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Compliance in a complex cloud architecture is a workload-level responsibility shared across the cloud provider, your organization, and sometimes tenants and partners. A provider’s certifications and audit reports can support your assessment, but they do not certify your configuration, tenant relationships, data flows, or use of its services. Start by mapping each obligation to the affected workload, service, data, control, and accountable owner.
Who is responsible for compliance in the cloud?
Both the provider and the customer have responsibilities, but the boundary changes with the service and deployment. Under Microsoft’s shared-responsibility example, customers remain responsible for data, configurations and settings, and identities and users across IaaS, PaaS, and SaaS. The provider takes on more of the underlying platform as you move toward managed services: Microsoft identifies physical hosts, networks, and datacenters as its responsibilities for those cloud offerings, and operating systems shift to Microsoft in PaaS and SaaS. Applications and network controls also shift across service models. Check the allocation for the specific service rather than treating a model label as a complete control map. Microsoft’s responsibility matrix is an example, not a universal allocation for every provider or service.
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As Microsoft puts it, “For all cloud deployment types, you own your data and identities.” That makes identity lifecycle, access policy, and customer-managed configuration central to the compliance design, even when the provider operates most of the stack.
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- IaaS: The provider operates the underlying physical infrastructure; the customer has a broader set of systems and settings to manage.
- PaaS: The provider operates more of the platform, including the operating system in Microsoft’s example, while customer responsibilities for data, identities, and settings persist.
- SaaS: The provider operates the application service, but customer data, identities, and access decisions remain important customer responsibilities.
These are orientation points, not a substitute for reviewing the selected service, deployment details, and integration. AWS likewise describes control operation and verification as shared responsibilities and says customers should consider the selected services, how they integrate into the IT environment, and applicable laws and regulations. Its guidance discusses customer technologies such as host firewalls, intrusion detection or prevention, encryption, and key management for addressing stronger security needs. AWS Risk and Compliance
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How to turn obligations into an evidence trail
A provider’s assurance evidence answers questions about the provider-controlled service within a stated scope. It does not, by itself, establish that your workload or organization complies. Build a traceable chain from each obligation to the evidence and controls that address it.
- Identify the obligations. List applicable regulatory, contractual, organizational, and insurance requirements. Keep the requirement specific enough to assess rather than relying on a broad label such as “regulated data.”
- Map each requirement to the workload. Record the relevant data, cloud services, integrations, and customer controls. Identify who operates each control, including any tenant or partner responsibilities.
- Inspect provider evidence for the exact service. Check which services are in scope for the relevant report or attestation, the audit period, and any relevant region or service availability details. Microsoft notes that its audit reports identify included cloud services and that different audits may cover different services. Some Trust Center documents require an authenticated account. Microsoft’s compliance offerings page
- Assess the control outcome. A provider may address a risk with controls different from those used in your on-premises environment. Evaluate whether the risk is addressed instead of assuming that an identical on-premises control must be reproduced. Microsoft’s risk assessment guide
- Record gaps and owners. Document what the provider evidence covers, what your organization must implement or verify, who owns each action, and what evidence will demonstrate operation.
A defensible statement names the framework or obligation, the service and audit scope reviewed, and the customer controls assessed. Avoid saying “the provider is certified, so the workload is compliant.” Provider compliance material is not legal advice; get qualified counsel to interpret legal obligations.
What changes when an architecture is multitenant?
In a multitenant system, compliance depends on how tenant records move through shared services, not only on where the primary database sits. Treat tenant boundaries as an architectural concern and document the full data path, including shared identity systems and analytics or AI components. Microsoft’s multitenant governance guidance
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Map tenant data and access
- List the stores and systems that hold tenant data, including logs, backups, shared identity services, and derived datasets where applicable.
- Specify how records are isolated between tenants and who can access sensitive workloads, including administrators, operators, and partners.
- Decide whether tenants need separate encryption keys and how key ownership and access fit the design.
- Define how a tenant can export or access its own data without exposing another tenant’s records.
- Identify where data may be stored and processed, and whether residency or sovereignty restrictions apply.
- Decide whether aggregated or anonymized tenant data is reused for analytics, machine learning, or AI grounding, and make the intended use and safeguards explicit.
Tenants may bring different industry, geographic, contractual, or insurance requirements. Where they differ, Microsoft’s guidance suggests planning for the most stringent standard across the environment. That is a governance approach, not proof that a specific standard has been met.
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Which operating model fits the cloud estate?
Governance can be centralized, shared between platform and workload teams, or decentralized. The right choice depends on estate size, team capability, hybrid or multicloud needs, and how much consistency is required. The trade-offs below follow Microsoft’s cloud operating-model guidance. Prepare your organization for the cloud
| Model | How responsibilities are organized | Main trade-off |
|---|---|---|
| Centralized | A central team governs the environment and provides consistent controls. | Uniformity can become a bottleneck as the estate grows. |
| Shared management | Platform teams provide landing zones and shared services such as connectivity, identity, management, and security; workload teams operate within guardrails. | Requires coordination and clear boundaries between platform and workload responsibilities. |
| Decentralized | Workload or product teams have greater responsibility for their environments. | Can suit skilled teams, but may weaken standardization. |
Whatever the model, document governance, security, and operations owners, including primary and backup contacts. Define partner scope so platform operations, workload management, and innovation responsibilities complement internal teams without leaving gaps or duplicating authority. Revisit assignments when the environment or team capabilities change.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How to make customer identity controls operational
Customer-owned identities remain part of the compliance boundary even in managed cloud services. Microsoft assigns customers responsibility for account lifecycle and access controls, including MFA and conditional access. Put those controls into the workload’s operating procedures, not just its architecture diagram.
- Assign an owner for account creation, changes, and removal, and include a review process for access.
- Apply MFA and conditional access according to the organization’s policies and the identity provider’s capabilities.
- If using a FIDO2-compatible hardware security key for MFA, verify that it works with the identity provider and the relevant policy. A key supports authentication; it does not make an architecture compliant by itself.
What to verify before calling a workload compliant
Use a workload-specific review rather than a provider-wide assurance claim. Before making a compliance determination, confirm that the assessment accounts for:
- The applicable obligations and the services, integrations, and data flows in scope.
- The provider’s evidence for the exact services and audit period, with region and availability details checked where relevant.
- Customer-owned data, identity, configuration, and access controls, plus the evidence that they operate as intended.
- Tenant isolation, export, residency, access, encryption-key expectations, and any permitted reuse of tenant data.
- Named owners for governance, security, operations, platform services, workloads, and partner activities.
Microsoft’s compliance offerings page was last updated on April 5, 2023, so do not assume its listed scope or service availability is current in 2026. Verify current provider evidence directly; audit coverage and service details can differ by service and region. The provider-authored guidance cited here explains responsibility boundaries and assurance material, but it does not decide whether a particular customer meets a law, contract, or audit criterion.
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