When SAP Comes Knocking: A $5 Million Audit Claim Against a Consumer Goods Manufacturer

The client is a Brazilian consumer goods manufacturer with revenues of approximately USD 1.2 billion and SAP ECC as its core ERP system. In late 2024, they received an Indirect Access Claim from SAP following a routine LAW measurement run that SAP's account team had arranged as a "complimentary licence health check." The initial claim totalled USD 5.1 million in backdated licence fees and ongoing compliance costs.

Simultaneously, SAP's account team was presenting a RISE with SAP. For negotiation context, see our SAP knowledge hub migration proposal as the path to resolving the indirect access exposure. The message was clear: migrate to RISE, and SAP would waive the indirect access claim as part of the transition deal. This is a pattern Redress Compliance has seen across 80+ indirect access disputes. It is not a resolution — it is a commercial mechanism that converts a disputed liability into a long-term subscription commitment at terms that favour SAP.

The client engaged Redress Compliance as SAP commercial advisory specialists before accepting either outcome — the settlement or the RISE migration on SAP's proposed terms.

What SAP Was Claiming and Why

SAP's claim centred on three integration scenarios that were generating documents in SAP from non-SAP systems. The client's e-commerce platform was creating sales orders in SAP via a middleware integration. Their third-party warehouse management system was creating goods movement and material documents in SAP. Their trade promotion management application was creating financial postings and promotional order documents in SAP.

Under SAP's digital access model, each of these constitutes indirect usage — documents created in SAP by an external system without a corresponding named user licence for each transaction originator. SAP's measurement of these three scenarios over a 36-month lookback period produced the USD 5.1 million claim figure.

What SAP did not disclose upfront: the 36-month lookback period is not mandated by SAP's standard licensing terms, which specify a 12-month measurement period. SAP routinely uses the longest defensible lookback period to maximise claim value in the initial presentation. The client's liability under a 12-month measurement was USD 1.9 million — materially different from the opening claim.

"SAP routinely presents the maximum defensible claim figure as the opening position. The actual liability under standard measurement terms is often 60 to 80 percent lower. Most buyers settle without understanding this distinction." — Fredrik Filipsson, Co-Founder, Redress Compliance

The Dual Challenge: Defending the Audit While Evaluating RISE

The structure of SAP's approach — presenting both an audit claim and a RISE proposal simultaneously — is deliberate. It creates time pressure (the audit is outstanding), emotional pressure (the threat of legal escalation), and a manufactured safe harbour (RISE migration solves everything). Buyers who respond to this structure without independent commercial analysis. Our SAP commercial advisory specialists ran consistently reach worse commercial outcomes.

Our approach was to run two parallel workstreams: a rigorous challenge to the audit methodology and claim quantum, and an independent assessment of the RISE proposal on its commercial merits — our SAP RISE advisory team merits — separate from the SAP audit defence settlement question. This separation is critical. An audit settlement and a RISE migration are two different commercial decisions. Conflating them gives SAP the ability to trade concessions in one against concessions in the other in ways that obscure the true value of each.

Challenging the Audit Claim: The Defence Methodology

Our audit defence analysis. Our SAP audit defence framework covers this methodology covered four dimensions.

Measurement Period: We challenged SAP's 36-month lookback and established that the contractual measurement basis was 12 months. This reduced the claim base from USD 5.1 million to USD 1.9 million before any further analysis.

Document Attribution: SAP's measurement tools (USMM and SLAW) counted reversal documents, correction entries, and batch-generated confirmation documents as separate chargeable events. We demonstrated that 22% of the document count was attributable to system-generated reversals and corrections that do not represent independent transactions. Removing these reduced the adjusted claim to USD 1.48 million.

Existing Named User Coverage: The client's SAP Professional users had authority to perform all transactions executed by the integration systems in question. We argued — and SAP eventually accepted — that integrations executing actions within the scope of existing named user roles can be attributed to those users rather than requiring additional digital access licences — see the complete digital access guide. This eliminated approximately 35% of the remaining claim.

Digital Access Adoption Programme (DAAP): SAP operates a formal programme that allows customers to regularise indirect access exposure with prospective pricing and transition terms, rather than paying backdated fees. We secured the client's participation in DAAP as part of the settlement, converting a historical liability into a structured forward-looking licensing arrangement.

