Commission Seeks Feedback on SAP’s Proposed Commitments

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The European Commission has invited comments on commitments offered by SAP to address concerns that the company may have restricted competition in the market for maintenance and support services for its on-premises ERP software. The investigation, opened on 25 September 2025, preliminarily found that SAP holds a dominant position and may have imposed contractual conditions that limited customers’ ability to combine SAP’s support services with those of alternative providers, prevented the termination of support for unused licences and extended non-terminable licence periods. The Commission also expressed concerns about reinstatement and back-maintenance fees that could deter customers from switching away from SAP.

To resolve these concerns, SAP has proposed commitments allowing customers to split their systems into separate parts with different support providers, broaden access to single-metric contracts, clarify rules on initial licence terms and end the practice of restarting them, and abolish reinstatement fees while reducing back-maintenance fees. These commitments would apply worldwide for ten years and be monitored by an independent trustee.

The Commission is seeking feedback from interested parties within one month of the publication of the summary of commitments in the Official Journal, before deciding whether to make SAP’s commitments legally binding.