Common SOC2 Audit Findings and How to Avoid Them

SOC 2 (Service Organization Control 2) compliance has become the gold standard for demonstrating robust security and privacy practices to customers and partners. However, achieving SOC 2 certification is challenging, and many organizations stumble during their first audit, receiving findings that delay certification or require significant remediation efforts.

Understanding common audit findings before they occur saves time, money, and stress. This comprehensive guide explores the top 10 most frequently identified issues during SOC 2 audits, explains why they matter, and provides actionable strategies to prevent them. Whether you're preparing for your first SOC 2 audit or working to improve your existing compliance program, these insights will help you avoid common pitfalls and achieve successful certification.

Understanding SOC 2 Audit Findings

Before diving into specific findings, it's important to understand what they mean and how they impact your audit.

Types of Audit Findings

• Exception: A deviation from a control that was not designed or operating effectively during the audit period. Exceptions are documented in the final report and visible to customers.
• Management Response: Your organization's explanation of how you'll address the exception, including timeline and responsible parties.
• Qualified Opinion: The most serious outcome—when auditors cannot provide an unqualified opinion on your controls. This significantly impacts customer trust.

Impact of Audit Findings

• Delayed certification and market entry
• Additional audit costs for remediation and re-testing
• Lost business opportunities with security-conscious customers
• Damage to reputation and customer confidence
• Internal resource drain addressing issues
• Potential security vulnerabilities exposed

Finding #1: Inadequate Access Control Management

Access control issues are among the most common SOC 2 findings. These occur when organizations fail to properly manage who has access to systems, applications, and data.

Why Auditors Care

Improper access control is a direct security risk. Former employees with active credentials could access sensitive data. Excessive permissions increase the blast radius of compromised accounts. Shared credentials eliminate accountability and audit trails.

Prevention Strategies

• Implement Identity Management: Use centralized identity providers (Okta, Azure AD, Google Workspace)
• Enforce Least Privilege: Grant minimum necessary permissions for each role
• Automate Provisioning: Integrate HR systems with access management for automatic onboarding/offboarding
• Regular Access Reviews: Quarterly reviews of all user access and permissions
• Privileged Access Management (PAM): Special controls for admin and service accounts
• Multi-Factor Authentication (MFA): Required for all users, especially privileged accounts
• Document Processes: Written procedures for access requests, approvals, and revocation

Finding #2: Insufficient Documentation

"If it isn't documented, it doesn't exist" is the unofficial motto of SOC 2 audits. Many organizations have solid security practices but fail to document them adequately.

Required Documentation

Policies (High-Level):

• Information Security Policy
• Access Control Policy
• Change Management Policy
• Incident Response Policy
• Data Classification Policy
• Vendor Management Policy
• Acceptable Use Policy
• Business Continuity/Disaster Recovery Policy

Procedures (Detailed Steps):

• User provisioning and deprovisioning
• Code deployment processes
• Backup and restoration procedures
• Incident response playbooks
• Vulnerability management workflow
• Security monitoring procedures

Evidence Documentation:

• Access review reports
• Change approval tickets
• Security training completion records
• Vulnerability scan results
• Incident response logs
• Backup test results

Documentation Best Practices

• Centralized Repository: Use a single source of truth (Confluence, SharePoint, dedicated GRC platform)
• Version Control: Track changes and maintain revision history
• Regular Reviews: Annual policy reviews with documented approval
• Accessible: Ensure employees can easily find and reference policies
• Realistic: Document what you actually do, not aspirational processes
• Evidence Collection: Build evidence gathering into operational processes

Finding #3: Weak Change Management Controls

Change management ensures that modifications to systems, applications, and infrastructure are properly authorized, tested, and documented. Inadequate change management is a frequent finding.

Why This Matters

Uncontrolled changes are a leading cause of outages and security incidents. Without proper change management, unauthorized or poorly tested changes can impact system availability, integrity, and security. Auditors need assurance that changes won't compromise the trust services criteria.

