may audit your environment, provided reasonable notice is given, typically during normal business hours, and that you are obligated to cooperate fully.
For example, the contract might state SAP can access usage logs or ask you to produce reports to validate that user counts, third-party interfaces, and transactions are within permitted levels.
You may be unable to eliminate this clause (SAP will insist on its audit rights), but managing it through negotiation is crucial (more on that in the Playbook section).
The contract may also include language requiring the customer to self-report any overuse that is not automatically tracked; in other words, you might have to certify compliance periodically.
Risks under RISE:
Many customers mistakenly think a subscription means “all-you-can-use” – but RISE subscriptions are bounded by specific metrics (like number of users, or cloud resources). If an SAP audit (or SAP’s monitoring) finds you exceeded those bounds – e.g., you created more user accounts than you paid for, or an external system integrated without proper licensing – it’s a contract breach requiring remediation.
SAP can require you to purchase additional subscriptions or services to cover the excess, often with an immediate budget impact. In worst cases, non-compliance could even threaten your system access (since in a cloud model, SAP can enforce limits or suspend service for serious breaches).
Moreover, SAP’s enhanced visibility in RISE can make compliance issues more apparent without a formal audit. Because SAP manages the RISE cloud environment, it can potentially see your user counts, activated modules, and digital document volumes in real-time.
This constant oversight means compliance checks can be continuous—you might be alerted to an overage or asked to true up before a formal audit occurs. The risk for customers is assuming that “nobody is watching.”
In reality, SAP will enforce the contract. Without careful license management, you may face an unexpected true-up bill or a forced subscription increase if SAP detects overuse.
This is the new paradigm: SAP’s audit rights are alive and well in RISE, backed by technical insight into your system.
Key Challenges for RISE Customers in Staying Compliant
RISE may simplify some licensing aspects, but customers still face several compliance challenges:
- Unclear Licensing Metrics: RISE introduced new metrics, such as Full User Equivalents (FUE), for user licensing, which aggregates different user types into a single unit. Many sourcing teams initially find FUEs confusing – e.g., how many “light users” equal one FUE? What about developer users? Misunderstanding these metrics can lead to underestimating usage. Obtaining clear definitions for all RISE metrics (users, digital documents, storage, etc.) in your contract is critical. If metrics aren’t crystal clear, you risk inadvertent non-compliance due to ambiguity. For instance, if your contract doesn’t explicitly list a particular SAP module or service, assume it’s not included – using it would violate terms.
- Complex License Constructs Persist: RISE bundles core ERP and some services in a subscription, but it doesn’t eliminate complexity. You might still have separate entitlements for certain Line-of-Business (LoB) solutions, add-on modules, or SAP Business Technology Platform (BTP) services. Customers often struggle to determine which components are covered by the base RISE subscription versus those that require add-on licenses. Overlooking a component (e.g., using an SAP industry solution or an additional SAP cloud product not included in your RISE order form) can create a compliance gap. The Digital Access licensing for indirect use is a prime example (see below) – it’s usually not automatically included in RISE and needs separate attention.
- Overdeployment and “Usage Creep”: The ease of cloud provisioning in RISE can ironically increase the risk of overdeployment. In on-premises systems, adding new users or spinning up a new instance can be a slow process; under RISE, an admin can create dozens of new user accounts or activate a new functionality in minutes. Without strong internal controls, you might exceed your licensed counts before you realize it. For example, if you have 500 FUEs contracted and your IT team keeps adding users for new hires or testers, you could quietly drift to 550 FUEs in use. This “creep” is dangerous – SAP will eventually catch it and require a subscription expansion. Named user compliance still matters: even though FUE pools simplify user licensing, you must monitor the number of active users and ensure it stays within your paid allotment. Similarly, if your RISE contract caps things like storage, CPU, or SAPS, watch those usage levels (SAP can enforce caps or charge overages for exceeding infrastructure parameters).
- Named User Classification & Recycling: In traditional licensing, customers had to classify users as Professional, Limited, Employee, etc., which caused compliance headaches. RISE’s FUE model largely bundles those categories, but proper user management is required. Mismanaging user roles can waste FUE capacity or lead to non-compliance if you try to assign access in ways outside your entitlement. For instance, developer users might count as 2 FUEs each – if your team unnecessarily gives a lot of people high-level access, you’ll burn through your FUE quota faster than expected. Also, RISE doesn’t remove the need to deactivate or reassign licenses when employees leave – dormant accounts still count toward your usage. Keeping user counts accurate (and reclaiming licenses from departures) is essential to staying compliant and cost-efficient.
