Author: Marçal Santos, vCISO | +20 Years Cybersecurity Experience
Let's be honest, over the last 20 years of running go-to-market strategies and protecting brand reputation in the B2B world, trust really is the biggest driver of speed. Every sales team knows that if you can't get past procurement because of compliance issues, it's a huge roadblock in the sales process.
Let's get straight to the point here:
Do penetration tests really have to be a part of SOC 2?
No, they're not explicitly required by the AICPA's Trust Services Criteria, which is the foundation of SOC 2 compliance. However, while not a formal requirement, penetration testing is a crucial part of demonstrating how effective your organisation's security controls are and how tough your overall security posture is.
Are they a must-have for a smooth audit?
Absolutely. Penetration testing is the really important bit that shows auditors you've taken proactive steps to stop cyber threats. It does this by simulating real-world attacks using the same tools and techniques as real hackers. This approach helps find vulnerabilities before the bad guys do, and that lets your team fix any problems they find before the auditors do.
A lot of people view SOC 2 as a straightforward "tick-the-box" exercise - just a formality so the sales team can get on with it. But when you look at the real world, it's clear there's a big gap between what the SOC 2 standard actually requires and what your top clients really demand.
he grey area in all this is Penetration Testing.
If you ask someone who's really into the rules, they'll say a pentest isn't necessary for SOC 2. But if you ask someone who knows how the real world works (like me, or your VP of Sales), they'll say it's absolutely vital. Here's why ignoring the pentest is a strategic mistake, even if the rulebook says you can.
"A SOC 2 report without a pentest is like a Ferrari without an engine - it looks amazing in the garage but it's never going to win any races."
Busting the "Technically Not Mandatory" Myth: Pentest SOC2
Let's get real here. If you delve into the AICPA's Trust Services Criteria, you won't find any line that explicitly says: "You must perform a penetration test". The Trust Services Criteria are a set of standards for data security, availability, integrity, confidentiality and privacy. SOC 2 does not explicitly require penetration testing, but doing SOC 2 penetration testing is what most people expect.
The framework is intentionally flexible. It asks you to show you're keeping an eye on your controls and assessing risk. Here's how penetration testing and vulnerability scanning fit into that:
- Vulnerability scanning:
- Not required for SOC 2, but doing so is a best practice.
- Automated scanners keep your security posture in top shape by giving you a constant check on things.
- Helps identify known and new vulnerabilities, assess the effectiveness of your existing security controls, and check on your monitoring systems and how systems operate.
- Supports the detection of external threats and helps protect systems and company assets.
- Penetration testing:
- You really need to do it manually to find out about and exploit weaknesses in web applications, APIs and network infrastructure.
- Validates and improves your security controls and overall security posture.
- Shows how well you can defend against cyberattacks and real world attacks, using the same tools as malicious attackers to simulate the threats that will actually happen and test your defenses.
While vulnerability scanning can help, auditors know that a high-quality penetration test is what really stands out. Without one, auditors are going to dig deeper, ask more challenging questions, and potentially flag your report.
Penetration testing is a simulated cyber-attack designed to find out where the vulnerabilities are in your IT systems and assess the potential damage they might cause. It involves:
- Reconnaissance
- Scanning
- Manually exploiting vulnerabilities in applications, APIs and cloud infrastructure using the same tools as real attackers to find weaknesses and test your defenses right across the organisation and company.
There are different types of penetration testing - for example:
- Black Box: Simulates an external attacker with no prior knowledge of the system to find vulnerabilities and assess security controls. This approach provides an outside-in view and is useful for evaluating your defenses against external threats.
- White Box: Gives the testers full knowledge of system architecture and configuration for a targeted evaluation. This allows for a comprehensive assessment of the company's security posture and internal controls.
- Grey Box: Offers a balance of external and internal views for effective evaluation, providing testers with some knowledge about the system to simulate insider threats and test both internal and external controls.
The scope of a SOC 2 penetration test should be tailored to your assets and systems, such as web applications, but it should also consider the whole organisation, including the company's environment, systems and assets. What data you have that is sensitive needs to be classified properly and ensuring that the right areas are being tested.Regular penetration testing is a yearly must-have, at least, if not more frequently - especially when it comes to critical systems. Not only is this the right thing to do as a best practice, but its also in line with the established rules and what auditors are expecting to see. And, let's face it, it's what many service organizations require to show off their long term commitment to having their security and compliance ducks in a row.
Types of Penetration Tests
When it comes to SOC 2 compliance, not all penetration tests are created equal. There are different kinds of penetration testing that will help you check your security controls from every angle, so you don't leave yourself wide open to potential hackers. Each type will have its own separate evaluation, and they all matter for having a solid security posture for your company. Here’s what you need to know about each type and why they matter:
- External Penetration Testing: This is your first line of defense. External penetration testing looks at your publicly-facing assets - think websites, APIs, and IP addresses. The goal here is to identify any vulnerabilities that could let cyber threats slide right in and get to your internal systems. It’s a critical thing to do to see what it looks like to a potential hacker and to make sure your security controls are actually stopping them.
- Internal Penetration Testing: So, what can a hacker do if they’ve managed to get inside your network? Internal penetration testing simulates this, probing your internal systems and access controls to see if there are any vulnerabilities that could be exploited from within. This helps you spot weaknesses that could lead to data breaches or unauthorized access to sensitive data.
Doing regular penetration testing across these different types isn’t just something you do to check a box for SOC 2 compliance. It’s a best practice that helps you identify and fix any potential vulnerabilities before they can be exploited. And, by doing ongoing and separate evaluations, you can show auditors that your security controls are effective, your risk assessment is solid, and you’re serious about keeping customer data safe.
