Is a Penetration Test Required for SOC 2?

Is penetration testing required for SOC 2 compliance? What are SOC 2 pen test requirements? Find out SOC 2 report requirements in this article.

Compliance plays a pivotal role in cybersecurity, serving as a framework for organizations to build robust security measures. It helps in safeguarding sensitive data and maintaining customer trust, which is crucial in today's interconnected world. One such compliance standard that often comes up is SOC 2 (Service Organization Control 2), designed by the American Institute of Certified Public Accountants (AICPA). 

A common question many businesses grapple with is whether SOC 2 explicitly demands penetration testing. This article aims to provide clarity on this subject and delve into what SOC 2 actually requires, the role of pen testing within this compliance framework, and offer insights on implementing it effectively.

What Is SOC 2 Compliance? 

SOC 2 is a framework for managing data security in cloud-based systems. It sets guidelines for protecting customer data and focuses on the five Trust Services Criteria (TSC).

What SOC 2 Actually Requires 

As also highlighted above, SOC 2 demands strict adherence to its TSC for data security and management. Understanding the actual requirements is crucial for achieving compliance, so let's take a closer look at the five key principles:

  • Security: This is the foundational principle that focuses on safeguarding information and systems from unauthorized access. It encompasses a range of safety measures, including firewalls, access controls, and encryption, aimed at protecting data against both internal and external threats.
  • Availability: This criterion is concerned with the accessibility of systems, products, or information as promised or committed. It involves measures like network performance monitoring, disaster recovery, and incident handling to ensure that services are available when needed.
  • Processing Integrity: It emphasizes the accuracy and reliability of system processing and ensures that information processing occurs in a manner that is approved, complete, accurate, and timely. Controls may include data validation checks and quality assurance processes.
  • Confidentiality: It involves limiting information access and disclosure to a set of specified parties or functions and includes the use of encryption, access controls, and network segmentation to protect sensitive information like customer data or intellectual property.
  • Privacy: This criteria deals with the collection, use, retention, and disposal of personal information in compliance with an organization's privacy notice and applicable laws and uses controls like consent mechanisms, data masking, and privacy impact assessments.

Types of SOC 2 Assessments

This framework comes in two primary forms: Type I and Type II. Both are developed to assess an organization's information systems, but they differ in scope, timing, and depth of evaluation. Understanding these differences is crucial for businesses aiming for SOC 2 compliance, especially when considering the role of penetration testing.


SOC 2 Type I

SOC 2 Type II


Assesses control design at a specific moment.

Evaluates control design and their operational efficacy over an extended duration.


Restricted to the examination date.

Encompasses a broader timeframe, offering a more complete view.


Single snapshot

Continuous, typically spanning at least 6 months.

Depth of Evaluation

Examines the adequacy of control design.

Scrutinizes both the adequacy and effectiveness of controls.

Assurance Level

Affirms the suitability of safety measures.

Provides a more comprehensive level of assurance by examining ongoing effectiveness.


Requires proof of control architecture.

Necessitates comprehensive evidence of both control architecture and sustained effectiveness.

Penetration Testing

May incorporate penetration tests to assess design suitability.

It may include penetration testing as it can assess sustained control effectiveness.

Report Complexity

Generally less intricate and quicker to secure.

More detailed due to ongoing monitoring and evidence collection.

Stakeholder Confidence

Offers limited assurance focused on design and intent.

Elevates stakeholder trust by demonstrating operational effectiveness.

The dissimilarities between them are clear. While Type I is often a starting point, SOC 2 Type II assessment is generally considered the gold standard, offering a more comprehensive and credible evaluation of an organization's compliance with the TSC.

Do SOC 2 Really Require Penetration Testing? 

Although penetration testing is mentioned in the TSC as one of many "different types of ongoing and special evaluations" that organizations might consider, it is not listed as a mandatory control. The framework is designed to be adaptable, allowing companies to choose the most appropriate safety measures for their specific needs. 

This flexibility is both an advantage and a challenge. On one hand, it allows firms to tailor their security measures to their unique requirements. On the other hand, it leaves room for interpretation, leading to questions like whether a pen test is essential for certification. The point is that while a penetration test can be a valuable tool for identifying vulnerabilities and enhancing security, it's not a one-size-fits-all requirement under SOC 2. So while it's technically not required we at Eden Data highly recommend it.

Can Penetration Testing Be Incorporated Into SOC 2?

Before answering the question, let us know more about this cybersecurity practice. Penetration testing is a foresighted approach to identifying susceptibilities in an organization's security infrastructure. It involves simulating cyberattacks to evaluate the effectiveness of security controls. 

This technique is categorized into three main types: internal, external, and hybrid. Each offers distinct advantages and focuses on different aspects of a business's security posture.

