M&A · License Assignment & Consent

How to transfer Microsoft licenses between entities: the 2026 assignment-and-consent playbook

By Fredrik Filipsson, Managing Director, Microsoft Negotiations

Published 2026-03-13 · Reviewed by the Microsoft Negotiations advisory team · Not affiliated with Microsoft Corporation

TL;DR

Transferring Microsoft licenses between corporate entities is governed by the licence transfer clauses of the Microsoft Business and Services Agreement (MBSA) and the Enterprise Agreement, plus the underlying Product Terms. Microsoft's default position is that volume licences are non-transferable except in narrow circumstances — intra-affiliate transfers, M&A transactions where the licences follow the assets, and Microsoft-approved assignments. The practical mechanic for entity-to-entity transfer is therefore a written transfer notice plus Microsoft consent, executed through the Microsoft account team via an amendment or a license-assignment letter. The transfer instrument matters: assignment carries forward existing terms; novation creates a fresh contract relationship with re-priced terms. The novation path is materially more expensive than assignment, so the buyer-side discipline is to position the transfer as an assignment unless novation is the only available path. This article covers the legal mechanics, the consent-seeking posture, the assignment-vs-novation distinction, the seven transfer scenarios that recur in practice, and the 2026 amplifiers that change the consent posture. For the M&A-specific transfer mechanic see the M&A license transfer article.

The starting position on transferring Microsoft licenses between entities: Microsoft's default contract language frames volume licences as non-transferable. The MBSA and the EA both restrict transfer of rights and obligations without Microsoft's prior written consent. In practice this default is permissive in narrow circumstances and restrictive in the rest. The narrow permissive cases are: (a) intra-affiliate transfers within the same EA-affiliate inclusion schedule, (b) M&A transactions where the licences follow the assets being sold, and (c) Microsoft-approved assignments documented in a written amendment or assignment letter. Outside these narrow cases, the buyer-side discipline is to engage Microsoft proactively, position the transfer as an assignment of existing terms rather than a novation, and structure the deal documents so Microsoft consent is a closing condition rather than a post-close hope.

Transfer Microsoft licenses: the seven scenarios that recur in practice

Seven entity-to-entity transfer scenarios recur. Each has distinct mechanics, consent posture, and pricing implications.

Transfer scenarioTypical mechanicMicrosoft consent posture
Intra-affiliate transfer (parent to subsidiary or sibling-to-sibling)Affiliate-inclusion schedule update; no formal transfer requiredSchedule update only; no consent needed beyond schedule confirmation
M&A acquisition (buyer absorbs target's licences)Written assignment letter as part of close documentsMicrosoft consent required; typically granted
Divestiture (target carves out licences to new owner)Assignment to buyer or termination-and-repurchaseMicrosoft consent required; typically granted but at re-priced terms unless negotiated
Spin-off (parent to SpinCo)Assignment to SpinCo as part of spin documentsMicrosoft consent required; new-logo pricing posture absent pre-negotiation
Internal restructuring (legal-entity reorganisation)Assignment letter plus updated affiliate scheduleMicrosoft consent required where the receiving entity is not on the existing affiliate schedule
Joint-venture formation (parent to JV entity)Assignment to JV with JV-specific affiliate scheduleMicrosoft consent required; JV-specific pricing negotiable
Receivership / insolvency transferTransfer to successor entity through bankruptcy court order plus Microsoft consentMicrosoft consent required; consent posture varies by jurisdiction and successor entity creditworthiness

Transfer Microsoft licenses: the assignment-vs-novation distinction

The instrument used to transfer the licences shapes the post-transfer commercial position. The distinction between assignment and novation is the single most important commercial decision in the transfer planning.

Instrument 1 · Assignment of existing agreement

Assignment carries forward the existing contract terms to the receiving entity

An assignment is a transfer of rights and obligations under an existing contract from one entity to another, without changing the contract terms. The receiving entity steps into the assigning entity's position. The existing pricing, discount tier, anniversary date, SA-coverage, and amendment history all carry forward. From the buyer-side perspective, assignment is the preferred instrument because it preserves the commercial position. Microsoft account teams sometimes propose novation where assignment is available because novation gives Microsoft an opportunity to re-price.

Instrument 2 · Novation (fresh contract)

Novation creates a new contract between Microsoft and the receiving entity

A novation terminates the existing contract and creates a new one with the receiving entity. The receiving entity is treated as a new commercial relationship. Pricing, discount tier, anniversary, and SA-coverage are all re-set. Microsoft account teams price novations at then-current list, often without grandfathering the prior discount tier. Novation is materially more expensive than assignment in most scenarios. Novation is appropriate only where the legal structure prevents assignment (e.g., the receiving entity is not yet established at transfer-decision time, or the assigning entity is being dissolved).

Instrument 3 · License assignment letter

The written instrument that documents an assignment

The license assignment letter is the written instrument that documents a transfer between named entities. The letter identifies (a) the assigning entity, (b) the receiving entity, (c) the licences being transferred (by SKU, count, agreement, and anniversary), (d) the effective date, (e) the basis for transfer (M&A, restructuring, spin-off, etc.), and (f) the Microsoft consent acknowledgement. The letter is typically prepared by the LSP or by the customer's licensing advisor and signed by all three parties (assigning entity, receiving entity, Microsoft).

