How to Avoid Common Pitfalls with your MSDPR Independent Assessment

Many suppliers working with Microsoft are now required to complete the Microsoft Supplier Data Protection Requirements (MSDPR) Independent Assessment each year to maintain Supplier Security and Privacy Assurance (SSPA) compliance. In practice, we continue to see organizations misinformed about what’s actually required, which often leads to unnecessary costs, re-tests, or delays. 

In this article, we break down three key areas suppliers should pay attention to when preparing for their MSDPR Independent Assessment so they can avoid common pitfalls and ensure successful compliance. 

3 Steps to Avoid Pitfalls in the MSDPR Assessment 

Successfully navigating the MSDPR assessment doesn’t have to be overwhelming. By focusing on a few key areas where suppliers often run into trouble, you can save time, reduce costs, and avoid unnecessary rework. Here are three practical steps to keep your compliance process on track. 

Step 1: Confirm Whether Section J Really Applies 

A common mistake we see is suppliers paying to have security requirements, known as Section J, assessed when it’s not necessary. If your organization already holds a valid ISO 27001 certification or a SOC 2 Type 2 report with an unqualified opinion covering the services provided to Microsoft, you do not need to cover Section J in your MSDPR Independent Assessment.  

Microsoft recently reinstated SOC 2 Type 2 as a valid option, which means suppliers now have two acceptable paths for demonstrating compliance for security requirements. Unfortunately, some auditors overlook this update, causing suppliers to pay extra fees for redundant and unnecessary testing.  

Please note, it’s important to verify that your ISO 27001 or SOC 2 Type 2 report is accepted by Microsoft and covers the same scope before excluding Section J from your independent assessment. 

Step 2: Ensure AI Requirements Are Properly Assessed 

If your organization provides AI-related services to Microsoft, as noted in your supplier profile, you’re subject to additional requirements under Section K of the MSDPR. 

Your AI controls must be assessed by a preferred assessor identified on Microsoft’s SSPA webpage. We’ve seen suppliers be required to undergo costly retests because their previously chosen auditor wasn’t aware of this requirement and was not on the preferred assessor listing. 

Before scheduling your assessment, confirm that your auditor is on Microsoft’s list of preferred assessors, which you can find here. 

Step 3: Plan Ahead to Avoid Deadline Pressures 

Timing is another area where suppliers often stumble. Microsoft grants a single default 90-day window to complete the MSDPR assessment each year, plus typically one 90-day extension — for a total of six months. 

A signed confirmation of engagement letter may allow for a short additional extension, but relying on this is risky. We encourage suppliers not to wait until the last minute as firms may have limited availability or may charge a premium for a tight turnaround on assessments. 

It’s best practice to start the engagement process early to avoid unnecessary stress, higher costs, and the risk of falling out of compliance. 

Keeping Your SSPA Compliance on Track 

Avoiding pitfalls in the MSDPR Independent Assessment comes down to preparation and awareness. By confirming whether Section J applies, ensuring AI requirements are handled by a Microsoft-preferred assessor, and planning well ahead of deadlines, suppliers can save both time and money while keeping their SSPA compliance on solid ground. 

If you have questions about the MSDPR or the SSPA program, our team at Schellman is here to help. Contact us to learn more. 

In the meantime, discover additional Microsoft SSPA and DPR insights in these helpful resources:   

• An Overview of Microsoft DPR, Its New AI Requirements, and ISO 42001’s (Potential) Role 
• The Cost of an MS DPR Assessment  
• How to Leverage HITRUST Certification into Microsoft SSPA