Managing Who Has Access to Copilot

Overview

The fastest way to create Copilot risk in your organization is to turn it on for everyone before you’re ready. The fastest way to reduce that risk is through controlled access: deliberate licensing, pilot groups, and strong identity enforcement.

For government agencies operating in GCC, GCC High, or DoD environments, access management isn’t just about security. It’s about proving that every Copilot user was intentionally authorized, that access follows your existing identity and device standards, and that you can audit the entire chain of decisions.

This video walks you through the practical mechanics of Copilot access management: how to structure your licensing strategy, how to use group-based assignment for scale and auditability, and how to enforce your identity requirements through Conditional Access policies.

What You’ll Learn

• Licensing Strategy: How to start with a pilot group and expand deliberately using group-based assignment
• Conditional Access Enforcement: How to require MFA, compliant devices, and location restrictions for Copilot users
• Implementation Walkthrough: Step-by-step process to create access groups, assign licenses, and apply policies
• Validation and Operations: How to test your controls and maintain ongoing access reviews

Script

Hook: access control is your first governance win

The fastest way to create Copilot risk is to turn it on for everyone before you’re ready.

When you do that, you’ve got hundreds of users suddenly interacting with organizational data in new ways. You haven’t validated your permission model. You haven’t tested your audit logs. You haven’t aligned with your security baseline. That’s not a pilot. That’s an uncontrolled experiment.

The fastest way to reduce risk is controlled access: pilot groups, deliberate licensing, and strong identity enforcement.

If you get access management right, everything else gets easier. You’ve got a contained population to validate with, clear audit trails, and a foundation that scales safely. Let’s talk about how to build it.

Control lever number one: licensing strategy

Access management starts with licensing. The strategy is simple: start small, make it intentional, keep it auditable.

Start with a pilot group. Not “everyone in finance” or “all executives.” A specific set of users who understand they’re testing, know what feedback you need, and represent realistic work patterns.

Why so deliberate? Because every Copilot license is a decision. You’re saying this person should use AI to interact with organizational data. That decision needs to be defensible.

You could assign licenses one by one through the admin center, but that doesn’t scale and it’s not auditable. What you want is group-based licensing.

Create an Entra ID group specifically for Copilot access. Something like “Copilot-Pilot-Users.” Assign the Copilot license to that group. Now membership automatically controls who gets the license.

Why does this matter? Your audit question changes from “show me everyone with a Copilot license” to “show me the Copilot access group and its change history.” That’s a much cleaner answer for your authorizing official or auditors.

Here’s the practical guidance: if you can’t explain why someone has Copilot, you’re not ready to expand the rollout.

Every person in that group should be there for a documented reason. When you expand beyond the pilot, you expand the group deliberately. You add people to the group, and the licensing follows automatically.

Control lever number two: enforce identity and session requirements

Licensing controls who can potentially use Copilot. Conditional Access controls under what conditions they can actually access it.

This is where you align Copilot access to your existing identity and device standards. For government agencies, this is critical. You already have remote access requirements. You already have privileged access baselines. Copilot needs to follow those same rules.

Let’s talk about the most common Conditional Access patterns for Copilot users.

First, require multi-factor authentication. If someone’s accessing organizational data through an AI interface, you want strong identity verification. MFA should be non-negotiable.

Second, require a compliant device. This means the device accessing Copilot meets your security baseline: it’s managed, it’s got the right patches, it’s not jailbroken or rooted. You don’t want Copilot accessible from a random personal laptop.

Third, restrict risky sign-ins. Entra ID can detect anomalous sign-in patterns and elevated risk scores. You can block or require additional verification when someone tries to access Copilot from an unusual location or with suspicious activity patterns.

Fourth, consider location restrictions where appropriate. For some agencies, Copilot access should only be available from approved network locations or through your VPN. You can enforce that through Conditional Access.

Here’s the key point for government environments: this is where you align Copilot access to your existing remote access and privileged access standards. You’re not creating new requirements from scratch. You’re applying the controls you already use for sensitive systems.

In GCC High and DoD environments, you’ve likely got baseline policies already in place for Microsoft 365 workloads. Copilot should inherit those policies. If you’re treating Copilot users as a higher-risk population, you can layer additional requirements on top.

The technical mechanism is straightforward. You create a Conditional Access policy. You target it to the Copilot access group. You define the conditions: MFA required, device compliance required, block risky sign-ins, allow only from approved locations. Then you enforce it.

