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SOC 2 testing requirements

SOC 2 is an AICPA examination in which an independent service auditor reports on a service organisation's controls against the 2017 Trust Services Criteria. SOC 2 reports matter to B2B fintech platforms that go through customer vendor reviews. SOC 2 testing verifies access, change, vulnerability, and processing controls. FintechAssuranceLabs produces penetration test reports and a requirement-to-test traceability matrix.

Jurisdiction
Global, US-led (AICPA attestation standards)
Primary source
aicpa-cima.com

Engineering interpretation of testing requirements, not compliance advice.

What SOC 2 requires under the Trust Services Criteria

The AICPA Assurance Services Executive Committee publishes the criteria as TSP Section 100, the 2017 Trust Services Criteria with revised points of focus from 2022 (AICPA & CIMA, checked on 2026-09-16). The 2022 revision changed the points of focus only; the 2017 criteria stayed the same. The system description in a SOC 2 report follows the 2018 SOC 2 Description Criteria (DC 200), with implementation guidance revised in 2022.

A SOC 2 examination covers one or more of five categories: security, availability, processing integrity, confidentiality, and privacy. Security uses the common criteria CC1 to CC9. Each other category adds its own series: A for availability, PI for processing integrity, C for confidentiality, and P for privacy.

The criteria describe outcomes, and each entity chooses its own controls. Management may customise points of focus that do not fit the entity. SOC 2 therefore sets no fixed scan interval or test calendar. The service auditor tests the controls that management describes.

A type 2 SOC 2 report gives an opinion on operating effectiveness throughout a specified period and describes the auditor's tests of controls and their results. A type 1 SOC 2 report addresses the same subject matter without either of those parts.

For software teams, most of the test scope sits in these criteria:

  • CC6.1, logical access. The entity restricts logical access to protected information assets. The points of focus name APIs, multifactor authentication, encryption, protection of cryptographic keys, and a security assessment of new architectures before implementation.
  • CC6.2 and CC6.3, credentials and roles. Credentials are issued on authorisation and removed when access is no longer authorised. Access follows roles, least privilege, and segregation of duties.
  • CC6.6 and CC6.7, boundaries and transmission. The entity protects against threats from outside its system boundaries and protects information during transmission.
  • CC4.1 and CC7.1, evaluations and vulnerabilities. CC7.1 expects detection of configuration changes that introduce vulnerabilities and of newly discovered vulnerabilities. Its point of focus describes periodic vulnerability scans, scans after significant change, and timely remediation. The 2022 point of focus for CC4.1 lists penetration testing among possible separate evaluations.
  • CC8.1, change management. The entity authorises, designs, develops, configures, documents, tests, approves, and implements changes. The points of focus cover testing before production (unit, integration, regression, static and dynamic analysis, automated testing), segregation so that one person cannot develop and deploy a change alone, emergency changes, and patches. When confidentiality is in scope, confidential information stays protected during testing.
  • A1.2 and A1.3, recovery. Backup and recovery infrastructure exists, and recovery plan procedures are tested. A point of focus under A1.3 describes periodic tests of backup integrity and completeness.
  • PI1.2 to PI1.5, processing integrity. Inputs, processing, outputs, and stored items are complete, accurate, and timely against the system specifications.

SOC 2 criteria that testing verifies

RequirementWhat we testEvidence produced
CC6.1 Logical access to protected assets is restrictedAPI requests with no token, an expired token, and a token of another tenantTest result per endpoint with the HTTP status returned
CC6.2 Credentials are removed when access endsSessions, personal API tokens, and refresh tokens of a deactivated userTest log with the deactivation time and each rejected request
CC6.3 Access follows least privilege and segregation of dutiesEach role against its intended permissions, including approval of a payment run that the same user createdAccess control and authorisation test matrix
CC6.7 Information is protected in transmissionTLS configuration of public and partner endpoints, and webhook delivery to plain HTTP targetsTLS scan output and webhook delivery test log
CC4.1 Separate evaluations cover the described systemWeb application, public API, partner API, and mobile app named in the system descriptionWeb, API, and mobile penetration test report
CC7.1 Vulnerabilities are detected and remediatedScan findings after a significant change, and the same findings after the fixFindings with severity, reproduction steps, and retest results
CC8.1 Changes are tested before productionRegression suite runs for changes released during the examination periodCI run records linked to change tickets
CC8.1 One person cannot develop and deploy a change aloneA merge and a deployment attempted by the change author without a second approverPipeline and branch protection test result
A1.3 Backup integrity and completeness are testedRestore of a backup into an isolated environmentRestore test record with record counts and balance totals compared
PI1.3 Inputs are processed completely and accuratelyDuplicate, partial, and out-of-order input files for a payout or invoice runReconciliation test results per input case

Artifacts a SOC 2 service auditor requests

For the criteria above, a service auditor typically requests:

