How to Maintain SOC 2 Compliance Year-Round (+ Monitoring Checklist)
TL;DR
SOC 2 audits are typically conducted annually, with reports considered valid for 12 months. But passing the audit is the easy part — maintaining compliance between audits is where most organizations struggle. The AICPA's Trust Service Criteria explicitly require monitoring activities (COSO Principles 16-17), meaning your organization must independently verify that controls are working, not just assume they are. A practical year-round approach breaks this into weekly evidence checks, monthly access reviews, and quarterly internal assessments — supported by automated evidence collection and daily compliance guidance that keeps you audit-ready without the last-minute scramble.
Key Concept: SOC 2 continuous compliance — maintaining controls and evidence between annual audits
Reading Time: 12 minutes
Difficulty: Intermediate
Relevant for: Compliance officers, CTOs, founders with existing SOC 2 reports, security teams managing ongoing compliance
The Gap Between Passing and Staying Compliant
A SOC 2 audit captures how your company's controls were designed and operated during a specific period. Once the report is issued, the work isn't finished. Customers, investors, and partners expect those same practices to remain consistent throughout the year — and your next auditor will examine whether they did.
This is where most organizations stumble. They invest heavily in their first SOC 2 audit, celebrate passing, then gradually let practices drift. Access reviews get delayed. Policy acknowledgments lapse. Evidence collection becomes sporadic. By the time the next audit cycle approaches, the team is scrambling to reconstruct months of missing documentation.
The real challenge of SOC 2 is not passing the audit. It's maintaining compliance day after day, month after month, in between audits. That's what this guide addresses.
How Often Should SOC 2 Audits Be Conducted?
The answer depends on the type of report you hold and what your customers require.
SOC 2 Type I is a point-in-time snapshot that evaluates whether your controls are properly designed at a specific date. It's useful for early-stage companies proving they have a security framework in place, but most customers treat it as a stepping stone. There's no fixed renewal cadence — once you have a Type I, the expectation is that you'll progress to Type II. For a detailed comparison, see our Type I vs Type II guide.
SOC 2 Type II evaluates whether controls actually operated effectively over a review period of six to twelve months. This is the format procurement teams and enterprise customers require, and it needs to be renewed annually. Most organizations conduct Type II audits on a twelve-month cycle, aligning each new audit period to start immediately after the previous one ends — ensuring there are no gaps in coverage.
For most organizations, the rhythm is straightforward: one external SOC 2 Type II audit per year. That annual cycle keeps reports current and meets what vendor assessment questionnaires expect. Some organizations layer additional checkpoints on top: quarterly internal reviews to verify control consistency, and semi-annual readiness checks before major client renewals or fundraising rounds.
How Long Is a SOC 2 Report Valid?
There is no formal expiration date stamped on a SOC 2 report. In practice, however, reports are treated as valid for twelve months after the end of the audit period — not twelve months from the date the report was issued.
This distinction matters. If your audit covered January through December 2025 but your auditor didn't issue the report until March 2026, customers still expect a new report covering 2026 by early 2027. The clock runs from the audit period, not the issuance date.
Certain events can shorten this effective validity. A major system migration, acquisition, organizational restructuring, or significant security incident may prompt customers to request an updated report even if the current one is less than a year old. Enterprise procurement teams are increasingly sophisticated about this — they don't just check whether you have a report, they check whether the report reflects your current operating environment.
SOC 2 bridge letters
When there's a gap between the end of one audit period and the start of the next report, organizations sometimes issue a bridge letter (also called a gap letter). This is a management assertion — signed by your leadership — stating that no material changes have occurred to your control environment since the last audit period ended. Bridge letters aren't a substitute for a new audit, but they can satisfy customer requirements during transitional periods. Your auditor can advise whether a bridge letter is appropriate for your situation.
Why Continuous Monitoring Is a SOC 2 Requirement (Not Optional)
Many organizations treat monitoring as a nice-to-have — something responsible teams do but not something auditors specifically examine. That's wrong. The AICPA's Trust Service Criteria explicitly require monitoring activities as part of SOC 2's common criteria.
