If Windows Server is the house and SQL Server is the furniture, Remote Desktop Services (RDS) is the key to the front door.
For Service Providers, RDS is essential. It is the technology that allows you to deliver "Desktop-as-a-Service" or provide remote access to specific applications (like Microsoft Office) hosted in your datacenter. However, RDS licensing is often misunderstood, leading to some of the most common audit findings in the SPLA ecosystem.
Below is your guide to navigating RDS in SPLA, understanding the Subscriber Access License (SAL) model, and leveraging the new Flexible Virtualization Benefit.
The Standard SPLA Model: Subscriber Access Licenses (SAL)
Unlike Windows Server (which is licensed by Core) or SQL Server (which can be licensed by Core), Remote Desktop Services in SPLA is exclusively a User-based license.
The SAL Model
- How it works: You must report an RDS SAL for every unique individual authorized to access the shared server environment directly or indirectly.
- Concurrent vs. Authorized: SPLA does not support concurrent licensing. If you have 50 users created in Active Directory who can log in, you must pay for 50 SALs, even if only 10 log in at once.
The "Desktop Experience" Workaround
In the standard SPLA model, Service Providers are generally prohibited from hosting Windows Client Operating Systems (like Windows 10 or 11) on shared hardware.
- The Solution: To provide a desktop-like experience, providers typically use Windows Server with the "Desktop Experience" feature enabled.
- The Requirement: Because the user is accessing the Windows Server graphical user interface (GUI) remotely, an RDS SAL is mandatory for every user.
Common Compliance Pitfalls
Auditors frequently flag RDS errors because providers often assume the Windows Server license covers remote access. It does not.
- The "Office" Trap
If you are hosting Microsoft Office (e.g., Word, Excel) for a customer on your servers, the customer typically accesses it remotely.
- The Rule: You cannot use Office remotely without traversing the Windows Server GUI. Therefore, reporting Office SALs almost always requires reporting RDS SALs as well.
- Mistake: Reporting 50 Office SALs but 0 RDS SALs is an immediate red flag for auditors.
- The "Administrator" Exception
SPLA allows up to 20 distinct administrators per datacenter to access servers for maintenance without licenses.
- The Catch: This exception applies only to genuine administration (patching, maintenance). If an administrator uses the server for productivity (checking email, writing documents), they require an RDS SAL.
Special Scenario: The Flexible Virtualization Benefit (FVB)
The Flexible Virtualization Benefit, introduced in late 2022, revolutionized how desktop delivery works for Authorized Outsourcers. It effectively broke the long-standing rule banning Windows 10/11 on shared hardware.
The Scenario: BYO-Everything Your customer, DesignCo, has Microsoft 365 E3/E5 subscriptions or Windows 10/11 Enterprise E3/E5 licenses. They want a true Windows 11 desktop experience hosted in your cloud, but they don't want to use the Windows Server "Desktop Experience" workaround.
The New Rules (FVB):
- Windows 10/11 on Shared Hardware: Under FVB, if you are an Authorized Outsourcer (not a Listed Provider like AWS/Google/Microsoft/Alibaba), you can host Windows 10 or 11 Enterprise on your shared servers.
- No SPLA Reporting: You do not report RDS SALs or Windows Server licenses on your SPLA for these users.
- Customer Requirements: The customer must use their own subscription licenses or licenses with active Software Assurance (SA).
- Access: The customer’s users must be licensed with Windows 10/11 Enterprise E3/E5 or VDA (Virtual Desktop Access) per user.
- RDS CALs: If the solution involves accessing a Windows Server backend (rather than just a Windows 10/11 VM), the customer must bring their own RDS CALs with active SA.
Why this matters: Previously, offering a Virtual Desktop Infrastructure (VDI) with actual Windows 10/11 required Dedicated Hardware. Now, under FVB, you can host these VMs on Shared Hardware, significantly lowering the infrastructure cost for the provider and the customer.
RDS SAL Done Right with Octopus Cloud
With Octopus Cloud, you can confidently deliver remote desktops and applications without getting tripped up by RDS SALs or SPLA reporting.
From leveraging the Flexible Virtualization Benefit to hosting Windows 10/11 on shared infrastructure, Octopus Cloud ensures your licensing is correct, your audits are smooth, and your cloud services stay cost-efficient.
Focus on growing your business, and Octopus Cloud will take care of the licensing details. Reach out to our team today.