- Indirect Use and Third-Party Access: One of the trickiest areas is indirect access, which occurs when third-party systems or external users interact with SAP through its interfaces. In on-prem environments, this was infamously highlighted by SAP’s lawsuit against Diageo (for Salesforce-to-SAP integration). Under RISE, indirect use remains a concern. You must be properly licensed if non-SAP applications (e.g., an e-commerce platform, CRM system, or IoT devices) create or retrieve SAP data. SAP’s preferred solution is Digital Access (document-based licensing), where you purchase licenses for the number of documents created by external systems. RISE subscriptions do not automatically include unlimited digital access; customers must typically add a Digital Access Document Pack or a similar option to cover this. If you ignore indirect usage, an audit could reveal millions of document postings from your e-commerce site and hit you with a huge bill. A lack of visibility compounds this challenge – business units might set up new interfaces without informing IT asset managers. It’s imperative to inventory all third-party integrations with SAP and ensure they’re licensed (or formally exempt) upfront.
- Digital Access (Document Licensing): As a subset of indirect use, the Digital Access model charges for documents generated (such as sales orders and invoices) based on external inputs. Customers often find it unclear which documents count and how to estimate volumes. Under-licensing poses a significant compliance risk here. In a RISE context, SAP has technical means to track digital document creation (since they host the system). This means SAP could potentially warn or audit you if your interfaces created 100,000 sales orders but you only licensed 50,000. The onus is on you to negotiate sufficient digital access upfront or monitor usage closely. Unlicensed digital documents are a classic “stealth” compliance issue that can snowball if not addressed. Make sure your RISE contract explicitly covers your expected document volume, or be prepared to purchase additional document packs as needed.
- BTP Services and Other Consumables: RISE often comes with credits for SAP BTP (Business Technology Platform) services or other cloud services. Using more than the included amounts isn’t a compliance violation per se (SAP will generally just charge you for overages), but it can become a nasty financial surprise. If you treat BTP like an unlimited buffet, you may incur unforeseen costs. There’s also a risk that your RISE agreement does not cover certain advanced BTP services by default. Always check which specific services or limits are included. Treat BTP usage like a compliance item: regularly monitor your consumption against the included credits to ensure compliance. If you see you’ll exceed the prepaid volume, rein it in or proactively negotiate an extension with SAP (preferably at a better rate than pay-as-you-go). This proactive approach prevents a scenario where SAP returns later with an exorbitant bill for exceeded BTP usage.
In summary, RISE customers must navigate a range of old and new licensing challenges. The metrics and packaging differ from traditional SAP, but you must prevent user overuse, manage indirect access, and stay within contractual limits.
Many companies moving to RISE find it valuable to retrain their license management teams on the new model and even engage specialist advisors to navigate these complexities.
RISE vs. Traditional On-Premise Audit Terms – A Comparison
How do audit and compliance terms differ between the new RISE model and the classic on-premise SAP contracts? The following table summarizes the key differences and similarities:
Aspect | Traditional On-Premise SAP | RISE with SAP (Cloud) |
---|---|---|
Audit Clause & Rights | SAP reserves right to audit license compliance (usually via contract clause allowing annual audits). Customer must run measurement tools (e.g. SAP USMM/LAW) and provide data to SAP auditors on request. Audits cover all deployed SAP software and users. | SAP retains audit rights in contract, similar scope. Additionally, SAP can directly access usage data in the cloud service. Contract may explicitly allow SAP to pull usage logs or reports. Customer still obliged to cooperate with any formal audit process. |
Audit Frequency & Notice | Typically audits every 1-2 years; SAP provides notice (often 30 days) before sending scripts or auditors. Frequency can vary, but large customers are regularly on a cycle. | Similar cadence (SAP can audit periodically), but some compliance checks may be ongoing via system monitoring. It’s wise to negotiate specifics: e.g. at most one audit per year with 30 days notice, no audits in first year of go-live, etc. (if you can get those terms agreed). |
SAP’s Visibility into Usage | Limited direct visibility – SAP relies on customer-provided data (LAW reports, user lists) to assess compliance. They do not automatically see how many users or which transactions you’re running on-prem. | Much greater visibility – since SAP or its cloud infrastructure hosts the system, SAP can technically observe user counts, active modules, and even document counts in real time. This doesn’t mean they are constantly spying on you, but SAP could detect obvious overuse (like way over the licensed users) even outside formal audits. |