  • the system description under DC 200, with the in-scope infrastructure, software, and data;
  • for a type 2 SOC 2 report, evidence that covers the whole examination period, because the opinion covers operating effectiveness throughout that period;
  • for changes selected from the period, including emergency changes and patches, the ticket, the approval, the test record, and the identity of the person who deployed the change (CC8.1);
  • penetration test reports and the remediation tickets for each finding (CC4.1, CC7.1);
  • vulnerability scan reports and rescans that show closed findings (CC7.1);
  • the role and permission matrix, periodic access review records, and offboarding records for sampled leavers (CC6.2, CC6.3);
  • backup restore test records and recovery plan test results (A1.3);
  • vendor and business partner risk assessments, including third-party access to systems (CC9.2);
  • input, processing, and output reconciliation records when processing integrity is in scope (PI1.2 to PI1.4).

Common SOC 2 findings in fintech software

  • Hotfix without a test record. An engineer deploys an emergency fix to the payout service from a laptop, outside the pipeline, and no one records tests or approval afterwards. The defect breaks the emergency change point of focus of CC8.1.
  • Author approves and deploys the change. The author of a pricing change uses administrator rights to bypass branch protection, then merges and releases the change alone. The defect breaks the segregation point of focus of CC8.1 and CC6.3.
  • Test evidence deleted before the auditor asks. The CI platform removes run logs after a retention window that is shorter than the examination period. Sampled changes then have no test record for CC8.1.
  • API token outlives the employee. Single sign-on deprovisioning removes dashboard access, but a personal API token with refund rights keeps working. The defect breaks CC6.2.
  • Another tenant's bank details in the response. An invoice endpoint returns any invoice ID without an ownership check, including another customer's account data. The defect breaks CC6.1 and CC6.3.
  • Production data copied into staging. A team restores unmasked customer records into staging to reproduce a reconciliation defect. The defect breaks the confidentiality point of focus of CC8.1.
  • Penetration test scope smaller than the system description. The test covers the web dashboard, while the system description also lists the partner API and the mobile app. The evaluation evidence for CC4.1 does not match the described system.
  • Backups never restored. Backup jobs report success, but no one has restored a backup and checked completeness. The gap breaks the A1.3 point of focus on backup integrity.
  • Payout file processed twice after a retry. A timeout triggers a retry, and the batch job pays the same beneficiaries again. The defect breaks PI1.3, and the company must recover the duplicate payouts from the beneficiaries.

How we cover SOC 2 testing

The security testing service delivers the web, API, and mobile penetration test report, findings with severity, reproduction steps, and retest results, and the access control and authorisation test matrix. Those deliverables give evidence for CC4.1, CC6.1, CC6.3, and CC7.1.

The audit evidence testing service builds the requirement-to-test traceability matrix for the in-scope criteria and a test evidence pack per audit scope. The service adds a gap report before the examination period starts and retest evidence after remediation. The service auditor forms the opinion; the evidence pack gives the auditor test results mapped to each criterion.

Test automation delivers CI pipeline integration with release gates and a regression suite for critical money flows. Each release then leaves a test record linked to its change ticket, which is the change evidence a service auditor samples under CC8.1.

We run SOC 2 test work for platforms that other businesses connect to, such as Banking-as-a-Service and card issuing, open banking, KYC and AML, billing, accounting, and payroll products. The comparisons of SOC 2 and ISO 27001 and of PCI DSS and SOC 2 explain where the evidence overlaps. The bank vendor due diligence scenario sets out the sequence when a partner bank requests a SOC 2 report.

FintechAssuranceLabs holds a SOC 2 credential, verified via Deloitte Spain and valid until 2030.

Questions

Does SOC 2 require penetration testing?

The 2017 Trust Services Criteria do not name a mandatory penetration test or a test frequency. The 2022 points of focus for criterion CC4.1 list penetration testing as an example of a separate evaluation. A service organisation that uses penetration testing as a control shows the test report and the remediation records to the service auditor as evidence for CC4.1 and CC7.1.

Does SOC 2 require vulnerability scanning?

Criterion CC7.1 of the 2017 Trust Services Criteria expects procedures that detect configuration changes which introduce vulnerabilities and detect newly discovered vulnerabilities. The CC7.1 point of focus describes infrastructure and software vulnerability scans run periodically and after significant changes, with timely remediation. The AICPA states that some points of focus may not be suitable or relevant to an entity, and management may customise them.

What is SOC 2 compliance?

SOC 2 compliance usually means that a service organisation has a SOC 2 report from an independent service auditor. A SOC 2 report covers the system description and the controls against the AICPA Trust Services Criteria for one or more categories: security, availability, processing integrity, confidentiality, and privacy. A type 2 SOC 2 report adds an opinion on operating effectiveness over a period.

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