Building Effective Change Management

1. Define Change Types:
   • Standard changes: Pre-approved, low-risk (e.g., applying security patches)
   • Normal changes: Require approval and testing
   • Emergency changes: Expedited process with post-implementation review
2. Establish Approval Workflow:
   • Document who can authorize different change types
   • Require change requests with business justification
   • Implement separation of duties (requester ≠ approver ≠ implementer)
3. Testing Requirements:
   • Development and staging environments for testing
   • Automated testing (unit tests, integration tests)
   • Security impact assessment
   • Rollback plans documented
4. Documentation and Tracking:
   • Use ticketing systems (Jira, ServiceNow)
   • Link changes to code commits and deployments
   • Maintain change logs and audit trails
   • Post-implementation review for significant changes

Tools and Automation

• Ticketing Systems: Jira, ServiceNow for change requests and approvals
• CI/CD Pipelines: GitHub Actions, GitLab CI, Jenkins for automated deployments
• Infrastructure as Code: Terraform, CloudFormation for auditable infrastructure changes
• Monitoring: Alert on production changes for visibility

Finding #4: Inadequate Security Monitoring and Incident Response

Organizations must demonstrate they can detect, respond to, and recover from security incidents. Gaps in monitoring and incident response capabilities are common findings.

Security Monitoring Requirements

What to Monitor:

• Authentication events (failed logins, unusual access patterns)
• Privileged access and administrative actions
• System and application errors
• Network traffic anomalies
• File integrity monitoring for critical systems
• Vulnerability scan results
• Antivirus and endpoint detection alerts

Monitoring Tools:

• SIEM Solutions: Splunk, Datadog, Sumo Logic, ELK Stack
• Cloud-Native Monitoring: AWS CloudWatch, Azure Monitor, Google Cloud Monitoring
• Endpoint Detection: CrowdStrike, SentinelOne, Microsoft Defender
• Network Monitoring: Cisco Stealthwatch, Darktrace

Incident Response Framework

1. Preparation:
   • Document incident response plan with roles and responsibilities
   • Define incident severity levels (P1-P4)
   • Establish communication protocols
   • Maintain updated contact lists
   • Create incident response playbooks for common scenarios
2. Detection and Analysis:
   • Alert on security events
   • Triage and classify incidents
   • Gather evidence and determine scope
3. Containment, Eradication, Recovery:
   • Isolate affected systems
   • Remove threat actors or malware
   • Restore systems from clean backups
   • Implement additional controls to prevent recurrence
4. Post-Incident Activities:
   • Document incident details in ticketing system
   • Conduct post-mortem review
   • Update security controls and documentation
   • Provide training if needed

Evidence to Maintain

• Security monitoring dashboard screenshots
• Alert configurations and escalation procedures
• Incident tickets and investigation notes
• Post-incident review reports
• Annual incident response plan testing documentation

Finding #5: Incomplete or Missing Risk Assessments

Risk assessment is foundational to SOC 2 compliance. Organizations must identify, analyze, and mitigate risks to the trust services criteria. Missing or inadequate risk assessments are frequent findings.

Conducting a Comprehensive Risk Assessment

1. Identify Assets and Threats:
   • Catalog critical systems, applications, and data
   • Identify potential threats (cyber attacks, natural disasters, human error)
   • Consider vulnerabilities in your environment
2. Assess Likelihood and Impact:
   • Rate probability of each risk occurring (Low/Medium/High)
   • Evaluate potential impact on confidentiality, integrity, availability
   • Calculate risk level (likelihood × impact)
3. Determine Risk Treatment:
   • Accept: Risk is low enough to tolerate
   • Mitigate: Implement controls to reduce risk
   • Transfer: Use insurance or third parties
   • Avoid: Eliminate the risky activity
4. Document and Track:
   • Create risk register documenting all identified risks
   • Assign owners responsible for risk treatment
   • Set timelines for implementing controls
   • Track remediation progress
5. Review and Update:
   • Annual risk assessment reviews minimum
   • Ad-hoc updates for significant changes (new systems, major incidents)
   • Management review and acceptance of residual risks

Risk Assessment Tools and Frameworks

• Frameworks: NIST Risk Management Framework, ISO 27005, FAIR
• Tools: Vanta, Drata, Secureframe (compliance automation platforms)
• Templates: NIST SP 800-30 provides comprehensive risk assessment guidance

Finding #6: Vendor Management Deficiencies

Third-party vendors represent significant risk, especially when they have access to your systems or data. Inadequate vendor management is a common finding that auditors take seriously.

