Direct MCA customer (no CSP partner): how do we accept the German Data Secrecy Amendment (§ 203 StGB) for Azure?

Nico 0 Reputation points
2026-10-26T11:32:15.3966667+00:00

We are a small German software startup hosting our product on Azure through a Microsoft for Startups subscription. We procure Azure directly from Microsoft under a Microsoft Customer Agreement (MCA), with no CSP partner as intermediary and no Microsoft account team.

We plan to offer our product soon to companies that are professional-secrecy holders under German law, for example law firms and tax advisors. Under § 203 StGB such companies may only use service providers if the entire chain down to the cloud provider is bound to confidentiality. Microsoft provides a standard document for this: the “Zusatzvereinbarung für Berufsgeheimnisträger” (Professional Secrecy Amendment for Germany). It is listed in Partner Center for Cloud Solution Providers (CSP):

The problem: it is unclear to us how we, as a startup and direct customer, can accept this amendment or conclude it with Microsoft. In the CSP model, as far as we understand it, the partner downloads the document from Partner Center and provides it to the customer, the customer accepts it and attaches it to their MCA, the amendment takes effect upon acceptance, and Microsoft does not countersign. In our case there is no partner presenting the document, so we are unsure how the acceptance is supposed to work.

Note: we are able to download the document ourselves.

Our questions:

  1. Is it sufficient for a direct MCA customer to document the acceptance themselves (signed acceptance declaration with date, billing account ID and tenant ID, filed together with the document version and our MCA acceptance record), or does the amendment have to be presented by a partner in order to become a valid part of our MCA?
  2. Does the acceptance have to be submitted or registered anywhere with Microsoft, or is there any form of confirmation we can request?

Thank you in advance for any guidance.

Azure | Azure Startups
Azure | Azure Startups

Startups: Companies that are in their initial stages of business and typically developing a business model and seeking financing.

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  1. Zoha Fatima 675 Reputation points
    2026-10-27T16:59:59.76+00:00

    Hi Nico,

    Microsoft's documentation lists the German Professional Secrecy Amendment under the CSP program and states that only Direct Bill Partners and Indirect Providers can download the standard amendments.

    The documentation does not clarify whether a direct MCA customer can independently accept this amendment or how such acceptance would be registered with Microsoft.

    I recommend contacting Microsoft Azure billing or commercial support to confirm whether the amendment can be executed under your direct MCA and to obtain written confirmation of the required acceptance procedure. Do not assume that signing and retaining your own declaration automatically incorporates the amendment into your agreement.

    Reference: https://learn.microsoft.com/en-us/partner-center/enroll/csp-documents-and-learning-resources

    Thank you, and feel free to respond back for more assistance.

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