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May 26, 2026
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9
 min read

SOC 2 Controls: The Complete 2026 Reference (CC1-CC9 + A, C, PI, P Criteria)

The complete SOC 2 controls reference for 2026: every Common Criterion (CC1-CC9) plus Availability, Confidentiality, Processing Integrity, and Privacy controls, with evidence examples.

SOC 2 Controls: The Complete 2026 Reference (CC1-CC9 + A, C, PI, P Criteria)
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TL;DR

  • SOC 2 controls are organized by Trust Services Criteria (TSC): Security has 9 Common Criteria (CC1-CC9) totaling ~64 underlying control points. Availability adds 3, Confidentiality adds 2, Processing Integrity adds 5, Privacy adds 18.
  • Auditors evaluate each control on design (does it exist and is it appropriate?) and operating effectiveness (does it work consistently over the observation period?).
  • The two highest-leverage Common Criteria for security-led teams: CC6 (Logical and Physical Access Controls — 8 control points, the largest section) and CC7 (System Operations — 5 control points, includes incident response and vulnerability management).
  • Strac Comply maps every piece of live system evidence (cloud config, SaaS audit logs, endpoint posture, DLP events, MCP tool calls) to each SOC 2 control automatically. The same data security platform that protects your environment generates the control evidence.
  • For the broader SOC 2 program guide, see SOC 2 compliance. For the audit-process view, see SOC 2 audit.

Looking for SOC 2 control automation? Strac Comply auto-maps live evidence from your cloud, SaaS, endpoints, and AI surfaces to each SOC 2 control — with Strac\'s DLP product providing the underlying data-protection evidence directly. One platform, every framework. Start at comply.strac.io →

✨ How SOC 2 Controls Are Structured

The AICPA's 2017 Trust Services Criteria (the version current auditors use) organizes controls into:

  • Common Criteria (CC1-CC9): The Security TSC. All SOC 2 audits cover these regardless of which optional TSCs you include.
  • Availability (A1): 3 control points covering system uptime, disaster recovery, business continuity.
  • Confidentiality (C1): 2 control points covering protection of confidential information.
  • Processing Integrity (PI1): 5 control points covering completeness, accuracy, timeliness, authorization, validity.
  • Privacy (P1-P8): 18 control points aligned to OECD privacy principles — notice, choice, consent, collection, use, retention, access, disclosure, monitoring.

Each control point has one or more Points of Focus — suggested implementation guidance the auditor uses to evaluate sufficiency. Points of Focus are not mandatory; they inform professional judgment.

✨ CC1 — Control Environment

The foundation. Auditors confirm leadership commitment to security and ethical conduct.

Control
What it covers
Common evidence
CC1.1
Demonstrates commitment to integrity and ethical values
Code of conduct, employee acknowledgment records
CC1.2
Board oversight
Board meeting minutes covering security topics
CC1.3
Management structures, reporting lines, authorities
Org chart, role descriptions
CC1.4
Commitment to competence
Hiring policies, performance reviews, training records
CC1.5
Accountability for internal control
Security responsibilities in job descriptions

✨ CC2 — Communication and Information

How the organization captures and shares security-relevant information.

Control
What it covers
CC2.1
Information requirements identified and obtained
CC2.2
Internal communication of security objectives, policies, and changes
CC2.3
External communication of relevant security matters to customers and stakeholders

Common evidence: internal security newsletters, customer-facing security pages, employee training records, change-communication artifacts.

✨ CC3 — Risk Assessment

How you identify, assess, and treat risk.

Control
What it covers
CC3.1
Specifies objectives related to security
CC3.2
Identifies and analyzes risk
CC3.3
Considers potential for fraud
CC3.4
Identifies and assesses changes that may significantly impact internal control

Common evidence: annual risk assessment, risk register, threat-modeling exercises, fraud risk review.

✨ CC4 — Monitoring Activities

How the organization confirms controls are still working.

Control
What it covers
CC4.1
Selects, develops, and performs ongoing and/or separate evaluations of controls
CC4.2
Evaluates and communicates deficiencies to those responsible

Common evidence: internal audit reports, continuous monitoring dashboards (this is where compliance automation platforms shine), remediation tracking.

✨ CC5 — Control Activities

The actual implementation of policies and procedures.

Control
What it covers
CC5.1
Selects and develops control activities
CC5.2
Selects and develops general controls over technology
CC5.3
Deploys policies and procedures across the org

Common evidence: policy documents (information security, acceptable use, access control, change management, incident response, business continuity, vendor management), policy acknowledgment records.

