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What Microsoft completed—and when
The EU Data Boundary was delivered in three phases. Microsoft’s February 26, 2025 announcement described the final milestone as the culmination of a multi-year engineering effort spanning hundreds of product teams and thousands of developers.
| Phase | Timing | What Microsoft added |
|---|---|---|
| 1 | January 2023 | Storage and processing of Customer Data for core services, including Microsoft 365, Dynamics 365, Power Platform, and Azure. |
| 2 | January 2024 | Expanded coverage to pseudonymized personal data. |
| 3 | February 2025 | Storage of Professional Services Data generated through technical support for covered services. |
The practical significance of the last phase is that support-related data joined the boundary’s commitments. It did not remove the separately documented exceptions to where some data may be processed or accessed.
What the EU Data Boundary covers
Microsoft defines the boundary as a geographic commitment for Microsoft enterprise online services, including Azure, Dynamics 365, Power Platform, and Microsoft 365. The data categories do not all receive the same commitment: Customer Data and pseudonymized personal data are committed to be stored and processed within the boundary, while Professional Services Data is committed to be stored there. These distinctions matter when evaluating a particular service, support interaction, or compliance requirement.
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| Data category | Documented commitment | What that means |
|---|---|---|
| Customer Data | Store and process within the EU Data Boundary | Applies to covered services, subject to documented exceptions. |
| Pseudonymized personal data | Store and process within the EU Data Boundary | Added in the second phase; it is a distinct category from Customer Data. |
| Professional Services Data | Store within the EU Data Boundary | Includes data generated during technical-support interactions for covered services. For Azure, customer configuration is required for this storage commitment. |
Which countries are in the boundary?
The boundary’s geography is the EU plus EFTA—not only the EU. Microsoft identifies EFTA members Liechtenstein, Iceland, Norway, and Switzerland alongside EU countries. Its documentation lists operating or announced datacenters in Austria, Belgium, Denmark, Finland, France, Germany, Greece, Ireland, Italy, the Netherlands, Norway, Poland, Spain, Sweden, and Switzerland, and allows for additional EU/EFTA locations in the future. That datacenter list is not a promise that every covered service is available in every listed country, nor does the boundary definition reduce to the locations on that list.
What “complete” does not mean
Microsoft says some services remain temporarily excluded while work continues. One important category is Azure non-regional services, which do not currently let customers specify a deployment region. The precise applicability of an exclusion depends on the service; the broad completion announcement should not be read as proof that every Microsoft cloud service or SKU is covered.
Microsoft also documents ongoing or circumstance-dependent transfers connected with cloud operations, remote access by personnel outside the boundary, customer-initiated transfers, resiliency and service management, support, previews and trials, directory data, and network transit. As a result, a residency commitment is not equivalent to a blanket promise of zero cross-border data movement or access.
- Storage and processing are different questions. The commitment for Professional Services Data is storage within the boundary; Customer Data and pseudonymized personal data have store-and-process commitments.
- Physical location and access are different questions. Microsoft documents remote access by personnel outside the boundary as a continuing scenario.
- Coverage is service-specific. Exclusions, preview status, and the type of data involved can affect the answer for a particular workload.
What changed in Microsoft’s documentation in 2026?
The published documentation remains live after the 2025 completion announcement. Its change log records a July 9, 2026 addition covering OpenAI-operated models with Microsoft Generative AI Services among services that can transfer a subset of data outside the boundary on an ongoing basis. A July 21, 2026 entry clarifies Macro Region Geography and configuration requirements for Dynamics 365 and Power Platform. These updates reinforce why organizations should check the current documentation for the specific service and configuration they use rather than relying on the headline milestone alone.
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Yes, if an Azure customer wants Azure Professional Services Data stored within the boundary: Microsoft says Azure Resource Manager must be configured for the EU Data Boundary. The documentation supplied for this feature does not establish a universal menu path or a single set of steps applicable to every Azure environment, so administrators should follow Microsoft’s current Azure-specific instructions and verify the relevant configuration for their tenant and support scenario. This requirement concerns Azure Professional Services Data storage; it should not be generalized into an additional setup requirement for every data category or every Microsoft service.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How to assess the boundary for a real workload
- Identify the exact service and offer. Determine whether the workload uses Azure, Microsoft 365, Dynamics 365, or Power Platform, and check whether a specific service or preview is listed as excluded.
- Classify the data and activity. Separate Customer Data, pseudonymized personal data, and Professional Services Data, including support interactions. Do not assume that one category’s commitment automatically applies to another.
- Check the geography and configuration. Confirm the applicable EU/EFTA scope and any service-specific geography or customer configuration requirements. Azure customers seeking boundary storage for Professional Services Data need the Azure Resource Manager configuration.
- Review permitted flows and access. Assess the documented exceptions that may matter to the workload, including remote personnel access, resiliency, support, customer-initiated movement, and network transit.
- Recheck current service documentation. Incorporate relevant change-log updates, particularly for AI services and configuration requirements that may evolve after the original completion announcement.
For a compliance or procurement assessment, record the service, data category, geography, configuration, and relevant exceptions separately. That produces a more useful answer than treating “EU Data Boundary compliant” as a single yes-or-no property of a Microsoft tenant.
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