Many organizations begin the SOC 2 journey focused on the report itself, when the greater challenge is establishing the operational maturity required to support it. A successful SOC 2 examination is the product of strong governance, clearly defined accountability, and controls that operate consistently over time. Before engaging an auditor, companies should understand whether their current environment is truly prepared for examination. This playbook outlines a practical approach to assessing SOC 2 readiness, identifying control gaps, and prioritizing improvements that strengthen both compliance outcomes and customer trust.

The purpose of this playbook is to help IT and compliance leaders understand where their organization stands on the path to SOC 2 readiness, identify risks and control gaps, and establish a clear roadmap for achieving and sustaining audit readiness.

Confirming the Critical Service Offering(s)

The assessment process should begin with clearly defining the service offerings that are in scope for the eventual SOC 2 Report. Management should identify the specific products or services that are delivered to customers, for which effective processes and controls should be in-place. As part of this assessment, management should also confirm the underlying technologies and third-party dependencies which support the critical service(s). Clearly articulating the in-scope service offering(s) sets the necessary boundaries for the assessment and informs control scoping decisions. This step is critical, as it helps ensure that the resulting SOC 2 Report aligns with customer expectations and accurately reflects how the organization operates in practice.

Identifying the ‘In-Scope’ Trust Services Criteria

Once the critical service offering(s) have been defined, management should determine which AICPA Trust Services Criteria (TSC) are relevant and should be included in the SOC 2 Report. Based on framework established by the AICPA, the TSC of Security is required to be assessed as part of all SOC 2 examinations. Management should also consider whether criteria beyond Security (i.e. Availability, Confidentiality, Processing Integrity, or Privacy) are relevant for the assessment based on the nature of the services provided. The identification of the in-scope TSC helps ensure that the assessment is appropriately scoped, avoids unnecessary complexity, and results in a SOC 2 Report that is both meaningful to stakeholders and achievable from a control perspective.

Building the Control Framework

Management should then develop a control framework that translates SOC 2 reporting requirements into clear and actionable controls tailored to the organization’s environment. Many organizations leverage the COSO 2013 Internal Control – Integrated Framework when developing an effective control environment. The framework focuses on five key focus areas – Control Environment / Governance, Risk Assessment, Control Activities, Information and Communication, and Monitoring Activities. Using the COSO 2013 framework can help organizations create a balanced control structure between entity-level and process-level controls. It also clearly defines control ownership and reinforces the importance of consistent execution and oversight. Once established, this framework provides the foundation for sustainable SOC 2 compliance by promoting consistent control execution, enabling efficient testing, and supporting the timely remediation of identified gaps.

Designing or Identifying Key Controls

Once the control framework is established, management should identify the controls needed that address each applicable Trust Services Criterion. The controls should be designed to directly mitigate risks that may impact the organization’s systems and data. At this step, management should determine whether existing processes and controls meet SOC 2 expectations, or if new controls need to be implemented. This also includes defining control objectives, assigning ownership, and establishing consistent procedures for execution and documentation. Thoughtful design and selection of key controls ensures that the organization can demonstrate both proper design and operating effectiveness, forming the foundation for a successful SOC 2 readiness assessment.

Assessing Effectiveness of Key Controls

After key controls are identified or designed, management should determine if they are operating effectively. This step involves testing controls to confirm that they are consistently and properly executed by the assigned owners. Several testing strategies can be taken, such as reviewing documentation, observing processes, and sampling transactions. While performing the testing procedures, management should identify any deficiencies or failures. Evaluating control effectiveness provides assurance that controls are operating reliably, strengthens audit readiness, and ensures the organization can demonstrate compliance with the selected Trust Services Criteria.

Identifying Gaps and Observations

While the controls are being tested, it is critical for management to identify any gaps or observations that could affect SOC 2 readiness. Management should document instances where there are control gaps, control enhancements, or process improvement opportunities:

Control Gap: A required control is missing and would likely result in an exception during a SOC 2 examination if not remediated.
Control Enhancement: An existing control is partially effective but should be strengthened to improve alignment with SOC 2 expectations and reduce audit risk.
Process Improvement Opportunity: An existing control could be improved for efficiency or maturity, but the issue does not directly affect SOC 2 control compliance or audit readiness.

As part of this process, management should prioritize findings based on their potential risk, impact, and level of effort to remediate. Clear, actionable documentation of gaps ensures that stakeholders understand the key areas needing attention and the proposed timeline for remediation efforts in those areas.

Remediating Gaps and Observations

Once gaps and observations have been identified, management should develop and execute a remediation plan to address them timely and effectively. This involves assigning ownership for each remediation task, defining clear steps to correct any identified deficiencies, and establishing deadlines to ensure progress is tracked and monitored. Remediation can include implementing new controls, updating existing processes, enhancing documentation, or providing training to control owners. Management’s remediation efforts should not only correct the identified issues but also strengthen the overall control process to prevent issues from being identified again in the future. A SOC 2 examination cannot be pursued until the identified findings have been remediated and closed.

Sustaining and Continuously Improving the Effective Control Environment

Following the remediation of identified control gaps, management should focus on demonstrating that controls are operating consistently and effectively over a sustained period before pursuing a SOC 2 examination. As a leading practice, organizations often maintain evidence of control operation for approximately six months to establish a reliable track record of control effectiveness and operational discipline. This may also involve incorporating lessons learned into control execution, updating controls as processes evolve, and strengthening governance practices. Continuously maintaining a control environment provides more than just supporting a successful SOC 2 examination; it also reinforces operational resilience and stakeholder confidence.

Pursuing a SOC 2 Examination

Once the foundational elements of the control environment have been established, validated, and operating effectively over a sustained period, management can engage an independent service auditor to perform a SOC 2 examination. The examination evaluates both the design and operating effectiveness of controls against the organization's selected Trust Services Criteria and culminates in the issuance of a SOC 2 Report. A successful SOC 2 examination provides independent assurance that the organization has implemented and maintained controls designed to safeguard customer data and support the integrity of critical business processes.

Summary

Organizations that approach SOC 2 readiness strategically are often better positioned to meet customer expectations, demonstrate operational discipline, and navigate increasingly complex risk environments. By establishing a strong control framework, remediating identified gaps, and sustaining control effectiveness over time, management can pursue a SOC 2 examination with confidence while creating lasting value beyond the report itself.

As organizations prepare for 2026, increased attention should be placed on key focus areas such as access management, enterprise risk management, and third-party/vendor oversight. 2026 priorities include validating user access, performing risk assessments that drive informed business decisions, proactively monitoring cybersecurity risks, and maintaining effective governance over critical vendors and service providers. Investing in these areas can help strengthen the control environment and support long-term compliance objectives.

Eliassen's SOX & Internal Audit professionals bring extensive experience helping organizations assess readiness, identify and remediate control gaps, design scalable control frameworks, and prepare for successful SOC 2 examinations. Through a practical, risk-based approach, Eliassen helps organizations build sustainable compliance programs that inspire confidence and foster trust with customers, partners, and stakeholders.