SAP Audit Trends 2025–2026: What CIOs Need to Know
Why This Topic Matters Now
The next two years will be pivotal for SAP customers. SAP ECC’s end-of-support is looming (mainstream support ends in 2027), and SAP is ramping up pressure on enterprises to modernize their environments.
CIOs are finding that SAP software audits are heating up in tandem with this transition. Key focus areas, such as indirect access, HANA database sizing,
S/4HANA migration compliance and cloud usage are coming under greater scrutiny. SAP’s audit teams are intensifying reviews in these areas to catch any licensing gaps before customers shift to new platforms.
In short, preparing for stricter SAP audits has become an essential part of IT planning in 2025 and 2026. If organizations don’t anticipate these audit trends, they could face steep unbudgeted license fees or compliance penalties at the worst possible time.
SAP’s motivation is clear: as customers migrate from legacy systems to S/4HANA or cloud solutions, SAP wants to ensure that no usage goes unlicensed. The vendor has become less tolerant of “gray areas” that might have been overlooked in the past.
Every integration, every additional user, and every gigabyte of database usage is a potential source of revenue.
CIOs, procurement leads, and SAP program owners must be proactive in their approach. Otherwise, they may get an unpleasant surprise in the form of an audit true-up just as they’re juggling critical transformation projects.
Emerging Audit Focus Areas (2025–2026)
SAP’s audit priorities have evolved. Below are the major SAP audit trends for 2025–2026 that CIOs should keep on their radar, and why they matter now:
Indirect Access Enforcement
Indirect access – when third-party systems or external users indirectly use SAP data and functions – remains a top audit focus.
SAP has long warned about unlicensed use via APIs, middleware, robotic process automation, or external web portals that connect to an SAP ERP.
In 2025, SAP indirect access audits are stricter than ever. SAP expects customers to have addressed indirect usage either by assigning proper named-user licenses or adopting its Digital Access licensing model.
Under the Digital Access program, indirect usage is licensed based on specific document types (like sales orders or invoices) created by external systems. This was introduced to bring transparency, but now SAP is auditing it with rigorous scrutiny.
Why now? Because many customers have had years to adjust. SAP offered incentive programs for digital access licensing, and by 2025, that grace period will be effectively over. Auditors will no longer overlook unlicensed integrations.
For example, if your e-commerce platform creates thousands of sales orders in ECC or S/4HANA without proper licensing, expect SAP to count those documents and present a hefty bill. CIOs should map all third-party applications, interfaces, and bots that interact with their SAP system.
Ensure each scenario is covered by either an appropriate user license or a digital access document license. Indirect access can pose a multi-million-dollar risk if left unmanaged, especially as digital ecosystems continue to grow.
A vendor-skeptical view is warranted here: SAP’s auditors are effectively revenue guards – if there’s any external use of SAP data happening, they will enforce the license rules to capture that revenue.
Read about SAP Audit Tools: USMM, LAW (SLAW/SLAW2).
HANA Capacity & Sizing Audits
As enterprises transitioned to SAP HANA databases (either as part of ECC on HANA or S/4HANA), HANA capacity has become a key focus of audit attention.
SAP often licenses HANA by memory volume, meaning your contract may specify a maximum RAM usage or data volume.
In 2025 and 2026, SAP’s audit teams are zeroing in on how much HANA memory customers are using versus what they’ve licensed.
If your HANA systems have been quietly growing in data size or if you’ve added extra hardware nodes for high availability, you might unintentionally exceed your licensed capacity.
SAP auditors will likely request current HANA usage statistics or even enable telemetry to verify peak memory usage. One spike in HANA memory usage above your licensed amount can trigger a compliance finding.
For example, if your contract allows 2 TB of HANA memory but your system peaked at 2.2 TB during a high load, SAP could demand you purchase the difference (often at list price).
The same applies to having a disaster recovery or failover node, which effectively increases your available capacity. SAP may also require it to be licensed, even if it’s rarely used. This trend is gaining importance now because data volumes are ever-growing and S/4HANA projects often involve re-sizing systems.
