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What leaves Europe

  1. Comparison table

    Does Copilot stay inside the EU Data Boundary?

    Eligible Microsoft 365 Copilot is an EU Data Boundary service. That sentence is true and incomplete. Flex Routing inferencing, Anthropic models, web grounding, Multi-Geo and Foundry Global are not the same row. Data at rest is not the same as inferencing.

    Inside or outside the EU Data Boundary
    PathIn the EU Data Boundary?Leaves or excluded whenWhat to check
    Microsoft 365 Copilot (eligible tenant, Flex Routing off)Yes — listed EUDB serviceYou are not eligible (e.g. Multi-Geo), or you enable an excluded model / web groundingOrg profile; Copilot is an EUDB workload
    Copilot Chat (work, commercial, eligible)Yes, same catalogueSame exceptions as CopilotEnterprise data protection / DPA applies to work identity
    Data at rest (prompts stored, Graph content)Yes, stays in the BoundaryLimited pseudonymized operational data may be stored outsideDo not confuse storage geo with inferencing geo
  2. Three-way split

    If Copilot is in the EU Data Boundary, is Azure AI Foundry too?

    No. Copilot EU Data Boundary, Foundry Data Zone EU and Foundry Global are three commitments. Copilot tenant settings do not govern Foundry. A green Copilot score does not cover a Global model endpoint.

    Copilot EUDB ≠ Foundry Data Zone ≠ Global
    PathWhere prompts inferWhat it is not
    Copilot, Flex Routing offEU Data Boundary (eligible tenants)Not a Foundry deployment type. Does not govern Azure resources.
    Copilot, Flex Routing onUS, Canada or Australia at peak loadNot Foundry Global. Different toggle, different product.
    Foundry regional EU resourceThat Azure region, unless the model card says otherwiseNot Copilot EUDB. Resource region is a choice in Azure.

Common questions

Does Copilot Flex Routing leave the EU?

Inferencing can. Data at rest does not, except limited pseudonymized operational data. Prompts, responses and grounding data may be processed in the United States, Canada or Australia when Flex Routing is on and EU capacity is tight.

If Copilot is in the EU Data Boundary, is Azure AI Foundry too?

No. Copilot settings do not govern Foundry. Foundry follows resource region and deployment type.

Is Microsoft’s Copilot DPIA template enough for Article 35?

No. The template does not know your Flex Routing value, oversharing picture, or whether DLP lists Copilot as a location. Those are tenant rows.