You do not need CALs for:

• any of your servers already licensed to run instances of the server software (i.e. for licensed server to access another licensed server);
• up to two devices or users to access your instances of the server software only to administer those instances;
• any instance running in a physical operating system environment used solely to:
• run hardware virtualization software;
• provide hardware virtualization services;
• run software to manage and service operating system environments on the licensed server.
• any user or device that accesses a Web Workload or HPC Workload.

Source:

https://www.microsoft.com/en-us/UseTerms/Retail/WindowsServer2019/DatacenterAndStandard/Useterms_Retail_WindowsServer2019_DatacenterAndStandard_English.htm

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