Compliance Focus Areas | Broad: user license counts by type, package/engine usage (CPU, SAPS, GB of HANA, etc.), indirect access instances, and whether any unlicensed SAP products are installed. On-prem customers had to track many separate metrics. | Narrower core metrics: primarily total FUEs (user equivalents) and any explicitly licensed add-ons or services. Many traditional engines are bundled into the subscription. However, any services outside the bundle (extra LoB modules, third-party interfaces requiring digital access, additional cloud services) remain in scope for compliance. Indirect usage and document counts are still policed in RISE. |
Handling Overuse | If audit finds usage beyond entitlement (e.g. more users, or an engine used without a license), SAP issues a formal compliance notice. Customer must purchase additional licenses plus back maintenance for the period of overuse, often within a tight timeframe. In some cases, SAP could impose list price or penalties, making true-up costs significant. | If SAP finds you exceeded subscribed metrics, you’ll be required to upgrade your subscription or buy extra capacity. Since RISE is subscription, there’s no “back maintenance,” but you may have to pay for the overuse retroactively from when it occurred (depending on contract terms). Often, SAP will simply adjust billing going forward to a higher tier. Extreme or sustained overuse could lead SAP to enforce technical limits (e.g. prevent adding more users) or treat it as a breach. |
Customer’s Responsibilities | Maintain records of usage, run SAP measurement programs, and ensure all users are licensed appropriately. Must report and rectify any shortfalls. Essentially, the onus was on customers to self-police and be audit-ready with data. Failure to cooperate with an audit could lead to breach of contract. | Largely the same responsibilities: even if SAP can see some data, you are expected to manage your user licenses and usage internally and stay within contract limits. You may be contractually required to periodically certify compliance or allow SAP to deploy monitoring agents. Cooperation in audits is mandatory. One slight benefit: fewer license categories to track (thanks to FUE simplification), but you must actively monitor those few key metrics (user counts, document counts, etc.) on your side. |
Key Takeaway: RISE doesn’t remove SAP’s ability to audit or your obligation to comply—it alters the mechanics. You face fewer granular metrics than on-prem, but SAP’s auditing may feel even more stringent given its direct cloud access.
Always review the audit clause in a RISE contract as carefully as you would in an on-prem deal. Ensure you understand what SAP can check and how overages will be addressed.
Common Compliance Risks: On-Premise vs. RISE
Certain compliance “hot spots” persist in the RISE era. Below is a comparison of common risk areas and how they manifest differently between traditional licensing and RISE:
Compliance Risk | On-Premise Scenario (Classic SAP) | RISE Scenario (Subscription Model) |
---|---|---|
Exceeding User Licenses | Purchased Named User licenses (e.g. 500 Professional, 300 Limited). Risk if actual named users exceed those numbers or if users shared accounts. | Contracted for X FUEs (aggregated users). Risk if total active user count (weighted by usage type) exceeds FUE entitlement. Easier to add users in cloud, so need strong tracking. No user-sharing allowed here either. |
User Classification | Users misclassified to cheaper license types (e.g. giving a heavy user a “Limited” license). Audits would re-classify and find shortfall. | FUE model removes explicit user categories – one pool covers all types. This avoids classic misclassification issues. However, wasting FUEs on very high-privilege accounts or idle accounts can effectively cause overuse. License administration focuses on not exceeding total FUEs and using the flexibility wisely. |
Indirect Access (Third-Party Systems) | External systems (CRM, webshop, etc.) reading or writing SAP data without proper licenses. Huge controversy in on-prem world; often addressed either by extra named user licenses for external users or by SAP’s Digital Access (documents) licensing. | Still a concern: if a third-party app integrates with your RISE system, those interactions must be licensed (usually via Digital Access). The difference: SAP can potentially monitor document creation via these interfaces since it’s their cloud. If you haven’t licensed this, you could get a compliance notice. Mitigation is to include sufficient digital access usage in your RISE contract or explicitly discuss and document allowable integrations. |
Digital Documents | Under Digital Access model, on-prem customers buy packs of, say, 100K documents. If an audit finds 150K sales orders generated indirectly, you’d owe for an extra 50K (plus maintenance). Some customers lacked insight into their own document counts until audited. | RISE customers also need Digital Access packs (unless by rare chance SAP bundled it). If you exceed your purchased document count, SAP will charge for more. The cloud environment may provide more immediate data on document counts, so you should actively track documents created by external inputs. The risk of surprise bills remains if you “ignore” this area. Always anticipate document volume when planning RISE licensing. |
