Agent Builder on DR.365

Agent Builder, Copilot Studio or Foundry: who owns the risk?

Mon, 19 Oct 2026 07:00:00 +0200

Three requests arrive in the same week. HR wants an agent that answers questions about the travel expense policy. The service desk wants an agent that creates tickets in the ITSM tool. Legal wants an agent that checks supplier contracts against a clause library and flags deviations. All three are “an agent”, and in most tenants the same person could build all three on the same afternoon.

The governance questions behind them are very different, and the choice of tool answers many of them before anyone writes a policy. That is why this series starts here, before lifecycle, runtime controls and compliance. Microsoft recently described how it enables agent creation in its own tenant (Microsoft Inside Track). I use that guide as a starting point, but I read it from a different seat: that of an operator in a regulated environment, usually with several tenants and an IT service provider in the picture.

Three tools, three kinds of builders

Agent Builder in Microsoft 365 Copilot is for information workers. Its agents answer questions from content the user can already reach: SharePoint, OneDrive, email, Teams messages, Copilot connectors, Dataverse or the web. Code interpreter and image generation are built in, so “retrieval only” is not quite accurate. What Agent Builder cannot do is call external services. There are no actions, connectors or workflows, and Microsoft’s answer for those is to copy the agent to Copilot Studio (Microsoft Learn).

Copilot Studio is for makers, from trained business users to Power Platform developers. Agents reach other systems through connectors, run agent flows with approvals, react to triggers as autonomous agents and call other agents. Governance lives in Power Platform environments: data policies, separate development, test and production environments, and admin approval before an agent is published to the organization (Microsoft Learn).

Microsoft Foundry and the Microsoft 365 Agents Toolkit are for developers. In Foundry, the team picks the model, writes the orchestration and runs the agent as hosted code with its own Entra identity (Microsoft Learn). The Agents Toolkit in Visual Studio Code builds both declarative agents, which use the Copilot orchestrator just like Agent Builder agents, and custom engine agents with their own orchestration (Microsoft Learn). So the tool alone does not decide who carries the risk. The architecture does.

Who carries the risk?

Microsoft’s guide sorts the three tools by who owns the risk. Agent Builder has intrinsic governance: the platform carries the risk, because the agent stays inside existing Microsoft 365 boundaries. Copilot Studio has configurable governance: the administrator carries the risk, because connectors, flows and data movement need rules. Foundry has explicit governance: the organization carries the risk, because it decides on model, orchestration and architecture.

I find the distinction useful, with one caveat for the first model. “The platform carries the risk” describes the technical boundary. Agent Builder grants no new permissions and only uses content the user can already see (Microsoft Learn). The data risk stays with you: an agent on top of an overshared SharePoint site makes the oversharing easier to find. In addition, every user may share Agent Builder agents with the whole organization by default, and sharing an agent can share the underlying SharePoint files at the same time (Microsoft Learn). The platform sets the boundaries. Whether the data inside them is in order remains your job.

Microsoft’s zone model for Copilot Studio governance follows the same line: zone 1 for Agent Builder and SharePoint agents with read-only access, zone 2 for Copilot Studio, zone 3 for professional development with Foundry and Copilot Studio (Microsoft Learn). Part 2 builds on these zones.

Questions to answer before anyone builds

Microsoft’s guide lists questions for builders. I use a slightly different set, because operators need one more:

Goal: what should the agent achieve, and how will you notice that it works?
Data: which sources does it need, and are they personal, team or enterprise data? The classification matters as much as the location.
Mode: should it retrieve information, act in other systems or run on its own? Retrieval fits Agent Builder. Actions mean Copilot Studio at the latest. Autonomous agents without a signed-in user shift most of the risk into configuration.
Reach: an agent shared with five colleagues and one in the organization’s catalog are different products.
Operation: who runs the agent after go-live, and in which tenant? This is the question I see missing most often. It decides who keeps knowledge sources current, who reviews permissions and who switches the agent off.

