Cyber Essentials v3.3 and Microsoft 365: The Cloud Asset Check UK SMEs Should Do Before Renewal

Under Cyber Essentials v3.3, Microsoft 365 and your other cloud services are firmly in scope. Here's a practical asset check covering users, devices, guests and admin accounts to do before your next renewal.

Cyber Essentials v3.3 and Microsoft 365 cloud asset check

For many small businesses, "our systems are in Microsoft 365" can sound like the end of the security conversation. In practice, it's the point where the conversation needs to get more specific.

The NCSC's Cyber Essentials Requirements for IT Infrastructure v3.3, which applies from April 2026, says cloud services that hold your organisation's data or run its services must be in scope, and it uses Microsoft 365 as an example of software as a service (SaaS).

That doesn't mean you're expected to run Microsoft's data centres or patch Microsoft's servers. It does mean you're responsible for the parts you control: who can sign in, which devices can reach your information, how the service is configured, and whether access is removed when it's no longer needed.

The same goes for your other cloud platforms: file sharing, CRM, finance software, hosted phones and online project tools.

Why an asset list beats a software list

A software list might say "Microsoft 365, accounts package, CRM and backup". A useful asset review asks better questions:

  • Which people use each service?
  • Which laptops, phones and tablets can access company information?
  • Which accounts have administrator rights?
  • Which guests, contractors or suppliers still have access?
  • Which business processes would stop if a service or account became unavailable?
  • Who is responsible for configuring and reviewing each service?

Cyber Essentials v3.3 describes asset management as a core security function that supports all five technical controls, even though it isn't one of the five itself. That's the right way to think about it: the list isn't paperwork for its own sake. It should help you make better decisions about firewalls, configuration, updates, access and malware protection.

A practical Microsoft 365 asset review

You don't need a perfect catalogue on day one. Start with the assets most likely to affect continuity or expose sensitive information.

1. Record your core cloud services

Write down your Microsoft 365 tenant and every other cloud platform the business relies on. Include the owner, supplier, purpose, renewal date and the type of information held there.

Be specific. "Microsoft 365" is a starting point, but SharePoint, OneDrive, Teams, Exchange Online and Entra ID can each have different settings, owners and access patterns.

2. Check users and privileged accounts

Export or review your current user list and look for:

  • former staff whose accounts are still enabled
  • dormant accounts that are no longer needed
  • shared accounts with no clear owner
  • guest users invited for a short-term project
  • administrator accounts being used for everyday email and browsing

Cyber Essentials v3.3 expects accounts to be removed or disabled when they're no longer required, including after someone leaves or after a set period of inactivity. Our employee offboarding checklist covers the leaver side in detail, and too many admin accounts is one of the most common gaps we find.

Record the action, owner and date for anything that needs fixing. A short, trackable list of improvements is worth far more than a long report.

3. Review the devices that reach business data

List company laptops, desktops, phones and tablets, then identify any personal devices used for work. Note who owns each one, who uses it, whether it's still supported, and whether it can be locked or wiped remotely if needed.

Microsoft's security guidance for businesses with up to 300 users recommends protecting every device that accesses company data, personal or company-owned, using device management, multi-factor authentication and, where available, Conditional Access.

This is where a vague BYOD policy becomes a practical decision. You might allow personal phones to read email but not download sensitive files, or require an approved app and a screen lock. The right answer depends on the information and how your team works.

4. Check how access is configured

For each important service, ask whether:

  • multi-factor authentication is on for every user
  • administrators use separate accounts for admin work
  • access is restricted when a device or sign-in looks risky (see our guide to Conditional Access)
  • external sharing is limited to what the business actually needs
  • leavers and role changes are handled promptly

Don't treat a green dashboard or a high Secure Score as proof that everything is safe. Use those tools to find actions, then confirm the settings fit the way your team really works.

Turn the review into a renewal-ready plan

Once you have the list, split the findings into three groups:

  1. Fix now: enabled leaver accounts, missing MFA, unsupported devices, unknown administrators.
  2. Plan next: device management, guest access reviews, sharing rules, better logging.
  3. Document: what's in scope, who owns each service and how changes are approved.

Keep the evidence proportionate. A dated asset list, an access review, a device register and a short record of what you've fixed will make your next assessment much easier, and it lets your IT provider focus on the real gaps instead of rebuilding the picture from scratch. If you're preparing for certification for the first time, our Cyber Essentials prep checklist walks through the rest.

Cyber Essentials isn't a substitute for sensible day-to-day security, and your certification body has the final say on scope. But v3.3 is a useful prompt for any business that has grown quickly in the cloud.

Your next step

Set aside an hour this week with someone who understands the business, not just the technology, and walk through your Microsoft 365 users, devices, cloud services and suppliers. Give every item an owner and a next action.

If the list turns up unknown accounts, unmanaged devices or services nobody owns, that's useful information, not a failure. Managed IT Support can help turn it into a practical plan. Book a free IT review or email hello@managedtech.uk and we'll go through it with you.

The goal isn't a perfect spreadsheet. It's a clear view of what your business depends on, who can reach it, and what needs attention before a renewal, incident or urgent change exposes the gaps.

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