SOC 2 audits are serious business. Penetration testing is the one requirement that causes more confusion and delays than almost any other if you’re in the middle of preparing for one, or worse, trying to pass after failing the first round.
Here’s the catch: just because you ran a vulnerability scan doesn’t mean you’ve completed a penetration test that satisfies your auditor.
What SOC 2 Actually Says About Pen Testing
Letâs set the record straight. SOC 2, particularly under the Common Criteria (CC6 and CC7), expects organizations to demonstrate:
- Active identification of vulnerabilities
- Simulation of real-world attack scenarios
- Evidence that remediation processes are in place and effective
Although it isn’t always stated clearly, auditors generally expect penetration testing. Pen testing is one of the most obvious signs that your environment is being proactively secured, especially for Type II reports, which evaluate the continuous efficacy of controls over time.
What Doesn’t Count as a Penetration Test
SOC 2 auditors are increasingly rejecting the following:
- Automated vulnerability scans (Nessus, Qualys, etc.)
- Internal scans without third-party validation
- Reports with no evidence of exploitation or chaining vulnerabilities
In short, if there’s no manual effort or analyst-led testing, itâs not going to pass muster.
What Does Count (And What Auditors Look For)
To be clear: auditors aren’t looking for a 200-page PDF full of jargon. They want evidence of risk-based testing and remediation. That includes:
- Testing conducted by an independent security team (internal or third-party)
- Manual testing methods to exploit vulnerabilities and simulate real-world attackers
- A documented scope tied to in-scope systems
- Clear findings, risk ratings, and remediation tracking
A successful SOC 2 penetration test includes pertinent systems and APIs, complies with Trust Service Criteria, and generates a report that can be used right away.
Common Mistakes That Can Derail Your SOC 2
Even well-meaning teams fall into these traps:
- Submitting a scan thinking it’s a pen test
- Testing only external assets, ignoring APIs or internal systems
- Not retesting after remediation (missing the audit window)
- Using outdated tests (older than 12 months)
Each of these can result in delays, qualified opinions, or worseânon-compliance.
How Bluefire Redteam Does SOC 2 Penetration Testing Right
At Bluefire Redteam, we specialize in pen testing built for complianceâwithout compromising on real-world depth:
- Human-led testing based on adversary simulation, not only automation
- Full-scope coverage of in-scope assets, APIs, and integrations
- Audit-ready reporting mapped directly to SOC 2 controls
- Remediation support to help you patch and pass with confidence
When you work with Bluefire, you’re not just checking a boxâyouâre proving your security posture to your customers and auditors alike.
Need a Pen Test That Passes SOC 2?
Letâs talk. Book your free SOC 2 readiness consult to see how we help companies like yours meet audit expectations and improve their security.
Frequently Asked Questions (FAQ) - SOC 2 Pen Test
- Is penetration testing mandatory for SOC 2?
It's not explicitly required, but auditors expect itâespecially for Type II auditsâto validate your security controls in practice.
- Can vulnerability scans fulfill the SOC 2 pen test requirement?No. SOC 2 expects evidence of manual, risk-based testing that mimics real-world attacksânot just automated scans.
- How recent does my pen test need to be for a SOC 2 audit?
Ideally, within 12 months and scoped to in-scope systems. Retesting after remediation is also crucial.
- Who should conduct the penetration test for SOC 2?
An independent teamâeither a qualified internal group or a third-party provider like Bluefire Redteam.
- What should a SOC 2-ready penetration test report include?
Scope, methodology, findings with risk ratings, remediation recommendations, and evidence of testing effort.
