Learn · SOC 2 Evidence
SOC 2 Evidence:
What Auditors Actually Accept
Evidence is accepted when it is attributable, complete, timely, and produced by a system the auditor can rely on. Nearly every argument about screenshots and spreadsheets comes back to those four tests.
The distinction that decides the argument: evidence of a control’s current state is not evidence of its operation during the period. A screenshot taken in November tells an auditor about November.
Plain-English explainer · AT-C 105 & 205 examination · Last reviewed August 2026
A SOC 2 auditor accepts an artefact as evidence when it is attributable to a named actor or system, complete against a population they can bound, timely with respect to the period, and produced by a source whose reliability they can establish. Those four properties are not one firm’s house style. They fall out of the attestation standards a SOC 2 examination runs under — AT-C sections 105 and 205, together with the AICPA’s SOC 2 guide — which require the practitioner, where the evidence is information you produced, to evaluate whether it is sufficiently reliable, including by obtaining evidence about its accuracy and completeness. That requirement is why your spreadsheet came back with questions attached while the raw export beside it went into the workpapers, and it is also why sample design cannot begin until the population is settled.
The acceptance test
What makes an artefact evidence
An artefact is not evidence because it exists, but because a reader who was not there can conclude something from it.
Attributable
The artefact shows who performed the control, or which system did, where, and when. AT-C 320 — the SOC 1 section, whose reasoning a SOC 2 tester applies — puts three questions to the service auditor: how the control was applied, how consistently it was applied, and by whom. Those three questions are what attribution has to answer.
Complete
It represents the whole population it claims to — every change, every joiner, every privileged account. Completeness is something the auditor must establish independently, which is why a population arrives with a source, a filter, a run record and a count that reconciles.
Timely
It was captured at or near the moment the control operated, and that moment falls inside the observation period. Evidence assembled afterwards describes the present, not the period.
Reliable at source
AT-C 205 sets out how a practitioner weighs evidence: what they obtain directly beats what they infer, documentary beats oral, and originals beat transformations. A screenshot is a transformation.
Type 1 vs Type 2
The same control, two different asks
Almost everything on this page describes a Type 2. That distinction has to be made early, because the two report types ask for genuinely different artefacts. A Type 1 opines on the fairness of the description and the suitability of the design of controls as of a specified date. The subject matter is state at a date, so state-at-a-date evidence is the right evidence: a defensible screenshot of the enforced MFA policy, taken on or near the as-of date, is often sufficient and appropriate. Nothing is being asserted about March.
A Type 2 opines on operating effectiveness throughout a period. Now every artefact needs a date inside the period and a population standing behind it, because the auditor is sampling occurrences rather than observing a configuration. The same MFA control that passed on one screenshot in the Type 1 now needs the enrolment report for the full user population, plus the change history proving the policy was not relaxed in month seven.
The trap is predictable and expensive: a team passes the Type 1 on screenshots, keeps the same evidence habits, and discovers in month ten that the source logs behind the last nine months were never retained. Moving from a Type 1 to a Type 2 is mostly a change in evidence discipline, and it should start on day one of the period, not at the end of it.
Screenshots
Weak evidence — and sometimes the only evidence
A screenshot is weak for two reasons, and teams argue only about the first. Provenance: the image is a transformation of a system’s state, framed and saved by the party being audited. Scope: information about the implementation of a manual control at a point in time does not evidence its operation at other times. Your rule set on 12 October evidences 12 October, not March.
That second point is stated most plainly in AT-C 320, the section governing SOC 1. It is application guidance for a different report, but it is the reasoning SOC 2 practitioners apply, because AT-C 205 addresses point-in-time evidence only in general terms. Where this page cites AT-C 320 below, read it the same way: written for SOC 1, applied by analogy.
Screenshots remain unavoidable, because some systems do not export: a buried console setting, a vendor portal with no reporting, a physical access panel, an empty queue that must be shown to be empty. What an auditor insists on then is a defensible capture.
