Licensing Windows Desktop OS on GCP

Google will enable you to bring your own licensing for Windows Desktop Operating System to GCP sole-tenant[1] and remain compliant for Microsoft licensing.

Assigning a License

Before you bring your own Windows Desktop OS license to GCP, you must first assign a Windows Desktop OS license to the end-user, referred to as a “licensed user”, or “licensed device”, typically a personal computer.

To ‘assign’ a license means simply to designate that license to a user or device that can access the Windows Desktop OS in a virtual machine.

Running Windows Remotely

You can bring your own Windows 7, Windows 8.1, or Windows 10 desktop and run iton GCP sole-tenant and remain license compliant. Under the assigned volume license, you may access Windows Desktop OS remotely in a virtual machine as a benefit of Software Assurance for Windows.

GCP will ensure isolation of the hardware and other resources to make sure it remains fully dedicated to your use.[2] GCP will not support two customers to share the same set of resources, such as hardware or storage for the term of your subscription.

License Model

User Subscription Licenses – Remote use of the Windows desktop OS deployed on a GCP sole-tenant is allowed for the licensed user, who is the primary user of at least one device, which is their primary work device. There must be a qualifying Windows desktop OS installed and licensed via an OEM license, on the accessing device.

Per Device Licenses – Remote use of the Windows desktop OS deployed on a GCP sole-tenant is allowed for the licensed ‘primary’ user, of the licensed device, or for any other user, from another separately licensed device. There must be a qualifying Windows desktop OS installed and licensed via an OEM license, on the accessing device.

Microsoft defines the ‘primary’ user an individual that would use the licensed device more than 50% of the time in any 90 day period, so a per-device licensing model may not be suitable for some shift workers or workers in shared workspaces.

VDA[3] User Subscription Licenses – Under this licensing model, remote use of the Windows desktop OS deployed on a GCP sole-tenant is allowed for any assigned licensed user or device. There is no minimum ‘primary’ user requirement for the end-user accessing device, or a requirement for a ‘qualifying’ Windows OS to be installed on the accessing device.

This licensing model is more suitable for businesses that plan to use Google Chrome books, or other client devices where there is no OEM licensed Windows desktop OS on the accessing device.

Developer Licensing – Under a Visual Studio subscription license, use is permitted for the purposes of design, development, testing and demonstrations of your programs. However, in most situations the software will be used in another way, and a Windows Desktop OS license is required for the licensed device or licensed for remote access.

Volume Agreement

You can use Windows 10 Enterprise E3 or E5 licenses, Windows 10 Education E3 or E5 Licenses, Windows 10 Enterprise VDA licenses, or Microsoft 365 E3 or E5 licenses, via most Microsoft Volume Agreements.

Software Assurance is already included when purchasing via Enterprise Agreement (EA), Microsoft Products and Services Agreement (MPSA), Open Value, and Open Value Subscription Agreements, and Enrollment for Education Solutions (EES), and (OVS-ES).

You can use Windows 10 Enterprise Edition Per-Device Licenses, via Enterprise Agreement (EA), or other volume licensing programs.

You cannot use Windows Desktop OS licensed via a Microsoft Cloud Agreement (MCA)[4] on GCP.

Software Assurance

Under the assigned volume license, you may access Windows Desktop OS remotely in a virtual machine as a benefit of Software Assurance for Windows. It is recommended to maintain active Software Assurance to enable access to ‘New Version Rights’ as new software versions are released, and other Software Assurance Benefits.[5]  

Qualifying Operating System

Microsoft Volume Agreements do not offer licenses for the full Windows Desktop OS. This is an ‘upgrade license’ and requires the associated device to be already licensed with an ‘Qualifying Operating System’.[6]

The ‘qualifying’ desktop OS is purchased pre-installed through an Original Equipment Manufacturer (OEM), or System Builder, as a retail packaged product. This is commonly available as ‘Pro Edition’.

