SOC 2 compliance & audit readiness — the standard enterprise SaaS customers require.
SOC 2 is the de facto security certification for SaaS and cloud service providers, demonstrating to enterprise customers that your controls safeguard the security, availability, and confidentiality of their data. SIRI Law LLP builds your SOC 2 control framework, evidence programme, and audit readiness from scratch, or optimises and accelerates an existing programme.
Getting "what changed for 2026" right
SOC 2 itself hasn't changed. What auditors expect as evidence has — substantially.
A lot of compliance marketing content claims "SOC 2 changed for 2026." That's imprecise in a way that actually matters for planning your engagement. The AICPA's Trust Services Criteria remain the 2017 version, with the 2022 revised Points of Focus — no new framework version has been issued, and the five categories (Security, Availability, Confidentiality, Processing Integrity, Privacy) are unchanged. If a vendor tells you SOC 2 changed, what they almost always mean is that auditor interpretation has shifted, not that the underlying standard was rewritten.
That interpretation shift is real and worth planning for specifically. AI-fluent auditors in 2026 are asking for evidence that traditional SaaS SOC 2 engagements never produced: model lineage documentation (which dataset, code, and approval sits behind a deployed model), prompt and inference logs with PII redaction applied before logging, drift-monitoring output, and vendor risk assessments for every third-party LLM your product calls. Shadow AI — engineers piping company data into unapproved AI tools — is now something auditors actively probe for, and "agent accountability" has become a genuine finding category: when an autonomous agent takes a privileged action attributable to no specific human request, SOC 2's expectation that privileged actions trace to an accountable person is treated as unmet.
For any organisation building or renewing product with AI features, this means the readiness assessment now needs to explicitly scope AI-specific evidence alongside the traditional Security TSC controls — not as an afterthought bolted on before the audit, but as part of the control framework design from the outset.
What it is and why it matters
The five Trust Services Categories
SOC 2 is an attestation framework developed by the AICPA, assessed by independent CPA firms against the Trust Services Criteria. Security is required; the rest are selected based on your business model.
Security
The Common Criteria — logical access, change management, monitoring, incident response, vendor management. Every SOC 2 report includes this.
Availability
Typically added by SaaS companies where uptime SLAs are customer commitments.
Confidentiality
Relevant when you process business-confidential information beyond personal data.
Processing Integrity
Relevant for transaction processing or financial services platforms.
Privacy
Relevant when you process personal data — integrated with DPDPA and GDPR compliance in our engagements.
Source: AICPA TSP Section 100, 2017 Trust Services Criteria with 2022 Revised Points of Focus — the current standard as of publication. SOC 2 Type I reports on control design at a point in time; Type II reports on operating effectiveness over a 6–12 month observation period. Enterprise customers almost universally require Type II.
Scope of services
What our engagement covers
The full engagement lifecycle — readiness assessment, control framework design, evidence collection automation, vendor management, penetration testing, and auditor liaison.
Readiness Assessment
Gap assessment against applicable TSC categories, Trust Services Category selection advisory, and a realistic timeline to Type I and Type II readiness.
Control Framework Design
Policy, procedure, and control mapping — access management, change management and SDLC controls, encryption and data handling, audit log management.
Evidence Programme
What to collect, how to automate it, and how to organise it for the audit — including 2026-relevant AI evidence where applicable.
Vulnerability & Penetration Testing
TSC-required annual penetration testing programme, conducted by our security team and reported in a format that satisfies SOC 2 auditors.
Incident Response & Vendor Management
Incident response policy and procedures, business continuity and availability controls, and a vendor/sub-processor management programme.
Privacy TSC — DPDPA/GDPR Integration
Our legal team integrates DPDPA and GDPR obligations directly into the Privacy TSC, avoiding duplicate compliance work across frameworks.
Evidence, not guesswork
SOC 2 vs. ISO 27001 — which one, or both
The two most commonly conflated certifications. Here's the practical difference.
| Dimension | SOC 2 Type II | ISO 27001 |
|---|---|---|
| Governing body | AICPA, assessed by independent CPA firms | ISO/IEC, assessed by accredited certification bodies |
| Primary market recognition | US enterprise buyers — typically more recognised | European, Indian, and global buyers — more universally understood |
| Output | An attestation report describing controls and testing results | A certification against a management system standard |
| Renewal cycle | Type II report covers a 6–12 month period, renewed annually | 3-year certification cycle with annual surveillance audits |
| Overlap | Substantial control overlap — many SaaS companies pursue both, sharing evidence and documentation across engagements | |
Both frameworks address overlapping but not identical requirements. Confirm which combination fits your specific buyer base and market before committing to a dual-certification programme.
What the numbers actually mean
Four figures that frame SOC 2 planning today
From readiness programme start to a complete Type II report — compressible with mature existing controls.
The period over which controls must demonstrably operate, not just exist on paper.
Average audit fee rise reported by mid-tier and Big Four firms as AI evidence scope expands engagements.
Security required; Availability, Confidentiality, Processing Integrity, and Privacy selected based on your business model.
Our engagement process
How we work, step by step
Scoping & Assessment
Gap assessment against the applicable framework, engagement scope definition, and a prioritised remediation roadmap with timeline and effort estimates.
Programme Design
Control framework, documentation structure, evidence requirements, and governance processes — tailored to your organisation, including AI-specific evidence where relevant.
