SOC 2 Penetration Testing

For many service providers, achieving SOC-2 certification is now essential to prove to third-party stakeholders and partners that the company is serious about safeguarding the sensitive data and information systems held in the cloud. Often, a SOC-2 report (or lack thereof) can even determine whether a business deal will go through.

Many businesses may undergo vulnerability scanning or penetration testing when aligning with SOC 2 requirements or the AICPA Trust Services Criteria. However, whether this is mandatory for SOC-2 compliance is often unclear. In this article, Hicomply will explain the requirements regarding SOC-2 penetration testing and vulnerability scanning to help you decide whether this step is necessary for your business.

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SOC 2 testing at a glance

• SOC 2 reports help prove to stakeholders and partners that a service provider safeguards cloud-based sensitive data.
• Penetration testing and vulnerability scanning are common when aligning with SOC 2 requirements or the AICPA Trust Services Criteria.
• The article says whether testing is mandatory for SOC 2 compliance is often unclear, so the decision depends on business context.

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What is SOC-2 compliance?

SOC-2, which stands for Systems and Organization Controls 2, is a security framework that informs businesses on the best practices to protect cloud-based sensitive data from security vulnerabilities such as unauthorised access, breaches, and data leaks.

Organisations wishing to become SOC-2 compliant must implement comprehensive policies and procedures that mitigate, manage, and address cybersecurity risks. Once certification has been awarded, regular independent audits must also be undertaken to test these security measures.

What are SOC-2 penetration testing and vulnerability scanning?

Penetration testing and vulnerability scanning are methods used to access a computer’s security system internally to assess its strength and the organisation's overall security posture, particularly its ability to respond to cyber-attacks.

SOC-2 penetration testing, or ‘pentesting’, involves simulating a cyber-attack using the same tools, techniques, and procedures as a malicious individual.

The aim of a pentest is to identify weaknesses and vulnerabilities within the system that a hacker could exploit to demonstrate impact on the network or the organisation. The demonstration of impact could take several different forms, including access to sensitive data.

Conversely, vulnerability scanning is an automated process designed to highlight vulnerabilities already known to the business, in order to assess the strength of the company’s security posture.

SOC-2 penetration testing and vulnerability scanning will both identify security risks; however, each method has its own set of pros and cons. SOC-2 penetration testing is more rigorous, so it will uncover more hidden weaknesses; however, it’s also a more time-consuming process. Vulnerability scanning is much quicker and cheaper but less thorough.

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Pen testing vs vulnerability scanning

• Pentesting demonstrates impact by identifying weaknesses a hacker could exploit, including access to sensitive data.
• Vulnerability scanning assesses security posture by highlighting known vulnerabilities.
• Both methods identify security risks, but the article distinguishes rigour, speed, cost, and thoroughness.

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Is SOC-2 penetration testing mandatory?

SOC-2 penetration testing is not mandatory for compliance. However, it’s an extremely valuable process that auditors often recommend when fulfilling the following section of the Trust Services Criteria:

• Principle 16: The entity selects, develops, and performs ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning.

The criteria mentions SOC-2 penetration testing as a useful method for performing these evaluations. However, if your business is already ISO 27001 compliant, the certificate may be enough proof that the organisation is regularly evaluating its security posture.

There are several benefits to SOC-2 penetration testing, including the opportunity to expose risks and vulnerabilities your organisation may not have previously known about, improving your overall defence against cyber-attacks.

Is SOC-2 vulnerability scanning a requirement?

SOC-2 vulnerability scanning is not mandatory. However, auditors recommend it as a best practice for businesses seeking compliance. Vulnerability scanning can satisfy the following requirements from the Trusted Services Criteria:

• CC7.1: To meet its objectives, the entity uses detection and monitoring procedures to identify (1) changes to configurations that result in the introduction of new vulnerabilities, and (2) susceptibilities to newly discovered vulnerabilities.

• CC7.1 point of focus: Conducts Vulnerability Scans – The entity conducts vulnerability scans designed to identify potential vulnerabilities or misconfigurations on a periodic basis and after any significant change in the environment and takes action to remediate identified deficiencies on a timely basis.

Although vulnerability scanning isn’t essential, it supports the SOC-2 control CC7.1, so companies seeking compliance should consider hosting regular vulnerability scans to keep their security systems up-to-date and at a reduced risk of an attack.

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Mandatory or recommended?

• SOC 2 penetration testing is not mandatory for compliance, but auditors often recommend it.
• Trust Services Criteria Principle 16 covers ongoing and/or separate evaluations of internal control.
• Vulnerability scanning is not mandatory, but auditors recommend it as a best practice for businesses seeking compliance.
• CC7.1 focuses on detection and monitoring procedures for new vulnerabilities and susceptibilities.

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Should my business conduct penetration testing and vulnerability scanning to achieve SOC-2 compliance?

Despite not being mandatory for compliance, SOC-2 penetration testing and vulnerability scanning can be vital for companies looking to bolster their cyber security efforts. A pentest can improve your defences against cyberattacks and the resulting emerging threats and help you to identify areas that need improvement.

Combined, these methods will work as part of a comprehensive security program to ensure your systems are completely protected.

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In Hicomply's experience

The practical question is not whether every SOC 2 audit forces a pentest, but whether your evidence shows regular evaluation, remediation, and monitoring. Hicomply recommends linking scans, pentest findings, corrective actions, and audit evidence in one compliance workflow so teams can prove improvement without rebuilding the story for each audit.

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SOC-2 penetration testing simplified with Hicomply

Is your organisation seeking SOC-2 compliance? Hicomply’s full-fledged ISMS will streamline the process – including automated SOC-2 penetration testing! – so you can focus on running your business. Contact us today to learn more about achieving compliance as you work.