SOC 2 PenTest: key testing requirements for audits

Imagine you’ve built a medieval fortress, complete with moats, drawbridges, and arrow slits—but you never invite someone to actually try scaling the walls. That’s essentially what relying solely on automated vulnerability scans feels like: you assume the defenses hold, but you’ve never truly tested their mettle. 

In this article, I’ll walk you through why penetration testing—even if not explicitly mandated by SOC 2—should be a cornerstone of your audit-readiness strategy. You’ll learn how the AICPA’s Trust Services Criteria frame pen testing as a “separate evaluation,” what to include in your test scope, how often to run tests, and best practices for reporting and remediation.

Understanding SOC 2’s trust services criteria and separate evaluations

At its core, SOC 2 evaluates controls against the Trust Services Criteria, ensuring organizations safeguard data according to security, availability, processing integrity, confidentiality, and privacy principles. Within this framework, auditors look for both ongoing monitoring and distinct, point-in-time checks—what SOC 2 calls “separate evaluations.” Penetration testing ticks that box, demonstrating controls work under adversarial conditions rather than merely existing on paper.

PRO TIP

Tag each pentest engagement in your GRC tool as a “separate evaluation” under CC 4.1. This allows you to report it alongside internal audit results—giving your auditor a clear view of both ongoing and point-in-time checks.

CC4.1 Monitoring activities and the role of penetration testing

CC4.1 requires management to “use a variety of different types of ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning.” One point of focus explicitly cites penetration tests as an acceptable separate evaluation, placing them alongside internal audits and third-party certifications such as ISO 27001. By including pen tests here, the AICPA signals that simulated attacks offer critical evidence of control effectiveness.

CC7.1 Vulnerability management and detection procedures

While CC7.1 (System Operations–Vulnerability Management) doesn’t explicitly demand penetration testing, it does require periodic detection and monitoring procedures—think vulnerability scans—and timely remediation of newly discovered issues. Penetration tests complement scans by uncovering chained exploits and business logic flaws that scanners often miss. Together, these activities satisfy both the letter and spirit of CC7.1, proving you don’t just spot vulnerabilities, you prioritize and fix them promptly.

Why you should perform a pentest for SOC 2 audits

Automated tools can flag missing patches or misconfigurations, but they rarely prove whether an attacker could actually breach your systems. Penetration testing bridges that gap by actively exploiting weaknesses to reveal real-world impact on systems, data, and users. This active approach provides auditors with tangible proof that your controls don’t just exist—they withstand an attacker’s methods.

Pen tests also bolster your SOC 2 evidence under CC4.1, giving auditors confidence that controls function in practice. Findings feed directly into your risk-management process, ensuring you address high-impact vulnerabilities before they reach production. In other words, pen tests aren’t just a checkbox; they’re a proactive way to strengthen your security posture and streamline audit approvals.

PRO TIP

When you deliver pen test results, include a one-pager that maps each high-impact finding to the relevant Trust Services Criterion (e.g., CC 7.1). That mapping shows auditors exactly how your test satisfies SOC 2 requirements.

Scoping your SOC 2 penetration test

One of the first—and most critical—decisions is defining what systems, applications, and processes fall within test scope. A well-scoped engagement ensures you allocate resources effectively and uncover vulnerabilities where they matter most.

Begin with your highest-risk assets—systems that process personal data, financial transactions, or critical business functions. From there, you can expand scope to include emerging surfaces like APIs and mobile apps.

Determining frequency and timing for pentests

Just as you wouldn’t rebuild a bridge and wait years to test its load capacity, you shouldn’t leave long gaps between penetration tests. Aligning your pentest schedule with SOC 2’s annual audit cycle ensures you always have fresh evidence of control effectiveness.

• Annual baseline: At minimum, conduct a full external and internal network test once per year.
  
• Post-change engagements: Any major infrastructure overhaul, cloud migration, or new application launch should trigger an ad hoc pen test.
  
• Risk-based cadence:
  
  • High-risk systems: quarterly
    
  • Medium-risk systems: semi-annually
    
  • Low-risk systems: annually
    

By tailoring test frequency to system criticality, you strike the right balance between thoroughness and cost-effectiveness—just like prioritizing engine checks on your flagship aircraft over its winglet inspection.

