Why Six Weeks Is Not Enough — But Is What You Have
The ideal Microsoft true-up preparation starts 12 months before your anniversary date, with continuous monthly licence hygiene creating a clean, well-documented deployment picture that takes the surprise out of your annual reconciliation. That is the governance model we recommend and build for every client. It is also not the situation most enterprise buyers are in when they first contact us.
Most organisations start true-up preparation when they receive the order form from their LAR — which typically arrives 4–8 weeks before their anniversary deadline. This guide is built for that reality. Six weeks is not enough time to fix structural governance failures, but it is enough time to identify and remediate the majority of avoidable true-up exposure and ensure your submission reflects your actual deployment — not Microsoft's preferred interpretation of it.
For organisations that have more time, start earlier and the same framework applies — you simply have more runway for the remediation work in Weeks 3–5. For organisations that have less than six weeks, prioritise the data gathering and stale account remediation phases above everything else. Those two steps typically recover 70–80% of addressable exposure even when compressed into two to three weeks.
Based on our advisory experience across 500+ engagements, organisations that begin formal preparation at least six weeks before their anniversary deadline consistently achieve lower true-up bills than those that respond reactively when the order form arrives.
Weeks 1–2: Data Gathering and Baseline Validation
The first two weeks of preparation are entirely about building an accurate picture of your current Microsoft deployment. You cannot manage what you have not measured, and you cannot dispute Microsoft's count without your own independently produced numbers.
Pull Your Complete User Population Data
From the Microsoft Entra ID admin centre (formerly Azure Active Directory), export the complete list of licensed users with their last sign-in date, licence assignments, and account status. You need three specific datasets: all users with M365 licences assigned (regardless of last activity), users with no sign-in activity in the last 30 days, and users whose accounts are marked "enabled" but have no sign-in in the last 90 days.
The 90-day no-activity cohort is your primary exposure reduction target. In a well-managed IT environment, 90 days without authentication typically indicates: terminated employees whose accounts were not disabled at offboarding, contractors whose projects concluded but whose accounts were not deprovisioned, and shared accounts used for specific processes that have since been automated. None of these should be included in your true-up count — but all of them will be, if you do not address them before submission.
- Export Entra ID licensed user list with last sign-in date
- Filter for 30-day and 90-day no-activity cohorts
- Cross-reference with HR system's active employee list
- Identify contractor and external user accounts separately
- Flag accounts belonging to entities not enrolled as EA affiliates
Pull Licence Inventory and Add-On Products
From the Microsoft 365 admin centre, pull the complete licence inventory report showing every SKU currently assigned across your tenant, the number of licences purchased vs assigned vs available, and the products included in each SKU that users have been enabled for. This report gives you two critical pieces of information: your current deployment count by SKU (which should match your planned true-up submission) and a list of every product currently active in your tenant — which you need to cross-reference against your EA coverage.
The add-on product cross-reference is the step most organisations skip. Take your EA order history (available from your LAR) and compare it against the admin centre's active products list. Any product in your tenant that is not explicitly covered in your EA baseline creates potential true-up exposure. Common discoveries: M365 Copilot enabled for selected users during an informal trial, Power Platform premium connectors activated without formal EA coverage, and Defender for Endpoint Plan 2 upgraded from Plan 1 without EA amendment.
Validate Your EA Baseline
Before you can calculate your true-up exposure, you need to verify what your EA baseline actually says. Retrieve your EA agreement documents and the most recent Amendment (if any) and confirm the committed quantity for each covered product. It sounds obvious — but in our advisory practice, we regularly encounter organisations where the LAR's true-up order form does not exactly match the client's EA documentation, typically because the LAR's system reflects a later amendment that the client was not aware had changed the baseline.
If there is any discrepancy between the order form baseline and your EA documentation, flag it immediately. Do not proceed on the assumption that the LAR's numbers are correct.
Weeks 3–4: Remediation and Exposure Reduction
Weeks 3 and 4 are your remediation window — the period in which you can actually reduce your true-up count before the submission deadline. The actions available to you depend on what the data gathering phase revealed, but the priorities are consistent across most enterprise environments.
Deprovision Accounts Before the Count Date
The stale account cohort identified in Week 1 is your highest-priority remediation target. Every account deprovisioned before your true-up submission date reduces your reported count by one licence — at whatever the per-user annual rate is for that licence type. For M365 E5 at approximately £500/user/year, deprovisionng 200 accounts before your submission date saves £100,000 in true-up exposure. The mathematics are straightforward; the execution requires coordination between IT operations, HR, and your access management team.
The standard process: export the stale account list to HR for confirmation of employment status. HR confirms terminations and live employees who happen not to have recently authenticated. IT processes licence removal for confirmed terminations and flags live employees for notification to reset authentication activity. The cycle time for this process is typically 5–7 business days in a well-coordinated team — which is why starting in Week 3 (not Week 5) is critical.