While SOC 2 doesn’t technically require penetration testing, it’s clear that doing regular, well-scoped pen testing is the gold standard for meeting the Trust Services Criteria, especially the security principle. It helps you stay on top of new vulnerabilities, reduce the risk of data breaches, and keep a strong overall security posture - all of which gives your customers and auditors confidence that you’re committed to data security and continuous improvement.
2. The Auditor's Perspective: Making It Easy for Them to Say "Yes"
Auditors need evidence to back up their claims. While the SOC 2 standard is open to interpretation, auditors are getting stricter about requiring external penetration testing. Understanding what auditors are looking for during penetration testing is crucial - you want to make sure your systems are secure, available, and fully in line with audit requirements.
There are a few things auditors care about:
- Monitoring and detection: Being able to spot configuration changes and new vulnerabilities is a big deal (including detection and monitoring procedures).
- Third-party validation: Getting outside help for penetration tests ensures objectivity and credibility.
- Continuous monitoring: Penetration testing is a strong form of continuous monitoring, as it shows you’re not just talking about your risk assessment in theory (but actually making sure your security controls are working).
Having a clean penetration test report from a reputable company:
- Shows you have an active and effective vulnerability management program in place.
- Helps you identify security risks that just scanning for vulnerabilities might miss.
- Makes the audit process way smoother and less time-consuming.
The final penetration test report should have:
- A concise executive summary
- Risk ratings
- Evidence of any exploitation that happened
You should also make sure to remediate any vulnerabilities found in accordance with your organization's vulnerability management policy.
For SOC 2 Type II audits, the reporting period is usually 6-12 months. And, it’s best to get those penetration tests wrapped up 2-3 months before an audit period ends to give you time to make any necessary changes and retest.
3. The Commercial Reality: Penetration Testing as a Sales Game Changer
From a marketing standpoint, getting a SOC 2 report is just the first step - it gets you in the door but it rarely seals the deal.
Enterprise buyers and the folks in Vendor Risk Management aren't just looking at a piece of paper that says you're following the right procedures:
- A SOC 2 report will simply confirm that you’re following the rules.
- A penetration test will give a much clearer picture of your actual security posture - which is what matters most.
Security is all about continuous assurance these days. When procurement looks over your SOC 2 Type II report, they’ll probably want to know about your latest penetration test results right away.
And if you tell 'em "We didn't do a penetration test because the SOC 2 standards don’t technically require it," you’ve got a problem on your hands:
- You’re slowing down the sales process.
- You’re making it easy for those security engineers to pick you apart.
- You’re giving your competitors an edge if they’ve actually gone the extra mile and done their penetration testing.
Showing you’re serious about security by doing penetration testing along with getting your SOC 2 report sends a much stronger message to customers about how serious you are about keeping their data safe.
4. Brand Image: "Check-the-Box" vs. "Security is Our Thing" Security Controls
Penetration testing is a yearly must-have, at least, if not more frequently - especially when it comes to critical systems. Not only is this the right thing to do as a best practice, but it’s also in line with the established rules and what auditors are expecting to see. And lets face it, it’s what many service organizations require to show off their long term commitment to having their security and compliance ducks in a rowDoing the bare minimum just to scrape by makes it pretty plain that security is something you're trying to keep as cheap as possible.
But investing in penetration testing sends a totally different message:
- 'We're not just going through the motions, we're actually testing our security to make sure it's rock solid'
At a time when supply chain attacks are all over the news, showing a penetration test report to your customers makes a pretty loud statement about how seriously you're taking keeping their data safe:
- 'We really do care about our customers' data, and we're not afraid to prove it to you'
Penetration testing is a crucial part of protecting customer data and making sure you're ready to deal with real-life cyber threats - which is a no-brainer when it comes to getting SOC 2 compliance right
FAQ
Is penetration testing explicitly required for SOC 2 compliance?
No, the AICPA Trust Services Criteria do not explicitly mandate it, but it is practically essential. Most auditors and clients expect it to demonstrate effective security controls.
How frequently should I perform penetration testing for SOC 2?
You should conduct penetration testing at least annually to meet best practices and auditor expectations. Critical systems may require more frequent testing to maintain a strong security posture.
What is the difference between vulnerability scanning and pentesting?
Vulnerability scanning relies on automated tools to check for known issues, while penetration testing involves manual exploitation to simulate real attacks. This manual approach validates your security controls more effectively than automated scanning alone.
What specific types of penetration tests does SOC 2 involve?
A comprehensive approach includes both External Penetration Testing for public assets and Internal Penetration Testing for network systems. This ensures you cover vulnerabilities from both outside and inside your organization.
Why do auditors prefer penetration testing over just scanning?
Auditors value third-party validation that simulates real-world attacks to prove your controls actually work. A clean report from a reputable tester makes the audit process smoother and faster.
How SecureLeap Can Help You Navigating Your SOC 2 Penetration Testing
At SecureLeap, we know that figuring out SOC 2 compliance and what penetration testing needs to cover can be a real pain - and for high-growth startups and small businesses in particular, it can be a huge time-suck. Our cybersecurity compliance and risk services are tailored to make the whole process as painless as possible for you.
Our team of experts offer a full-service penetration testing service that helps you identify vulnerabilities, validate your security controls and give you clear guidance on what to do to fix any problems. Whether its an internal test, an external one or some focused on your apps, we make sure that your assessments line up with the SOC 2 Trust Services Criteria and what your auditors are looking for.