✨ CC6 — Logical and Physical Access Controls

The largest section. This is where most SOC 2 audit time gets spent. 8 control points cover the entire access-and-data-protection surface.

Control
What it covers
Typical implementation
CC6.1
Logical access controls
MFA on every privileged account, SSO, RBAC, JIT access provisioning
CC6.2
New user provisioning controlled
HRIS-driven provisioning, approval workflow
CC6.3
Access modifications and removal
Quarterly access reviews, automated deprovisioning
CC6.4
Physical access
Office badging, data center access (if applicable)
CC6.5
Logical access termination on personnel change
Same-day deprovisioning, evidence of termination workflow
CC6.6
Boundary protection (firewalls, network segmentation) + data classification and protection
DLP across SaaS / cloud / endpoint, data classification labels
CC6.7
Restricted access to information and data — encryption, DLP, vault
Encryption at rest + in transit, DLP redaction, secret management
CC6.8
Protection against unauthorized or malicious software
Endpoint protection, application allowlisting, vulnerability scanning

CC6.6 and CC6.7 are where Strac Comply uniquely differentiates — Strac DLP's continuous data classification and redaction across SaaS/cloud/endpoint/AI surfaces produces the audit evidence directly. Most compliance platforms send you to integrate a separate DLP; Strac Comply ships with the DLP product.

✨ CC7 — System Operations

Day-to-day operational security.

Control
What it covers
Typical implementation
CC7.1
Vulnerability identification and remediation
Vulnerability scanning, patch management, SLAs by severity
CC7.2
Anomaly and event monitoring
SIEM, security alerting, on-call rotation
CC7.3
Evaluation and reporting of security events
Incident triage, escalation playbook
CC7.4
Incident response procedures
Documented IR plan, runbooks, tabletop exercises
CC7.5
Recovery from incidents and breaches
Recovery playbook, post-incident review

✨ CC8 — Change Management

Production change controls.

Control
What it covers
CC8.1
Authorized changes to system components

Common evidence: peer-reviewed pull requests, change tickets, deployment automation logs, infrastructure-as-code repositories with approval gates.

✨ CC9 — Risk Mitigation

Business continuity and third-party risk.

Control
What it covers
CC9.1
Business continuity and disaster recovery
CC9.2
Vendor and business-partner risk management

Common evidence: BC/DR plan with tabletop exercise records, vendor security review process with documented assessments per critical vendor.

✨ Optional TSC Controls

Availability (A1)

  • A1.1 — Capacity management, performance monitoring
  • A1.2 — Environmental protection, system recovery
  • A1.3 — Recovery infrastructure tested

Confidentiality (C1)

  • C1.1 — Identification and protection of confidential information
  • C1.2 — Disposal of confidential information

Processing Integrity (PI1)

  • PI1.1 — Definitions of processing objectives
  • PI1.2 — System inputs are complete, accurate, valid
  • PI1.3 — System processing is accurate, complete, timely, authorized
  • PI1.4 — Outputs are complete, accurate, timely
  • PI1.5 — Stored data remains complete, accurate, available

Privacy (P1-P8)

18 control points aligned to the OECD privacy principles, covering notice (P1), choice and consent (P2), collection (P3), use and retention (P4), access (P5), disclosure (P6), quality (P7), and monitoring (P8). Privacy is the longest optional criterion and requires the most policy documentation.

✨ How Strac Comply Maps Evidence to Every Control

Strac Comply is the AI-native compliance automation platform built for security-led teams. The platform watches your live systems and auto-maps the right evidence to each SOC 2 control.

Where Strac Comply uniquely covers controls competitors don't:

  • CC6.6 + CC6.7 (data protection): Strac DLP\'s continuous data classification, OCR inspection on files, and inline redaction across SaaS / cloud / endpoint surfaces produce the evidence directly. No separate DLP integration required.
  • MCP-aware controls: AI agents using Model Context Protocol (MCP) read your SaaS data directly. Strac\'s MCP DLP audit logs map to CC6.1 (logical access by agents), CC6.6 (data classification at the tool-call boundary), and CC7.2 (anomaly monitoring on agent behavior). Strac\'s 18 SaaS MCP connectors generate this evidence continuously.
  • AI compliance: AI-system controls map to SOC 2 in 2026 (CC6, CC7) and to ISO 42001 + EU AI Act. Strac Comply\'s mappings cover all three.