Unlicensed Modules/ Engines | A team activates an SAP module (e.g. SAP CRM, HR, or an industry solution) that wasn’t licensed, or exceeds a licensed capacity (like HANA memory beyond licensed GB). Audits catch these because LAW reports list all active modules and capacities. | RISE contracts list all included SAP products/services. If you use something not in the contract, it’s unlicensed – though technically SAP controls what is deployed in cloud, so this mainly arises if you negotiate additional components mid-term without updating the contract. Also, most technical “engines” (HANA DB, etc.) are bundled into RISE sizing, so classic engine overuse is less common. The remaining risk is deploying additional SAP cloud services (or significantly increasing system size) without proper licensing – which would require a contract adjustment. |
Infrastructure Overuse | (For on-prem or IaaS customers) Using more hardware, CPUs, or memory than licensed (especially for licensed HANA or Oracle processor metrics). Could trigger licensing of additional cores, etc. | In RISE, infrastructure is part of the subscription. If you require more system resources (e.g. move to a bigger instance for performance), SAP will treat it as a scope increase and charge accordingly. Often, they won’t let you exceed contracted capacity without formally upgrading your subscription. But watch out for storage limits or user counts – exceeding those may not immediately stop your system, but will show up in SAP’s reports and be chargeable. |
Key Takeaway: Many of the same risk areas exist in RISE (e.g., user counts, indirect use), but the methods for measuring or enforcing them can differ.
RISE simplifies user licensing via FUEs and bundles infrastructure, reducing certain classic compliance headaches (like juggling dozens of license types or DB licenses).
However, indirect access and usage overages remain the top risks, now with SAP’s cloud insight making it easier for them to detect issues.
Customers should proactively address the following areas: managing user counts and roles, including indirect usage in planning, and monitoring any limits outlined in the RISE agreement.
Audit and Compliance Playbook for RISE Customers
To manage SAP audit obligations and maintain compliance under a RISE contract, organizations should adopt a proactive and structured approach.
Below is a playbook of actionable steps and strategies:
- Negotiate Fair Audit Terms in the RISE Contract: Don’t accept SAP’s audit clause at face value – you can (and should) negotiate its parameters for clarity and fairness. While you likely cannot remove SAP’s right to audit, you can add conditions to the audit process. For example, insist on at least 30 days’ written notice before any audit. Define that audits should occur at most once per year (no constant disruptions). If you’re early in your RISE journey, you might consider negotiating no audits in the first year post-go-live, allowing the system to stabilize without compliance scrutiny. It’s also wise to stipulate that SAP must conduct audits to minimize business disruption (e.g., remote data gathering, no excessive on-site presence) – mirror the standard language “audits will not unreasonably interfere with Customer’s business operations.” Another negotiation angle is focusing on transparency instead of surprise: you could request that SAP provide you with regular license usage reports or dashboards (since they can see your usage) so that you can self-correct any growing compliance issues.In some cases, customers have negotiated the right to perform a self-audit and self-report annually – essentially implementing a formal true-up process rather than an ambush audit. If possible, obtain a clause that providesa short cure period (30-60 days) to remediate any compliance gap before SAP takes further action. This way, if an audit finds you need 50 more users, you can buy them at normal rates, rather than facing penalties. All these contract tweaks create a more reasonable audit framework: SAP’s interests are protected, but you gain predictability and the opportunity to addressissues collaboratively.
- Maintain Continuous License Compliance Governance: Treat SAP license compliance as a continuous process, not a one-time true-up. The organizations that fare best in audits are those that routinely conduct internal audits. Establish a governance practice (often via your SAM – Software Asset Management team or IT asset managers) to review SAP usage monthly or quarterly. Key activities should include: running SAP’s license measurement tools (like USMM and LAW for on-prem – and for RISE, check what equivalent user reports or admin metrics are available) to track user counts against your FUE subscription; monitoring creation of digital documents if you have external interfaces (SAP may provide tools or logs for digital access measurement – use them proactively); and tracking consumption of any limited metrics (e.g. if your contract has a cap on peak users, or uses of a component). By doing these checks regularly, you can spot trends – e.g., user count creeping up toward your limit – and take action before SAP’s official audit or system alert. This internal oversight should be baked into IT operations. For example, some companies make it a policy that whenever a new project wants to integrate a third-party app with SAP, the architecture team must first approve the license implications. Another best practice is to hold a quarterly compliance review meeting between IT, the SAP basis team, and procurement/licensing specialists to review usage vs. entitlements. In these meetings, compare current metrics to what’s contracted and decide if any cleanup (like deleting unused user accounts) or contract adjustments are needed. Consistent internal monitoring ensures you’re never blindsided and can turn audits into mere formalities.
