Organizations aiming to achieve SOC 2 Framework compliance often face challenges, such as scoping their SOC 2 reports, addressing gaps in control implementation, and allocating resources for audits.
Partnering with an experienced compliance advisor can help your organization navigate these hurdles efficiently.
Facing obstacles with your SOC 2 Framework implementation? Schedule a consultation today to get expert guidance.
SOC 2 Framework Pain Points and How to Overcome Them
The SOC 2 Framework is designed to be flexible, allowing organizations to implement controls that meet their clients’ and stakeholders’ expectations. However, achieving compliance can still be challenging without proper planning and guidance.
Most organizations’ SOC 2 compliance challenges fall into three main categories:
- Uncertainty about SOC audits: Confusion over whether your organization needs a SOC audit and which type is required.
- Control gaps and deployment issues: Difficulty ensuring controls fully meet SOC 2 requirements.
- Resource constraints: Challenges in allocating enough time, personnel, and budget for SOC 2 preparation and assessment.
Addressing these challenges requires intentional planning and resource allocation. Partnering with a dedicated SOC 2 advisor makes the process smoother and more efficient.
Pain Point 1: Uncertainty in Audit Scope
One of the biggest challenges in achieving SOC 2 Framework compliance is understanding which SOC framework applies and which controls need to be implemented. While SOC 2 and SOC 3 share many similarities, both aligning with the Trust Services Criteria (TSC), the right choice depends on your organization’s objectives.
Some organizations may pursue alternative SOC deployments, such as SOC for Cybersecurity or SOC for Supply Chain, while others must decide between Type I or Type II SOC reports under the SOC 1 or SOC 2 Framework.
Clearly defining the audit scope upfront ensures more efficient control implementation and smoother audit preparation.
Determining Which SOC Reporting to Conduct
The American Institute of Certified Public Accountants (AICPA) oversees three main SOC control frameworks:
- SOC 1 Framework: Focuses on controls at service organizations related to user entities’ internal control over financial reporting (ICFR). Typically used by financial service providers, SOC 1 reports can be Type 1 or Type 2.
- SOC 2 Framework: Evaluates controls related to security, availability, processing integrity, confidentiality, and privacy. Applicable to a wide range of organizations, SOC 2 reports are intended for specialist audiences and come in Type 1 or Type 2.
- SOC 3 Framework: Covers the same areas as SOC 2 but is designed for general audiences and public availability. SOC 3 reports do not have a Type designation.
Most organizations undergo either a SOC 1 report or a SOC 2 and/or SOC 3 report. While SOC 2 and SOC 3 target similar organizations, they serve different audiences, whereas SOC 1 addresses entirely different objectives. Choosing the correct SOC report upfront ensures efficient planning, accurate control implementation, and smoother audit preparation.
See below for resource allocation requirements for Type 1 vs. Type 2 SOC reports.
Pain Point 2: Gaps in Control Deployment
A common challenge in implementing the SOC 2 Framework is installing and maintaining the necessary controls. Organizations must implement controls from the Trust Services Criteria (TSC) framework to meet compliance requirements.
Common Criteria (CC): These apply to all SOC 2 audits, covering the Security principle and often touching on other TSC principles.
Additional Criteria: These apply to other TSC principles and may or may not be required, depending on stakeholder expectations. If the scope is unclear, implementing all controls is safest. However, if clients or prospects specify only the CC, or the CC plus select Additional Criteria, you can optimize control deployment accordingly. Properly addressing these gaps ensures that your organization meets SOC 2 requirements efficiently and avoids costly audit issues.
Security and Overall Cyber defense Deployment in the SOC 2 Framework
The Trust Services Criteria (TSC) Common Criteria (CC) cover all security requirements of the SOC 2 Framework and also touch upon elements of the other four principles. Every SOC 2 audit requires implementing these controls at a minimum to ensure comprehensive compliance.
CC1 Series – Control Environment
- CC1.1: Demonstrate commitment to integrity and ethical values
- CC1.2: Maintain board independence in internal control oversight
- CC1.3: Define responsibilities and logistics for achieving objectives
- CC1.4: Recruit and retain staff aligned with organizational goals
- CC1.5: Hold individuals accountable for internal control objectives
CC2 Series – Communication and Information
- CC2.1: Use relevant, high-quality information to support internal controls
- CC2.2: Communicate internal control information internally
- CC2.3: Disseminate internal control information externally
CC3 Series – Risk Assessment
- CC3.1: Clearly define objectives to identify relevant risks
- CC3.2: Identify risks to objectives and address them
- CC3.3: Consider potential fraud in risk identification
- CC3.4: Assess changes that could impact internal controls
CC4 Series – Monitoring Activities
- CC4.1: Perform assessments to ensure internal controls function properly
- CC4.2: Communicate deficiencies to responsible parties promptly
CC5 Series – Control Activities
- CC5.1: Develop controls to mitigate risks and support objectives
- CC5.2: Implement specialized technological controls
- CC5.3: Deploy controls through clear policies and defined responsibilities
CC6 Series – Logical and Physical Access Controls
- CC6.1–CC6.8: Implement robust logical and physical access measures, including authorization, least privilege, secure data transmission, and software controls
CC7 Series – System Operations
- CC7.1–CC7.5: Monitor system operations, analyze anomalies, respond to incidents, and implement recovery protocols
CC8 Series – Change Management
- CC8.1: Control and implement infrastructure changes to meet objectives
CC9 Series – Risk Mitigation
- CC9.1: Minimize risks that could disrupt business operations
Implementing these Common Criteria ensures your organization meets the SOC 2 Framework standards for security and overall cyber defense, helping protect data, maintain client trust, and prepare for successful audits.
