Microsoft SPLA to CSP Migration Guide 2026: Step-by-Step for Hosting Providers

Why Migration Is Now Unavoidable for Many Providers

Until October 1, 2025, hosting providers had a commercially viable model where they could use their own SPLA licenses to deliver hosted Microsoft server workloads on public cloud infrastructure — Amazon Web Services, Google Cloud Platform, or Microsoft Azure. This model was attractive because it allowed providers to arbitrage the SPLA rate against the hyperscaler's own license-included pricing, delivering customer workloads at a lower cost while maintaining control of the licensing relationship.

That model ended on September 30, 2025. The Listed Provider restriction prohibits SPLA licensees from deploying their SPLA licenses on AWS, GCP, Azure, or Alibaba Cloud infrastructure from October 1, 2025 onward. Providers who continued to report SPLA licenses for Listed Provider-hosted workloads after this date are in material breach of their SPLA agreement, creating audit exposure with termination risk in addition to financial penalties.

For providers who were operating this model, migration is not a strategic option — it is a compliance requirement. The question is not whether to migrate but how to execute a migration that preserves customer continuity, minimises commercial disruption, and positions the provider competitively for the post-migration operating model.

The Broader Migration Context

Beyond the Listed Provider compliance trigger, there are several additional factors driving SPLA-to-CSP migration for a wider population of providers. The January 2026 SPLA price increases for Exchange and SharePoint make the economics of on-premises hosted email and collaboration services less competitive against CSP-delivered Microsoft 365 cloud services. Microsoft's strategic investment is overwhelmingly in cloud-based products — Exchange Online, SharePoint Online, Teams — rather than on-premises server versions, which receive only security updates and no new features. And Microsoft 365 Copilot (available at $30 per user per month as an add-on, or included in the new top-tier M365 E7 SKU which also bundles AI and security capabilities previously sold separately) is only available as a cloud subscription through CSP or EA, not through SPLA.

For hosting providers who want to offer their customers access to Microsoft's current and future product roadmap — including AI capabilities, Microsoft 365 Copilot, and the E7 feature set — CSP is the only path. SPLA covers only the on-premises server product versions, which are increasingly frozen in terms of new capability development.

Understanding the CSP Hoster Programme

The Cloud Solution Provider programme includes a specific licensing track designed for hosting providers: the QMTH (Qualified Multitenant Hoster) programme and the broader CSP Hoster framework. Understanding how CSP Hoster differs from standard CSP — and from SPLA — is essential before planning a migration.

Standard CSP vs CSP Hoster

Standard CSP allows Microsoft partners to resell Microsoft 365 and Azure subscriptions to end customers who use them for their own internal purposes. The subscription is provisioned in the customer's own Microsoft 365 tenant, and the customer's users directly access Microsoft's cloud services. This is the appropriate model for resellers and MSPs who manage customer environments but do not deliver hosted services from their own infrastructure.

CSP Hoster (QMTH) is the licensing variant for providers who deliver hosted services from their own data centre infrastructure using Microsoft server products. QMTH providers can deploy Windows Server and SQL Server (and certain other products) on multitenant hardware in their own data centres and license those deployments through CSP rather than SPLA. QMTH retains the No-CAL benefit that is central to SPLA economics, meaning customer users do not need to hold their own CALs to access the hosted service.

What CSP Hoster Covers

CSP Hoster covers Windows Server, SQL Server, and certain other on-premises products when deployed on the QMTH provider's own infrastructure. For cloud-based Microsoft services — Microsoft 365 (covering the full SKU stack from E1 through E3, E5, and the current top tier E7), Exchange Online, SharePoint Online, Teams, Dynamics 365 — standard CSP subscription licensing is available regardless of where the provider's infrastructure is located.

The combination of QMTH for on-premises server products and standard CSP for cloud services allows a hosting provider to cover both the infrastructure workloads (Windows Server, SQL Server) and the productivity and collaboration services (M365 E1 through E7, Exchange Online) from a single CSP framework, replacing the SPLA relationship with a single Microsoft partner relationship.

The No-CAL Benefit Continuity

One of the most commercially important questions in SPLA-to-CSP migration is whether the No-CAL benefit is preserved. Under SPLA, the SAL replaces the CAL requirement for customer users. QMTH CSP Hoster preserves the No-CAL equivalent: customers accessing services hosted by a QMTH provider do not need to hold their own CALs. This continuity is essential — a migration model that requires customers to obtain their own CALs would fundamentally change the economics of the hosted service model and make it commercially unviable for most providers.

Commercial Comparison: SPLA vs CSP for Key Product Categories

The commercial case for migration varies significantly by product category. Not every SPLA product line has a direct or economically equivalent CSP counterpart, and providers need to build a product-by-product comparison before committing to a migration strategy.