SAP sees an opportunity here: unused or over-provisioned capacity is a licensing opportunity from their perspective. CIOs should right-size their HANA environments with audit compliance in mind.
Regularly monitor your HANA database size and clean up or archive data if possible. Don’t assume extra hardware will go unnoticed – SAP has become adept at identifying any excess capacity during audits.
SAP Digital Access Audits: Pitfalls, Compliance Risks, and Negotiation Strategies
S/4HANA Migration Compliance Gaps
Many organizations are transitioning from ECC to S/4HANA.
These migrations – whether a full “brownfield” conversion or a phased rollout – come with unique compliance challenges. SAP is paying close attention to S/4HANA migration audit risks through 2025–2026.
Why? Because the transition period is when licensing can get messy. Enterprises often negotiate new S/4HANA contracts or conversion credits for their old licenses.
SAP may grant dual-use rights for a time (allowing you to run ECC and S/4HANA in parallel during the migration), but these rights have limits.
Audit teams are ensuring customers aren’t “double dipping” – for instance, running the old ECC system productively beyond the agreed-upon timeline or using more licenses than they converted for S/4HANA.
If your contract says you must retire ECC by a certain date and you slip behind schedule, that lingering ECC production use could be deemed unlicensed after that date.
Similarly, if your S/4HANA licensing uses a new metric (such as a different user classification or a processor metric), SAP may audit whether the numbers used during contract conversion were accurate.
Non-standard migration paths (such as extended pilots, multiple parallel systems, or hybrid scenarios) are especially risky – they can expose gaps where neither the old nor the new licenses fully cover usage.
This audit focus is intensifying now because ECC’s end-of-support is near, and SAP wants to ensure customers properly transition under the correct licenses.
In some cases, SAP might even use audits as a nudge: customers still on ECC in late 2025 could face stricter audits to encourage them to migrate to S/4HANA or RISE (SAP’s cloud offering).
CIOs should comb through their migration agreements for any compliance clauses.
Keep meticulous track of who is using ECC versus S/4 during the migration, and adhere to the agreed-upon timeline or obtain written extensions if necessary. The goal is to avoid any license compliance surprises just when you’re focusing on a go-live.
Cloud User Counts & SaaS Usage
SAP’s cloud products (SuccessFactors, Ariba, Concur, SAP Cloud Platform services, etc.) are now widespread in many enterprises.
One emerging trend is audits (or compliance checks) focusing on SAP cloud user counts and consumption. Unlike on-premise software, where SAP had to trust your self-reported figures, cloud services give SAP direct visibility into actual usage.
SAP cloud usage audits in 2025–2026 often involve SAP comparing your contracted entitlements to what the cloud systems show.
For example, in SuccessFactors (SAP’s HR SaaS), contracts are usually based on the number of employees or named users. If you purchased 5,000 user licenses but have 5,500 active employees in the system, SAP will notice a 10% overage.
They typically address this at renewal or through periodic certification, meaning you’ll be asked to true up the difference (with back charges or an updated contract).
Similarly, modules like Concur or Ariba may have transaction- or document-based licenses – for example, a maximum number of expense reports or purchase orders per year.
If your usage exceeds these numbers due to business growth, SAP will enforce the contract limits and require an upgrade to a higher tier or payment for the excess usage. We’re seeing SAP enforce cloud metrics more tightly now that these services are mature and widely adopted.
This area is gaining importance because many CIOs still think in terms of on-premise “true-ups” once a year, but cloud services are effectively auditing you in real-time.
Moreover, some organizations have purchased cloud modules under older assumptions or as part of bundled deals (perhaps tied to their ECC license negotiations years ago). Those deals might have been forgiving, but as the ECC era comes to a close, SAP wants to ensure that all those cloud users are properly licensed in the future.
The key takeaway is that cloud usage compliance is not optional – if you have SAP SuccessFactors, Ariba, Concur, or other cloud services, it is essential to monitor your usage on a monthly basis.