  • Internal Penetration Testing: This type of testing is crucial for assessing the robustness of internal controls and policies. In this approach, the tester has some level of privileged access to the firm's internal network. The objective is to emulate what an insider, such as an employee or third-party vendor, could potentially exploit. This is particularly useful for identifying vulnerabilities that may be manipulated after an initial breach has occurred, such as privilege escalation or data exfiltration. 
  • External Penetration Testing: It is conducted from outside the organization's network, with the examiner having no prior knowledge or access to internal systems. The goal is to understand how well an organization can defend against external threats and to validate the effectiveness of perimeter security controls. Measures include testing perimeter defenses like firewalls, as well as publicly accessible applications and services. 
  • Hybrid Penetration Testing: It combines elements of both internal and external penetration tests. This comprehensive approach aims to provide a complete picture of an organization's security landscape. By simulating both insider and outsider attacks, hybrid tests can offer insights into how different layers of security controls work together and where potential weaknesses may lie. 

As mentioned above, while not explicitly required by SOC 2, penetration testing can be utilized as a practical tool for validating the robustness of a firm's safety measures, particularly in relation to confidentiality in the TSC. Confidentiality in SOC 2 mandates that access to sensitive data is limited to authorized individuals, utilizing tools like encryption and access controls, which are rigorously assessed for effectiveness through penetration testing.

For example, it might try to decipher encrypted data, gain access to restricted areas of the network, or extract sensitive information. Successfully repelling these attacks would go a long way to validating the effectiveness of an organization's confidentiality controls. Aside from that, penetration testing can reveal how different measures interact with each other, providing a more holistic view of security. For example, if an attacker is unable to decrypt data but can circumvent access controls, the data still remains vulnerable. 

Another advantage is that pen testing can be tailored to mimic threats that are most relevant to a firm's specific operational context. This is particularly useful for industries that are targeted for their valuable confidential information, such as finance or healthcare. By simulating realistic attack scenarios, companies can better understand their risk profile and make more educated decisions when seeking SOC 2 compliance.

Who Can Perform Penetration Testing for SOC 2?

When it comes to SOC 2 compliance, not just any penetration tester will suffice. The individual or team conducting the test must have specific credentials to ensure that the assessment is both accurate and compliant with the requirements. 

Here are five key qualifications needed:

1. Certified Ethical Hacker (CEH) or Equivalent Certification

A CEH or equivalent certification is often considered a baseline qualification. This credential ensures that the tester has undergone rigorous training in ethical hacking techniques and is well-versed in the latest cybersecurity threats and countermeasures. Also, it provides a level of assurance that the examiner has the foundational skills necessary to conduct a thorough and ethical check.

2. Experience With Regulatory Compliance

The tester should have experience with regulatory frameworks in addition to technical expertise. Understanding the nuances of SOC 2, including its TSC, is crucial for aligning the checks with compliance objectives. This ensures that the test not only identifies vulnerabilities but also assesses the effectiveness of controls in a manner relevant to the requirements.

3. Industry-Specific Knowledge

Different industries have unique security requirements and risk profiles. An examiner with experience in your industry can provide more targeted and relevant testing. For example, healthcare organizations must comply with additional regulations like HIPAA, while financial institutions may have specific data protection requirements. An assessor with industry-specific knowledge can tailor the test to these unique needs, making the results more actionable.

4. Strong Communication Skills

Penetration testing is not just about identifying vulnerabilities; it's also about effectively communicating these findings to stakeholders. The expert should be capable of producing detailed reports that not only list susceptibilities but also provide context and recommendations for remediation. Strong communication skills are essential for translating findings into actionable insights that both technical and non-technical stakeholders can understand.

5. Proven Track Record

Finally, look for an examiner with a proven track record of successful penetration tests, particularly in the context of SOC 2 or similar compliance frameworks. Previous achievements are frequently a reliable measure of the assessor's capability to perform a comprehensive and efficient evaluation. Client testimonials, case studies, or references can provide valuable insights into the tester's credibility and expertise.

Implementing Penetration Testing

Implementing penetration testing involves a series of well-planned steps to ensure that it aligns with the TSC and provides actionable insights. Here's a step-by-step guide:

  • Define Objectives: Clearly outline what you aim to achieve with the test. This could range from validating the effectiveness of specific controls to assessing the overall security posture. Make sure the objectives align with SOC 2 TSC requirements relevant to your organization.
  • Scope Identification: Determine the extent of the test, including which systems, networks, and applications will be assessed. The scope should be comprehensive enough to provide meaningful results but focused enough to align with your objectives.
  • Select a Qualified Tester: Choose a penetration tester or testing firm that meets the qualifications discussed earlier, such as CEH certification and experience with SOC 2 and your specific industry.
  • Pre-Test Planning: Collaborate with the selected examiner to plan the test in detail. This includes deciding on the types of attacks to simulate, the methods to use, and the timeline for the test.
  • Conduct the Test: Execute the test according to the pre-defined plan. Ensure that all activities are logged and documented for later analysis and for providing evidence of compliance.
  • Analyze Results: Once the examination is complete, analyze the findings to identify vulnerabilities and assess the effectiveness of your controls. Also, prioritize issues based on their potential impact and relevance to SOC 2 compliance.
  • Remediation: Develop a remediation plan to address the identified susceptibilities. This should include timelines for implementation and re-testing to ascertain the effectiveness of the corrective actions.
  • Documentation: Compile a detailed report that includes the test methodology, findings, and remediation steps. This documentation is crucial for compliance and may be requested during an audit.
  • Review and Update: After remediation and re-testing, review the entire process to identify any areas for improvement and update your penetration testing and SOC 2 compliance strategies accordingly.

