Building an SAP License Compliance Program: Roles, Policies & Internal Controls

building an sap license compliance program

Introduction – Why Build a Compliance Program

SAP license compliance isn’t a one-time task—it’s an ongoing discipline embedded in the organization.

SAP audits are inevitable for large customers, and SAP often uses them to drive revenue. If you’re unprepared, they can expose license shortfalls and lead to hefty, unplanned fees.

A proactive compliance program helps prevent unintentional violations. By continuously monitoring license usage and correcting issues early, you avoid last-minute “true-up” purchases under audit pressure.

You’ll also eliminate shelfware and strengthen your negotiation position in future contracts. For an overview, read our ultimate guide to SAP License Compliance Management: Preventing Audits Through Governance.

In short, a formal compliance program protects your organization from surprise costs and disruptions.

Key goals of an SAP license compliance program include:

  • Transparency: Central visibility into what licenses you own and how they’re used.
  • Governance: Clear internal ownership, defined policies, and repeatable processes for managing licenses.
  • Early Risk Detection: Identifying potential compliance gaps or overuse long before auditors arrive.

Step 1 – Define Ownership and Structure

Start by assigning clear ownership for SAP licensing and building a cross-functional governance team, so every aspect of licensing has an accountable owner.

Core roles and their responsibilities:

RoleResponsibilities
SAP License Manager / SAM LeadMaintains license inventory and usage data accuracy. Coordinates compliance efforts.
SAP Basis TeamRuns SAP license measurement tools (USMM, LAW) and ensures user access aligns with license rules.
Procurement / Vendor MgmtTracks SAP contracts, entitlements, and renewal dates. Aligns purchases with actual needs to avoid shelfware.
Finance / LegalOversees license spend and contract compliance. Ensures budgets cover any true-ups or audit-related costs.
Executive Sponsor (CIO/CFO)Champions the program. Approves policies, allocates resources, and ensures compliance gets top-level attention.

Establish a steering committee with these stakeholders and set clear reporting lines (ideally up to the CIO or CFO). Schedule regular compliance review meetings (e.g. quarterly) to discuss license usage and risks. This governance framework ensures nothing in SAP licensing goes unowned or unnoticed.

Tip: “If compliance has no executive visibility, SAP will set your priorities for you.”

Step 2 – Document Policies and Standards

With roles in place, formalize policies and standards for SAP license management. Documented policies ensure consistency and continuity, even as staff change. They act as a rulebook for how licenses are handled day-to-day.

Key policy areas to include:

  • User Lifecycle: Procedures to assign, adjust, or remove SAP access as employees join, move roles, or leave. Keeps license allocations current and removes dormant accounts promptly.
  • License Assignment Rules: Guidelines for mapping job roles to SAP license types (Professional, Limited, Developer, etc.). Ensure users are classified correctly so no one is over- or under-licensed.
  • Integration & Indirect Access: A license impact review is required for any new system or interface connecting to SAP, including third-party applications. Define how external usage is licensed (e.g., via named users or SAP’s Digital Access model) to avoid indirect usage violations.
  • Contract Management: Centralize storage and tracking of all SAP agreements and renewal dates. Assign ownership to maintain up-to-date contract records and awareness of key terms (license metrics, audit rights).

Having these policies approved by leadership gives them authority. They should be communicated across IT, procurement, and other teams that interact with SAP. For example, a provisioning policy might state:

Sample Policy: “All SAP user provisioning must follow the license classification guidelines set by the SAM team. Any exception requires CIO approval.”

Clear policies make expectations explicit and enforceable, so everyone follows the same rules for license usage.

More insights on SAP compliance reporting, SAP Compliance Reporting & Metrics: Tracking License Utilization and Audit Readiness.

Step 3 – Establish Measurement & Review Processes

Implement ongoing processes to measure license usage and review compliance. Regular internal checks will find issues on your terms, well before any official SAP audit.

Establish an internal audit cadence (for example, run USMM/LAW across systems each quarter, and conduct a full simulated audit once a year). This way, you catch and fix compliance issues proactively.

Use SAP’s built-in measurement tools (USMM for user counts, LAW for multi-system consolidation) regularly, not just during audits. Leverage SAP’s Digital Access Estimation tool to gauge indirect usage. Consider third-party SAM software for automated license tracking and alerts.

Measurement Process Checklist:

  • Run USMM in all productive SAP systems (collect user license data).
  • Consolidate results with LAW and compare usage vs. your purchased entitlements.
  • Investigate any gaps and discuss them with procurement/finance to plan fixes (reallocate licenses or purchase additional ones as needed).

