What are SOC 2 Penetration Testing Requirements in 2025?

Fiza Nadeem
June 13, 2025
7
min read

A SOC 2 penetration test is often strongly advised by auditors to show how well the security controls are working. This test helps verify that the measures put in place are effective in protecting systems and data during the SOC 2 audit.

SOC 2 was created by the American Institute of CPAs (AICPA) and provides a set of rules based on five main areas for data handling and trust building with customers. However, having good security policies by itself is not enough to stay compliant. It often takes testing those policies in ways similar to how hackers try to find weaknesses in security systems.

This is where SOC 2 penetration testing becomes essential. Before we discuss why a pentest is so necessary for SOC 2, let’s first understand more about the compliance requirements involved.

What is SOC 2 Penetration Testing?

SOC 2 penetration testing is a simulated cyberattack conducted to assess your systems for potential weaknesses. It helps find security gaps in your IT systems and understand how these could affect the protection of customer data.

It uses the Trust Service Criteria (TSC) to guide the testing process. This approach helps identify security weaknesses and provides clear steps to address them. As a result, it improves your overall cybersecurity and shows your dedication to data protection.

SOC 2 Itself Requires Nothing

A SOC 2 assessment does not need to include penetration testing. The primary focus of the audit is to review the controls that support the five AICPA trust services criteria.

The AICPA’s SOC 2 Trust Services Criteria includes five basic principles. These principles help organizations manage and protect data securely and ensure they follow the correct standards:

Security: Refers to the protection against unauthorized access and potential threats. Essential steps include using access controls, encryption, securing networks, managing vulnerabilities, and having plans in place to respond to incidents.

Availability: Availability ensures systems and services are always working and can be accessed when needed. To achieve this, organizations utilize backup systems and disaster recovery plans, manage capacity effectively, and ensure they meet their service level agreements (SLAs).

Processing Integrity: Processing integrity means data is handled correctly, entirely, and on schedule. Essential practices include verifying data for accuracy, handling errors properly, monitoring the system, and controlling process changes.

Confidentiality: Confidentiality safeguards sensitive information from being accessed by unauthorized people. Essential measures include data classification, encryption, strict access controls, secure storage, and proper data disposal.

Privacy: Privacy ensures that personal information is handled carefully and responsibly by applicable laws and privacy notices. It involves informing people about how their data will be used, obtaining their consent, collecting only necessary data, respecting their rights, and assessing the impact on their privacy.

When reviewing these five principles, an auditor will check that there are controls in place to meet these standards. In a SOC 2 Type II audit, the auditor will also assess the effectiveness of those controls in practice.

When Might SOC 2 Require a Penetration Test?

Some people believe that penetration testing is useful for measuring how well the Confidentiality trust service principle works. The best way to check if controls that prevent data theft and misuse are effective is to try to bypass them and see if data can be stolen.

Depending on the security framework your organization uses, a penetration test can be an effective way to demonstrate the effectiveness of your controls. Although standards like the MITRE ATT&CK framework and the CIS Top 10 do not require penetration testing, if these are the main frameworks your organization follows, it can be tough to assess how well your controls work without conducting a penetration test.

Many organizations might prefer to avoid penetration testing and instead rely on vulnerability assessments or scans. The belief is that performing regular vulnerability scans, such as every three months, can confirm that security measures are working well. These scans are often considered more affordable than conducting a full penetration test.

Read more on: Vulnerability Assessment vs Penetration Testing.

Vulnerability scanning checks that each system, such as computers, web applications, cloud resources, or other infrastructure, has the latest updates and patches. However, scanning does not provide any other details about the security level of these assets and does not show whether sensitive information is being protected.

Penetration testing is a more thorough type of risk assessment than a vulnerability scan. It tests an organization's ability to defend against cyberattacks by simulating a real attack. Besides checking for known vulnerabilities, it also evaluates internal controls and monitoring systems.

When Won’t SOC 2 Require a Penetration Test?

The advantages of penetration testing can vary depending on whether your organization is aiming for a SOC 2 Type I or Type II report. A Type II assessment focuses on checking how adequate controls are.

On the other hand, a Type I assessment checks whether the controls are in place and how management describes them. For a SOC 2 Type I report, penetration testing is less important and has a lesser impact.

To confirm that controls are in place, you can run reports from the relevant systems. While penetration testing remains useful, it tends to be more expensive and time-consuming.

What are SOC 2 Penetration Testing Requirements per Compliance in 2025?

Although SOC 2 does not specifically require penetration testing, it indirectly supports it through its Trust Service Criteria (TSC). Auditors often suggest conducting penetration tests as a helpful way to meet specific TSC controls and principles, as explained below:

Validating Security Controls (Security Principle)

CC4.1: “The organization chooses, creates, and regularly reviews its controls to ensure that all parts of the internal control system are in place and working properly.”

In simple terms, a SOC 2 penetration test goes beyond just reviewing policies and procedures. It actively tries to find and exploit weaknesses in the system. This provides a clearer picture of how effective your security controls, such as firewalls and access controls, are in real-world situations. It helps ensure that the Security principle is properly addressed.

SOC 2 Pentesting Requirements per Compliance

Identifying Unknown Weaknesses (Availability Principle)

A1.2: “The organization approves, plans, creates, or buys, puts into action, manages, and keeps an eye on measures such as environmental protections, software, data backup methods, and recovery systems to achieve its goals.”

Penetration testers employ various methods to identify and address security gaps that traditional vulnerability scans may overlook. If a real attacker exploits these weaknesses, they could cause system downtime or disrupt access to sensitive information. Fixing these issues helps improve your compliance with the Availability principle of SOC 2.

Assessing Data Breach Risk (Confidentiality Principle)

C1.1: “The organization recognizes and keeps track of sensitive information to achieve its goals related to confidentiality.”

A penetration test for SOC 2 compliance simulates how an attacker could try to access sensitive information. This helps your company and auditors assess the risk and potential consequences of a successful attack on customer data, in line with the Confidentiality principle.

Strengthen Your SOC 2 Readiness with ioSENTRIX

At ioSENTRIX, we specialize in delivering audit-aligned penetration testing services tailored to SOC 2 requirements. Our PTaaS offering includes:

  • Audit-ready deliverables with executive summaries, technical findings, and Excel-based remediation trackers.
  • Testing mapped directly to the AICPA Trust Services Criteria.
  • Real-time vulnerability tracking and support for post-audit remediation.

Schedule your SOC 2 readiness consultation today!

FAQs

Does SOC 2 require penetration testing?

SOC 2 audits do not specifically require penetration testing. However, it is strongly advised that auditors evaluate your security measures and show how well your controls work. This helps ensure you meet the Trust Service Criteria, especially for monitoring activities.

Is SOC 2 compliance mandatory?

SOC 2 compliance is not required by law. However, it is considered a top standard for security. Having it shows your customers that you are serious about protecting their data. This helps build trust and can be an important factor for businesses when choosing a dependable partner.

What is the timeline for SOC 2 penetration testing?

The timeline for SOC 2 penetration testing depends on the type of report being prepared. For SOC 2 Type 1, only one test is required, which typically takes 10 to 12 working days. For SOC 2 Type 2, several tests are needed over the reporting period, which can last from 3 to 12 months.

What is the difference between SOC 2 pentest and penetration testing?

SOC 2 penetration tests are a specific type of security test designed to verify the controls required for the SOC 2 audit. While regular penetration tests may cover many different security issues, SOC 2 pentests focus mainly on areas such as data security and access controls.

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