Windows Server Infrastructure

Windows Server under SPLA and QMTH CSP Hoster are functionally equivalent for providers operating on their own data centre infrastructure. Both provide the No-CAL benefit. The pricing structures differ — SPLA uses monthly per-processor or per-core rates while QMTH CSP Hoster uses annual subscription pricing — and the commitment model changes from SPLA's month-to-month flexibility to CSP's annual or three-year terms. For providers with stable, predictable infrastructure footprints, the annual CSP subscription may offer cost advantages over SPLA monthly rates. For providers with highly variable loads, SPLA's monthly model may remain more cost-effective.

For Windows Server workloads that were running on Listed Provider infrastructure — AWS, GCP, Azure — the QMTH CSP Hoster model only applies if the workloads are migrated to provider-owned infrastructure. Workloads that remain on Listed Provider infrastructure after October 2025 require either BYOL (customers bringing their own qualifying licenses) or direct licensing through the hyperscaler's own licensing programs.

Exchange Server to Exchange Online

Hosted Exchange Server through SPLA and Exchange Online through standard CSP are different products with different economics. Exchange Online (Plan 1 or Plan 2, or as part of Microsoft 365 E1, E3, E5, or E7) is priced per user per month at rates that are generally comparable to or below the post-January-2026 SPLA Exchange SAL rate, particularly when bundled within a Microsoft 365 subscription. Exchange Online includes continuous cloud updates, a 99.9% uptime SLA backed by Microsoft, and access to the full Exchange Online feature set without server infrastructure management.

The migration from hosted Exchange to Exchange Online is a customer migration: mailboxes and data move from the provider's hosted Exchange environment to Microsoft's Exchange Online service in the customer's tenant. Providers no longer carry the server infrastructure cost or the SPLA licensing cost for Exchange. The trade-off is that the provider's relationship with the customer for email services shifts from a direct managed service to a CSP reselling relationship — a commercially different but often more scalable model.

SharePoint Server to SharePoint Online

SharePoint Online (available in Microsoft 365 plans from E1 through E7) has largely replaced the use case for hosted SharePoint Server for most enterprise customers. SharePoint Online offers Teams integration, Copilot capabilities, continuous feature development, and Microsoft-managed infrastructure. The SPLA cost for hosted SharePoint Server, particularly after the January 2026 price increase, is difficult to justify commercially when SharePoint Online is available at similar or lower per-user cost within a Microsoft 365 subscription through CSP.

SQL Server Infrastructure

SQL Server is where the SPLA-to-CSP migration calculation is most complex. SQL Server under SPLA for on-premises hosting has no direct CSP equivalent at the per-database-instance level. SQL Server on Azure (Azure SQL Database, SQL Managed Instance, or SQL Server on Azure VM) is a different commercial and technical model from SPLA-licensed SQL Server in a provider's own data centre. Providers who are running SPLA SQL Server for customer database hosting on their own infrastructure should evaluate QMTH CSP Hoster as the primary migration path — this preserves the on-premises hosting model while transitioning from SPLA to CSP commercial terms.

Phase-by-Phase Migration Framework

A well-managed SPLA-to-CSP migration is a phased programme, not a single cutover event. The following framework reflects the approach we apply in our Microsoft licensing advisory engagements with hosting providers navigating this transition.

Phase 1: Compliance Triage (Weeks 1–4)

Before planning the migration, establish the compliance baseline. Identify every SPLA product line in your current reporting portfolio, map each product to its deployment location (own infrastructure vs Listed Provider infrastructure), quantify the Listed Provider exposure for any workloads that may be in breach of the October 2025 restriction, and document the customer relationships associated with each deployment. This triage provides the basis for a prioritised migration roadmap that addresses the highest-risk compliance exposure first.

If there is confirmed Listed Provider exposure after October 1, 2025, this phase must include independent legal and licensing assessment before any communication with Microsoft or resellers. The exposure requires careful management to avoid escalating audit risk while the migration is being planned and executed.

Phase 2: Programme Setup (Weeks 4–12)

Establish the CSP and QMTH programme relationships needed to support the migration destination. This includes becoming an authorised CSP partner (or expanding an existing CSP partnership to include QMTH), selecting a CSP tier and indirect reseller relationship if applicable, and provisioning the Microsoft Partner Centre capabilities needed to manage customer CSP subscriptions. For providers who are not already CSP partners, the enrolment and certification process takes four to eight weeks.

During this phase, also model the commercial impact of the migration for each customer and product category. For infrastructure workloads migrating from SPLA to QMTH CSP Hoster, model the change from monthly SPLA rates to annual CSP subscription pricing and identify which customers may see cost increases or decreases. For collaboration workloads migrating from hosted on-premises to cloud subscriptions, model the Exchange Online and SharePoint Online subscription costs against the current SPLA-based hosted service cost basis.