PRO TIP

Align your pen test schedule with your code-release calendar by triggering a scoped “smoke test” penetration check whenever a major feature goes live. This “shift-left” approach catches gaps before they hit production and provides continuous evidence for SOC 2.

Crafting effective pentest reports

A penetration test’s value hinges on clear, actionable reporting. Your SOC 2 audit team will scrutinize both the findings and the narrative showing how tests were conducted. A comprehensive report should include:

1. Executive summary with high-level findings and business impact.
   
2. Methodology detailing scope, phases (reconnaissance, assessment, exploitation, post-exploitation), and tools used.
   
3. Detailed findings for each vulnerability, complete with risk ratings, screenshots or logs, and reproduction steps.
   
4. Remediation recommendations offering specific guidance tied to your environment.
   
5. Evidence and artifacts such as proof-of-concept exploit code, raw tool output, and relevant logs.
   

When you present this report, auditors see not only what went wrong but also how you plan to fix it—and that narrative is what satisfies CC4.1’s “functioning” control requirement.

PRO TIP

Include a “test replay” appendix in your report: short video clips or screen recordings of key exploit steps. Not only does this impress auditors, it helps developers reproduce issues faster for remediation.

Establishing remediation timelines and tracking

Finding vulnerabilities is only half the battle. SOC 2 auditors under CC7.1 expect documented SLAs for fixing vulnerabilities based on severity, as well as evidence of remediation.

Maintaining a remediation-tracking system—complete with timestamps, owner assignments, and verification logs—creates that audit-ready trail. When auditors ask, you can show not only that you found and fixed issues but that you did so within your documented SLAs.

PRO TIP

Automate your remediation SLAs in your ticketing system (e.g., Jira) by linking severity to due-date rules. This creates audit-ready logs showing exactly when and how each vulnerability was resolved against your published SLA.

Implementing best practices for SOC 2 pentesting

Penetration testing isn’t a one-off event; it’s part of a continuous security journey. Adopting the following best practices will maximize ROI and streamline audits:

• Qualified testers: Engage independent, certified professionals (e.g., OSCP, GPEN, CEH) to avoid conflicts of interest.
  
• Established frameworks: Follow NIST SP 800-115, the Penetration Testing Execution Standard (PTES), or the OWASP Testing Guide for consistent methodology.
  
• Continuous monitoring: Pair pen tests with automated scans (dynamic application security testing and static application security testing) and real-time security logging to catch emerging risks.
  
• Version-controlled reporting: Store test reports, retest evidence, and remediation logs in a secure, auditable repository—think of it as your fortress’s historical archives.
  

By weaving pentesting into a broader security program, you’ll not only ace your SOC 2 audit but also fortify defenses against attackers who never stop innovating.

Streamline your SOC 2 compliance with CyberUpgrade

SOC 2 compliance demands airtight controls, clear evidence, and proof that your security measures truly work under scrutiny. CyberUpgrade offers predefined, customizable workflows aligned with Trust Services Criteria that automate tasks like background checks, access reviews, and incident logging. Real-time Slack and Teams prompts guide your team through every step, slashing manual effort by up to 80% and ensuring no control gets overlooked.

All compliance evidence—from vulnerability scans to MFA logs—is centralized in an audit-ready repository, making it easy to satisfy both ongoing monitoring and “separate evaluation” requirements under CC 4.1 and CC 7.1. Built-in risk assessments, pen-testing integrations, and continuous monitoring shore up your defenses, while our fractional CISO service provides expert guidance and strategic leadership. 

With CyberUpgrade, you’ll not only meet today’s SOC 2 standards but build a scalable, future-proof compliance program—so audits become confirmation, not chaos.

Strengthening your security for what’s next

Penetration testing may not be a hard SOC 2 requirement, but it’s the closest thing to a “stress test” for your security controls. When you pair annual and post-change pen tests with regular vulnerability scans and robust remediation tracking, you satisfy CC4.1’s separate evaluations and CC7.1’s vulnerability management criteria. More importantly, you build genuine resilience—ensuring that when real threats knock at your gates, your defenses hold firm.