What Counts as SOC 2 Evidence for CC7.1?

If you’re preparing for a SOC 2 audit, you already know that CC7.1 is a critical requirement under the System Operations section of the Trust Services Criteria. Specifically, CC7.1 requires your organization to demonstrate that your system controls are effective in detecting, responding to, and mitigating security threats. While SOC 2 offers flexibility in how you achieve compliance, penetration testing stands out as one of the most widely accepted and impactful forms of evidence you can provide for auditors.
Here’s what compliance managers, CTOs, and technical stakeholders need to know about demonstrating SOC 2 CC7.1 compliance through penetration testing.
Do I Have to Do a Pentest for CC7.1?
Technically speaking, SOC 2 does not explicitly mandate a penetration test as the only method of meeting CC7.1. However, in practice, auditors consistently expect clear and credible evidence that security controls have been tested rigorously.
While automated vulnerability scans can provide basic security coverage, manual penetration testing provides significantly stronger evidence. A penetration test performed by qualified professionals shows auditors that your organization has proactively validated security controls against realistic threats.
What Auditors Expect to See as Evidence for CC7.1
Auditors and compliance reviewers aren’t simply checking boxes—they want clear, verifiable evidence. When evaluating your SOC 2 audit evidence, auditors specifically look for several elements:
First, auditors expect that testing was performed by an independent, qualified penetration testing firm. Testing performed by your internal security or engineering team may be helpful for ongoing assurance, but it typically isn’t sufficient as formal SOC 2 audit evidence.
They’ll also want to see that the test was recent — typically within the last 12 months and aligned with your audit period. Old reports lose relevance quickly, especially given how fast new vulnerabilities and exploits emerge.
Reports that include only scanner output or automated findings tend to raise red flags. Manual testing provides deeper insight, especially for things like complex logic flaws or chained attack paths that automated tools often miss. Auditors trust validated, human-driven findings.
Risk ratings also matter — not just generic equations, but real-world context. Asteros uses the OWASP Risk Rating Methodology to help communicate how each issue applies to your application and environment, not just how severe it might be in the abstract.
Mapping to the Trust Services Criteria — especially CC7.1 — is another critical element. A good report should call out exactly how and where your controls were evaluated, so auditors don’t have to guess or piece it together.
And finally, auditors want to see actionable remediation guidance. A good report doesn’t just identify vulnerabilities — it gives your team the context and direction needed to resolve them efficiently. That helps you stay within your defined SLA for vulnerability resolution, which is exactly what auditors want to see: not just awareness of risk, but timely, documented efforts to reduce it. That’s part of demonstrating control effectiveness, which is what CC7.1 is really about.
At Asteros, our penetration testing reports explicitly address all these requirements, providing comprehensive, auditor-friendly evidence.
What’s in the Asteros Report for CC7.1?
Asteros penetration tests specifically designed for SOC 2 CC7.1 compliance deliver clear and comprehensive reporting:
Every report begins with an executive summary tailored to stakeholders and auditors. We clearly outline the high-level risks and their potential business impacts, making compliance conversations straightforward.
Our reports provide contextual risk ratings based on the OWASP Risk Rating Methodology. Instead of just numeric scores, we clearly explain the likelihood and impact of each issue in your specific context.
Detailed, prioritized remediation guidance ensures your developers understand exactly what to fix and why. This isn’t generic advice—it’s actionable guidance tailored to your application or infrastructure.
We manually validate every finding. This guarantees accuracy, eliminates time-wasting false positives, and gives auditors clear confidence in the results.
All reports include retesting of resolved vulnerabilities at no additional cost, along with updated documentation to reflect remediation status clearly.
For web applications and APIs, our testing aligns with the OWASP Application Security Verification Standard (ASVS), which provides thorough and structured coverage far beyond simple OWASP Top 10 testing.
How Long Does It Take?
Asteros typically completes SOC 2 penetration testing engagements in about two weeks. Our structure involves one week of intensive testing, followed by a week dedicated to detailed reporting and peer review.
If you’re dealing with a smaller scope (for example, just one web application), the turnaround can be even quicker. While we pride ourselves on speed, we never cut corners. Our standards-based penetration testing methodology ensures consistent, rigorous assessments.
Usually, we can start your project quickly. However, if you anticipate an urgent compliance deadline, it’s best to reach out early. If you’re already under pressure, take a look at our guide on Emergency Penetration Testing.
What You’ll Need to Provide
To streamline the process and start quickly, consider gathering the following information ahead of our initial discussion:
- Point of Contact and Deadline: Identify who will be our main contact and when you need your report delivered.
- Target Scope: Specify domains, IP ranges, or apps that require testing.
- Credentials/Test Accounts: Provide any necessary credentials or test users to allow thorough testing, if applicable.
- Known Security Controls: Inform us about specific controls or architecture nuances that could impact testing.
- Compliance Goal: Confirm that your primary goal is SOC 2, ISO 27001, PCI, or another standard to help us align findings accordingly.
- Preferred Report Format: Let us know if your auditor or vendor requests a particular reporting style or format.
Common Pitfalls to Avoid
When preparing SOC 2 CC7.1 audit evidence, we often see three common pitfalls:
First, submitting an automated vulnerability scanner dump without manual validation severely weakens your compliance argument. Auditors can spot shallow, automated-only reports quickly and will likely push back for manual evidence.
Second, reports that highlight vulnerabilities but lack clear remediation plans frustrate auditors. Every finding should have actionable, prioritized guidance.
Lastly, don’t wait too long to schedule testing. Engaging a penetration testing firm late in your audit window can cause scheduling conflicts and unneeded stress.
Why Asteros?
Asteros offers clear, structured reports specifically designed for compliance stakeholders and auditors. Every penetration test we conduct is manually validated by experienced security professionals—never outsourced or delegated to junior testers.
Our commitment to quality includes retesting remediated issues and updating your report at no extra cost. We’ve successfully guided startups and global enterprises alike through SOC 2 CC7.1 compliance.
Our detailed approach, particularly leveraging OWASP ASVS for web applications, means our findings deliver deep, comprehensive validation. Clients appreciate our ability to translate technical security testing into clear, compliance-ready evidence.
Need Audit-Ready Evidence for SOC 2 CC7.1 Fast?
Asteros delivers standards-based penetration testing reports tailored specifically to SOC 2 CC7.1 compliance requirements. Our reports are thorough, clear, and audit-ready—exactly what auditors expect. Reach out today, and we’ll respond promptly, usually within one business day.
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