By performing routine internal measurements, you maintain control and avoid surprises. You never want SAP’s audit to be your first system-wide measurement in years.

For more insights, Conducting Internal SAP License Audits: How to Self-Audit and Stay Ahead of SAP.

Governance Tip: “Never let SAP’s audit be your first system-wide measurement in years.”

Step 4 – Build a Central License Repository

Create a central repository as the single source of truth for all SAP licensing information. This ensures everyone references the same data and documents when evaluating compliance.

Include in your repository:

  • Contracts & Entitlements: All SAP contracts, order forms, license schedules, and definitions of license types/metrics (include any important licensing communications from SAP).
  • License Inventory: A current list of all SAP license entitlements by type and quantity purchased.
  • Usage History: Archive of past USMM/LAW measurement results and internal license audit reports.

Maintain it rigorously by updating data for any changes, restricting edit access, and backing it up regularly. A well-maintained repository lets you respond quickly to any SAP audit inquiry. All your license evidence is readily available, making your compliance position easy to demonstrate.

Step 5 – Integrate Compliance with Daily Operations

Embed compliance checkpoints into daily business processes so that staying compliant becomes part of the organization’s routine.

Key operational integrations:

  • HR Offboarding: Remove departing employees’ SAP access immediately to reclaim their licenses.
  • Change Management: Require a license impact check for any new SAP integration or project (get compliance sign-off before go-live).
  • Procurement & Finance: Involve the compliance team in all SAP purchases and renewals to validate license needs. Also, allocate SAP license costs to departments to make them accountable for usage.

Operational Checklist:

  • HR and IT have an automated process to de-provision SAP access for leavers (license is freed immediately).
  • Change request templates include a section for SAP license impact, requiring compliance approval.
  • No SAP contract purchase or renewal is completed without a review of license needs by the compliance owner.

For instance, you might update IT policies to include a requirement like:

Example Clause: “Any new application or interface connecting to SAP must undergo a license impact analysis by the SAP compliance team before go-live.”

Integrating these steps ensures compliance is built into projects and user management, rather than an afterthought. No project or hire should inadvertently create a licensing exposure.

Step 6 – Continuous Improvement & Governance Reviews

Treat SAP license compliance as an ongoing improvement process. Monitor metrics and hold regular governance reviews to keep the program effective and aligned with business changes.

Track key compliance metrics such as user license classification accuracy, number of inactive licenses reclaimed, and the variance between entitlements purchased vs. licenses used.

Review these metrics with the steering committee in quarterly meetings. Discuss any new risks or upcoming events that could impact licensing (e.g., expansions, migrations) and adjust your strategy accordingly.

Keep leadership informed of these compliance metrics. When executives see concrete gains (like “audit risk reduced by 80%”), it reinforces the program’s value. Regular executive visibility also ensures continued support and resources for the compliance initiative.

Step 7 – Educate Stakeholders

Even the best processes fail if people ignore them. Prevent that by educating all stakeholders on SAP license rules and why they matter.

Include SAP license compliance basics in training for new hires, send periodic reminders to SAP users and admins, and share real audit stories to keep everyone vigilant.

The more awareness you create, the less likely it is that inadvertent mistakes will undermine your compliance efforts.

5 Steps to Launch an SAP Compliance Program

  1. Nominate a Compliance Lead: Assign a person or team to own SAP license compliance.
  2. Define & Approve Policies: Establish core SAP license policies (covering user access, license classification, contract handling, etc.) and get executive approval.
  3. Build a License Repository: Collect all SAP contracts, entitlements, and current usage data in one centralized repository (your single source of truth).
  4. Run an Internal Audit Baseline: Use SAP’s tools (USMM and LAW) or a SAM tool to measure current usage across systems. Identify any immediate compliance gaps and address them early.
  5. Launch Quarterly Review Meetings: Set up a recurring meeting (e.g. quarterly) with your SAP compliance stakeholders to review usage vs. entitlements and adjust allocations as needed.

Read about our SAP Advisory Services.

author avatar
fredrik.filipsson
Fredrik Filipsson is the co-founder of Redress Compliance, a leading independent advisory firm specializing in Oracle, Microsoft, SAP, IBM, and Salesforce licensing. With over 20 years of experience in software licensing and contract negotiations, Fredrik has helped hundreds of organizations—including numerous Fortune 500 companies—optimize costs, avoid compliance risks, and secure favorable terms with major software vendors. Fredrik built his expertise over two decades working directly for IBM, SAP, and Oracle, where he gained in-depth knowledge of their licensing programs and sales practices. For the past 11 years, he has worked as a consultant, advising global enterprises on complex licensing challenges and large-scale contract negotiations.
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