Automated vs. Manual Pen Tests

The decision between automated and manual tests is a crucial one, each offering distinct advantages and limitations that can significantly impact the quality of your SOC 2 assessment. 

Automated Tests

These scans are conducted using software tools that scan for known vulnerabilities and can cover a broad range of potential security issues in a short time. They are excellent for identifying common weaknesses like outdated software, missing patches, or configuration errors. However, automated tests are limited to known vulnerabilities and may not be able to identify complex security issues that require a deeper understanding of the system's logic and functionality.

Manual Tests

They are carried out by human testers who simulate real-world attack scenarios. These experts can think creatively and adapt their strategies, allowing them to identify complex vulnerabilities that automated tools might miss. Manual tests are particularly useful for assessing the effectiveness of security controls, as they can be tailored to align with the TSC. However, they are generally more time-consuming and costly.

Balanced Approach

For a comprehensive assessment, a balanced technique that combines both automated and manual tests is often recommended. Automated tests can quickly identify and eliminate easy-to-spot weaknesses, allowing manual checkers to focus their efforts on more complex and potentially critical gaps. This hybrid approach ensures a thorough evaluation, aligning closely with SOC 2's rigorous standards and providing a more complete view of a business's security posture.

Alternatives to Penetration Testing

While penetration testing is a valuable tool for assessing an organization's security posture, it's not the only option available. One notable alternative is vulnerability scanning, which also aims to identify security weaknesses but operates differently.

Here's a table comparing and contrasting vulnerability scans and penetration testing:


Vulnerability Scanning

Penetration Testing


To identify known vulnerabilities in systems and applications.

To simulate cyberattacks to evaluate the effectiveness of security controls.


Broad, covering a large number of systems quickly.

More focused, often targeting specific systems or applications based on the test objectives.


Highly automated, using software tools.

It can be automated or manual, often a combination of both for a thorough assessment.

Expertise Required

A lower level of expertise is needed, often run by internal staff.

Requires a higher level of expertise, often outsourced to specialized firms.

Relevance to SOC 2

It is useful for ongoing monitoring and aligns with the Security and Availability principles.

More comprehensive, it can validate the effectiveness of controls across multiple TSCs.

While vulnerability scanning is a quicker alternative that identifies known weaknesses without exploiting them, penetration testing provides a deeper, more comprehensive analysis of an organization's security posture. Choosing between the two – or using them in conjunction – depends on your specific security needs, compliance requirements, and resource availability. 

Read more about the differences between penetration testing and vulnerability scanning.

Become SOC 2 Compliant With Eden Data 

Embarking on the path to SOC 2 compliance can be a complicated endeavor, especially when it comes to understanding the role of penetration testing in the process. That's where Eden Data comes in. We specialize in helping startups and next-gen organizations navigate the intricate requirements of cybersecurity compliance frameworks, build trust with stakeholders, and avoid penalties.

Why Choose Eden Data?

  • Expert Guidance: Our team of experts, including Big 4 professionals and former military specialists, will guide you through the nuances of what assessors look for in SOC 2 compliance. We'll help you understand how to validate the effectiveness of your security controls, aligning them with the TSC for a smooth audit experience.
  • Strategic Roadmap: We don't just identify where you are in your compliance journey; we help you plan where you're going. Our personalized action plans will outline the steps needed, including the role of penetration testing in validating your security measures.
  • Cost-Effective Solutions: Compliance doesn't have to break the bank. Our advanced, budget-friendly solutions streamline the process, reducing both time and financial resources spent on managing security and compliance. We'll help you focus on what matters most: safeguarding your data and building customer trust.
  • No Onboarding Fees: We believe that good relationships start with trust, not financial barriers. That's why we've eliminated onboarding fees, allowing you to commence your journey without any initial financial burden.
  • 100% Satisfaction Guarantee: We're so confident in our ability to guide you through the SOC 2 penetration testing process that we offer a 100% satisfaction guarantee. Our commitment is to exceed your expectations in every aspect, from initial consultation to successful audit completion.

So, are you ready to level up your security game? Let our experts assess your SOC 2 readiness.


Although penetration testing isn't mandatory for SOC 2 compliance, Eden Data's strong opinion is that it is very beneficial for validating security measures and enhancing data protection. It aligns with TSC principles and can create a more robust cybersecurity strategy for your company and thus, highly recommended. Plus, organizations often leverage experts like Eden Data for smooth integration of penetration testing into their SOC 2 compliance process.

Our team is ready to answer any and all questions you may have.