The operator’s view

Microsoft describes one very large tenant with its own CISO office, an internal hub for builders and a team that measures maker friction. According to Microsoft, monthly active makers grew from about 2,000 to 20,000, about 150,000 personal development environments are under governance, and measured maker friction fell from roughly 50 to 5 percent (Microsoft Inside Track). These are figures from Microsoft’s own tenant. I would not use them as a benchmark for a utility with 3,000 employees.

In regulated environments with a service provider, three things change.

The administrator often works for someone else

Service providers usually hold admin roles in customer tenants through GDAP, scoped and time-bound. Microsoft now offers multi-tenant agent management in the Microsoft 365 admin center, currently in preview. With the AI Administrator role, a provider can view, install and block agents across all governed tenants from one place. Risk signals and activity data require Agent 365 licenses (Microsoft Learn). That helps, and it makes one question more pressing: if the configurable model puts the risk on “the administrator”, which administrator is meant?

The three models split between customer and provider

My working model, not Microsoft’s:

Model	Customer	Service provider
Intrinsic (Agent Builder)	Data risk: permissions, labels, what gets shared	The settings it manages under contract, such as sharing controls and registry reviews
Configurable (Copilot Studio)	Approval of agents and connectors, business ownership	Environments, data policies and connector rules, if it designs and runs them
Explicit (Foundry)	Purpose, data and acceptance	Model, code and release process, if it builds the agent

The second row is where contracts are usually vague. The service description should state who maintains data policies and how quickly a request to block an agent is executed. The third row has a regulatory side: a provider that builds an agent for a customer can end up in a provider role under the AI Act, depending on purpose and branding. Part 4 deals with that.

Shadow AI has a different weight

Microsoft argues that too much control does not remove risk, it pushes builders to unsanctioned tools and costs both productivity and visibility. I agree with the mechanism. In regulated environments, I draw the line by function rather than by tool. Zone 1 can stay open: Agent Builder agents on content people can already read, with org-wide sharing limited to a defined group. The hard boundary belongs where an agent acts in other systems or runs without a signed-in user. One argument also carries more weight under NIS2 than in Microsoft’s case: an agent that nobody has registered is missing from the asset inventory, and auditors ask for that inventory.

Five things to check tomorrow

Check who may share Agent Builder agents with the whole organization. Unless someone changed it, the answer is everyone.
Filter the agent registry by platform and count the agents per tool. That shows which risk model dominates your tenant.
List for each customer tenant who holds the AI Administrator and Power Platform administrator roles, the customer or the provider.
Add the operation question (who runs it, in which tenant) to your agent request form.
Check whether your Agent 365 licensing covers the tenants where you need risk signals. Without it, the registry shows the inventory but no risks (Microsoft Learn).

How the series continues

Part 2, lifecycle: how much lifecycle an agent needs, and how it differs between the admin center, Copilot Studio environments and a Foundry release process (part 2).
Part 3, runtime: whose permissions an agent uses when it calls tools and other agents, and where responsibility shifts along the way (part 3).
Part 4, compliance: who has to deliver evidence under the AI Act, GDPR, NIS2 and ISO 27001/42001, and how much of it Microsoft 365 provides (part 4).

Sources

Agent lifecycle: how much governance does a Copilot agent need?

Mon, 12 Oct 2026 07:00:00 +0200

📝 This series has been extended

In October 2026 this series gained an introductory part. This post was originally part 1 and is now part 2. Part 1 sorts Agent Builder, Copilot Studio and Foundry by who carries the risk.

Building an agent with Agent Builder in Microsoft 365 Copilot takes a few minutes. Getting rid of it takes forever in many tenants, because nobody feels responsible. The colleague who built an agent for the travel expense policy last spring has moved to another department. The agent keeps answering questions anyway, based on a policy that has been out of date since July.

That is the problem an agent lifecycle solves. In this post I describe how I would set up a lifecycle for agents built with Agent Builder and Copilot Studio, and which tools Microsoft now provides for it. My take: not every agent needs the full process. Every agent does need an owner, and that only works for agents that are registered. What does not show up in the agent registry cannot be assigned to a person, reviewed or switched off.

