Microsoft 365 Copilot and Cyber Essentials

Where Copilot sits

Microsoft 365 Copilot is licensed on top of an eligible Microsoft 365 or Office 365 plan. Users sign in with a work or school account in Microsoft Entra ID, and Copilot works with the content those users can already access in services like Outlook, Teams, SharePoint and OneDrive.

For Cyber Essentials, Microsoft 365 is already an in-scope cloud service (SaaS). Copilot is a feature of that service rather than a separate one, so you do not normally list it as a new scope item. If you also use other AI tools outside Microsoft 365, see AI tools and Cyber Essentials scope.

Entra ID and work accounts

• Every Copilot user has an individual Entra ID account. Shared logins should not be used.
• Joiner and leaver processes cover Copilot licences as well as accounts, so leavers lose access promptly.
• Guest and external accounts are reviewed, since they also sign in to your tenant.

MFA and admin accounts

Authentication to cloud services must use MFA, so every account that can use Copilot must be covered by your MFA policy. Copilot does not change that requirement, but a rollout is a good moment to confirm it.

• Enforce MFA for all users, ideally through Conditional Access, with no legacy authentication route around it.
• Keep Global Administrator and other privileged roles to a small number of separate admin accounts, protected by MFA.
• Licence management and Copilot settings are admin functions. Make sure the people doing them use their admin accounts, not their everyday ones.

Passkeys can satisfy the MFA requirement. See passkeys and Cyber Essentials.

Devices accessing Copilot

Copilot is used from Windows PCs, Macs, phones and the web. Every device staff use to access Microsoft 365 for work, whether company-owned or personal, needs to meet the Cyber Essentials controls that apply to its device type, such as a supported operating system, CE-required vulnerability fixes applied within 14 days, malware protection where applicable, and secure configuration including device unlocking. If you allow personal devices, check how you apply those controls (for example through app protection policies or device enrolment).

Plugins, connectors and agents

Copilot can be extended with connectors, plugins and agents that reach other data sources or services. Keep two questions separate:

Oversharing is the most talked-about Copilot risk. It matters, but it is a data access and governance issue, not a Cyber Essentials control.

Evidence to prepare for Cyber Essentials

• Your MFA or Conditional Access policy and the users it applies to.
• Confirmation that legacy authentication is blocked.
• A list of privileged role holders and their separate admin accounts.
• Your device inventory showing operating system and update status.
• A note of any third-party services connected to Copilot and how they are covered.

For the full tenant checklist, use our Microsoft 365 Cyber Essentials guide. For evidence specifically about MFA, see Microsoft 365 MFA evidence.

What Cyber Essentials does not cover

• How Microsoft's models work or how Copilot generates answers.
• Sensitivity labels, data loss prevention and retention policies.
• Whether Copilot output is accurate or appropriate.
• Your AI usage policy and staff training.

These are worthwhile, but they sit outside Cyber Essentials. If you build AI products rather than use them, see Cyber Essentials for startups and AI companies.

Sources

• Microsoft Learn: Microsoft 365 Copilot requirements
• NCSC Cyber Essentials resources, including Requirements for IT Infrastructure v3.3