Building a Vendor Management Program

1. Vendor Inventory:
   • Catalog all vendors with system access or handling your data
   • Document services provided and data accessed
   • Classify vendors by risk level (critical, high, medium, low)
2. Vendor Due Diligence:
   • Security questionnaires for new vendors
   • Review SOC 2 Type II reports (or equivalent certifications)
   • Penetration test reports for high-risk vendors
   • Insurance certificates (cyber liability)
3. Contractual Requirements:
   • Data Processing Agreements (DPAs) for data processors
   • Security requirements and obligations
   • Right to audit clause
   • Breach notification requirements
   • Data deletion/return upon termination
4. Ongoing Monitoring:
   • Annual SOC 2 report review for critical vendors
   • Vendor performance reviews
   • Monitor for vendor security incidents
   • Periodic vendor risk re-assessment

Evidence Collection

• Vendor inventory spreadsheet or database
• Vendor contracts with security addendums
• Vendor security assessments and questionnaires
• SOC 2 reports from critical vendors
• Annual vendor review documentation

Finding #7: Insufficient Security Training and Awareness

Human error remains a leading cause of security incidents. Organizations must provide regular security awareness training, but many fail to do so adequately.

Implementing Effective Security Training

Training Components:

• New Hire Training: Security awareness during onboarding (within first week)
• Annual Refresher: Yearly training for all employees
• Role-Based Training: Additional training for privileged users (developers, admins)
• Phishing Simulations: Regular simulated phishing tests
• Security Updates: Communication about new threats and policies

Training Topics:

• Phishing and social engineering recognition
• Password management and MFA
• Data classification and handling
• Acceptable use of company resources
• Physical security practices
• Incident reporting procedures
• Privacy and data protection (GDPR, CCPA)
• Secure remote work practices

Training Platforms:

• KnowBe4 (comprehensive platform with content and phishing simulations)
• Cofense (phishing-focused training)
• SANS Security Awareness
• Proofpoint Security Awareness Training
• Custom training via LMS (Learning Management System)

Documentation Requirements

• Training policy and schedule
• Training content or curriculum
• Completion tracking (per employee, with dates)
• Phishing simulation results and remediation
• Security awareness communications and updates

Finding #8: Inadequate Backup and Recovery Capabilities

Business continuity and disaster recovery are critical trust services criteria. Organizations must demonstrate the ability to recover from disruptions.

Backup Best Practices

• 3-2-1 Rule: 3 copies of data, on 2 different media types, with 1 offsite/offline
• Automated Backups: Daily or more frequent for critical systems
• Immutable Backups: Protection against ransomware (write-once, append-only storage)
• Encryption: Backup data encrypted in transit and at rest
• Monitoring: Alert on backup failures
• Retention: Define retention periods based on requirements (compliance, business needs)

Disaster Recovery Planning

1. Define Objectives:
   • Recovery Time Objective (RTO): Maximum acceptable downtime
   • Recovery Point Objective (RPO): Maximum acceptable data loss
2. Document Procedures:
   • Step-by-step recovery processes
   • Contact information for team members
   • Access credentials for recovery systems
   • Communication plans for stakeholders
3. Test Regularly:
   • Annual full disaster recovery test minimum
   • Quarterly restoration tests for critical systems
   • Document test results and remediation actions

Evidence to Maintain

• Backup policy and schedules
• Backup monitoring logs and alerts
• Restoration test results (quarterly/annually)
• Disaster recovery plan documentation
• DR test results and post-test reviews

Finding #9: Insufficient Vulnerability Management

Regular vulnerability scanning and timely patching are essential security controls. Gaps in vulnerability management frequently appear in audit findings.

Building a Vulnerability Management Program

1. Regular Scanning:
   • Monthly vulnerability scans minimum for external systems
   • Quarterly scans for internal systems
   • Continuous scanning for critical infrastructure
   • Post-deployment scans after major changes
2. Vulnerability Assessment:
   • Review scan results within 7 days
   • Validate findings to eliminate false positives
   • Assess risk based on severity, exploitability, and exposure
   • Prioritize remediation based on risk
3. Remediation Timelines:
   • Critical vulnerabilities: 15 days or less
   • High vulnerabilities: 30 days
   • Medium vulnerabilities: 90 days
   • Low vulnerabilities: Next maintenance window or 180 days
4. Patch Management:
   • Automated patching where possible (OS, applications)
   • Testing patches in non-production before deployment
   • Emergency patching process for zero-day vulnerabilities
   • Track patch compliance and exceptions
5. Penetration Testing:
   • Annual penetration test by qualified third party
   • Testing after significant application changes
   • Document findings and remediation evidence

