Effective September 1, 2025, Microsoft updated its Product Terms to include Microsoft 365 Copilot Chat under Core Online Services and introduced terms for the EU Data Act. These changes impact data residency commitments and compliance obligations for customers using Microsoft Online Services.
On September 1, 2025, Microsoft:
- Added Microsoft 365 Copilot Chat to the list of Core Online Services under the section Location of Customer Data at Rest.
- Introduced EU Data Act terms to address data export, security, and transparency requirements.
These updates apply to customers under Microsoft’s Enterprise Agreement (EA), Enterprise Subscription Agreement (EAS), and related programs.

What is Microsoft 365 Copilot Chat?
Microsoft 365 Copilot Chat is an AI-powered chat feature integrated into Microsoft 365 services. It assists users by generating content, answering questions, and providing contextual support within Microsoft 365 applications.
Key Features
- Core Online Service Status
- Copilot Chat is now classified as a Core Online Service.
- Customer Data at rest will be stored within the geographic region where the tenant is provisioned (e.g., EU, US, UK).
- Data Residency Commitment
- Aligns with Microsoft’s existing commitments for Office 365 and other Core Online Services.
- EU Data Act Compliance
- New terms cover:
- Exporting Customer Data from Online Services.
- Security measures for protecting Customer Data.
- Transparency on government data access requests.
- ICT infrastructure requirements for EU Data Act Services.
- New terms cover:
Licensing
The inclusion of Microsoft 365 Copilot Chat as a Core Online Service does not change its licensing model but reinforces compliance and data residency obligations.
For detailed licensing guidance and to ensure compliance with these updates, consult SCHNEIDER IT MANAGEMENT for expert advice.
More Information
- Supporting Resources
- Data export guidance: https://aka.ms/customerdataexport
- Government access transparency: https://aka.ms/governmentaccessrequests
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