A defensible screenshot contains
No AT-C section specifies screenshot contents. This is what firms consistently ask for, and each line follows from one of the four tests.
- The system clock in frame — the operating-system clock or an in-application timestamp, not the file’s metadata date.
- The logged-in user, visible in the interface, so the capture is attributable to verifiable access.
- The full URL, or a tenant identifier — how a reviewer separates production from staging.
- The complete, uncropped window. Cropping is the fastest route to a request for the export.
- Any filter or date range in the same frame as the result. A result without its query is an assertion.
- Storage as a named, dated file in the evidence repository, not pasted into a document.
Exports vs spreadsheets
Why your spreadsheet costs more
AT-C 205 requires that when a practitioner uses information produced by the entity, they evaluate whether it is sufficiently reliable — obtaining evidence about its accuracy and completeness, and judging whether it is, in the standard’s phrase, sufficiently precise and detailed. AT-C 320 illustrates the same requirement for a service organisation, listing what it bites on: population lists used to select samples, exception reports, user access lists, reconciliations and system-generated reports. Almost everything you are asked for.
A hand-built spreadsheet is not rejected because anyone doubts your integrity, but because it carries no independent evidence of its own completeness — forcing the auditor to test the compilation before testing the control.
Practice, not a standards requirement — but it is what satisfies the completeness test.
Every population should travel with four things: the source system and exact query, the filter applied, the run date and the user who ran it, and a record count that reconciles to the source.
The last is the cheapest control in the exercise: the count in the console must equal the rows in the file. Where manual compilation is unavoidable, declare it early and supply the underlying exports alongside the compiled view. The table below is where those exports actually live in the tools most engagements run on — naming a product is not an endorsement of it, it is the difference between a principle and an instruction.
Where the acceptable export actually lives
| Population | Source and export path | What proves it is complete |
|---|---|---|
| User access listing | Okta → Reports → Current Assignments, or Microsoft Entra ID → Users → Download users. Export as CSV without opening and re-saving it. | The row count equals the active-user count the console displays on the directory page, captured in the same session. |
| Privileged access on AWS | IAM → Credential Report (CSV), supported by an IAM Access Analyzer export for cross-account access. | The credential report carries its own generated timestamp and one row per IAM user, so the count reconciles to the IAM user list. |
| Production changes | Jira, exported to CSV from a JQL search: project = PROD AND type = Change AND resolved >= 2025-10-01 AND resolved <= 2026-09-30 | The JQL string captured in the same frame as the result count. The query is what proves the export includes every change and excludes nothing. |
| Code changes and peer review | GitHub audit log export for the period, plus branch-protection rules read through the API rather than photographed in settings. | The API response shows the rule as it stood, with the repositories it applied to. A settings screenshot shows today only. |
| Security awareness training | The LMS per-user completion report for the period, exported with completion dates rather than a percentage tile. | Reconciled line by line against the HRIS headcount report for the same date, with joiners and leavers explained. |
| Vulnerability remediation | The scanner’s dated scan-comparison report — two scans that bracket the remediation — not the current dashboard. | Two dated scans bound the window in which the finding closed. A dashboard shows the state on the day it was opened. |
One rule sits underneath every row: export, do not re-save. Opening a CSV in a spreadsheet application and saving it again strips the provenance that made it acceptable, and an auditor who sees a modified timestamp after the run date will ask what changed between the two.
Period, not moment
Evidence has to be distributed
AT-C 320 settles the logic for a SOC 1 service auditor, and the SOC 2 guide reasons identically: evidence about prior periods does not evidence operating effectiveness in the current one. The same reasoning defeats the reverse move — today’s state cannot cover last spring. How much gets sampled is judgement. AT-C 205 governs sample design, and its application material points to the AICPA Audit Guide Audit Sampling. No body mandates sizes, so the figures below are observed market practice, reconciled with our sample-size reference.