Vulnerability Management Tools

• Scanners: Tenable (Nessus), Qualys, Rapid7, OpenVAS
• Cloud-Native: AWS Inspector, Azure Security Center, Google Cloud Security Command Center
• Application Security: Snyk, WhiteSource, Veracode for code vulnerabilities
• Tracking: Jira, ServiceNow for remediation tracking

Finding #10: Lack of Physical and Environmental Controls

While cloud computing has reduced physical security concerns, organizations must still demonstrate appropriate physical and environmental controls for any on-premises infrastructure or offices with access to sensitive data.

Physical Security Controls

• Access Controls:
  • Badge or key card access to offices
  • Visitor logs and escort requirements
  • Surveillance cameras in critical areas
  • Access reviews for physical locations
• Environmental Controls:
  • Fire detection and suppression systems
  • Climate control for equipment rooms
  • Uninterruptible power supplies (UPS)
  • Redundant power and network connectivity
• Endpoint Security:
  • Laptop encryption (BitLocker, FileVault)
  • Screen lock after inactivity
  • Clean desk policy for sensitive information
  • Secure disposal of hardware (data wiping, physical destruction)

Cloud and Remote Work Considerations

• Cloud Data Centers:
  • Obtain SOC 2 reports from cloud providers (AWS, Azure, GCP)
  • Review physical security sections of provider reports
  • Document inherited controls in your system description
• Remote Work Security:
  • VPN requirements for accessing corporate resources
  • Endpoint detection and response (EDR) on all devices
  • Mobile device management (MDM) for BYOD
  • Remote work security policy and training

General Remediation Strategies

If you do receive audit findings, follow these steps for effective remediation:

1. Immediate Response:
   • Acknowledge the finding promptly
   • Assess actual risk and prioritize accordingly
   • Implement temporary mitigating controls if needed
2. Root Cause Analysis:
   • Understand why the control failed
   • Identify systemic issues beyond the specific finding
   • Determine if other areas are similarly affected
3. Remediation Plan:
   • Document specific actions to address the finding
   • Assign ownership and accountability
   • Set realistic timelines
   • Consider both immediate fixes and long-term improvements
4. Implementation:
   • Execute remediation activities
   • Document all actions taken
   • Collect evidence of control effectiveness
5. Testing and Validation:
   • Test that controls are operating effectively
   • Gather sufficient evidence for auditor review
   • Allow adequate time for control operation (typically 30-90 days)
6. Communication:
   • Provide management response in audit report
   • Keep auditors informed of progress
   • Update customers if findings impact them

Proactive Preparation: Avoiding Findings

The best approach is preventing findings in the first place through thorough preparation:

Pre-Audit Readiness Assessment

• Conduct internal audit or readiness assessment 2-3 months before audit
• Use SOC 2 readiness checklists or compliance automation platforms
• Identify and remediate gaps before the official audit
• Perform mock evidence collection to ensure availability

Continuous Compliance

• Treat SOC 2 as ongoing program, not annual event
• Automate evidence collection where possible
• Regular internal reviews and testing of controls
• Stay current with framework updates and industry practices

Leverage Expertise

• Work with experienced SOC 2 audit firms
• Consider compliance consultants for readiness
• Use compliance automation platforms (Vanta, Drata, Secureframe)
• Join compliance communities and learn from peers

Conclusion

SOC 2 audit findings are common, especially for first-time audits, but they're also largely preventable with proper preparation and understanding of requirements. The ten findings covered in this guide represent the most frequent issues auditors encounter, but they all share a common theme: lack of formalized processes, documentation, and evidence collection.

Success in SOC 2 compliance requires treating it as an ongoing program rather than a one-time project. Build security and compliance into your operations from the start, maintain comprehensive documentation, collect evidence continuously, and regularly test your controls. When you receive findings, view them as opportunities to strengthen your security posture rather than setbacks.

Remember that SOC 2 isn't just about passing an audit—it's about building trust with customers and demonstrating your commitment to security. Organizations that embrace this mindset and implement robust security practices will find compliance a natural outcome rather than a burden. Start addressing these common findings today, and you'll be well on your way to successful SOC 2 certification.