A global asset manager refused SAP's RFC inspection request under data-protection grounds, ran the measurement on its own terms, and settled at seventy per cent below the opening claim.
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The client is a global asset manager with operating subsidiaries in the United States, the United Kingdom, Luxembourg, and Singapore. SAP S/4HANA replaced ECC in 2024 under a phased conversion, with seven engine licences, an SAP BW data warehouse supporting regulatory reporting, and approximately 11,200 named users across the four regulated entities.
SAP's audit function issued a measurement notification together with a formal request for RFC inspection access to two production systems, citing the need to validate engine measurements directly against system data. The opening position arrived two weeks later at fourteen million five hundred thousand dollars, with $7.8M attributed to indirect-use exposure on the trading platform's connection to the SAP general ledger, $4.3M to USMM reclassification, and $2.4M to BW engine measurement.
The asset manager operates under data-protection regimes in four jurisdictions, and direct RFC access to production systems by an external party raised both regulatory and policy concerns. The matter was escalated to the data-protection officer within twenty-four hours of the RFC request being received.
External defence was instructed before any data was released and before any further engagement with SAP on the RFC request.
The defence opened with a written refusal of the RFC inspection request, citing the data-protection regimes in force in all four operating jurisdictions and the contractual language of the master agreement, which provides for measurement via the standard SAP LAW and USMM toolset and does not provide for direct system access by SAP personnel or its contractors. SAP's response was to request meetings with the data-protection officer, which we accepted on a written-record basis.
The measurement was then run under privilege using the standard LAW and USMM toolset, with the output reviewed line by line before transmission to SAP. The user classification rebuild followed the standard transaction-evidence methodology. Of the 4,100 users in dispute, 3,200 had no Professional-grade activity over the trailing twelve months. The corrected position on the USMM line was $0.7M against the $4.3M opening.
On the trading-platform indirect-use line, we documented the integration topology and demonstrated that the chargeable events under the existing contract definitions were the settlement-instruction posts only, not the full order-book activity SAP had assumed. The chargeable volume was approximately 320,000 events per month, not the 4.2 million in the opening position. Converted to Digital Access at a negotiated per-document tier, the final exposure was $2.4M against $7.8M.
The BW engine measurement was reconstructed against the actual cube and query activity, demonstrating that approximately one-third of the counted activity was reporting traffic excluded under the engine definition. The final BW position was $0.8M against $2.4M opening.
Settlement closed at four million four hundred thousand dollars cash, against the fourteen point five million opening claim. The reduction was approximately seventy per cent. The trading-platform indirect-use position was converted to Digital Access at a per-document tier with an annual measurement cap. No additional named-user licences were purchased.
Four contract clauses were rewritten in the release. The audit-rights clause was narrowed to a two-year cycle, with measurement strictly limited to the SAP LAW and USMM toolset and an explicit exclusion of RFC inspection access. A data-protection clause was added to the master agreement governing the handling and circulation of any measurement output. The engine measurement clause for BW was redefined to exclude reporting traffic by query class. And a settlement-as-release clause closed the audited period.
Elapsed time from the initial notification to signed release was thirteen weeks.
The matter closed under privilege and the specifics are confidential, but the methodology applies to most SAP estates of comparable size. The pattern is repeatable across the financial services sector and beyond.
For the firm's full procedural sequence on matters of this kind, see the SAP Audit Defence Playbook and the related working notes in the the sap audit letter response cluster.
The data-protection refusal of the RFC inspection set the negotiating tone for the entire process. After that, every measurement happened on contractual terms.
End-to-end engagement on matters of this kind. We take control of the process the day the letter arrives, define the scope in writing, validate every measurement, and negotiate the settlement.
Read the brief →We rebuild the integration topology, identify the chargeable events under the contract definitions, and convert exposure to Digital Access where the economics support it.
Read the brief →The topic page covering the field this matter sits within, with linked guides and field notes from across the practice.
How a global asset manager refused SAP's data-export request and forced the measurement to proceed under the existing audit-rights clause.
A Continental bank rebuilt 18,000 named-user classifications against transaction evidence, dropping the audit exposure by seventy-two per cent.
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