- Utilize Tools and Audit-Readiness Strategies: Leverage available tools to facilitate license compliance. SAP provides several built-in reports for user counts, engine usage, and the License Administration Workbench (LAW) aggregator – ensure your team is familiar with how to use these. Third-party SAP license management tools (from vendors like Snow Software, VOQUZ, etc.) can automate monitoring of SAP license usage and even optimize user classification. In an RISE environment, inquire with SAP about cloud analytics or portals that display your consumption (for example, a usage analytics dashboard for your S/4HANA Cloud tenants or a BTP usage meter). Automating these checks can alert you to anomalies (e.g., a spike in documents created, or a bunch of new users added by a department).Additionally, prepare an audit response plan in advance. Identify an internal “license compliance manager” or team who will interface with SAP if an audit notice comes. Have all your SAP contracts and entitlements organized and accessible. You should maintain a “license inventory” document that lists your current allowed user count, packages, and special terms. If SAP’s audit team claims a compliance gap, you can quickly cross-check their findings against your understanding. Being organized and audit-ready can significantly shorten the audit process and even allow you to challenge any incorrect findings from SAP (yes, SAP’s scripts or assumptions can sometimes be wrong). Part of your playbook might even include conducting a mock audit periodically with the help of an independent licensing consultant – they can leverage their experience to identify any weak spots before SAP does.
- Monitor Usage Monthly & Track Key Metrics: As an ongoing operational task, establish a monthly (or at least quarterly) review cadence to assess key license metrics. Some critical things to watch: Active user count vs. FUE purchased – if you’re at (or over) 100% utilization of your FUEs, it’s a red flag. If you’re at 90%, start planning whether to archive some users or budget for more FUEs, because business growth could push you over. Document counts for Digital Access – if you have a known integration (e.g., your Salesforce creating orders in SAP), track how many documents are generated monthly. Compare it to the number of documents you’re licensed for (if you bought 1 million documents/year and have already reached 900k in Q3, you either need to curb usage or purchase more capacity). BTP credits consumption – check the usage reports for BTP services included in RISE; early in the month, verify you’re not exceeding the allotment, and forecast if you might by year-end. Additional SaaS services – if you have any SAP cloud services as part of RISE (e.g., SAP Analytics Cloud users included, or Ariba/SuccessFactors modules bundled), monitor their user counts or transactions similarly. Keeping an active scorecard of these metrics transforms compliance from a scary unknown to a manageable KPI. Some companies integrate these checks into their ITSM or monitoring systems – for example, sending an alert if someone attempts to create a user that would exceed the license count. (Some RISE systems might allow creation beyond the limit, while others might not – but don’t rely on a hard stop.) The mantra is: “What gets measured gets managed.” If you treat license usage data like vital operational metrics, you can correct the course in time and avoid compliance issues.
- Watch for Red Flags of an Impending Audit: Often, there are telltale signs that SAP is gearing up to review your compliance. Knowing these can give you a head start. Unusual inquiries from SAP are one sign – for example, if your SAP account executive or cloud success manager starts asking about how many users you have active, or how you’re using a certain feature, out of the blue. They might be gathering info or hinting that your usage looks high. Similarly, if you receive an email from SAP’s Global License Compliance team (formerly known as GLAC, now sometimes GAILC) asking you to run an SAP measurement program or to “verify your user count,” treat that as an audit notice in disguise. Another red flag is if SAP offers to do a “license optimization session” or suggests using their License Utilization Information (LUI) application to review your consumption. While pitched as a helpful service, it often precedes a compliance discussion. In the RISE context, if you see any system messages or notices in your SAP admin portal about usage limits (for example, a warning that you’ve hit 100% of licensed storage or have more named users than licensed), expect SAP to follow up. Additionally, towards the end of your contract term, SAP may scrutinize your usage to set the stage for renewal negotiations. If they notice overuse, they will certainly bring it up. Finally, be mindful of quarter-end or year-end timing: SAP’s sales teams have targets and sometimes leverage audits to drive sales. If you’re approaching Q4 and haven’t been audited in a while, be extra prepared – there’s a chance SAP will initiate a compliance check, hoping to close a supplemental deal by year-end. By recognizing these signals, you can proactively engage or rectify issues before the formal audit hits. For instance, if SAP requests user counts, double-check them yourself and clean up any obvious excesses immediately, then respond with confidence. It’s much better to address a red flag on your terms than under the pressure of an official audit clock.
