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How to Review a Vendor's SOC 2 Report: A Step-by-Step Checklist

How to review a vendor's SOC 2 report: type and period, the opinion, scope, exceptions, complementary controls, subservice organizations and follow-up.

Bip Thelin2 min readPublished

Reviewing a vendor's SOC 2 report means checking that it covers the service you use, for a recent period, with an opinion you can rely on, and then taking on the work it hands back to you. Confirm the report type and that the review period ended recently. Read the auditor's opinion and note any qualification. Check that the system described is the service you buy and that the Trust Services Criteria in scope match your risk. Read every exception and management's response. Map the complementary user entity controls to owners in your organization. List the subservice organizations and decide which reports you need from them too. Record the review and any follow-up, and diary the next one.

A SOC 2 report is easy to file and hard to read. Vendor risk teams often check that one exists and move on, which leaves the parts of the report that matter most, the exceptions and the controls it hands back to you, unread.

Step 1: Check the basics

  • Report type: a Type 2 tests operation over a period; a Type 1 only tests design at a date.
  • Review period: when it ended, and whether you need a bridge letter for the time since.
  • Issue date and the audit firm that signed the report.
  • The auditor's opinion: unqualified, qualified, adverse or a disclaimer, and what any qualification is about.

The guide to bridge letters covers what to check when the period ended a while ago.

Step 2: Check the scope

Read the system description and confirm it covers the product, environment and regions you use. A vendor with several products may have a report on one of them. Then look at which Trust Services Criteria categories are in scope. Security is always included; if you rely on the vendor's uptime, Availability matters, and if you send confidential data, Confidentiality does.

Step 3: Read the exceptions

In the tests and results section, find every control where exceptions were noted. For each one, ask how severe it is, whether it touches the part of the service you rely on, whether several exceptions point to the same weakness, and whether management's response explains the cause and the fix. The guide to SOC 2 exceptions and opinions covers how to read them.

Step 4: Take on the complementary user entity controls

The report lists controls the vendor assumes you operate, such as managing your users' access or protecting the API keys it issues you. The auditor did not test them, and the vendor's controls only meet the criteria if you run them. Assign each one an owner and confirm it runs. The guide to CUECs and subservice organizations covers them in detail.

Step 5: Look through to subservice organizations

Most reports carve out the vendor's own critical providers, such as its cloud host. Their controls were not tested in this report. Decide which ones matter for your data, and ask the vendor how it monitors them, or ask for their reports directly where it matters.

Step 6: Record the review and follow up

RecordWhy
Report details: type, period, auditor, opinionShows which report you relied on and when
Scope fit and any gapsShows whether the report covers what you use
Exceptions and your assessment of eachShows you read them and decided they were acceptable, or not
CUEC ownersShows the controls handed back to you are being operated
Follow-up questions and answersCloses the gaps the report left open
Next review dateUsually when the next report is due

These records are also evidence for your own audits: vendor monitoring is part of the SOC 2 common criteria, and under DORA and NIS2 it is part of managing third-party and supply-chain risk. The third-party risk management solution shows how Noru keeps vendor reports and reviews in one place.

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FAQ

SOC 2 questions answered

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What is the most important part of a vendor's SOC 2 report?

After confirming the scope and the opinion, the exceptions and the complementary user entity controls. Exceptions show where the vendor's controls fell short, and the complementary controls show what you have to do yourself.

How recent does a vendor's SOC 2 report need to be?

Most reviewers expect the review period to have ended within roughly the last twelve months, with a bridge letter for the time since. An older report is a reason to ask when the next one is due.

Is a Type 1 report enough for a vendor review?

It shows the controls were designed properly at a date, not that they operated. It can be acceptable for a new vendor with a Type 2 on the way, but treat it as weaker assurance.

What should we do if the opinion is qualified?

Read what the qualification is about and whether it affects the service you use. Ask the vendor what caused it and what has changed, and decide whether you need additional assurance or contract terms.