SAP’s New API Policy Raises New Compliance and Continuity Risks

Time 4 Minute Read
Legal Update

In late April 2026, SAP published a new API Policy on the SAP Help Portal as part of the product documentation for relevant SAP solutions. The policy states that it “forms part of the Documentation” for the SAP solution with which it is provided and is intended to standardize the use of APIs, extensions, and related data transmission interfaces made available as part of SAP solutions. At a high level, the policy limits permitted use to APIs published in the SAP Business Accelerator Hub or otherwise identified in product-specific documentation, and only for the documented purposes described there, such as integration, extensions, data synchronization, data exchange, and event-triggered business scenarios. The policy also prohibits access to non-published APIs unless SAP documentation or SAP authorization permits it, requires customers and partners to verify that endpoints used for documented purposes are “Published APIs,” and imposes API-specific controls such as rate limits, quotas, depreciation schedules, data ingress/egress quotas, bulk extraction conditions, and other technical or security requirements. In addition, SAP prohibits API use for competitive analysis, undocumented or unauthorized scenarios, activity that risks system performance or security, and—except through SAP-endorsed architectures, data services, or service-specific pathways—certain AI-driven interaction, scraping, harvesting, and systematic or large-scale extraction or replication. SAP further states that it may monitor API usage and take enforcement action, including throttling, suspension, or termination of access, for non-compliance, while also preserving any legal obligation it may have to provide required data export or other data egress capabilities.

For customers, the practical impact is that SAP now has a more explicit policy basis for scrutinizing integration patterns, especially where a customer relies on non-published interfaces, bulk extraction, or AI-enabled or automated interaction with SAP environments. Even where SAP characterizes the policy as clarifying existing rules, the policy’s verification requirements, use restrictions, monitoring language, and operational remedies can create real implementation and business continuity risk if SAP concludes a customer’s current architecture is out of bounds. Customers should therefore review their SAP agreements to determine whether later-issued policies can actually become contractually operative. Customers should focus in particular on amendment provisions, the definition of “Documentation,” provisions negating online or portal terms, and limits on SAP’s monitoring rights. Customers should also look for clauses limiting SAP’s unilateral modification rights to service changes that do not materially degrade core functionality, and for restrictions on product supplements or service descriptions that cannot impose additional customer obligations or alter existing use rights. In short, the key contractual question is whether the customer’s agreement allows SAP to treat a later-posted API policy as binding Documentation at all—and, even if it does, whether all or only portions of that Documentation can have effect.

Read our previous client alert on Salesforce’s modifications to its Slack API Terms of Service.

Should you need any assistance analyzing or negotiating these issues, please contact a member of Hunton’s global technology, sourcing and complex contracting team. 

About Hunton’s Global Technology, Sourcing and Complex Contracting Team

Hunton’s global technology, sourcing and complex contracting team combines remarkable depth and breadth of experience on a worldwide platform. In any given year, the team works on multiple domestic, global, offshore and multi-shore sourcing and technology transactions with total contract value in the billions of dollars. We are well-versed in these issues, have guided customers through contract negotiations for decades, and are happy to assist you as you manage these developments.

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