| Control frequency | Drawn from | Baseline (no deviations expected) | After one deviation | Must still exist at fieldwork |
|---|---|---|---|---|
| Automated / continuous | Configuration state and its change history | Tested once, supported by general controls over change and access | The general controls themselves come under scrutiny — a deviation here is rarely isolated | Configuration history for the period, not the current state |
| Daily | Job logs, alert queues, monitoring output | 25 of roughly 250 business days | 40 | Retention back to day one of the period |
| Weekly | Weekly reports and review records | 5–9 of 52, spread across the period | 12–15 | The dated artefact for each selected week |
| Monthly | Reconciliations, patch cycles, monthly reviews | 2 of 12 | 4–5; all 12 if a second deviation appears | Completed record and reviewer identity per month |
| Quarterly | Access, risk and vendor reviews | 2 of 4 | All 4 | The listing, the decisions, and proof they were actioned |
| Annual | Policy approval, risk assessment, penetration and restoration tests | The single occurrence, tested in full | No extension exists — one deviation is a 100% deviation rate | The dated deliverable and proof it fell inside the period |
| Event-driven | Joiners, leavers, changes, incidents | A sample from a population you must bound; below roughly 25 items, often all of them | Where the population was already tested in full there is nothing to extend into | The population export plus a record per event |
The fourth column is why a single missed month is expensive: it does not just fail one item, it enlarges every remaining selection. Applied to the sixty-person software company in the request list below — period 1 October 2025 to 30 September 2026 — its 412 production changes give a selection of 25, its four quarterly access reviews are all tested, and its single restore test on 14 May 2026 is tested in full because a population of one has no sample. Its 11 hires sit at the awkward size: five is a common selection, and some firms take all eleven, because below roughly twenty-five items sampling stops saving anyone effort.
One further consequence is worth knowing before selections land: a selected item to which the practitioner cannot apply the designed procedure, or a suitable alternative, is treated as a deviation. “We cannot find that ticket” is not neutral.
Retention
Evidence that no longer exists
The most avoidable failure in a first Type 2 is not a missing control. It is a control that operated perfectly and left an artefact since deleted: ninety-day log retention against a twelve-month period; a chat tier that discards the only record of an escalation; a leaver’s mailbox purged, taking a change approval with it.
The sixty-person company above ran exactly into this. Its chat tier discarded messages after ninety days, and two of its three recorded incidents had been escalated and coordinated in chat. By the time fieldwork opened on 2 November 2026, the only surviving record of those two escalations was the incident ticket itself — which is why the ticket, not the conversation, has to be the system of record.
The rule: evidence must survive from the day the control operated to the day the auditor tests it — the period, plus the weeks to fieldwork, plus the firm’s review before release. Period end plus six months is a floor; thirteen months is what we recommend, which for a period ending 30 September 2026 means nothing is deleted before 31 October 2027.
Note where the obligation sits. AT-C 105 requires the CPA firm to assemble its final engagement file within sixty days of releasing the report, and the firm then retains that file for years afterwards under the AICPA’s quality-management and peer-review requirements. Nothing in the attestation standards tells a service organisation how long to keep the logs that file was built from — which is why a ninety-day retention setting survives three audits before it costs someone a Type 2.
Tickets
The best evidence a manual control can produce
Change management, incident response and offboarding are manual controls at heart, and a well-formed ticket carries all four properties at once. The anatomy below is firm practice rather than a standards requirement — no AT-C section describes a ticket — but each row exists because a tester has to answer a specific question from the artefact alone.
What and why
The change described well enough to stand alone, linked to its trigger.
Requester and approver
Two different people, identified by the system rather than typed into a field.
Approval as state
An action the system logged with its own timestamp — not a comment reading “approved”.
Pre-deployment testing
A link to the test run or check performed before release, with its result.
Deployment record
When it shipped, who released it, and to which environment.
An immutable history
Created, approved, deployed, closed — with times that could not be edited.
Three anti-patterns account for most change-management exceptions: self-approval, approval captured in free text rather than workflow state, and tickets opened after deployment. Retrospective tickets are defensible only where the process defines an emergency path and a review closed it. The ticket population is itself information produced by the entity.