The RISE Negotiation: Evaluating the Proposal on Its Own Merits

With the audit claim separately negotiated down to a manageable settlement, we then evaluated the RISE with SAP proposal without the distorting pressure of the outstanding liability. This produced a very different negotiation dynamic.

The client's ECC system ran on EHP 7, which means mainstream maintenance ends on December 31, 2027. With less than two years to that deadline, the 2027 cliff was a real commercial factor — but not the emergency SAP's account team was presenting it as. According to Gartner data from end-2024, only 39% of SAP's approximately 35,000 ECC customers have licensed S/4HANA. Gartner projects approximately 17,000 companies will not be migration-ready by 2027. Horváth's 2025 survey of 200 enterprises found only 37 had completed migration, with 60%+ over budget.

This industry context is important for negotiation because it establishes that SAP cannot afford to treat every customer who misses the 2027 deadline as a revenue loss. Extended Maintenance at 24% of licence value (versus 22% for standard maintenance) and the ERP Private Edition Transition Option (introduced Q1 2025, extending ECC to 2033 for select large enterprises) are commercial backstops that SAP will offer rather than lose a customer. Knowing this changes how you negotiate RISE.

Facing an SAP indirect access claim alongside a RISE proposal?

Redress Compliance has defended 80+ indirect access disputes. We separate audit settlements from migration decisions.
Get Independent Advice →

Negotiating RISE from a Position of Strength

With the audit claim resolved and an independent assessment of the RISE proposal completed, we entered the RISE negotiation with three forms of leverage that the client had not previously had.

First, we had a resolved audit claim. SAP's ability to use the audit as commercial pressure in the RISE negotiation was eliminated. Second, we had quantified migration credits accurately — identifying that SAP's initial proposal had excluded three categories of eligible on-premise licences from the credit calculation. Third, we had benchmarked the RISE infrastructure pricing against current market rates and identified that the client's proposal was 18% above comparable deals closed in the same quarter.

The final RISE agreement delivered a 25% reduction versus SAP's initial RISE proposal. This saving was distributed across migration credit recovery (USD 340K), infrastructure pricing correction (USD 580K), BTP credit adequacy adjustment (USD 220K), and a three-year price cap on annual uplift (net present value USD 410K over the contract term).

The Total Outcome: $5M in Penalties Avoided, 25% RISE Savings

The combined outcome of the audit defence and RISE renegotiation was a total commercial improvement of approximately USD 6.5 million versus SAP's initial commercial position. The audit settlement cost USD 480,000 — 9.4% of SAP's opening claim of USD 5.1 million. The RISE savings over a three-year term amounted to USD 1.55 million. The digital access exposure was eliminated through a properly structured DAAP settlement and an explicit contractual bundle in the RISE agreement covering the client's current integration landscape.

SAP's initial framing — "migrate to RISE and we'll resolve the audit" — would have delivered a materially worse outcome: a RISE commitment on SAP's initial commercial terms plus a claim that was never properly challenged on its merits.

What Brazilian and LATAM Enterprises Need to Know

Brazilian enterprises face a specific version of the 2027 challenge. SAP ECC is deeply embedded in the Brazilian market, and ECC EHP 6-8 mainstream maintenance ends December 31, 2027 — a deadline that is already close. Many Brazilian companies are also navigating fiscal compliance requirements that create mandatory SAP integrations with SEFAZ, eSocial, and other government systems. These integrations generate high document volumes in SAP and represent significant digital access exposure that most companies have not assessed.

The message from this engagement is straightforward: receive an SAP audit claim and a RISE proposal at the same time, and your first call should be to an independent commercial adviser — not to SAP's account team. The two decisions are separable, and separating them is the most important thing you can do for your commercial outcome.

Migration credits decrease approximately 10% per year. Acting in 2025 or early 2026 delivers meaningfully more value than acting in 2027 under end-of-support pressure. But acting under audit pressure without independent analysis is consistently the most expensive path of all.

SAP Licensing Intelligence for LATAM Enterprises

Quarterly updates on SAP audit trends, RISE pricing changes, and 2027 deadline developments from our SAP commercial advisory team.