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Compliance in a complex cloud architecture is a workload-level responsibility shared between the provider, your organization, and sometimes partners. A provider’s certification or audit report can support your assessment, but it does not certify your configuration, tenant relationships, data flows, or use of the service. Start by mapping each obligation to the workload, cloud service, data, and accountable owner.
Who is responsible for compliance in the cloud?
Responsibility depends partly on the service model, but the model is a starting point—not a substitute for reviewing the service and deployment you actually use. In Microsoft’s example responsibility matrix, customers retain responsibility for data, configurations and settings, and identities and users across IaaS, PaaS, and SaaS. The provider takes on more of the underlying technology as the service becomes more managed.
| Control area | IaaS | PaaS | SaaS |
|---|---|---|---|
| Customer responsibilities | Data, configurations and settings, identities and users | Data, configurations and settings, identities and users | Data, configurations and settings, identities and users |
| Operating system | Customer | Provider | Provider |
| Physical hosts, network, and datacenters | Provider | Provider | Provider |
This is Microsoft’s example for its cloud offerings; actual allocations depend on the specific service and deployment. Applications and network controls also shift across service models, so confirm their treatment in the service-specific documentation rather than assuming the table resolves every control. See Microsoft’s shared-responsibility matrix.
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Microsoft summarizes the enduring customer role this way: “For all cloud deployment types, you own your data and identities.” AWS likewise describes control operation and verification as shared responsibilities, with the allocation affected by the services selected, their integration into the IT environment, and applicable laws and regulations. AWS’s risk and compliance guidance discusses customer security technologies such as host firewalls, intrusion detection and prevention, encryption, and key management.
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A provider may address a risk through controls that differ from the ones your organization used on premises. Assess whether the risk is adequately addressed; do not assume that every existing control must be reproduced identically in the cloud. Microsoft’s risk-assessment guide explains this assessment principle.
How do you build a cloud compliance evidence trail?
- Identify the obligations. Gather the regulatory, contractual, and organizational requirements that apply to the workload. Applicability may depend on industry, geography, or customer and insurance requirements.
- Map each obligation. Connect each requirement to the workload, data, cloud service, and control owner. Record how the control is implemented and what evidence demonstrates its operation.
- Check provider evidence against the service. Review the relevant assurance documentation and audit period. Confirm which services are in scope and, where relevant to the evidence, which regions are covered. Different audits may include different services; some trust-portal documents require an authenticated account. Microsoft’s compliance offerings page describes its assurance materials and their scope.
- Assess the customer-controlled parts. Provider evidence is an input to your assessment, not a conclusion about your organization’s compliance. Verify your own configuration, identities, data handling, integrations, and operating procedures.
- State the conclusion precisely. Name the framework or requirement assessed, the service and audit scope reviewed, and the customer controls evaluated. Do not claim that a workload is compliant merely because its provider holds a certification.
Provider compliance material is not legal advice. For interpretation of a law or contract, consult qualified counsel.
What needs special attention in a multitenant architecture?
In a multitenant system, compliance depends not just on the cloud service but on how tenant data and access are separated, used, and governed. Build an inventory of the stores and systems that hold tenant information, including shared identity systems. Then make and document decisions about:
- Isolation: How tenant data is separated, and whether particular tenants need their own encryption keys.
- Tenant access and export: How a tenant can access or export its own records without exposing another tenant’s data.
- Location and access: Where data is stored and processed, which residency or sovereignty restrictions apply, and who can access sensitive workloads.
- Aggregation and reuse: Whether aggregated or anonymized tenant data is used for analytics, machine learning, or AI grounding, and what restrictions govern that use.
- Different tenant obligations: How the design accommodates tenants with different industry, geographic, contractual, or insurance requirements.
Where tenants have different requirements, Microsoft’s multitenant governance guidance suggests planning for the most stringent standard across the environment. Its guidance is general governance information, not instructions for compliance with a particular standard. Read Microsoft’s multitenant governance guidance.
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Which cloud operating model fits your organization?
Choose an operating model based on the size and complexity of the estate, team capabilities, hybrid or multicloud needs, and the level of consistency required. Each model has a different balance of control and coordination.
| Model | How responsibilities are organized | Main trade-off |
|---|---|---|
| Centralized | A central team manages governance and controls. | Uniform controls can become a bottleneck as the estate grows. |
| Shared management | Platform teams provide landing zones and shared services, such as connectivity, identity, management, and security; workload teams operate within guardrails. | Balances shared standards with workload-team ownership, but requires clear coordination. |
| Decentralized | Skilled teams have greater responsibility for their own workloads. | Can suit capable teams, but may weaken standardization. |
For any model, document who owns governance, security, and operations, with primary and backup owners. Define partner scope so platform operations, workload management, and innovation responsibilities complement internal teams without gaps or overlap. Revisit assignments when the environment or team capabilities change. Microsoft’s cloud-adoption guidance describes these operating models and ownership considerations.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How should you compare architecture choices?
When evaluating alternatives, compare the same workload requirements against each option rather than treating a provider’s general certification as a complete answer.
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- Service and control boundary: Identify what the provider operates and what your teams must configure and monitor.
- Evidence scope: Check the exact services, applicable regions, audit period, and availability of the relevant assurance documents.
- Tenant data handling: Compare isolation, encryption-key expectations, export paths, residency, access, and any aggregation or reuse.
- Operating model: Weigh centralized consistency against bottleneck risk, the coordination needs of shared management, and the standardization risks of decentralized ownership.
- Integration and obligations: Consider how each service fits existing systems and which laws, regulations, and contracts affect the deployment.
Microsoft’s compliance offerings page was last updated on April 5, 2023. Because audit scope, service availability, and service or region details can differ, check the current evidence for the specific service and deployment you are assessing.
How do you maintain customer identity controls?
Customer responsibility for identity does not disappear when a provider operates more of the stack. Microsoft’s guidance assigns customers responsibility for account lifecycle and access controls, including multifactor authentication (MFA) and conditional access. Define who provisions, reviews, and removes accounts, and apply the access policies required for the workload. A FIDO2-compatible hardware security key can support MFA; verify compatibility with your identity provider and policy. A key is an authentication control, not proof that the architecture complies with a framework. Microsoft’s shared-responsibility guidance describes the customer’s identity role.
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