Ensure the number of active users or documents remains within your purchased limits. If you anticipate growth, negotiate additional licenses proactively rather than letting an audit catch you off guard. Governance processes should be extended to SaaS: for instance, promptly remove or deactivate users who leave the company to free up that license.
Common Enterprise Scenarios
To illustrate how these audit issues manifest in real life, consider a few scenarios that many enterprises have experienced:
- Indirect Access Surprise: A manufacturing company built a custom web portal for partners to input orders, which then flow into SAP ECC. They assumed their existing licenses covered this. During a routine SAP indirect access audit, SAP discovered tens of thousands of sales orders created by unlicensed partner users. The result was a multi-million dollar backcharge for indirect access. This could have been avoided by proactively licensing those interactions through SAP’s digital access documents or a more favorable contract arrangement.
- HANA Capacity Overshoot: A global retailer migrated their ECC database to SAP HANA and sized the system generously for future growth. They installed extra memory to handle peak holiday loads, assuming unused capacity wouldn’t be needed. An audit revealed that the HANA system’s peak memory usage (during a one-time Black Friday spike) exceeded its license by 15%. SAP promptly flagged this and demanded that the retailer purchase additional HANA capacity licenses to accommodate the peak usage. The lesson: Over-provisioning hardware without adjusting licenses can come back to bite you.
- S/4HANA “Rogue” Sandbox Users: A large enterprise in the middle of an S/4HANA migration set up a sandbox environment for testing and training. Over time, this “sandbox” began to be used by hundreds of users for semi-productive work, as it contained real data – far beyond the intended testing scope. During the next audit, SAP questioned these users since the sandbox had only developer/test licenses. The company had to scramble to purchase additional licenses and tighten environmental controls. It highlighted the importance of governing S/4HANA development and testing environments, as well as educating users on license boundaries during the migration period.
Each of these scenarios highlights how easily one can fall into compliance traps when proactive governance is lacking.
They also show SAP’s increasingly firm stance: whether it’s a third-party interface, a technical capacity limit, or a temporary project system, SAP will enforce the contract terms.
6 Forward-Looking Recommendations for CIOs
To navigate these audit risks, CIOs and IT leaders should adopt a proactive and strategic approach. Here are six forward-looking recommendations to strengthen your SAP license compliance posture for 2025 and 2026:
- Budget for New License Types Early. As you plan for the next couple of years, assume you’ll need to invest in new kinds of SAP licenses. This could include Digital Access licenses for indirect use, expanded HANA capacity licenses, or new user licenses for additional SAP modules you adopt. Don’t wait for an audit to reveal a shortfall – include a buffer in your IT budget for SAP licensing. By forecasting these costs (for example, budgeting for digital access documents or extra S/4HANA user types), you can avoid scrambling for funds when an audit true-up hits. Proactive budgeting also strengthens your hand in negotiations with SAP, since you won’t be caught off guard financially.
- Implement a “Digital Access” Program for Indirect Use. Rather than treating indirect access on an ad-hoc basis, set up a formal internal program to manage it. This involves inventorying all non-SAP applications that interface with SAP, identifying the data they create or retrieve, and then determining the best licensing approach for each. Some connections might warrant a Digital Access document license, while a technical user license or a specific interface agreement might cover others. Establish policies so that whenever a new integration is built, the licensing impact is evaluated upfront. By making “SAP digital access compliance” a standard checklist item in project planning, CIOs can effectively address this risk area. The goal is to never be in a position where an auditor discovers an interface you weren’t tracking. Some companies even form a governance board that reviews integrations for indirect usage exposure. While it may seem tedious, it’s far cheaper than a surprise indirect access bill.