- Foster a Compliance-Aware Culture: Although it’s a softer measure, it’s still important. Ensure your IT and business teams understand that SAP licenses are not unlimited, even in the cloud. Train administrators and project managers to consider the impact of licensing when expanding usage. For example, if HR wants to onboard a new group onto SAP, someone should ask, “Do we have enough licenses for these users?” If a development team wants to integrate a new app with SAP, they should involve the licensing team to check the implications of indirect access. Embedding this awareness in your processes prevents many compliance issues at the source. Make someone (or a team) formally accountable for SAP license compliance within your organization; this role should have visibility into changes in the SAP landscape (such as upgrades, new modules, or new integrations) so they can make preemptive adjustments to contracts or licenses. When compliance is part of the company DNA, audits become non-events.
By following this playbook—negotiating fair terms, staying proactive with monitoring, utilizing the right tools, and looking out for warning signs—RISE customers can significantly reduce the risk of an unexpected compliance issue.
Remember, SAP audits are only as scary as your level of preparedness. If you’re consistently on top of your usage and entitlements, an audit should confirm what you already know.
Real-World Examples from RISE Compliance Experiences
- Excess Document Usage Caught in Audit: A global manufacturer on RISE learned the hard way about indirect usage. They had integrated a third-party e-commerce platform with S/4HANA to automate online orders. Over a year, this interface generated hundreds of thousands of sales orders in SAP. The company hadn’t purchased sufficient digital access licenses for these documents, assuming (incorrectly) that RISE’s subscription covered it. When SAP conducted a compliance check, it identified roughly 100,000 unlicensed documents created via the external system, resulting in a substantial bill for additional Digital Access licenses. This example echoes the famous Diageo incident (where SAP sought £54M for unlicensed Salesforce interactions). Lesson learned: Indirect usage is very real under RISE. The company has since negotiated a fixed document allowance into their contract and implemented monthly tracking of document counts to avoid any repeats. It’s far cheaper to license expected documents up front than to pay for them retroactively after an audit.
- Optimizing User Licenses Before RISE Migration: In another case, a large enterprise preparing for RISE took the opportunity to audit its user licenses during negotiations. They discovered many inactive users and duplicate accounts in their legacy ECC system. By cleaning this up and right-sizing user roles, they determined they needed fewer FUEs than initially estimated. For example, one company’s internal assessment reduced the required FUE count by 227 units, resulting in significant RISE subscription cost savings. They negotiated the RISE contract based on this lower number, rather than SAP’s higher quote, saving an estimated 15% on subscription fees. Lesson learned: Always baseline your usage and optimize license counts before signing a RISE contract. Shelfware and over-licensing are common – if you don’t pinpoint them, you’ll overpay in a subscription model. Regular internal user activity audits can reveal opportunities to drop unused licenses and avoid paying maintenance or subscription fees for idle users.
- Negotiating a “No-Penalty” True-up Clause: A Fortune 500 company shared a best practice from their RISE negotiation: they included a 60-day cure period for compliance issues. If an audit (or SAP’s monitoring) finds that they have exceeded a metric, the company has 60 days to purchase additional licenses at the pre-agreed pricing, with no penalties. For instance, when an unexpected business unit expansion pushed 50 users over their limit, they could true-up those 50 FUEs at the standard rate during the grace period, avoiding compliance fines. This kind of clause is not standard, but they achieved it by leveraging a competitive situation and insisting on fairness in the contract. Lesson learned: Pushing for reasonable remedies (like a grace period or pre-set pricing for extra licenses) can transform the audit experience. It turns a punitive scenario into a normal purchasing exercise. While SAP won’t volunteer such terms, savvy customers with bargaining power have secured them. This demonstrates the importance of solid procurement negotiation – audit clauses can be made more customer-friendly if you ask.