Implementation Advisory
Working alongside your technical and operational teams to build controls that are practical and auditable, not just theoretically compliant.
Internal Audit & Validation
An internal audit or readiness assessment identifying any remaining gaps before the formal certification or attestation process begins.
Certification / Attestation Support
Managing auditor queries, providing evidence, and resolving findings on the day of the formal audit or assessment.
Post-Certification Advisory
Surveillance audit preparation, change management, and regulatory update advisory once you're certified, including evolving 2026 AI evidence expectations.
Benefits & deliverables
What you get from this engagement
SOC 2 Readiness Report
Detailed gap assessment with control-by-control status, remediation roadmap, and timeline to Type I and Type II.
Control Framework Documentation
Complete documentation library — policies, procedures, control descriptions, and evidence collection guide.
Penetration Test Report
TSC-compliant penetration test report suitable for inclusion in your SOC 2 evidence package.
Type I Readiness Confirmation
Internal pre-audit confirmation that control design satisfies applicable TSC before the CPA firm's assessment.
Type II Observation Support
Advisory throughout the 6–12 month observation period, ensuring controls operate consistently and evidence is collected continuously.
Auditor Liaison
Management of the CPA auditor relationship during fieldwork — responding to queries, providing evidence, and resolving exceptions efficiently.
Integration advantage
Compliance engagements backed by qualified legal counsel
Our compliance engagements ensure your programme satisfies both technical certification requirements and legal obligations under DPDPA, IT Act, and sector-specific regulation.
We tell you what actually changed
Rather than the flat "SOC 2 changed for 2026" claim, we explain what's genuinely different — auditor interpretation, not the TSC itself — and scope your evidence programme to what auditors are actually testing for now.
Privacy TSC + DPDPA/GDPR in one workstream
Our legal team integrates DPDPA and GDPR obligations directly into your Privacy TSC scope, avoiding the duplicate compliance work most standalone consultants create.
In-house penetration testing
The TSC-required annual penetration test is conducted by our own security team and reported in a format SOC 2 auditors accept directly, not outsourced to a disconnected vendor.
Certified engineers
Our team holds CCSP, CISM, CIPP/E, CEH, OSCP, CISSP, CPENT, and ISO 27001 Lead Auditor credentials — the mix auditors and boards expect from a serious compliance programme.
Frequently asked
SOC 2, answered directly
How long does SOC 2 Type II take?
Achieving SOC 2 Type II typically takes 12 to 18 months from starting the readiness programme — 3 to 6 months to build controls and achieve Type I readiness, then a 6 to 12 month observation period for Type II. Organisations with mature existing controls can compress this timeline significantly. We provide a realistic estimate after the readiness assessment.
Did SOC 2 actually change for 2026, or is that marketing?
The Trust Services Criteria themselves have not changed — they remain the AICPA's 2017 TSC with the 2022 revised Points of Focus, and no new version has been issued. What has genuinely shifted is auditor interpretation: firms are asking harder, more specific questions about AI governance, model lineage, shadow AI usage, and agent accountability than they were even a year ago, and organisations whose last report predates this shift often find their 2024 or 2025 SOC 2 no longer fully satisfies a 2026 enterprise security review. If a vendor tells you "SOC 2 changed," what they usually mean is that what auditors expect as evidence has tightened, not that the underlying framework was rewritten.
Which Trust Services Categories should we include?
Security is mandatory. Availability is typically added by SaaS companies where uptime SLAs are customer commitments. Confidentiality is relevant when you process business-confidential information. Privacy is relevant when you process personal data, and we integrate this with DPDPA and GDPR compliance. Processing Integrity is relevant for transaction processing or financial services platforms. We advise on the right set for your business model.
Can SOC 2 replace our ISO 27001 certification?
For US enterprise customers, SOC 2 Type II is typically more recognised. For European, Indian, and global customers, ISO 27001 is more universally understood. They address overlapping but not identical requirements. Many SaaS companies pursue both. We advise on whether pursuing both is appropriate for your market and on efficient combined implementation.
Do we need to share our SOC 2 report with every customer?
SOC 2 reports are confidential — they are shared under NDA with customers and prospects who require them as part of security review. You control who sees the report. Many companies reference their SOC 2 status publicly, on a trust page or website, while sharing the full report only under NDA.
What AI-specific evidence should we prepare if our product includes AI features?
Model lineage documentation for deployed models, prompt and inference logs with PII redaction applied before logging, drift-monitoring output, and vendor risk assessments for any third-party LLMs your product calls. Auditors also test for shadow AI usage and whether privileged actions taken by autonomous agents can be traced to an accountable person — both increasingly standard findings categories in 2026 audits.
Ready to start your SOC journey?
All engagements begin with a complimentary scoping call.
Let us understand your environment and propose the right approach to SOC 2 Type I, Type II, or a combined ISO 27001 programme.
Related services
Other ways SIRI Law LLP supports your compliance posture
Visit or contact us
SIRI Law LLP — Hyderabad, India
| Registered office | HITEC City, Madhapur, Hyderabad, Telangana 500081, India |
| Telephone | +91 79819 12046 |
| info@sirilawllp.com | |
| Other offices | New Delhi, India · Austin, Texas, USA · Online worldwide |
| Hours | Mon–Sat, 9:30 AM – 7:00 PM IST · Emergency line 24/7 |