- Right-Size HANA Capacity with Audit in Mind. Don’t treat your HANA infrastructure planning purely as a technical exercise – factor in licensing. If you’re moving to S/4HANA or expanding HANA for analytics, carefully model your expected data growth versus the license capacity you own. Leave some headroom for growth, but avoid grossly over-provisioning HANA memory beyond your license. It’s a fine balance: you want performance and future scalability, but you also don’t want to pay for unused capacity because an audit will charge you for the peak potential usage. Implement monitoring to track HANA memory and CPU usage trends. If you notice your usage steadily climbing toward your licensed limit, engage with SAP early about a license extension or take action to archive data. It’s better to negotiate licenses on your terms (perhaps in a broader S/4HANA deal) than to buy them reactively at full cost during an audit. In short, treat HANA sizing as both an IT and a compliance exercise.
- Govern S/4HANA Sandbox and Development Users. During an S/4HANA migration, it’s common to have multiple systems (such as sandbox, development, and quality testing) running in addition to the production ECC and eventually S/4. Ensure that you tightly control who has access to these non-production systems and how they’re used. Development and test licenses are typically cheaper or provided under different terms, and they’re not meant for production-level activity. Put controls in place, for example, by requiring that test system login accounts correspond to licensed production users or are limited to project team members. Track the number of users and types of usage in these environments. If your migration timeline slips, consider requesting formal extensions of dual-use rights from SAP. The key is to prevent “license creep” – where a sandbox suddenly has many more users or becomes semi-production without proper licenses. A governance policy and regular audits of usage in project systems will help you avoid compliance surprises during mid-migration.
- Monitor Cloud Module Usage Monthly. For any SAP cloud services you use (HR, procurement, travel, analytics, etc.), establish a habit of regularly checking your consumption. Maintain a dashboard that displays cloud user counts and transaction volumes about your entitlements. This could involve running user reports in SuccessFactors every month, checking the number of documents processed in Ariba, or reviewing active user counts in your SAP Analytics Cloud or other SaaS tools. By monitoring continuously, you can spot if you’re trending over your license limits before SAP does. If you notice an issue – for instance, a particular module exceeding 100% of purchased capacity – you can take action: perhaps clean up inactive accounts, enforce policies to limit usage, or initiate a discussion with SAP about increasing your subscription. It’s far better to adjust proactively than to let overuse accumulate. Remember, SAP’s cloud compliance checks are automated; they will catch an extra 500 users or extra transactions, so you want to catch it first internally.
- Build a SAP Audit Readiness Playbook. Treat SAP audit preparation as an ongoing discipline, not a one-time project. Develop a playbook that outlines how your organization will respond to any audit or license review. This should include roles and responsibilities (who in IT, procurement, or finance handles what), a checklist of data to gather (user lists, system measurements, contract documents), and predefined processes for engaging with SAP auditors. Also include scenario plans: “What do we do if an audit finds indirect access usage? How will we validate and negotiate that?” or “How will we handle an assertion that our HANA usage was over the license?” Having this playbook ensures you’re not scrambling when the audit notice comes. It also forces you to do periodic SAP audit readiness drills – for example, simulate an internal audit annually. Organizations that practice in advance can approach real audits calmly and from a position of knowledge. In contrast, those who are unprepared often make costly mistakes, such as over-disclosing sensitive data or agreeing to unfavorable terms under pressure. Empower your teams with clear guidelines on audit etiquette (e.g., what to share, when to involve legal) and keep that muscle memory fresh through regular reviews.
Avoiding Audit Pitfalls
Just as important as proactive steps are the things to avoid. Here are a few audit pitfalls that trip up even the savviest CIOs, and how to steer clear of them:
- Don’t rely on legacy ECC licensing for modern cloud usage. One common mistake is assuming that older contracts or generous ECC-era license allotments somehow cover new cloud services or integrations. They typically do not. For example, having an “unlimited HR users” clause in an old ECC deal doesn’t mean you can onboard all employees into SuccessFactors without additional licenses. Always verify the licensing requirements of any new SAP product or cloud module, rather than relying on assumptions from legacy agreements.