Windows Pro OEM licenses do not confer virtualization rights to run Windows Desktop OS on GCP sole-tenant. An ‘upgrade license’ must be purchased via a Volume Agreement with active Software Assurance to enable you to bring your own licensing to GCP. If there is no qualifying desktop OS, then VDA user subscription licenses are available.

Per Device Licenses – When you purchase under an existing active volume agreement program, such as Enterprise Agreement (EA) and Open Value Company Wide (OV CW), you can use the software on devices licensed with specific prior qualifying versions of the software (Windows 8.1 or Windows 7).

When you purchase Windows desktop OS per-device licenses under a new volume agreement program, like Enterprise Agreement (EA), or Open Value Company Wide (OV CW), you can use the software on devices licensed with specific prior qualifying versions of the software (Windows 8.1 or Windows 7, Windows Vista, or Windows XP, or Apple MacOS).

If you purchase under a new or existing Education program, you can use the software on devices licensed with all versions of the software. (Windows 8.1 or Windows 7, Windows Vista, or Windows XP Pro). Windows Home Edition is also a ‘qualifying OS’ for the accessing device.

If you purchase under a new or existing Microsoft Products and Services Agreement (MPSA), or Select Plus program, you can use the software on devices licensed with specific prior qualifying versions of the software. (Windows 8.1 or Windows 7, Windows Vista, or Windows XP, or Apple MacOS).

User Subscription Licenses – Applicable to Windows Enterprise User Subscription Licenses, and VDA User Subscription Licenses, when you purchase a Windows desktop OS under a new or existing volume agreement such as Enterprise Agreement (EA), Microsoft Products and Services Agreement (MPSA), you can use the software on devices licensed with specific prior qualifying versions of the software (Windows 8.1 or Windows 7).

 Right to Run Prior Versions 

This is commonly referred to as ‘downgrade rights’. Microsoft volume agreements provide you with the right to downgrade to any prior version of the same product.[7] The use rights for the licensed version will still apply.

For example, you may downgrade Windows 10 Enterprise to Windows 8.1 Enterprise, or Windows 7 Enterprise.

When purchased under a Microsoft Cloud Agreement (MCA), the right to run or install a prior version of Windows 10 Enterprise E3 is not permitted.[8] The program also does not permit remote access of the Windows Desktop OS in a virtual machine on Google Cloud Platform[9].

If some users are licensed for Windows Desktop OS as part of a Microsoft 365 F1 user subscription, the licensed users cannot access prior versions, or remotely access of the Windows Desktop OS in a virtual machine [10] on GCP.

[1] Sole-tenant is a single-tenant server that is dedicated to one GCP account.

[2] Please refer to Section 8. “Outsourcing Software Management” in the Microsoft Product Terms, February 2019, page 6 of 112.

[3] ‘Virtual Desktop Access’ (VDA).

[4] Please refer to the Microsoft Product Terms for the use restrictions for Microsoft Cloud Agreement (Ref: Microsoft Product Terms, February 2019, Page 41 of 112).

[5] Microsoft confers ‘New Version Rights’ in the Microsoft Product Terms, February 2019, page 78 of 112.

[6] Please refer to the Microsoft Product Terms for a comprehensive list of ‘qualifying operating systems’ (Ref: Microsoft Product Terms, February 2019, Pages 38-39 of 112).

[7] There is a useful Microsoft licensing brief on downgrade rights available here.

[8] Please refer to the Microsoft Product Terms for the use restrictions for Microsoft Cloud Agreement (Ref: Microsoft Product Terms, February 2019, Page 41 of 112).

[9] Please refer to the Microsoft Product Termsfor the use restrictions for Microsoft Cloud Agreement (Ref: Microsoft Product Terms, February 2019, Page 41 of 112).

[10] Please refer to the Microsoft Product Terms for the use restrictions for Microsoft 365 F1 Windows 10 E3 (Ref: Microsoft Product Terms, February 2019, Pages 53-54 of 112).

Thanks All


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Tony Mackelworth is Head of Microsoft Advisory Services at SoftwareONE

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