Skip to content

Control 2.14: Declarative and SharePoint Agents Governance

Control ID: 2.14 Pillar: Security & Protection Regulatory Reference: GLBA 501(b) Last Verified: 2026-03-22 Governance Levels: Baseline / Recommended / Regulated

Objective

Govern the creation, sharing, user access, and data boundary enforcement for declarative agents, with specific attention to SharePoint-backed agents and other agents surfaced through Microsoft 365 Copilot. This control focuses on the security guardrails that determine who can use agents, who can share them, and how agent access is limited to approved publishers, audiences, and knowledge sources.

Why This Matters for FSI

  • GLBA 501(b) requires safeguards for customer information. Agents can accelerate access to site content, uploaded knowledge, and external tools, so security boundaries should be explicit.
  • Agent proliferation risk increases when users can create or broadly share agents without governance approval.
  • Data boundary enforcement matters because SharePoint-backed agents can expose sensitive site content to new audiences if permissions and sharing are not reviewed carefully.
  • FFIEC and OCC AI governance expectations support maintaining oversight of who can use AI tools, how those tools are shared, and what data they can access.

Control Description

Microsoft 365 now exposes agent governance through the Agents control plane in the Microsoft 365 admin center. Security decisions for agents are no longer limited to the original SharePoint agent creation flow. Administrators can now review agent inventory, restrict allowed agent types, control sharing, and scope user access through centralized settings.

Agent Types Relevant to CopilotGov

Agent Type Security Consideration Primary Governance Surface
Published by your organization Broad availability requires approval and ownership Agents > All agents / Registry
Shared by creator Creator-shared agents can spread quickly without central review Agents > All agents / Sharing controls
Microsoft agents First-party experiences require access decisions and usage oversight Agents > Settings > Allowed agent types
External partner agents External publishers may introduce new data handling terms or integrations Agents > Settings > Allowed agent types
SharePoint-backed agents Ground on SharePoint sites and therefore inherit site-permission risk Agents + SharePoint Admin Center

Central Security Controls

Control Description Admin Configuration
Allowed agent types Controls which classes of agents users can install Agents > Settings > Allowed agent types
Sharing Controls who can share agents broadly in the organization Agents > Settings > Sharing
User access Limits who can use agents at all Agents > Settings > User access
Registry review Tracks published, shared, blocked, or ownerless agents Agents > All agents / Registry
Knowledge source review Validates SharePoint sites, embedded files, and external data sources SharePoint Admin Center, Agent details, Search / connector review

Researcher and Analyst Nuance

Microsoft documents Researcher and Analyst as first-party experiences within the core Microsoft 365 Copilot chat experience. They coexist with agents and inherit related governance capabilities, but they do not fall under installable agent settings in the same way as Registry-managed agents. Document them as Copilot Chat capabilities when defining access policy and supervision requirements.

Agent Risk Assessment Matrix

Risk Factor Low Risk Medium Risk High Risk
Publisher Microsoft Internal approved creator External partner or unreviewed creator
Knowledge source Public intranet or non-sensitive content Department knowledge Client data, regulated records, or uploaded files with sensitive content
Sharing scope Creator only or named users Department Organization-wide or cross-functional
Allowed users Approved pilot group Documented business group Broad tenant access without governance review
Web / action capability Disabled or limited Approved business use External or high-impact actions without control evidence

Copilot Surface Coverage

M365 Surface Agent Access Security Governance Notes
Microsoft 365 Copilot Chat Yes Primary user experience for many agents
Teams Yes Review alongside collaboration and supervision controls
SharePoint Yes Important for SharePoint-backed agent knowledge scope
Copilot Pages Indirect Agent responses can create Pages; align with Control 2.11
Word / Excel / PowerPoint / Outlook Limited / varies Review by scenario and agent type

Governance Levels

Level Requirement Rationale
Baseline Restrict agent user access to approved users or groups; allow only approved agent types; review Registry inventory monthly; review SharePoint knowledge sources before publication Minimum control over who can use and share agents
Recommended All Baseline requirements plus: group-based sharing rules, documented owner for each published agent, quarterly source-site review for SharePoint-backed agents, formal approval workflow for broader publication Balanced production governance for most FSI deployments
Regulated All Recommended requirements plus: compliance review for high-risk or client-data agents, documented exception process for external or broadly shared agents, monthly registry review, evidence retained for examination support Stronger security posture for regulated or segmented environments

Setup & Configuration

Step 1: Configure Agent User Access

Portal: Microsoft 365 Admin Center
Path: Agents > Settings > User access

  1. Choose All users, No users, or Specific users/groups.
  2. For FSI deployments, prefer approved user or group scoping over broad default access.
  3. Document the approved audiences and the associated business justification.

Step 2: Configure Allowed Agent Types and Sharing

Portal: Microsoft 365 Admin Center
Path: Agents > Settings > Allowed agent types / Sharing

  1. Decide whether Microsoft, internal, and external agents are permitted.
  2. Restrict broad sharing to approved groups where required.
  3. Document how creator-shared agents are reviewed before broader use.

Step 3: Review Agent Registry

Portal: Microsoft 365 Admin Center
Path: Agents > All agents / Registry

  1. Review published, shared, blocked, and ownerless agents.
  2. Confirm each broadly available agent has an owner and approval record.
  3. Block or remove agents that do not meet policy.

Step 4: Review SharePoint-Backed Knowledge Sources

Portal: SharePoint Admin Center and agent details

  1. Review source sites or uploaded knowledge used by high-risk agents.
  2. Confirm permissions, labels, and sharing posture are appropriate.
  3. Cross-reference Control 1.2 for oversharing remediation and Control 2.5 for grounding scope decisions.

Step 5: Establish Security Review Workflow

  1. Define who reviews new agents before broader publication.
  2. Require extra review for:
  3. client-data or regulated-content agents
  4. external partner agents
  5. agents with embedded file knowledge
  6. Record approval, owner, and review cadence for each governed agent.

Financial Sector Considerations

  • Client-data agents: Agents grounded on client or account content should undergo stronger review than general knowledge assistants.
  • Publisher trust: External partner agents require review of data handling, privacy terms, and operational dependency.
  • SharePoint oversharing: A well-designed agent still inherits risk from an overshared source site. Security review should include the underlying content boundary.
  • Research and analysis workflows: If Researcher or Analyst are enabled for high-risk business functions, document that decision in Copilot governance even though those tools are not managed like Registry-installed agents.

Verification Criteria

  1. User access scoped: Verify agent access is limited to the approved users or groups.
  2. Allowed types configured: Confirm allowed agent types match the institution's policy.
  3. Sharing rules configured: Verify broad agent sharing is limited or approved.
  4. Registry inventory current: Confirm published and shared agents are inventoried and ownered.
  5. SharePoint source review completed: Confirm high-risk agents have documented knowledge-source review.
  6. Exception handling documented: Verify any external or high-risk agent exceptions have approval evidence.

Additional Resources