- Avoid ad hoc migrations without aligning license types. Rushing into an S/4HANA migration or standing up a quick SAP instance for a new project without sorting out licenses is asking for trouble. Every time you spin up a new SAP system or move users to a new software version, pause and consider: What licenses should cover this use? Ad hoc moves can lead to scenarios where you have the wrong license type (e.g., using a test license for a production scenario) or insufficient quantity. Before implementing any major change, consult your SAP licensing specialist or reseller to ensure your contract covers the new deployment properly. It’s much easier to adjust your contract ahead of time than to plead ignorance later.
- Don’t assume overcommitted hardware isn’t risky. It’s tempting to think that if you haven’t fully utilized a system, you’re safe from licensing concerns. But SAP often licenses based on capacity, not just current usage. If you build out a massive HANA cluster “just in case” or migrate to a bigger server for future growth, SAP may interpret that as available capacity that should be licensed. In essence, SAP sees unused HANA capacity or extra CPUs as a licensing opportunity. The audit team might request hardware specifications from your SAP systems and insist that your license reflect the maximum technical capacity, not the average usage. To avoid this pitfall, only deploy what you need or be prepared to license the full extent of what you deploy. If you require a large environment for resilience or future growth, consider discussing staged licensing with SAP (if possible) or include this in your contracts. Never assume “they won’t notice” – SAP auditors are quite thorough with system data.
Governance & Ongoing Audit Prep
Finally, establish strong governance around SAP licensing and compliance on an ongoing basis. This isn’t a one-time cleanup; it’s a continuous effort.
Here’s how to bake audit readiness into your IT governance:
- Cross-Functional Audit Reviews: Schedule quarterly or semi-annual review meetings to assess SAP compliance. Include stakeholders from IT (especially SAP Basis and Security teams), procurement/licensing, finance, and business units that use SAP. In these meetings, review user counts, indirect usage logs, and any changes in the SAP landscape (new modules, expansions, etc.). By having cross-functional oversight, you’ll catch issues that any one team might miss. For instance, IT might learn from a business unit that a new external app is being connected to SAP – a licensing red flag that needs to be addressed early.
- Visibility Through Dashboards: Maintain dashboards or reports that give visibility into key metrics relevant to SAP licensing. Track key metrics, such as the number of active named users versus licensed users, digital document counts (if on digital access licensing), HANA memory usage trends, and cloud service consumption (including user counts, transactions, and storage usage). Update these dashboards monthly and distribute them to the governance team regularly. This data-driven approach to SAP compliance planning helps avoid relying on gut feel or outdated assumptions. If something spikes or creeps upward, you have time to react.
- Simulate Audits and Educate Teams: Periodically conduct an internal “mock audit.” Have your team run SAP’s license measurement tools (such as LAW and USMM for ECC/S4), gather user classification reports, and verify them against entitlements. Test the process of responding to an audit letter – who would do what, how quickly can you compile the data, and what anomalies appear? This exercise not only tests your readiness but also often reveals minor inconsistencies that you can fix ahead of time. Additionally, educate your technical teams and end-users about licensing best practices and guidelines. For example, train developers to flag projects that might involve indirect access, or remind managers that adding 50 contractors to SAP requires proper licenses. Building a culture of license awareness greatly reduces unintentional compliance issues.
In conclusion, SAP audit readiness in 2025 and beyond is a strategic imperative.
The vendor’s audit focus is shifting with the times – targeting areas where today’s SAP customers are most likely to encounter issues, especially during the significant transition from ECC to S/4HANA and the expansion into cloud services.
CIOs and IT sourcing leaders should approach this with a healthy dose of skepticism and diligence. Assume that SAP audits will only get stricter as 2026 approaches, and plan accordingly.
By understanding the emerging audit trends and implementing strong governance, you can turn what is often seen as a reactive headache into a manageable, even routine, aspect of your SAP management.
Ultimately, the best defense against unexpected audit costs is straightforward: avoid surprises.
With preparation, transparency, and ongoing compliance efforts, you’ll know exactly where you stand – and you’ll keep your SAP environment under control no matter how hard the auditors come knocking.
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