Additional Criteria Control Deployment in the SOC 2 Framework
Beyond the baseline Common Criteria (CC), the SOC 2 Framework includes Additional Criteria that address other Trust Services Criteria (TSC) principles beyond Security. Depending on your SOC 2 assessment, some audits require all controls, while others may focus only on the CC or a selected set of Additional Criteria.
A Series – Availability
- A1.1: Maintain and monitor system capacity for necessary adjustments
- A1.2: Ensure environmental protections and recovery infrastructure
- A1.3: Test recovery plans and procedures to meet objectives
C Series – Confidentiality
- C1.1: Identify and maintain confidential information per defined objectives
- C1.2: Dispose of confidential information securely and on time
PI Series – Processing Integrity
- PI1.1: Obtain, use, and communicate information related to processing
- PI1.2–PI1.5: Control inputs and outputs, implement procedures, and store processes securely to ensure data completeness and accuracy
Privacy Criteria (P Series)
- P1 – Notice and Communication: Update data subjects on privacy practices
- P2 – Choice and Consent: Obtain consent for personal data processing
- P3 – Collection: Align personal data collection with objectives
- P4 – Use, Retention, Disposal: Limit use, retain properly, and dispose securely
- P5 – Access: Provide data subjects access and adjustments
- P6 – Disclosure and Notification: Manage third-party disclosures and breach notifications
- P7 – Quality Assurance: Maintain accurate personal data
- P8 – Monitoring and Enforcement: Monitor and resolve disputes regarding personal information
Depending on your SOC 2 assessment scope, some or all Additional Criteria may be required. Implement only the controls necessary to meet stakeholder expectations and avoid unnecessary overlap or effort.
Pain Point 3: Time and Resource Constraints
The final major challenge in achieving SOC 2 Framework compliance is allocating the right time and resources for implementation and audit. The SOC 2 Framework offers two audit Types, each with different resource requirements and levels of security assurance:
Type 1 Audits
- Evaluate the design of controls relative to the criteria being assessed.
- Provide a snapshot of the control system at a specific point in time.
- Require fewer resources and are quicker to complete—typically a few weeks to no more than six months.
Type 2 Audits
- Examine the operational effectiveness of controls over a period of time.
- Provide longitudinal assurance that systems maintain security consistently.
- More resource-intensive, often taking six months or longer, sometimes over a year.
- Deliver the highest level of security assurance for stakeholders.
Understanding the differences between Type 1 and Type 2 audits helps organizations plan their SOC 2 Framework implementation efficiently and allocate resources effectively.
Best Governance Practices for SOC 2 Framework Audit Preparation
Preparing for a SOC 2 Framework audit, especially Type 2 reporting, requires strong and efficient cybersecurity governance. This begins at the leadership level, with clear communication of responsibilities from executives such as Chief Information Security Officers (CISOs). Many growing organizations, however, may not have a CISO in place, and recruiting the right expertise can be challenging.
A Virtual CISO (vCISO) offers an effective alternative. A vCISO provides the same strategic guidance as a traditional CISO but at a fraction of the cost. Partnering with a vCISO can help your organization:
- Streamline SOC 2 Framework compliance preparation
- Identify gaps or risks that internal teams may overlook
- Optimize cybersecurity processes without expanding internal headcount
Additionally, managed security service providers (MSSPs) can complement this support, helping organizations rethink their security posture and strengthen audit readiness.
Solve Your SOC 2 Framework Challenges Today
Achieving SOC 2 Framework compliance can be complex due to the scale of implementation and assessment. Organizations must accurately define audit scope, deploy all required controls, and allocate sufficient resources for a Type 1 or Type 2 audit.
RSI Security has guided countless organizations through successful SOC 2 Framework implementation, covering both Type 1 and Type 2 reporting. We understand that implementing the framework correctly is the key to protecting your data and maintaining stakeholder trust.
By taking a disciplined approach now, your organization unlocks greater flexibility to expand within your industry or across new markets, confidently meeting regulatory and client expectations.
Contact RSI Security today to learn how your organization can achieve SOC 2 Framework compliance efficiently and effectively.
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