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Enterprise Azure Policy as Code (EPAC)


Enterprise Azure Policy as Code or EPAC for short comprises a number of scripts which can be used in CI/CD based system or a semi-automated use to deploy Policies, Policy Sets, Assignments, Policy Exemptions and Role Assignments.

Main features include:

  • Multi-tenant/environment policy deployment
  • Easy CI/CD Integration
  • Extract existing policy objects from an environment
  • Support JSON and CSV inputs for large complex policies
  • PowerShell Module
  • Integration with Azure Landing Zone recommended policies
  • Starter Kit with examples
  • Schema to provide Intellisense for VS Code development

Who Should use EPAC?

EPAC is designed for organizations with a large number of Policies, Policy Sets and Assignments. It is also designed for organizations with multiple tenants and/or environments. You can also combine ALZ and EPAC through the provided "Integration of EPAC with Azure Landing Zones".

EPAC can be used by small organizations with a small number of Policies, Policy Sets and Assignments. Depending on their DevSecOps maturity, Azure Landing Zones direct implementation of Policies might be a better choice.

For extremely small Azure customers with one or two subscriptions Microsoft Defender for Cloud automated Policy Assignments for built-in Policies is sufficient.

Major Change in v8.0.0

Starting with v8.0.0, Enterprise Policy as Code (EPAC) is tracking the usage using Customer Usage Attribution (PID). For details and how to opt-out see Usage Tracking.

Microsoft's Security & Compliance for Cloud Infrastructure

This enterprise-policy-as-code (EPAC) repo has been developed in partnership with the Security & Compliance for Cloud Infrastructure (S&C4CI) offering available from Microsoft's Industry Solutions (Consulting Services). Microsoft Industry Solutions can assist you with securing your cloud. S&C4CI improves your new or existing security posture in Azure by securing platforms, services, and workloads at scale.

Breaking changes in v7.0

Script Export-AzPolicyResources replaces Build-PolicyDefinitionFolder with a substantial increase in capability. It has a round-trip capability supporting the extract to be used in the build Definitions.

Introducing a new approach using PowerShell Module. This not (actually) breaking existing implementation since you can continue as is; however, for a simplified usage of EPAC, the PowerShell module is the best approach.

The move from synchronizing your repo with the GitHub repo to a PowerShell module necessitated the reworking of the default values for Definitions, Output, and Input folders. Many scripts use parameters for definitions, input and output folders. They default to the current directory, which should be the root of the repo. make sure that the current directory is the root of your repo. We recommend that you do one of the following approaches instead of accepting the default:

  • Use the script parameters -DefinitionsRootFolder, -OutputFolder, and -InputFolder (They vary by script).


Full name Simplified use in this documentation
Policy definition(s) Policy, Policies
Initiative definition(s) or Policy Set definition(s) Policy Set(s)
Policy Assignment(s) of a Policy or Policy Set Assignment(s)
Policy Assignment(s) of a Policy Set Policy Set Assignment
Policy Exemption(s) Exemption(s)
Role Assignment(s)s for Managed Identities required by Policy Assignments Role Assignment(s)
Policies, Policy Sets, Assignments and Exemptions Policy resources

Deployment Scripts

Three deployment scripts plan a deployment, deploy Policy resources, and Role Assignments respectively as shown in the following diagram. The solution consumes definition files (JSON and/or CSV files). The planning script (Build-DeploymentPlan) creates plan files (policy-plan.json and roles-plan.json) to be consumed by the two deployment steps (Deploy-PolicyPlan and Deploy-RolesPlan). The scripts require Reader, Contributor and User Access Administrator privileges respectively as indicated in blue text in the diagram. The diagram also shows the usual approval gates after each step/script for prod deployments.


CI/CD Tool Compatibility

Since EPAC is based on PowerShell scripts, any CI/CD tool with the ability to execute scripts can be used. The starter kits currently include pipeline definitions for Azure DevOps and GitHub Actions. Additional starter kits are being implemented and will be added in future releases.

Multi-Tenant Support

EPAC supports single and multi-tenant deployments from a single source. In most cases you should have a fully or partially isolated area for Policy development and testing, such as a Management Group. An entire tenant can be used; however, it is not necessary since EPAC has sophisticated partitioning capabilities.

In some multi-tenant implementations, not all policies, policy sets, and/or assignments will function in all tenants, usually due to either built-in policies that don't exist in some tenant types or unavailable resource providers. In order to facilitate multi-tenant deployments in these scenarios, utilize the " epacCloudEnvironments" property to specify which cloud type a specific file should be considered in. For example in order to have a policy definition deployed only to epacEnvironments that are China cloud tenants, add a metadata property like this to that definition (or definitionSet) file:

"metadata": {
  "epacCloudEnvironments": [

For assignment files, this is a top level property on the assignment's root node:

"nodeName": "/root",
"epacCloudEnvironments": [

Operational Scripts

Scripts to simplify operational task are provided. Examples are:

Understanding EPAC Environments and the pacSelector


Understanding of this concept is crucial. Do not proceed until you completely understand the implications.

EPAC has a concept of an environment identified by a string (unique per repository) called pacSelector. An environment associates the following with the pacSelector:

  • cloud - to select commercial or sovereign cloud environments.
  • tenantId - enables multi-tenant scenarios.
  • rootDefinitionScope - scope for custom Policy and Policy Set definition deployment.
  • Optional: define desiredState


Policy Assignments can only defined at rootDefinitionScope and child scopes (recursive).

These associations are stored in global-settings.jsonc in an element called pacEnvironments.

