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SOC 2 Type II Implementation Checklist: visual preview
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SOC 2 Type II Implementation Checklist

Trust Service Criteria Readiness Checklist

Overview

A SOC 2 Type II report shows that your controls operated effectively over an observation period, commonly somewhere between three and twelve months. This checklist covers each phase of preparation, from scoping and gap analysis to evidence collection and auditor engagement. Use it to coordinate engineering, security, and compliance work and to avoid the gaps auditors most often find.

The criteria themselves are published by the AICPA as the 2017 Trust Services Criteria (with revised points of focus, 2022). Read the points of focus for each criterion you select; they describe what an auditor expects to see far more precisely than any summary.

Readiness Phases

  • Define the system description and in-scope services
  • Map controls to the Trust Service Criteria
  • Conduct a gap analysis against current control state
  • Remediate identified gaps and document compensating controls
  • Collect evidence and test control operating effectiveness
  • Engage the auditor and manage the examination timeline

Month-by-Month Readiness Plan

MonthWorkOutput
1Choose criteria, define in-scope systems, name control ownersScope statement and owner list
2Gap analysis against each selected criterionGap register with priorities
3 to 4Remediate gaps, write missing policies, configure logging and access reviewsClosed gaps with evidence of the fix
4Readiness review with the auditor or an independent assessorList of remaining issues
5 onwardObservation period begins; controls operate and evidence accumulatesEvidence folders per control
End of periodAuditor fieldwork, sampling, and management review of exceptionsDraft report, then final report

Trust Service Criteria Summary

CriteriaFocus areaExample controls
Security (CC)Protection against unauthorized accessFirewalls, MFA, endpoint protection, access reviews
Availability (A)System uptime and disaster recoverySLA monitoring, failover testing, capacity planning
Processing Integrity (PI)Accurate and complete data processingInput validation, reconciliation, error handling
Confidentiality (C)Protection of confidential informationEncryption at rest and in transit, DLP, classification
Privacy (P)Personal data handling per commitmentsConsent management, data retention, access requests

Copy-Ready Checklist for the Security Criteria

  • CC1 Control environment: board or leadership oversight documented; security roles and code of conduct acknowledged by staff
  • CC2 Communication: security policies published internally; customers told how to report issues
  • CC3 Risk assessment: written risk assessment updated at least annually, including fraud risk
  • CC4 Monitoring: internal control reviews scheduled, findings tracked to closure
  • CC5 Control activities: policies mapped to the controls that enforce them
  • CC6 Logical and physical access: MFA on production and cloud consoles; joiner, mover, leaver process; quarterly access reviews
  • CC7 System operations: logging and alerting on production; vulnerability scanning; incident response plan tested
  • CC8 Change management: code review and approval before production deploys; emergency change process
  • CC9 Risk mitigation: vendor due diligence on file; business continuity plan and insurance reviewed

Evidence Auditors Typically Request

Control areaEvidenceSample size to expect
Access reviewsReview tickets with reviewer name, date, and changes madeEvery quarterly review in the period
Onboarding and offboardingHR records matched to account creation and removal datesA sample of joiners and leavers
Change managementPull requests with approvals linked to deploymentsA sample across the period
Vulnerability managementScan reports and tickets showing remediation within your stated timelinesA sample of findings by severity
Incident responseIncident tickets or tabletop exercise recordsAll incidents or the annual exercise
Vendor managementDue diligence records for in-scope vendorsVendors added or reviewed in the period

Evidence Collection Best Practices

Automate evidence collection wherever possible using GRC platforms or scripts that pull screenshots, logs, and configuration exports on a schedule. Organize evidence by control ID and map each piece of evidence to the specific criteria it supports. Maintain a chain-of-custody log for sensitive evidence. Start collecting evidence at least two months before the audit window opens to ensure you have enough operating history.

Filled Example: One Control, Written Up

Illustrative example of how to document a single control so an auditor can test it without a follow-up call.

Control ID: AC-04. Description: Production access is reviewed every quarter by the engineering manager, and any access no longer needed is removed within five business days. Criteria: CC6.2, CC6.3. Owner: Head of Engineering. Frequency: Quarterly. Evidence: review ticket listing every account with production access, the reviewer's decision for each, and the change tickets for removals. How it could fail: a review is skipped, or removals take longer than five days. Test the auditor will run: select each quarter's review, confirm it happened on time, and trace removals to closed change tickets.

Common Readiness Gaps

  • Missing or incomplete access reviews for critical systems
  • No documented change management process for production deployments
  • Insufficient logging or log retention below the required period
  • Lack of formal risk assessment updated at least annually
  • Vendor management program without documented due-diligence assessments
  • Incident response plan that has never been tested through a tabletop exercise

Auditor Engagement Timeline

Engage your auditor at least three months before the planned audit window to agree on scope, walkthrough schedules, and evidence submission formats. Conduct a readiness assessment six to eight weeks before the observation period ends. Provide evidence in organized folders with clear naming conventions. Schedule management meetings at the midpoint and end of the observation period to address any exceptions early.

Frequently asked questions

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