SOC 2 Audit Process Overview

The SOC 2 audit process involves preparing your organization, implementing controls, operating them over time (for Type II), and undergoing examination by a CPA firm. Understanding each phase helps you plan resources and set realistic expectations.

Timeline Summary

Type I: 2-4 months total (readiness + audit)
Type II: 9-15 months total (readiness + 6-12 month observation + audit)

Phase 1: Scoping & Planning (2-4 Weeks)

Before any audit work begins, you need to define what's being examined.

Define Your Scope

  • Services: Which products/services will be covered?
  • Systems: What infrastructure, applications, and tools support those services?
  • Trust Services Criteria: Which criteria apply? (Security is required; others optional)
  • Report Type: Type I or Type II?
  • Observation Period: For Type II, what period? (typically 6-12 months)

Select Your Auditor

SOC 2 audits must be performed by a licensed CPA firm. Selection criteria include:

  • Experience with your industry and technology stack
  • Reputation and references
  • Pricing and timeline
  • Communication style and accessibility

Establish Project Team

  • Executive sponsor
  • Project lead (often InfoSec or Compliance)
  • Technical representatives (Engineering, IT, DevOps)
  • Process owners (HR, Finance, Operations)

Deliverables: Scope document, auditor engagement letter, project plan

Phase 2: Readiness Assessment (4-8 Weeks)

A readiness assessment (gap analysis) compares your current state to SOC 2 requirements.

What's Assessed

  • Existing policies and procedures
  • Technical controls (access, encryption, monitoring)
  • Administrative controls (HR processes, vendor management)
  • Physical controls (if applicable)
  • Evidence collection capabilities

Gap Analysis Output

The assessment produces:

  • Control mapping to Trust Services Criteria
  • Gap identification (what's missing or weak)
  • Risk prioritization
  • Remediation roadmap with effort estimates

Readiness Options

  • Self-assessment: Internal team using templates/frameworks
  • Consultant-led: Expert assessment with recommendations
  • Auditor-led: Pre-audit by your CPA firm (watch for independence issues)

Deliverables: Gap analysis report, remediation plan, updated timeline

Phase 3: Remediation (4-12 Weeks)

Close the gaps identified in your readiness assessment.

Common Remediation Activities

  • Documentation: Create/update policies, procedures, standards
  • Access Controls: Implement MFA, access reviews, least privilege
  • Monitoring: Deploy logging, alerting, SIEM
  • Change Management: Formalize change control processes
  • Incident Response: Document and test IR procedures
  • Vendor Management: Assess and document vendor security
  • HR Controls: Background checks, security training, onboarding/offboarding
  • Business Continuity: DR planning and testing

Evidence Collection System

Critical for Type II: establish systems to automatically collect evidence:

  • Access review records
  • Change tickets and approvals
  • Training completion records
  • Incident tickets
  • Vulnerability scan results
  • Backup verification logs

Deliverables: Implemented controls, documented procedures, evidence collection processes

Phase 4: Observation Period (3-12 Months, Type II Only)

For Type II, controls must operate effectively over a period of time—typically 6-12 months.

What Happens During Observation

  • Controls operate as documented
  • Evidence is collected continuously
  • Exceptions are identified and addressed
  • Control improvements are made as needed

First-Time Type II Considerations

  • Minimum period: Most auditors require at least 6 months
  • Recommended period: 9-12 months for first report
  • Shorter periods: May be acceptable with auditor approval, but raises questions

Critical Success Factors

  • Consistent execution of controls (no "we forgot for 3 months")
  • Evidence retention (don't lose it)
  • Prompt exception handling (document and remediate)
  • Ongoing monitoring for control failures
Pro Tip: Type I Bridge

Many organizations get a Type I report while controls operate, then get Type II once they have sufficient operating history. This provides something to share with customers during the waiting period.

Phase 5: Audit Fieldwork (2-6 Weeks)

The CPA firm examines your controls through testing and evidence review.

Fieldwork Activities

  • Inquiry: Interviews with control owners and operators
  • Observation: Watching controls in operation
  • Inspection: Reviewing documents and configurations
  • Re-performance: Auditor performs the control themselves
  • Sample Testing: Selecting samples to verify consistent operation (Type II)

Evidence Requests

Expect requests for:

  • Policies and procedures
  • System configuration screenshots
  • Access lists and reviews
  • Change tickets from the period
  • Training records
  • Incident tickets
  • Vulnerability scans
  • Backup and restore logs
  • Vendor assessments

Handling Exceptions

If auditors find control failures:

  • Understand the exception fully
  • Provide context and compensating controls
  • Document remediation actions
  • Exceptions will be reported (can't hide them)

Deliverables: Completed testing, exception documentation, management responses

Phase 6: Reporting (2-4 Weeks)

The auditor drafts and finalizes the SOC 2 report.

Report Drafting

  • Auditor prepares draft report
  • You review system description for accuracy
  • You provide management responses to exceptions
  • Back-and-forth on clarifications

Management Representation Letter

You'll sign a letter representing that:

  • System description is accurate
  • Controls are designed and implemented as described
  • All relevant information was provided

Final Report Delivery

  • Auditor issues final report
  • Report is typically PDF format
  • Valid for the period covered (Type II) or point in time (Type I)

Deliverables: Final SOC 2 report

Complete Timeline

Type I Timeline (First Time)

Phase Duration Cumulative
Scoping & Planning 2-4 weeks Week 4
Readiness Assessment 4-6 weeks Week 10
Remediation 4-8 weeks Week 18
Audit Fieldwork 2-3 weeks Week 21
Reporting 2-3 weeks Week 24

Total: 4-6 months

Type II Timeline (First Time)

Phase Duration Cumulative
Scoping & Planning 2-4 weeks Month 1
Readiness Assessment 4-8 weeks Month 3
Remediation 6-12 weeks Month 6
Observation Period 6-12 months Month 12-18
Audit Fieldwork 3-6 weeks Month 13-19
Reporting 2-4 weeks Month 14-20

Total: 12-18 months

Tips for a Successful Audit

Before the Audit

  • Organize evidence before fieldwork begins
  • Brief participants on what to expect
  • Assign a single point of contact for the auditor
  • Test your evidence collection for completeness

During the Audit

  • Respond to requests promptly
  • Provide clean, relevant evidence (don't overwhelm)
  • Be honest about gaps—auditors will find them
  • Ask clarifying questions if unsure what's needed

Common Pitfalls

  • Starting observation period before controls are ready
  • Not collecting evidence throughout the period
  • Last-minute scrambling for documentation
  • Inconsistent control execution
  • Underestimating remediation effort

The audit itself is straightforward if you've done the preparation. Organizations struggle when they treat SOC 2 as a point-in-time exercise rather than building sustainable processes.