Phase 3: Infrastructure Workload Migration (Weeks 12–24)

Migrate Listed Provider-hosted workloads first, as these carry the highest compliance risk. Options depend on the workload and the provider's infrastructure: migrating workloads from Listed Provider infrastructure to owned or colocated infrastructure where they can be covered by QMTH CSP Hoster, transitioning customers to BYOL where they hold qualifying licenses, or working with the Listed Provider to establish a direct licensing relationship for the workloads that cannot be migrated.

For providers who are migrating on-premises infrastructure workloads from SPLA to QMTH CSP Hoster, the technical migration is minimal — the workloads remain on the same infrastructure. The change is in the licensing and billing structure: SPLA monthly reports are replaced by CSP subscription provisioning through the Microsoft Partner Centre, and SPLA reseller invoices are replaced by CSP subscription billing.

Phase 4: Collaboration Service Migration (Weeks 24–48)

Migrate hosted Exchange, SharePoint, and legacy Dynamics customer workloads to cloud-based equivalents delivered through standard CSP. This phase involves customer-facing changes: email migration, SharePoint data migration, and application migration require customer consent, planning, and execution. The provider's role shifts from infrastructure manager to migration project manager and, post-migration, to CSP reseller and support provider for the cloud services.

Customer migration windows should align with customer contract renewal dates where possible. Forcing migrations mid-contract creates commercial and operational risk. Build a customer-by-customer migration schedule that aligns the technical migration with the end of the current hosting contract term and the start of a new CSP-based service agreement.

Phase 5: SPLA Wind-Down and CSP Optimisation (Weeks 48–60)

Once all workloads have migrated, formally terminate the SPLA agreement (after confirming that all reporting obligations for the agreement period are satisfied), optimise the CSP portfolio for commercial efficiency (consolidating CSP subscriptions, negotiating CSP reseller terms, and building the bundled M365 service offerings that leverage the full E1 through E7 SKU range), and establish the CSP operational processes that replace the SPLA compliance framework.

Customer Communication and Transition Planning

The migration from SPLA to CSP is not just a technical and commercial transition for the provider — it is a change in the customer's service experience. Customers who have been receiving hosted on-premises Exchange, SharePoint, or Windows desktop services will experience changes in the service interface, feature set, and potentially the pricing model. Managing this transition requires a clear customer communication strategy.

Timing the Customer Conversation

Initiating the customer migration conversation at or before the current hosting contract renewal is the most commercially effective approach. Presenting the migration as a service upgrade — to a cloud-based model with improved reliability, Microsoft-managed updates, and access to AI capabilities through Copilot and the E7 feature set — is more commercially effective than presenting it as a compliance-driven change. Customers who understand they are moving from a server on someone's rack to Microsoft's global cloud infrastructure generally respond positively to a well-framed upgrade narrative.

Pricing the Migration

For many customers, the migration from hosted on-premises services to CSP cloud services will involve a change in the pricing model — from the provider's hosted service pricing (which bundles infrastructure, management, and licensing cost) to a CSP subscription pricing model (where the Microsoft licensing cost is explicit and management services are charged separately). Providers should model the total cost comparison for each customer — including the CSP subscription cost, management service fee, and any migration project cost — and present this as a comprehensive proposal rather than a line-by-line comparison that highlights individual price changes without context.

Common Migration Mistakes to Avoid

Treating migration as a single event: SPLA-to-CSP migration is a programme of 12 to 18 months for most providers with significant SPLA portfolios. Attempting to execute it as a rapid cutover creates operational risk, customer disruption, and compliance gaps during the transition period.

Ignoring Listed Provider exposure during migration planning: If your business has confirmed Listed Provider compliance exposure, the migration planning process must account for this separately from the strategic SPLA-to-CSP programme. Compliance triage and remediation run in parallel with the migration programme, not sequentially.

Failing to model QMTH economics: For providers with significant on-premises Windows Server and SQL Server hosting, QMTH CSP Hoster is the right migration destination — not a direct switch to cloud IaaS. Providers who assume the only CSP migration path involves moving customer workloads to Azure are working with an incomplete picture of their options.

Under-investing in customer communication: Customers who receive inadequate notice of migration plans, or who experience service disruption during migration, may use the transition as an opportunity to re-evaluate their provider relationship. The migration is a retention risk if managed poorly and a retention opportunity if managed well.

Not benchmarking CSP reseller terms: Just as SPLA reseller terms are negotiable, CSP indirect reseller margins are also subject to negotiation. Providers who accept the first CSP reseller relationship they are offered without competitive benchmarking consistently pay more than necessary for the CSP programme. Independent advice on CSP reseller selection and margin structure is part of a comprehensive migration advisory engagement.