Instrument 4 · Affiliate-inclusion schedule update

The mechanism for intra-affiliate transfers

Where the receiving entity is already on the existing EA's affiliate-inclusion schedule, no formal transfer is required — the receiving entity is already authorised under the EA. Where the receiving entity is not on the schedule but should be, a schedule update adds the entity. Schedule updates are the lowest-friction transfer mechanism but are only available within the affiliate-inclusion ambit. See the EA affiliates and subsidiaries article for the schedule mechanics.

Instrument 5 · Amendment to existing agreement

The omnibus instrument for complex transfers

Where the transfer requires changes beyond a simple assignment — new affiliate schedule, modified scope of licences transferred, partial assignment with retained entitlements — the cleanest instrument is an amendment to the existing agreement. The amendment specifies the transfer terms, the receiving entity's affiliate status, the licence-scope split, and any consequential changes (Unified Support tier, MACC, Copilot commitments). Amendments require Microsoft signature but are more flexible than assignment letters.

Microsoft consent is required for most entity-to-entity transfers. The posture used to seek consent materially shapes the outcome.

$4.6M / 3-yr
Anonymised 2025 license-transfer engagement: $2.4B-revenue technology services group performing internal legal-entity restructuring: existing operating entity (carrying the EA, 16,800 M365 E5 seats, $3.2M MACC, Advanced Unified Support) being merged into a newly formed holding company structure with three operating subsidiaries (8,400, 5,200, and 3,200 seat allocations). Microsoft account-team initial proposal: novate the existing EA into three new EAs at the three operating subsidiaries, with re-priced terms reflecting smaller-entity volume tiers. Proposal would have lost the Tier-B discount that the consolidated EA carried (subsidiaries each fell into Tier-C). Engagement re-architected the transfer: positioned as intra-affiliate restructuring with the holding company as named EA party and the three operating subsidiaries on a unified affiliate-inclusion schedule; assignment letter executed transferring the EA from the operating entity to the holding company without re-pricing; Microsoft consent obtained pre-close as a restructuring-document workstream rather than a post-close issue. Assignment instrument preserved the Tier-B pricing, the consolidated MACC at $3.2M / 3-yr, the consolidated Unified Support at the Advanced tier, and the consolidated SA-coverage benefits. $4.6M / 3-yr captured versus the novation trajectory Microsoft initially proposed, primarily from preserving Tier-B unit pricing on M365 SKUs and avoiding the Unified Support tier inflation that triple-novation would have triggered.

License transfer between entities? The assignment-vs-novation framing and consent posture are the leverage moves.

30-minute scoping call. License-transfer engagements are standard advisory work.

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2026 amplifiers shaping license transfer posture

Three 2026 dynamics change the license-transfer posture this cycle.

Amplifier 1 · EA tier-collapse amplifies the novation-vs-assignment gap

The EA tier-collapse pricing structure makes the cost difference between assignment (preserving an existing tier) and novation (re-priced at receiving-entity volume in the new tier grid) materially larger than at any prior cycle. The 2026 calculus favours assignment more strongly than the pre-2026 calculus did.

Amplifier 2 · CSP grace-period elimination creates secondary transfer scenarios

The CSP grace-period elimination of April 2026 creates new transfer scenarios for entities that need to move from CSP to EA / MCA-E mid-cycle to avoid the cancellation-fee posture. The transfer mechanics for CSP-to-EA mid-cycle migration are non-trivial; see the migration-planning angle below.

Amplifier 3 · Copilot & Agent 365 commitment portability

The Agent 365 framework and the Copilot Studio 2026 mechanism introduce new commitment instruments that have specific transfer-portability provisions. Where an entity transferring licences also carries Copilot or Agent 365 commitments, the commitment-portability mechanics should be addressed in the transfer instrument explicitly — Microsoft default position is that Copilot commitments are entity-specific rather than transferable.

Transfer Microsoft licenses: the pre-transfer discipline

The pre-transfer discipline determines the transfer cost. Six practices recur in mature pre-transfer planning.

Tactical Note

The single highest-leverage move in license transfer is to frame the transfer as an assignment of existing terms with no re-pricing, anchored in the EA's transfer clause and supported by the deal documents that establish the transfer basis. Microsoft account teams accept this framing where the customer is articulate and the deal documents are clear. Where the framing is unclear or the deal documents are absent, the default Microsoft position is novation with re-priced terms, which is materially more expensive. Independent advisory engages on license transfer as a discrete workstream that pairs with M&A close, restructuring, spin-off, or affiliate-restructuring engagements. The engagement typically runs 4-12 weeks depending on transfer complexity.

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Where to take the license-transfer discipline next

License transfer pairs with the broader M&A and restructuring framework. The M&A license transfer article covers the M&A-specific assignment mechanics; the M&A playbook covers the broader transaction context; the EA affiliates article covers the affiliate-inclusion schedule mechanic; the divestiture playbook covers carve-out transfer scenarios; the spin-off playbook covers SpinCo transfer scenarios; the post-merger integration article covers post-transfer combined-entity discipline; the EA negotiation pillar covers the broader contract context; the contract advisory service is the productised assignment-and-amendment engagement; the EA strategy service is the productised renewal-cycle engagement; the EA renewal checklist is the cadence guide. For organisations planning entity restructuring or M&A transfer, the scoping call is the direct engagement channel.

Primary · Engage

Run the license-transfer workstream

30-minute scoping call. Entity-to-entity assignment, restructuring, M&A transfer instruments.

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Secondary · Service

Contract Advisory Service

Productised assignment, amendment, and affiliate-restructuring engagement.

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Tertiary · Tool

EA Renewal Checklist

T-12 to T-3 cadence guide — adaptable to transfer-aligned renewal cycles.

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