As of 17 April 2026, Flex Routing is enabled by default for all Microsoft Copilot tenants in the EU and EFTA regions. Flex Routing lets Copilot’s AI processing (LLM inference) be routed to data centres outside the EU during peak demand, while customer data at rest remains within the EU Data Boundary. It may not be automatically non-compliant with GDPR — but it does require an explicit, documented decision. Here is what changed, the legal and governance implications, and the steps every organisation should take.
Puntos clave
- Since 17 April 2026, Flex Routing is enabled by default for existing EU/EFTA Microsoft Copilot tenants (and ON by default for tenants created after 25 March 2026), unless an administrator disables it.
- Flex Routing can route Copilot LLM inference to data centres outside the EU (for example the US, Canada, or Australia) during peak load — but data at rest stays within the EU Data Boundary, and all data remains encrypted in transit and at rest.
- It applies broadly: Microsoft 365 Copilot and Copilot Chat, Copilot in Dynamics 365, and Power Platform Copilot and Copilot Studio (Power Platform inherits the Microsoft 365 setting unless configured more restrictively).
- Flex Routing is not automatically a GDPR violation — Microsoft covers it under its Data Protection Addendum, Standard Contractual Clauses, and the EU–US Data Privacy Framework — but internal EU-only policies, DORA/NIS2, or contractual residency commitments may still require it to be disabled.
- The setting lives in the Microsoft 365 Admin Center (Copilot settings); the customer must review and change it themselves, and changes take effect after a short propagation delay.
- The real risk is inaction: leaving Flex Routing enabled without review or documentation can create governance, audit, or contractual exposure even where the processing is legally permitted.
Frequently Asked Questions
Preguntas frecuentes
What is Copilot Flex Routing?
Flex Routing is a Microsoft capability that maintains Copilot performance and availability during peak demand by allowing large language model (LLM) inference to be processed in data centres outside the EU when EU capacity is constrained. Data at rest remains within the EU Data Boundary; only processing may temporarily occur elsewhere, and all data stays encrypted in transit and at rest.
What exactly changed, and when?
Microsoft changed the default behaviour: tenants created after 25 March 2026 have Flex Routing ON by default, and existing EU/EFTA tenants have had it enabled by default since 17 April 2026 unless an administrator disabled it. It applies across Microsoft 365 Copilot and Copilot Chat, Copilot in Dynamics 365, and Power Platform Copilot and Copilot Studio.
Is Flex Routing a GDPR violation?
Not automatically. Microsoft covers this processing model under its Data Protection Addendum, the Standard Contractual Clauses, and the EU–US Data Privacy Framework. However, legal permissibility is only part of the picture — organisations with EU-only processing policies, sector regulations such as DORA or NIS2, or contractual data-residency commitments may still need to disable it.
How do we review or disable Flex Routing?
An administrator reviews the setting in the Microsoft 365 Admin Center under Copilot settings. Power Platform inherits the Microsoft 365 configuration unless set more restrictively. The customer must make this change themselves; it takes effect after a short propagation delay and can be changed at any time.
What should organisations do next?
Take a conscious, documented approach: review the current Flex Routing setting, assess your legal, regulatory, and contractual obligations, then make and document a decision — either enable Flex Routing for performance and availability, or keep it disabled to enforce EU-only inference. Transparency and a recorded rationale are what protect you in an audit, not the setting alone.
Qué significa esto para usted
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