Short answer
Yes. Include cloud services used for organisational data or services. For SaaS, you normally manage user access, MFA and tenant settings while the provider manages its infrastructure. For IaaS, you also manage your guest operating systems and their security updates. Document the shared-responsibility boundary and actual service scope with the assessor.
Why this matters
Scoping is where many Cyber Essentials submissions fail. The assessor needs to understand which users, devices, networks, and cloud services can access organisational data. A policy statement alone is not enough if the technical environment still allows access.
Agree the organisation, network boundary and locations with the assessor. A separately managed subset needs the required network segregation and a justified boundary. MDM, Conditional Access or a virtual desktop can help manage access, but none automatically excludes an endpoint or cloud service from assessment.
What to check next
- List all devices and cloud services that access organisational data.
- Document any exclusions and the technical enforcement behind them.
- Check BYOD, home working, and production cloud environments before submitting.
Official sources and related Fig Group guidance
For scheme-level confirmation, use the official NCSC and IASME resources. Fig Group links to these sources so Cyber Essentials buyers can verify the scheme, delivery partner and certificate record independently.