The register
One row per control, written before the period starts
“Everything lands in one repository” is advice nobody can act on. The register is the artefact that makes it actionable: one row per control, filled in before the period opens, so that on the day the request list arrives you are locating files rather than deciding what would count. Four rows from the sixty-person company are shown; a real register for that company runs to roughly forty.
| Control ID | Criterion | Owner (role) | Artefact and source | Capture cadence | Storage path | Retain until |
|---|---|---|---|---|---|---|
| CC6.3-01 | CC6.3 | Head of IT | Okta Current Assignments export, reviewed line by line, decisions recorded in the review ticket | Quarterly — Dec, Mar, Jun, Sep | /evidence/2026/CC6.3/ | 31 Oct 2027 |
| CC8.1-01 | CC8.1 | Engineering Manager | Jira change ticket with approval as a state transition, plus the pipeline deployment record | Per change — 412 in the period | /evidence/2026/CC8.1/ | 31 Oct 2027 |
| CC7.2-01 | CC7.2 | Security Lead | Alert-to-triage export from the monitoring tool, with disposition per alert | Monthly export, on the first business day | /evidence/2026/CC7.2/ | 31 Oct 2027 |
| A1.2-01 | A1.2 | Head of Infrastructure | Restore log with system timestamps, validation output, sign-off | Annual — performed 14 May 2026 | /evidence/2026/A1.2/ | 31 Oct 2027 |
Two columns do more work than they look like they should. The owner is a role, never a person, because people leave mid-period and a register that names them goes stale the same week. The retain-until date is a single date across the whole register — period end plus thirteen months — so that retention becomes one decision rather than forty.
The naming convention
CC6.3_quarterly-access-review_2026-03-18_okta-current-assignments.csv
Criterion, control, the date the control operated, source system. The rule that makes it matter is the third element: the date in the filename is the date the control operated, not the date somebody captured the file. A repository named for capture dates is exactly how a March artefact ends up looking like an October fabrication — and an auditor who has to ask why every file in a twelve-month period carries an October date has already stopped reading the evidence and started assessing the entity.
The request list
A worked excerpt, with populations
In practice the CPA firm’s request list — the PBC, for prepared by client — arrives two to six weeks before fieldwork, organised by control domain, each line carrying a reference, the request, the period it covers, an owner, a due date and a status. Nothing fixes that timing; it varies with the firm and the size of the engagement. It comes in waves: populations first, then selections drawn from them, then open items during fieldwork. The excerpt is illustrative: a sixty-person software company, period 1 October 2025 to 30 September 2026.
| Ref | Request | Population as defined | Selection | Evidence expected |
|---|---|---|---|---|
| HR-02 | New hires: onboarding and screening | 11 hires in the period, from the HRIS joiners report | 5 selected | Policy acknowledgement, screening record, onboarding ticket showing access after approval (CC1.4, CC6.2) |
| LA-01 | User access listing, production | 62 active and 7 deactivated accounts, exported from the identity provider, 3 Oct 2026 | Population reconciled; 8 privileged accounts tested | Raw export, capture of filter and count, authorisation per account (CC6.1, CC6.3) |
| LA-04 | Terminations: access removal | 7 leavers, from the HRIS leavers report, reconciled to deactivation events | All 7 | Last working day record, deactivation event with system timestamp, ticket (CC6.2) |
| LA-06 | Quarterly user access reviews | 4 reviews — December, March, June, September | All 4 | The listing reviewed, reviewer identity, decisions, tickets closing revocations (CC6.3, CC4.1) |
| CM-01 | Production changes | 412 change tickets, exported from the tracker using the query in the capture | 25 selected | Approval as a state transition, test evidence, deployment record with actor (CC8.1) |
| OPS-03 | Monitoring alerts and incidents | 1,148 alerts; 3 incidents recorded during the period | All 3 incidents; 10 alerts | Alert-to-triage record; incident timeline, containment, closure (CC7.2, CC7.4) |
| BC-02 | Backup restoration test | 1 test performed on 14 May 2026 | The single occurrence | Test plan, restore output with system timestamps, validation, sign-off (A1.2, A1.3) |
| VM-01 | Vendor risk reviews | 18 vendors rated; 6 classified critical | All 6 critical vendors | Current SOC 2 report or equivalent, review record with date and reviewer (CC9.2) |
Read the third column again: the population is where the engagement is won or lost, because an auditor who cannot establish that a population is complete cannot rely on anything drawn from it. Populations of one are tested in full. Criteria references are to the 2017 Trust Services Criteria (revised points of focus, 2022).