- SAP Proactive Compliance Partnership: Not all examples are adversarial. One mid-size tech company on RISE took a collaborative approach by engaging an independent licensing advisor to do annual compliance health checks. They would preemptively share a summary of this internal audit with SAP each year. SAP agreed not to formally audit them during those years as long as no major discrepancies arose. Essentially, the customer showed good faith by policing themselves, and SAP focused on selling value rather than hunting for compliance gaps. This informal arrangement maintained a positive relationship and prevented surprise audits. Lesson learned: Transparency and proactivity can sometimes dissuade SAP from aggressive auditing. If you demonstrate control over your licensing position, SAP may concentrate elsewhere. Of course, this approach depends on the account team and your risk appetite. Still, it underscores that compliance doesn’t have to be combative – it can be managed as a routine business-as-usual process with open communication.
(All examples above are anonymized composites of real-world scenarios to illustrate common issues. They highlight how mismanaging compliance can lead to serious costs, while good practices and negotiation can save money and headaches.)
Recommendations for Sourcing and IT Leaders
To conclude, here are actionable recommendations and best practices for sourcing professionals, CIOs, and IT leaders dealing with SAP RISE audit and compliance obligations:
- Embed Audit Protections in Your Contract: During RISE negotiations, prioritize adding clear audit clause protections—e.g., requiring a notice period, limiting audit frequency, and including a cure period to remedy any findings. Nail down how metrics will be measured and disputes resolved in writing. This sets the tone for a fair compliance process rather than a surprise ambush.
- Inventory and License All Usage Upfront: Before signing a RISE deal (and periodically thereafter), take a complete inventory of your SAP usage. Count the number of named users, categorize their usage levels, map out every third-party system interfacing with SAP, and estimate document volumes. Use this to negotiate the right number of FUEs and digital access licenses. Don’t leave known usage unlicensed – if you need an integration or module, get it included or at least acknowledged in the contract to avoid future disputes.
- Monitor Key Metrics Continuously: Make SAP license compliance a continuous and ongoing discipline. Track user counts, transaction volumes, and other key metrics monthly. If you approach a threshold (e.g., 90% of licensed users or documents), immediately clean up inactive users, consider purchasing additional capacity, or warn the business to slow down on that metric. Ongoing monitoring is your early-warning system to prevent breaches.
- Establish Strong Internal Governance: Assign clear ownership for SAP license management. This team or individual should regularly review usage, coordinate any needed true-ups, and maintain compliance documentation. Integrate license checks into IT change processes – e.g., a new integration can’t go live without a license impact assessment. Governance and awareness across IT and procurement will catch issues that pure tools might miss.
- Take Advantage of SAP Tools and Third-Party Expertise: To get accurate data, utilize SAP’s tools (LAW, System Measurement reports, etc.). Additionally, consider engaging third-party license optimization services or consulting with software asset management experts before major events, such as contract renewals or expansions. An expert review can uncover hidden compliance risks or identify areas to save costs (like removing unused users). Expert help is often far less expensive than a surprise true-up bill.
- Plan for Worst-Case Scenarios: Hope for the best, but plan for the worst in compliance. What if an audit finds a shortfall? Have a contingency budget or approval process ready to handle a required purchase quickly, so it doesn’t become a fire drill. Additionally, maintain open communication channels with your SAP account team. If you suspect a compliance issue, it is sometimes better to address it proactively with them and negotiate a reasonable solution than to wait for an official notice. Showing that you take compliance seriously can also build goodwill with SAP.
- Leverage Compliance as Negotiation Currency: Remember that compliance can be a strategic lever. If SAP identifies an issue, you might use that moment to negotiate better terms or a transition. For example, rather than just paying a penalty for overuse, you could roll that into an upgraded RISE package or additional products at a discounted rate. Conversely, if you’re fully compliant and SAP wants you to expand your footprint, you’re negotiating from a position of strength. When expanding or renewing, use your clean compliance record to ask for concessions (like more flexible terms or discounts). A well-managed compliance posture gives you options – you avoid being backed into a corner and can engage with SAP on your terms.
By following these recommendations, organizations can turn SAP’s audit and compliance requirements from a source of anxiety into a well-managed aspect of their SAP relationship.
In the cloud era with RISE, diligence and preparation are your best defense. Stay informed, stay vigilant, and make compliance a routine – this will ensure that audits are uneventful and your SAP investments deliver value without unwelcome surprises.