The lifecycle by platform

Part 1 covers which tool fits which builder and who carries the risk. For the lifecycle, the phases stay the same, but where they happen depends on the platform.

IT manages Agent Builder agents (intrinsic model, the platform sets the boundaries) in the Microsoft 365 admin center: visibility, sharing, owners, blocking and deletion. There are no versions and no environments, so the lifecycle here is mostly about sharing, ownership and cleanup.

Copilot Studio (configurable model, the administrator sets the rules) uses application lifecycle management with separate development, test and production environments. Data policies, connector rules and publishing approval are tied to those environments (Microsoft Learn).

Foundry (explicit model, the organization owns model and code) follows your own engineering process: versioning, evaluation and publishing run through the development team’s tools and pipelines (Microsoft Learn). Published Foundry agents appear in the agent registry, and admins can stop them there (Microsoft Learn). The rest of this post focuses on Agent Builder and Copilot Studio. Foundry goes through the same phases, implemented with conventional software engineering.

The bridge between Agent Builder and Copilot Studio is the copy feature: an agent from Microsoft 365 Copilot can be copied to Copilot Studio once it needs more than a personal helper can offer. In lifecycle terms, that is the moment an agent changes zones.

Three zones instead of one process for everything

A single approval process for every agent fails on two sides. An IT review is overkill for the personal agent that summarizes my own meeting notes. A click on “Share” is not enough for an agent that answers payroll questions for 3,000 employees.

Microsoft addresses this with a zone model (Microsoft Learn). In zone 1, anyone can build agents for personal or team productivity, grounded in content they can already access. In zone 2, makers approved by IT build agents for other teams. These agents go through an IT review and are deployed to environments that IT manages. Zone 3 is reserved for organization-wide agents that are treated like any other enterprise application. The current whitepaper Administering and Governing Agents is now structured along the same personal, team and enterprise levels.

Microsoft now maps tools to zones more tightly: zone 1 for Agent Builder and SharePoint agents, zone 2 for Copilot Studio, zone 3 for Foundry and Copilot Studio in professional development. I still allow Agent Builder agents in zone 2 as long as they only read content the team can already access. For me, reach decides the zone, not the tool.

For the lifecycle, the zone decides how many phases an agent goes through and how strict they are. An agent in zone 1 takes the short path. As soon as its reach, data access or criticality grows, it moves to the next zone and into a stricter process.

The seven phases at a glance

The diagram builds on a lifecycle model that has been circulating online. I extended it with the zones, the specific Microsoft tools for each phase and a separate decision gate.

1. Identify

Everything starts with a real problem. Ideas go into a backlog, for example a SharePoint list or a Planner board. Each idea gets a short profile with the problem, the target audience and an accountable owner. Without an owner, the idea goes no further.

2. Assess and prioritize

This is where the most important decision of the whole lifecycle happens: which zone does the agent belong in? I look at value and effort, but mostly at the data. Which knowledge sources will the agent use, who is allowed to read them, and should the agent trigger actions in other systems? The answers also determine the tool. Agent Builder covers many zone 1 and 2 scenarios. Once actions, connectors to line-of-business apps or a broad rollout come into play, the path leads to Copilot Studio. If the agent needs its own model or orchestration, it ends up in Foundry and in the development team’s process.

3. Design and prototype

Success criteria come before building. What does the agent need to answer, and how will I know it does that well? Only then does a prototype take shape: directly in Agent Builder for zone 1, in a Copilot Studio development environment for zones 2 and 3. Microsoft recommends environment routing to send makers to personal developer environments automatically, so not everything ends up in the default environment (Microsoft Learn).

4. Validate and decide

This phase finally has a proper tool. Agent Evaluation in Copilot Studio has been generally available since the end of March. It lets you create test sets, choose evaluation methods and repeat runs across agent versions. A Power Automate connector and a REST API (currently in preview) make it possible to include evaluations in CI/CD pipelines (Microsoft Learn).