Accepted vs rejected
The same request, answered two ways
Every rejection below is one of the four tests failing, and the accepted form cost the same effort. Which criteria are in scope changes what is requested: the first eight rows lean on Security and Availability because those appear in every engagement, and the last three show how the same logic lands when Confidentiality, Processing Integrity or Privacy is added.
| The request | Accepted | Sent back — and why |
|---|---|---|
| User access listing | Identity-provider export with the filter, run date, user, and a count matching the console | A spreadsheet of names kept by hand — nothing evidences it is complete |
| Access removal on termination | The deactivation event with the system’s timestamp, tied to the leaver record | A profile screenshot showing “inactive” today — the state now, not the date it changed |
| Change approval | Approval as a state transition by a second person, with the time the system logged | A comment reading “approved by the CTO” — not attributable, and editable |
| Quarterly access review | The listing reviewed, decisions against each line, and tickets closing revocations | A calendar invitation — evidence of a meeting, not of a review |
| Backup restoration | Restore log with timestamps, the data set restored, validation, and sign-off | A screenshot of the backup schedule — configuration, not a test |
| Security awareness training | Per-person completion report with dates, reconciled to the employee population | The course catalogue, or an aggregate percentage with no underlying list |
| Vulnerability remediation | Dated scan output before and after, with the remediation ticket and closure | A status email confirming the issue was fixed — inquiry, in written form |
| MFA enforcement | Policy export plus a user-level enrolment report for the full population | A settings-page screenshot taken during fieldwork — one day of twelve months |
| Confidential data disposal (C1.1, C1.2) | The dated classification inventory, plus the retention or disposal job log showing records actually destroyed | The data classification policy on its own — a statement of intent, not of operation |
| Input validation (processing integrity series) | The exception or reject-queue output for the period, with a disposition recorded against each item | A statement that inputs are validated, or a design document describing the validation rules |
| Consent and data subject requests (privacy series) | Consent records, and the request log with the date each request was received and the date it closed | The published privacy notice — evidence of what you promised, not of what you did |
Where this gets contested
Seven edge cases that generate the calls
Controls that leave no trace
Some controls produce nothing that survives — a supervisor eyeballing a queue, a verbal escalation, a physical check. The SOC 1 section, AT-C 320, recognises this in its application guidance: certain controls leave no evidence testable later, so the service auditor may test them at various times during the period. SOC 2 practitioners take the same route. Your options are scheduled observation, or re-engineering the control so it leaves a record.
The control changed mid-period
You replaced a manual review with an automated gate in April. The superseded control still operated for part of the period and still needs evidence. AT-C 320 requires a SOC 1 service auditor to test superseded controls before the change where practicable, and the SOC 2 reasoning is identical. Evidence both, and pin the cutover date in the system description.
Evidence held by a subservice organisation
Under the carve-out method their controls sit outside your description, so you evidence your monitoring: the report you obtained, when you reviewed it, and what you did about its exceptions and complementary user entity controls. Under the inclusive method their evidence is in scope, which means their populations and their retention become your problem too.
Evidence containing personal data
Redaction is legitimate; over-redaction destroys what made the artefact evidence. Black out the payload, keep identifiers, timestamps, actors and counts. Agree the convention with the CPA firm before producing, and never re-key a redacted export into a fresh spreadsheet — that turns a system record into information produced by the entity, and the completeness testing starts again.
