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The SPLA Audit Defense Field Guide

A buyer side field guide to surviving a SPLA audit, written for the operations, compliance, and finance leaders at hosting providers, managed service providers, and ISVs. It covers the 36 month lookback, the SPUR, monthly SAL reporting, and how to separate the non negotiable back fee from the negotiable penalty uplift.

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What is inside

Six to ten pages of substance, no filler, built from the 2026 SPLA audit landscape.

SPLA is Microsoft's monthly licensing program for hosters and outsourcers that deliver Microsoft software to external customers. It is pay as you consume, and compliance is verified for every monthly reporting cycle across a 36 month lookback. A Big Four firm conducts the audit under the MBSA audit clause with broad authority to request deployment records, server configuration data, customer contracts, and usage logs. This guide shows you how to be ready and how to defend when the letter arrives.

  1. How a SPLA audit is triggered and how it runs
  2. The 36 month lookback and why every month matters
  3. Applying the SPUR correctly, SAL and processor counts
  4. The defensive value of monthly reporting discipline
  5. A worked monthly reconciliation example
  6. Back fees versus the negotiable uplift of 25 to 125 percent
  7. A pre audit readiness checklist

For background, read the first 48 hours of a SPLA audit and SPLA reporting discipline as audit defense.

A sample from the guide

The uplift is the part you can move. The table below is indicative and shows how a settlement splits.

ComponentBasisNegotiable
Back feesPrice file rate across under reported monthsNo
Penalty uplift25 to 125 percent of back fees by severity and durationYes
Verification costsAuditor time, where the clause appliesSometimes

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