- Cross-reference 90-day no-activity list with HR confirmation of current employment
- Initiate licence removal for all confirmed terminations
- Notify "live but inactive" users to authenticate before the count date
- Process contractor account deprovision in coordination with procurement
- Document all changes with timestamps for your true-up working file
Decide How to Handle Out-of-EA Products
For each product identified in Week 1 as deployed but not covered by your EA, you have three options: remove the deployment before the true-up (eliminating the exposure), add the product to your EA through a formal amendment (creating a covered baseline), or accept the exposure and report it on your true-up (paying for the under-licensed period under whatever remediation terms apply).
The right choice depends on the product, the user count, and how strategically important the deployment is. M365 Copilot is a good example: if you have 50 users in an informal Copilot trial, the options are to turn off Copilot access for those users (removing the exposure but creating user disruption), formally add Copilot to your EA for those 50 users (normalising the exposure into an ongoing cost), or accept a true-up charge for the pilot period. Each option has a different commercial consequence — and the right answer is not always obvious without running the numbers.
Weeks 5–6: Submission Preparation and Order Form Review
The final two weeks before submission are for verification, documentation, and commercial review of the order form. This phase is where the commercial scrutiny needs to concentrate.
Build Your True-Up Working File
Before touching the LAR's order form, build your own true-up working file that documents your count for every covered product, the data source used for that count, any remediation actions taken during Weeks 3–4 and their impact, and any products where your count differs from Microsoft's system data and the reason for the difference. This working file serves two purposes: it gives you the confidence to submit a number you can defend, and it is your primary evidence base if any line item on the order form is disputed.
Review the Order Form Line by Line
When the LAR's order form arrives, review it systematically against your working file. Common discrepancies to check: baseline quantities that do not match your EA documentation (as discussed above); product descriptions that do not clearly map to a specific SKU in your EA (watch for generic "M365" entries that may aggregate multiple SKUs); and pricing that does not match the per-unit rates in your EA agreement. Each of these is a disputable position if you have your own documentation in order.
LARs and Microsoft account teams create urgency around true-up submission deadlines. The standard line is that late submission triggers penalties or affects your relationship standing. In our experience, the more significant commercial risk is signing an order form with errors under deadline pressure. If you need additional time to validate a line item, request an extension in writing. Microsoft has a documented process for good-faith extension requests — it is not well-publicised, but it exists and is exercised regularly in large EA negotiations.
2026-Specific Considerations
The 2026 true-up cycle introduces two specific complications that did not exist in the same form in previous years and that require additional preparation attention.
Copilot Deployment Tracking
For organisations that have deployed M365 Copilot — whether through formal EA commitment or informal trial — the true-up count must separately account for Copilot. Unlike core M365 SKUs, Copilot's deployment status can change rapidly: users can be assigned and unassigned Copilot access within your M365 Admin Centre without triggering a formal order process. Your Copilot count at the moment of true-up submission may differ significantly from your Copilot count at the start of the quarter if deployment has been actively managed. Pull a point-in-time Copilot licence assignment report on the date you intend to submit, not a rolling average. The Copilot annual true-up management guide provides the detailed Copilot-specific framework.
Power Platform Metered Service Reconciliation
If your organisation uses Power Platform premium connectors, Power Automate premium flows, or Copilot Studio agents with custom billing, Q1 2026 introduces a revised reconciliation process for these metered services that aligns their billing period with your EA anniversary date rather than a calendar month basis. This change simplifies the long-term reconciliation but creates a transition-year complexity for organisations whose EA anniversary falls in the first half of 2026. Work with your LAR to confirm how the metered service reconciliation will be handled in your specific renewal structure before your order form is issued.
After You Submit: Using the Data
Your true-up submission is not the end of the process — it is the beginning of your renewal preparation data-generation cycle. Immediately after submission, document your final submitted counts for every product, the date of submission, any discrepancies identified during the review process, and any informal agreements reached with your LAR regarding contested line items.
This documented true-up history — combined with the equivalent record from your previous anniversaries — is your most valuable asset going into renewal negotiations. It demonstrates your deployment reality to Microsoft with your own documented evidence, rather than leaving Microsoft's account team to define your "typical deployment" based on their data alone. For the full renewal leverage framework, the Complete Guide to Microsoft EA Negotiation and the true-up compliance guide cover how to convert three years of true-up data into renewal commercial position.
15-Item True-Up Preparation Checklist
Use this checklist to track preparation progress across the six-week sprint. Every item marked complete before submission reduces your exposure risk.
Weeks 1–2 (Data Gathering): Entra ID licensed user export with last sign-in dates completed; 30-day and 90-day no-activity cohorts identified; HR cross-reference of stale accounts initiated; M365 admin centre licence inventory report exported; add-on products in tenant cross-referenced against EA coverage; EA baseline quantities verified against original agreement documentation; LAR order form baseline compared against EA documentation for discrepancies.
Weeks 3–4 (Remediation): Confirmed terminations deprovisioned and licences reclaimed; contractor accounts processed with procurement confirmation; out-of-EA products assessed for removal vs amendment vs true-up reporting; live but inactive users notified to authenticate; remediation action log maintained with timestamps.
Weeks 5–6 (Submission): True-up working file completed with count, data source, and remediation actions for every product; order form reviewed line by line against working file; all discrepancies documented and either resolved or flagged for formal dispute; Copilot point-in-time snapshot taken on submission date; order form signed only after commercial review is complete.