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SOC 2 for AI Agents and MCP: Identity, Scopes and Audit Trails

How AI agents and MCP servers fit SOC 2: agent identity and access under CC6, monitoring under CC7, agent-authored changes under CC8, and what auditors ask.

Bip Thelin3 min readPublished

An AI agent that acts on your systems, directly or through an MCP server, is a user in SOC 2 terms, and the same criteria apply to it as to a person. Under the 2017 common criteria, CC6.1 to CC6.3 cover how the agent is identified, what it can reach and how that access is granted, reviewed and removed; CC7.2 covers monitoring what it does; and CC8.1 covers changes it makes or proposes. In practice that means a distinct, revocable identity for each agent connection, scopes limited to the task, every action logged against that identity, and a human approving changes that reach production. The AICPA's 2027 exposure draft adds points of focus on exactly these questions.

Engineering teams now run coding agents with repository access, operations agents with cloud credentials, and assistants that reach business systems through the Model Context Protocol. None of that needs new SOC 2 criteria. It needs the existing ones applied to a kind of user that can act much faster than a person and never gets tired of trying.

Agents under the 2017 criteria

CriterionWhat it asksWhat it means for agents
CC6.1Logical access security over protected information assetsA distinct credential per agent connection, never a shared or personal one, with access limited to what the task needs
CC6.2Registering and authorizing new users before access is grantedAn approval step before an agent is connected, recording who authorized it, for what and on whose behalf
CC6.3Authorizing, modifying and removing access based on roles and least privilegeScopes tied to the role of the user the agent acts for, periodic review of agent connections, and prompt revocation
CC7.2Monitoring system components for anomaliesAgent actions logged against their identity and watched for unusual volume, scope or timing
CC8.1Authorizing, testing and approving changesAgent-authored changes reviewed and approved by a person before they reach production, with separation between proposing and deploying
CC9.2Assessing and managing vendor riskThe model and agent providers you rely on assessed as vendors, including their terms on your data

Identity: one agent, one credential

The most common gap is an agent running on a person's own token or on a shared service account. Neither lets you tell what the agent did from what the person did, and neither can be revoked for the agent alone. Give each agent connection its own credential, bound to one organization and to the user who approved it, so its actions can be attributed and its access removed without touching anyone else's.

Scopes: least privilege for tools

An MCP server exposes tools, and a credential's scopes decide which ones the agent can call. Grant the narrowest scopes the task needs, prefer read-only credentials for read-only work, and check that write operations re-check authorization when they run rather than only when the tool list is fetched. Review agent connections alongside user access reviews, and remove those nobody uses.

Audit trails

Auditors will ask how you know what an agent did. Log every call an agent makes against its identity, in the same logs as actions taken in the user interface, with enough detail to reconstruct what changed. Keep those logs for the review period and alert on patterns a person would not produce, such as bulk changes or calls outside working hours.

Changes made by agents

A pull request opened by a coding agent is a change like any other. It needs review by a person who did not author the prompt that produced it, tests, approval and deployment through the normal pipeline. Agents that can merge or deploy their own changes break the separation CC8.1 expects, and the 2027 draft calls out restricting or monitoring unilateral development and deployment explicitly.

How Noru's MCP server is built

Noru runs an MCP server for its own customers, and its public documentation describes the same controls. Each OAuth connection is tied to one user, one organization and that user's role; scopes group the tools, and a viewer can only grant read scopes. Tools outside a credential's scopes are not listed, and write tools re-check the scope when they run. Writes through MCP land in the same logs as a click in the app. The MCP server documentation and the security model describe it in full.

What auditors are likely to ask

  • Which agents have access to production systems or customer data, and who approved each one?
  • What credentials do they use, and can each be revoked on its own?
  • How are their scopes chosen and reviewed?
  • Where are their actions logged, and who looks at those logs?
  • Can an agent change production without a person approving it?
  • Which model providers process your data, and on what terms?

Primary sources

Framework overviews

Related reading

FAQ

SOC 2 questions answered

Talk to us

Is an AI agent a user under SOC 2?

For access control purposes, yes. The criteria on registering, authorizing, reviewing and removing access apply to any identity that can act on your systems, and an agent acting through a credential is one.

Can an AI agent approve its own code changes under SOC 2?

Not if you want CC8.1 to hold. Change management expects separation between developing and deploying a change, so a person should review and approve agent-authored changes before they reach production.

Do we need to log every MCP tool call?

You need to be able to show what agents did, and logging tool calls against the agent's identity is the practical way to do it. At minimum, every write should be logged with who, what and when.

Does the 2027 SOC 2 draft mention AI agents?

The criteria stay technology-neutral, but the exposure draft adds points of focus on AI and automation, including how automated agents get access and how changes by a single actor are restricted or monitored.