[German]This is an exciting development. Microsoft has promised a consumer protection organization that private users in the European Economic Area (EEA) will receive the Extended Security Update (ESU) program without any requirements such as a backup app, Microsoft account, etc. and for free. In other regions ESU will come with several requirements.
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Windows 10 and Microsofts ESU reqirements so far
Microsoft's support for Windows 10 22H2 will end on October 14, 2025, and there will be no more security updates after that. However, users can opt for the Extended Security Update (ESU) program. For private users, the ESU program is available for one year.
In the articles Windows 10: News about ESU program – free options for consumers and Windows 10: ESU information and FAQ for home users, I outlined Microsoft's plans for this ESU program for consumers in August 2025.
- Users can use Windows Backup to synchronize their settings with the cloud. This should enable them to obtain free ESU licenses for Windows 10 PCs.
- You can redeem 1,000 Microsoft Rewards points (which you can earn by using Bing Search, for example) and receive one year of ESU at no additional cost.
- And you can purchase an ESU license for $30 (€31.49 in Germany) for one year.
In all cases, however, a Microsoft account was required. And that's still true for most parts of the world. But the whole thing is now being changed again for European consumers.
New conditions for Windows 10 private users in the EEA
Meanwhile, several media outlets (here, here, here – thanks to Axel, who pointed me to topic in this comment) are reporting that Microsoft is dropping all of the above restrictions for private users in the European Economic Area (EEA). The EEA comprises the 27 member states of the European Union as well as Iceland, Liechtenstein, and Norway.
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The information comes from correspondence between the consumer protection organization Euroconsumers Groupe and Microsoft Irland. The Euroconsumers Group is a global association of consumer organizations that promotes consumer information, protection, and rights. It consists of national organizations in Belgium (Test Aankoop), Italy (Altroconsumo), Portugal (DECOProteste), Spain (OCU), and Brazil (Proteste), representing over 1.5 million people. The group's letter to Microsoft Ireland states:
We are pleased to learn that Microsoft will provide a no-cost Extended Security Updates (ESU) option for Windows 10 consumer users in the European Economic Area (EEA). We are also glad this option will not require users to back up settings, apps, or credentials, or use Microsoft Rewards. This was our main Digital Markets Act (DMA) related concern, as linking access to essential security updates to engagement with Microsoft's own services raised reasonable doubt of compliance with obligations under Article 6(6) of the DMA.
In short: The Euroconsumer Group is pleased that Microsoft will offer a free option for extended security updates (ESU) for Windows 10 home users in the European Economic Area (EEA). It is also pleased that this option will not require the use of Windows Backup, Rewards, or login credentials (i.e., a Microsoft account).
The consumer organization appears to have put pressure on Microsoft in connection with the European Digital Markets Act (DMA). The group had reasonable doubts that linking access to important security updates to the use of Microsoft's own services was in line with compliance with the obligations under Article 6(6) of the DMA. If the above assumptions are correct, the group now considers its main concern in relation to the Digital Markets Act (DMA) to have been addressed.
Microsoft spokespersons have confirmed to the US media cited above that this is indeed the case – although it only applies to private users in the EEA. This would then be one area where the DMA would have had direct benefits for EU consumers.
How this will be implemented remains to be seen. An unnamed Microsoft spokesperson told Windows Central, that "the registration process will be updated to ensure that it meets local expectations and provides a secure, optimized user experience." I assume that an "Register ESU" option may be offered in Windows Update for Windows 10 Home (and possibly Pro) starting in October 2025. I just tested it with Windows 10 22H2 Pro and a local user account. There is no sign of any ESU option yet.
Criticism of 1-year ESU by the Euroconsumer Group
However, the Euroconsumer Group expresses clear criticism in its letter to Microsoft Ireland. With the above concessions, Microsoft offers European private users protection for Windows 10 with updates until October 13, 2026. After one year, the security updates will then expire (only companies can purchase paid ESU updates for three years).
In the letter, the Euroconsumer Group notes that several points from its original letter remain relevant. The ESU program is limited to one year, meaning that devices that are still fully functional after October 13, 2026, will be exposed to a [security] risk. Such a short-term measure does not meet consumers' reasonable expectations for a product, it argues.
It points out that Windows 10 is still widely used. The end of support is not in line with the spirit of the Digital Content Directive (DCD) or the EU's broader sustainability goals, it continues. Unlike previous operating system upgrades, which typically did not require new hardware, this is not the case for Windows 11. This is a significant point, as millions of Windows 10 Home systems that still work well would become electronic waste. This is because the devices cannot be upgraded to Windows 11 and people are not switching to Linux.
The Euroconsumer Group argues that this would place an enormous additional burden on consumers. According to estimates, over 850 million active devices still rely on Windows 10 and cannot be updated due to hardware requirements. It points out that there were no such restrictions when upgrading from Windows 7 or 8 to Windows 10.
The organization also writes in its response that Microsoft is phasing out Windows 10 in a much shorter timeframe than in the past. Support for Windows 10 will end just four years after the launch of Windows 11. Earlier versions were given a longer transition period:
- Support for Windows 7 ended eight years after the introduction of Windows 8,
- and support for Windows XP ended seven years after the introduction of Windows Vista.
In previous cases, Microsoft's decision to end support coincided with a decline in user numbers, the letter states, meaning that only a small
portion of the market was dependent on the expiring software. According to Euroconsumer Group's own survey, a significant proportion of consumers continue to use older but still functional devices: 22% still use Windows 10 on a PC or laptop from 2017 or earlier that cannot be upgraded to Windows 11 but still meets users' daily needs.
he organization hits a sore spot: security updates are crucial for the functionality of refurbished and used devices. Discontinuing updates for functional Windows 10 systems accelerates the creation of electronic waste. However, this undermines the EU's goals for durable, sustainable digital products. I already pointed out this problem in 2021 (see links at the end of the article).
Microsoft shot itself in the foot several times here. When Windows 10 was introduced, it was billed as "the last Windows," and the plan was to upgrade machines every six months and later every year to a version supported for 24 months. This was abandoned because management was determined to salvage the bits and pieces of the GUI from the scrapped and scrapped Windows 10X. The Windows 10 core, including the Windows 10X GUI, was then unleashed on humanity as "Windows 11." And because marketing wanted to sell as many new computers as possible, they tweaked the hardware requirements so that older machines are not officially upgradeable.
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