A compliance platform as the source of truth
Automated monitoring produces good evidence, and its scheduled captures solve timeliness. What it does not solve is its own completeness: the auditor must establish that the integration sees every in-scope account, host and repository, and will reconcile its inventory against source systems. Budget for source exports alongside the platform for access, change and infrastructure.
Infrastructure that no longer exists
Containers and auto-scaled hosts are gone by fieldwork, so host-level evidence is unobtainable by design. Evidence moves up a layer, to the control governing the fleet: the pipeline, the image build, the admission policy, the infrastructure-as-code history. Say so in the description, so the auditor tests the control that actually exists.
The genuine gap
March is missing and cannot be reconstructed. The worst response is a document created in October and dated in March: a fabricated record, turning a control problem into an integrity problem, and one an auditor finds because file metadata outlives good intentions. Disclose the gap and evidence any detective control covering that month.
Who does what
The line nobody is allowed to cross
Most evidence arguments are really boundary arguments — who runs the export, who checks it, who is allowed to choose the sample. Two rows carry the weight: nobody but the service organisation operates the control, and nobody but the CPA firm issues the opinion.
| Activity | Service organisation | Readiness partner (TCSA) | CPA firm |
|---|---|---|---|
| Operate the control | Always, and only | Never — operating it would make readiness indistinguishable from management | Never — operating it would destroy independence |
| Define the population | Owns the definition, because it owns the system boundary | Drafts it, then attacks it for the sub-populations people forget | Agrees the definition matches the control being tested |
| Run the export | Runs it, from its own systems, under its own credentials | Specifies the report, filter and date range in advance | Receives it, or observes it being run in a screen share |
| Test the population for completeness | Reconciles the count before the file leaves the building | Re-checks the reconciliation during readiness | Performs its own procedures — it cannot rely on ours |
| Select the sample | No — a selection made by the tested party is not a selection | No | Yes. Selection belongs to the auditor |
| Inspect the artefact | Produces it | Inspects it in readiness, so rejections happen before fieldwork | Inspects it as evidence for the opinion |
| Conclude on operating effectiveness | No | No | Yes |
| Issue the opinion | No | No — TCSA never certifies, attests or signs | The licensed CPA firm, alone |
This is also the answer to the security objection below. A readiness partner can specify the export and check the reconciliation; it cannot run your production systems, and neither can the CPA firm. Independence is a precondition of the examination, not a preference.
Pushback
Seven objections, and the answers
The first four come from inside the building. The last three come from the customer’s security reviewer, which is where the report has to survive.
“Screenshots were accepted last year.”
Sometimes they were, usually because the population was small enough for point-in-time evidence to be proportionate, or because the first engagement was a Type 1 opining on design at a date. As populations grow, and as a short first period becomes twelve months of operating effectiveness, the same artefact stops carrying the same weight. Nothing changed in the standard; what changed is what has to be demonstrated. The export is also cheaper to defend, because it does not depend on a judgement call about whether one image is proportionate.
“Engineering says pulling that export is a security risk.”
Usually this is a scoping problem wearing a security costume. The objection is rarely to the export itself but to handing over a file containing more than the test needs. Scope the export to the fields the procedure requires, run it in a screen share, or issue a read-only, time-boxed account. What is not available is a substitute: the auditor may collect and inspect, but must never operate your controls or run your systems for you, so someone on your side has to press the button.
“Our customer says a sampling exception means we failed.”
It does not, and the report itself says so. When a deviation appears, the practitioner investigates its nature and cause, considers whether the sample should be extended, and evaluates the effect on the conclusion. Whether it becomes a reported exception, and whether that modifies the opinion, are later and separate judgements. Point the reviewer at the opinion paragraph in Section 1 and at management’s response beside the exception in Section 4 — a qualified opinion looks materially different from an unqualified opinion with three noted exceptions.
“Why can the auditor not take our word for it?”