Like any other software or IaC solution, EPAC needs areas for developing and testing new Policies, Policy Sets and Assignments before any deployment to EPAC prod environments. In most cases you will need one management group hierarchy to simulate EPAC production management groups for development and testing of Policies. EPAC's prod environment will govern all other IaC environments (e.g., sandbox, development, integration, test/qa, pre-prod, prod, ...) and tenants. This can be confusing. We will use EPAC environment(s) and IaC environment(s) to disambiguate the environments.

In a centralized single tenant scenario, you will define two EPAC environments: epac-dev and tenant. In a multi-tenant scenario, you will add an additional EPAC environment per additional tenant.

The pacSelector is just a name. We highly recommend to call the Policy development environment epac-dev, you can name the EPAC prod environments in a way which makes sense to you in your environment. We use tenant, tenant1, etc in our samples and documentation. These names are used and therefore must match:

  • Defining the association (pacEnvironments) of an EPAC environment, managedIdentityLocation and globalNotScopes in global-settings.jsonc
  • Script parameter when executing different deployment stages in a CI/CD pipeline or semi-automated deployment targeting a specific EPAC environments.
  • scopes, notScopes, additionalRoleAssignments, managedIdentityLocations, and userAssignedIdentity definitions in Policy Assignment JSON files.

CI/CD Scenarios Flexibility

The solution supports any DevOps CI/CD approach you desire. The starter kits assume a GitHub flow approach to branching and CI/CD integration with a standard model below.

  • Simple
  • Create a feature branch
  • Commits to the feature branch trigger:
    • Plan and deploy changes to a Policy resources development Management Group or subscription.
    • Create a plan (based on feature branch) for te EPAC production environment(s)/tenant(s).
  • Pull request (PR) merges trigger:
    • Plan and deploy from the merged main branch to your EPAC production environment(s) without additional approvals.
  • Standard - starter kits implement this approach
  • Create a feature branch
  • Commits to the feature branch trigger:
    • Plan and deploy changes to a Policy resources development Management Group or subscription
    • Create a plan (based on feature branch) for te EPAC production environment(s)/tenant(s).
  • Pull request (PR) merges trigger:
    • Plan from the merged main branch to your EPAC production environment(s).
  • Approval gate for plan deployment is inserted.
  • Deploy the planned changes to environment(s)/tenant(s)
    • Deploy Policy resources.
    • [Recommended] Approval gate for Role Assignment is inserted.
    • Deploy Role Assignment.

Coexistence and Desired State Strategy

EPAC is a desired state system. It will remove Policy resources in an environment which are not defined in the definition files. To facilitate transition from previous Policy implementations and coexistence of multiple EPAC and third party Policy as Code systems, a granular way to control such coexistence is implemented. Specifically, EPAC supports:

  • Centralized: One centralized team manages all Policy resources in the Azure organization, at all levels (Management Group, Subscription, Resource Group). This is the default setup.
  • Distributed: Multiple teams manage Policy resources in a distributed manner. Distributed is also useful during a brownfield deployment scenario to allow for an orderly transition from pre-EPAC to EPAC.

Desired state strategy documentation can be found here.. The short version:

  • full deletes any Policies, Policy Sets, Assignments, and Exemptions not deployed by this EPAC solution or another EPAC solution.*
  • ownedOnly deletes only Policies with this repos’s pacOwnerId. This allows for a gradual transition from your existing Policy management to Enterprise Policy as Code.*
  • Policy resources with another pacOwnerId metadata field are never deleted.


If you have a existing Policies, Policy Sets, Assignments, and Exemptions in your environment, you have not transferred to EPAC, do not forget to include the new desiredState element with a strategy of ownedOnly. This is the equivalent of the deprecated "brownfield" variable in the pipeline. The default strategy is full.

Understanding differences between usage of EPAC, AzAdvertizer and AzGovViz

Enterprise Policy-as-Code (EPAC), AzAdvertizer and Azure Governance Visualizer (AzGovViz) are three distinct open source projects or tools internally developed and maintained by Microsoft employees, each helping address different needs in enterprise scale management and governance of Azure environments.

  • AzAdvertizer - AzAdvertizer is a publicly accessible web service that provides continually up-to-date insights on new releases and changes/updates for different Azure Governance capabilities such as Azure Policy's built-in policy and initiative (policy set) definitions, Azure aliases, Azure security & regulatory compliance controls, Azure RBAC built-in role definitions and Azure resource provider operations.

  • Azure Governance Visualizer (aka AzGovViz) - AzGovViz is an open source community project that provides visualization and reporting solution for any customer Azure environment or estate, delivering a rich set of detailed insights covering tenant management group hierarchies, RBAC assignments, Azure policy assignments, Blueprints, Azure network topology and much more. AzGovViz is listed as recommended tool in use for both Microsoft Cloud Adoption Framework (CAF) and Microsoft Well Architected Framework (WAF).

  • Enterprise Policy-as-Code (aka EPAC) - EPAC is an open source community project that provides a CI/CD automation solution for the development, deployment, management and reporting of Azure policy at scale. EPAC can maintain a policy "desired state" to provide a high level of assurance in highly controlled and sensitive environments, and a means of managing policy exemptions. While it uses standard JSON file structure for its repositories, operation and maintenance of policy and policy sets can actually be done via CSV files, reducing the skill expertise needed to operate the solution once implemented.

The table below provides a summary functions/features comparison between the three solutions/tools.

Function/Feature AzAdvertizer AzGovViz EPAC
Purpose Detailed insight tool on released Azure public cloud governance features like current built-in polices and initiatives Azure environment governance reporting and monitoring solution exposing tenant config/deployment detail of tenant hierarchies, RBAC assignments, policies, blueprints Azure environment automated policy governance deployment, management and reporting solution
Implementation hosted web service customer deployment, interactive Azure governance management and security reporting tool customer deployment, deployment automation and reporting tool
Requirements browser PowerShell 7.0.3 PowerShell 7.3.1


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