Now your access control is multi-layered. Licensing says who’s authorized. Conditional Access says under what conditions.

Walkthrough: implement and validate

Let’s walk through the implementation steps so you can see how this actually works.

Step one: create an Entra ID group for your Copilot pilot. Go to Entra ID in the Azure portal or the Microsoft 365 admin center. Create a new security group. Name it something clear like “Copilot-Pilot-Users.” Make it a dynamic group if you want rule-based membership, or a static group if you want manual control. For most pilots, static is simpler.

Step two: assign licenses to the group. Go to the group properties. Under licenses, add the Microsoft 365 Copilot license. Now, anyone you add to this group will automatically receive the license. Anyone you remove loses it.

Step three: apply Conditional Access to that group. Go to Entra ID, then Conditional Access policies. Create a new policy. Name it something descriptive like “Copilot Access - Require MFA and Compliant Device.” Under users and groups, target your Copilot access group. Under cloud apps, select Microsoft 365 Copilot or the broader Microsoft 365 suite if you want consistency. Under conditions, configure what you need: locations, device platforms, sign-in risk levels. Under access controls, set your requirements: require MFA, require device compliance, whatever fits your baseline.

Step four: validate with test cases. This is where a lot of organizations skip a critical step. You need to actually test that your controls work.

Here’s what good validation looks like. Add a test user to the Copilot group. Wait for license propagation. Then have that user try to access Copilot from a compliant device with MFA. They should succeed.

Now test the negative case. Have a user who’s not in the group try to access Copilot. They should be blocked or see a message that they don’t have the required license.

Test device compliance. Have someone in the group try to access Copilot from a non-compliant device or a personal device that’s not managed. They should be blocked with a clear error message.

Test location restrictions if you’ve configured them. Try accessing Copilot from outside your approved network or VPN. It should be blocked.

Finally, check your logs. Go to Entra ID sign-in logs. Look for Copilot-related sign-ins. You should see successful access for authorized users from compliant devices. You should see blocked attempts for users outside the group or from non-compliant contexts.

If your logs show what you expect, your controls are working. If they don’t, you’ve got a misconfiguration to fix before you expand the rollout.

Ongoing operations: review and reporting

Access management isn’t one-and-done. You need ongoing reviews and clear reporting.

Here’s what that looks like in practice.

Every month, review who has licenses. Pull a report from the admin center or use PowerShell to export group membership. Ask the question: should all these people still have Copilot access? Are there any users who’ve changed roles, left pilot participation, or no longer need the license?

Review your Conditional Access policies. Are they still aligned with your security baseline? Have you updated device compliance requirements or MFA policies elsewhere? Make sure Copilot policies stay consistent.

Track exceptions and document why. If someone needs Copilot access but can’t meet a particular requirement, that’s an exception. Exceptions need approval, documentation, and review dates.

For government environments, keep a change log. Every time you add someone to the access group, remove someone, or modify a policy, log it. Who made the change, when, and why. When auditors ask how you control Copilot access, you hand them the group membership history and the change log. That’s a defensible answer.

Use your identity governance tools. If you’ve got Entra ID Governance or privileged identity management, you can automate access reviews. Set up a quarterly review where group owners or managers certify that group members still need access. Anyone who’s not recertified gets removed automatically.

The key insight here is that access management is an ongoing practice, not a one-time setup. Treat Copilot access like you’d treat privileged access to a sensitive system. Regular reviews. Clear accountability. Auditable decisions.

Close: the reusable pattern

Here’s the pattern you can reuse across your organization.

Access to Copilot is controlled through three layers: licensing, group membership, and Conditional Access enforcement.

Licensing is assigned through group membership, not individual grants. If you’re in the Copilot access group, you get the license. If you’re not, you don’t.

Conditional Access enforces your identity and device requirements. MFA, compliant devices, approved locations, and risk-based blocking all layer on top of the licensing decision.

Validation happens through repeatable test cases and log review. You prove that authorized users can access, unauthorized users can’t, and non-compliant contexts are blocked.

Ongoing operations include monthly access reviews, change logging, and alignment with your broader identity governance program.

That’s controlled access. It’s auditable. It’s defensible. And it scales safely as you expand your Copilot rollout across GCC, GCC High, or DoD environments.

Sources & References

• Enable Users for Microsoft 365 Copilot — Primary documentation for enabling users and controlling access
• Assign Licenses to Users — License assignment options, including group-based approaches
• Conditional Access Overview — Conditional Access concepts used to enforce identity and session requirements