Security and data protection belong in this phase too: which data can the agent see, which identity does it run under, and do its permissions match the intended audience? If the agent calls other agents or tools, add a second question: do they act with the user’s permissions or with their own, possibly broader credentials? In Copilot Studio this is set per tool, and a connected agent does not inherit the setting of the agent that calls it. The phase ends with a deliberate decision.

The gate: Go, Change, Hold or Stop

The decision after phase 4 has four possible outcomes. Go leads to production. Change sends the agent back to phase 3 because quality or design still fall short. Hold parks it in the backlog, for example because a data source is not yet properly permissioned. Stop ends the idea in a controlled way.

Many organizations underestimate Stop. An agent that fails its tests should not stay in the tenant as a half-finished prototype.

5. Deploy and scale

In zone 3, nobody edits an agent directly in production. Microsoft recommends packaging agents as managed solutions and promoting them from development through test to production with Power Platform pipelines (Microsoft Copilot Blog). That gives you versioning, an auditable change history and the option to roll back.

Publishing to the organization runs through the Microsoft 365 admin center, where admins can approve or reject submitted agents. A gradual rollout follows. User training belongs in the same plan, otherwise even a good agent goes unused.

6. Operate and monitor

Operations is about usage, quality and cost. Copilot Studio provides analytics, Purview covers audit and data protection, and since May 2026 Agent 365 adds a dedicated control plane for agents. Copilot Studio agents appear in its agent registry once they are made available in Microsoft 365. The same agent can show up more than once, for example as a shared and as a published version (Microsoft Learn). Governance actions are logged in Purview.

Two things are a fixed part of operations for me: keeping knowledge sources current so the agent does not answer from outdated documents, and recertifying permissions on a regular schedule. Anyone working with customers in regulated industries knows this principle from identity management. It applies to agents in the same way.

7. Evolve or retire

Every agent ends at some point, either as a new version or through retirement. New versions go through the lifecycle again, starting at phase 2 or 3 depending on the scope of the change.

The admin center now includes the most important actions for retirement (Microsoft Learn). Admins can assign a new owner to Agent Builder and Copilot Studio agents, even when an agent is already ownerless. The new owner gets full edit and delete permissions plus access to the previous owner’s files, and the previous owner loses all access. Agent Builder agents can now have several owners, which admins can add or remove. Agents without a future can be blocked and deleted, with a 30-day window to restore them.

Microsoft’s Zero Trust workshop sums up the idea well: a lifecycle policy that nobody enforces remains a document (Zero Trust Workshop). Without this cleanup, the number of agents only ever grows.

Guardrails across all phases

Underneath the cycle sit six topics that apply in every phase and every zone: identity and ownership, data protection and compliance, permissions and sharing, environments and ALM, inventory and transparency, and quality and cost. In the diagram I mapped each topic to the tools available for it today, from Entra Agent ID through Purview to the agent registry.

Where it still falls short

The picture is not complete yet. Agent Builder agents have no real ALM with environments and versions. If you want to run one of them seriously, moving it to Copilot Studio is hard to avoid.

Copilot Studio has gaps as well. The built-in evaluations live in the cloud, not in source control, which makes automated quality gates in a pipeline harder than in classic software development. In an ESPC webinar, Stephan Bisser presented a CLI tool that versions test cases as YAML files to close that gap.

Finally, licensing: many registry features are available in the admin center. Risk signals in the registry and the advanced security and compliance capabilities of Agent 365 require Microsoft 365 E7 or an Agent 365 license (Microsoft Learn). Clarify this before you roll out.

Five things you can check tomorrow

Open the agent registry in the Microsoft 365 admin center and filter for agents without an owner.
Check whether environment routing sends Copilot Studio makers to their own developer environments, or whether everyone builds in the default environment.
Define the criteria that move an agent from zone 1 to zone 2, and write them down.
Create a first test set in Agent Evaluation for your most important agent.
Decide who takes over the agents of people who leave the organization.

What happens when an approved agent calls tools and hands work to other agents at runtime is the topic of part 3.