What Strac Comply automates per Common Criterion:

  • CC1-CC5 (governance): policy drafting from a 10-minute questionnaire, training tracking, risk-register management
  • CC6 (access + data): SSO + MFA evidence pulled from your IdP, access-review automation, DLP event evidence
  • CC7 (operations): vulnerability scan ingestion, incident response ticket evidence, monitoring screenshots
  • CC8 (change): GitHub / GitLab integration for PR review evidence
  • CC9 (risk + vendor): vendor security review workflow with auto-tracking

Start at comply.strac.io →

Strac Comply: SOC 2 controls evidence on autopilot

Strac Comply maps every piece of live evidence to the right SOC 2 control automatically — cloud config, SaaS audit logs, endpoint posture, DLP events, MCP tool calls. The same Strac platform protecting your data is the platform generating your audit evidence.

Start at comply.strac.io →

🌶️ Spicy FAQs for SOC 2 Controls

How many SOC 2 controls are there?

The Security TSC alone has 9 Common Criteria (CC1-CC9) with approximately 64 underlying control points. Adding all optional TSCs gets you to about 92 total. The exact count depends on which Points of Focus your auditor evaluates as separate controls.

Are SOC 2 controls prescriptive or principles-based?

Principles-based. The AICPA defines the criteria; you design the controls. Two companies can satisfy CC6.7 differently — one with full-disk encryption and a vault, another with DLP plus tokenization — and both pass. The auditor evaluates sufficiency.

Which Common Criteria has the most controls?

CC6 (Logical and Physical Access Controls) with 8 control points. It covers access provisioning, MFA, encryption, DLP, network segmentation, and endpoint protection. Most audit hours land here.

Do I need to implement controls for optional TSCs?

Only if you scope them in. If your audit covers Security only, you don't need Availability, Confidentiality, Processing Integrity, or Privacy controls. Most SaaS companies start Security-only; healthcare and fintech add Confidentiality and Availability.

What's the difference between a control and a Point of Focus?

A control is the requirement (e.g., "Logical access security software, infrastructure, and architectures over protected information assets"). A Point of Focus is the AICPA's suggested implementation example (e.g., "Identifies and Manages the Inventory of Information Assets"). Controls are mandatory; Points of Focus inform auditor judgment but are not themselves required.

How does CC6.7 (encryption + DLP) work with cloud DLP and AI?

CC6.7 reads: "The entity restricts the transmission, movement, and removal of information to authorized internal and external users and processes, and protects it during transmission, movement, or removal to meet the entity's objectives." In 2026 that means DLP coverage on SaaS messages and files, encryption in transit, and increasingly — redaction at the MCP tool-call boundary when AI agents pull data. Strac is the only platform that provides all three from a single product. See MCP security.

Can Strac Comply provide evidence for non-SOC 2 frameworks too?

Yes. Every piece of evidence is mapped to all applicable frameworks simultaneously — SOC 2, HIPAA, ISO 27001, PCI DSS, GDPR, CCPA, EU AI Act, ISO 42001. One control evidence covers up to seven frameworks at once.

How long does control implementation take with Strac Comply?

Most controls auto-light up on integration. Policy generation (CC5) takes a 10-minute questionnaire. Access reviews (CC6.3) become quarterly automation. The longest task is human-driven controls — risk assessments (CC3.2), tabletop exercises (CC7.4), vendor reviews (CC9.2) — which still require expert judgment but become tracked workflows in the platform.

Are these the same SOC 2 controls auditors use globally?

The AICPA Trust Services Criteria are US-defined. International audits typically use ISO 27001 instead, though SOC 2 is increasingly accepted globally by US-headquartered customers buying from non-US vendors. See SOC 2 vs ISO 27001 for the cross-framework view.

The Bottom Line

SOC 2 controls are organized into 9 Common Criteria (mandatory) plus optional TSCs. CC6 (access + data protection) is where most evaluation time lands. Strac Comply maps every live system event to the right control automatically — and uniquely covers CC6.6 and CC6.7 with the Strac DLP product directly.

See Strac Comply control automation →

How many SOC 2 controls are there?
Are SOC 2 controls prescriptive or principles-based?
Do I need to implement controls for optional TSCs?
What's the difference between a control and a Point of Focus?
How does CC6.7 (encryption + DLP) work with cloud DLP and AI?
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