Because the standards do not allow it. Written representations are evidence, and the examination requires them, but they do not on their own provide sufficient appropriate evidence about the matters they cover. Inquiry has to be combined with inspection, observation or reperformance. This is also why an auditor who accepted your word would produce a report no customer would value: the whole commercial point of the deliverable is that a licensed CPA firm looked rather than asked.
“Your report covers a period that ended four months ago — how do we know controls still operate?”
You do not, from the report alone, and no report can tell you otherwise: a Type 2 opines on a period that has closed. What bridges the gap is a bridge letter — management’s written statement to user entities that no material changes to the control environment occurred between period end and the letter date. It is management’s assertion, not the CPA firm’s opinion, and it carries no testing behind it. Reviewers who understand that treat it as a gap-filler, not a substitute for the next examination.
“We want to see your evidence, not just the report.”
The report is the deliverable. The workpapers behind it belong to the CPA firm, are subject to its confidentiality obligations, and are not distributable — no service organisation can hand them over even if it wanted to. What a customer can legitimately receive is the report under NDA, the bridge letter, answers to a security questionnaire, and where the request is specific, a targeted artefact such as the current penetration test summary. A reviewer who insists on raw workpapers is asking for something that does not exist in distributable form.
“Your subservice provider is carved out, so the report proves nothing about them.”
It proves something different, and the distinction matters. Under the carve-out method the subservice organisation’s controls are excluded from the description, and the report instead evidences the controls you operate to monitor them: obtaining and reviewing their SOC 2 report, tracking its exceptions, and implementing the complementary user entity controls it specifies. Ask for that monitoring evidence and for their report directly. The alternative — the inclusive method — puts their controls inside your description, which requires their cooperation and their assertion.
Operating model
Continuous capture beats the scramble
The end-of-period scramble has a calendar, and for the sixty-person company it looked like this: period closed 30 September 2026, request list issued 12 October, populations due 19 October, the auditor’s selections returned 26 October, fieldwork 2–13 November. That gives a small team seven days to produce twelve months of populations, and a further week to locate the specific items selected from them — while also running the business. It produces exactly the evidence described above as weak.
A missing March artefact discovered in April can often still be recovered — the source log has not yet rolled off. The same gap discovered in October cannot be recovered at all, and a control that did not operate in March deviated in March either way.
That asymmetry is the whole argument. The continuous model is four commitments: every control has a named owner and a defined artefact, confirmed against the CPA firm’s expected request list before the period starts; every artefact has a capture cadence matched to its frequency; every population is reconciled to its source before it leaves the building; and everything lands in one repository with retention past period end plus six months. The register above is what those four commitments look like written down.
Tranquility Cybersecurity does the readiness half: mapping controls to artefacts, building the evidence register, testing populations for completeness before the CPA firm sees them, and coordinating the examination with independent licensed CPA firms for clients in India, USA, UK, Australia and UAE. The opinion always comes from the CPA firm — we never certify, attest or sign. Readiness starts at a fixed fee from $4,000 for early-stage startups, quoted after scoping. The CPA firm’s attestation fee is separate and billed by the firm.
SOC 2 Evidence — Common Questions
What auditors accept, what they send back, and why.
What counts as acceptable SOC 2 evidence?
Evidence is acceptable when it is attributable, complete, timely and produced by a reliable source. Attributable means the artefact shows who or what performed the control, where, and when. Complete means it covers the whole population it claims to. Timely means it was captured while the control operated, inside the period. Reliable is a ranking: a system export outranks a screenshot, which outranks a spreadsheet.
Are screenshots acceptable evidence for SOC 2?
Yes, within two limits. A screenshot evidences one moment in one environment, so it cannot carry a control that must operate across twelve months unless you capture a dated series. And it must be defensible: system clock in frame, logged-in user visible, full URL, uncropped, with any filter shown beside the result. Where a system has no export, auditors accept a defensible screenshot routinely. For a Type 1, which opines on design at a date, a screenshot is often exactly the right artefact.
Why did the auditor reject our spreadsheet?
Because it is information produced by the entity carrying nothing that establishes its own completeness. AT-C 205 requires the practitioner to evaluate whether information you produced is sufficiently reliable, including obtaining evidence about its accuracy and completeness. A hand-typed list offers none, so the compilation gets tested before the control can be. Resubmit the raw export with four things: the source system and exact query or report name, the filter and date range applied, the run date and the user who ran it, and a record count that reconciles to the count shown in the source console. Do not open the file and re-save it — a modified timestamp after the run date invites a question you cannot answer.
What is IPE in a SOC 2 audit?
IPE is information produced by the entity — any report, listing or export you generate that the auditor then relies on. Most evidence falls into it: population lists used to draw samples, access listings, exception reports, reconciliations and system-generated reports. Because the auditor relies on something you made, the standards require them to establish its accuracy and completeness before using it.
How many samples will the auditor take?
It depends on control frequency, population size and assessed risk, and is professional judgement — no AICPA table fixes sample sizes. AT-C 205 governs sample design; its application material points to the AICPA Audit Guide Audit Sampling. As market practice, at zero expected deviations: an annual control tested in full, a quarterly control at 2 of 4, a monthly control at 2 of 12, a weekly control at 5 to 9 of 52, and a daily control at 25 of roughly 250 business days. One deviation typically extends those to all 4, to 4–5, to 12–15, and to 40. That extension is the real cost of a missed month: it enlarges every remaining selection, not only the one that failed.
How long do we need to keep SOC 2 evidence?
Long enough to survive from the day the control operated to the day the auditor tests it — the period, plus the gap to fieldwork, plus the firm’s review before release. Period end plus six months is a practical floor; thirteen months is what we most often recommend. The attestation standards impose file assembly and retention on the CPA firm, not on you, which is why nobody owns this and why a ninety-day log setting survives several audits before it costs someone a Type 2.
Can we use our compliance automation tool as our only evidence?
Partly. These platforms produce strong evidence, and their scheduled captures solve timeliness better than manual routines. What they do not solve is their own completeness: the auditor must establish that the integration sees every in-scope account, host and repository, and will reconcile the tool’s inventory against source systems. Expect to supply source exports alongside the tool for the access, change and infrastructure populations.
What does a SOC 2 auditor request list look like?
In practice it arrives two to six weeks before fieldwork — nothing fixes that timing — organised by control domain: governance, HR, logical access, change management, operations, vendor management, resilience. Each line carries a reference, the request, the period it covers, an owner, a due date and a status. It comes in waves: full populations first, then the auditor’s selections drawn from them, then open items raised during fieldwork.
What happens if evidence for one month is missing?
It is investigated, not automatically fatal, and the sequence is predictable. The auditor cannot apply the designed procedure or a suitable alternative to that item, so it is treated as a deviation. Nature and cause are investigated — a control that did not operate, or one that operated and left no surviving record? The practitioner then considers extending the sample, which for a monthly control usually means moving from 2 selections to 4 or 5. Only then does the question arise of whether it becomes a reported exception in Section 4, and separately whether the opinion is modified. Disclose the gap early, evidence any detective control covering that month, and never date a document backwards.
Related reading: sampling and sample sizes, choosing your observation period, the SOC 2 controls list, opinions and exceptions, common pitfalls, scope and system boundary, and the SOC 2 hub.
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How populations are defined, why completeness is tested first, and how one deviation is evaluated.
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Why SOC 2 fails in the last four weeks, and designing controls that generate their own evidence.
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No official list exists — illustrative controls by criteria series (CC1–CC9).
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The controls that fall between teams and get dropped — offboarding, vendor reviews, orphaned access reviews.
Read moreSOC 2 Knowledge Hub
Type 1 vs Type 2, criteria, timelines and audit prep — all guides.
Read moreSOC 2 Audit Preparation
Evidence, readiness checks and what the CPA firm will sample.
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