These requirements originate from the COSO Internal Control Framework, specifically Principles 16 and 17. Principle 16 requires that your organization "selects, develops, and performs ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning." Principle 17 requires that you "evaluate and communicate internal control deficiencies in a timely manner to those parties responsible for taking corrective action."
In practical terms, this means your organization must independently verify that controls are working — not just assume they are because they worked during the last audit. If your access control policy says you review user permissions quarterly, your auditor will look for evidence of four quarterly reviews during the audit period. If your change management process requires approval before deployment, the auditor will sample deployment records to verify approvals exist. Missing monitoring evidence is a leading cause of audit exceptions.
The monitoring requirement also includes a segregation principle: the person monitoring a control should not be the same person performing the control. Your software engineer shouldn't be the one reviewing whether change management was followed — there's an inherent conflict of interest. Build monitoring assignments that create accountability without self-review.
The Year-Round Compliance Checklist
Treating SOC 2 maintenance as an annual project guarantees stress. Breaking it into smaller, recurring tasks makes it manageable and keeps evidence flowing continuously. Here's a practical cadence that covers what auditors expect to see.
Weekly activities
Evidence spot-checks. Verify that automated evidence collection is functioning correctly. Are access logs being captured? Are deployment records flowing into your compliance platform? A quick weekly check catches integration failures before they create months-long evidence gaps. With automated evidence collection connected to your infrastructure, this becomes a five-minute verification rather than a manual collection exercise.
Incident review. Check whether any security events from the past week require formal incident documentation. Not every alert becomes an incident, but the triage decision itself should be documented. Your incident management process should capture both the events that escalated and the rationale for events that didn't.
Monthly activities
Access reviews. Verify that user access across critical systems matches current roles. Check for terminated employees who still have active accounts, contractors whose engagements have ended, and privilege creep where users have accumulated permissions beyond their current role. Document every review — even when no changes are needed — because the auditor needs to see that the review happened.
Policy acknowledgment tracking. Check whether any employees have outstanding policy acknowledgments, particularly new hires who joined in the past month. Your policy management process should track who has and hasn't acknowledged current policies, with escalation for overdue acknowledgments.
Vendor security monitoring. Review any security notifications or status changes from critical vendors. If a vendor experienced a breach or changed their security posture, document your assessment of the impact and any actions taken. This supports vendor risk management requirements.
Quarterly activities
Internal control assessment. Conduct a focused review of a subset of your controls each quarter, rotating so that all controls are assessed at least once during the year. Test whether controls are operating as documented — not just whether they exist. Sample actual evidence: pull five recent access requests and verify the approval chain, review ten change management tickets for proper documentation, check that backup restoration was tested.
Risk register review. Reassess your risk register for changes. Have new risks emerged? Have existing risks changed in likelihood or impact? Have treatment plans been executed? The risk register should be a living document that reflects your current risk landscape, not a snapshot from when you first created it.
Policy review cycle. Identify any policies due for review this quarter. Check whether regulatory changes, organizational changes, or incidents require policy updates. Document the review outcome even if no changes are made — "reviewed, no changes required" is valid evidence that the review occurred.
Training and awareness. Conduct or verify completion of security awareness activities. This might be formal training modules, phishing simulations, or topic-specific briefings. Track completion rates and follow up on non-compliance.
Annual activities
Pre-audit readiness assessment. Before your external audit begins, conduct a comprehensive readiness assessment that mirrors what your auditor will examine. Review every control for evidence completeness, test a sample of controls for operating effectiveness, and identify any gaps that need remediation before the audit period closes.
Scope review. Evaluate whether your SOC 2 scope still accurately reflects your operations. Have you added new systems, changed cloud providers, acquired a company, or entered new markets? Scope changes affect which controls are relevant and may require new controls to be implemented.
Auditor coordination. Align with your auditor on timing, scope, and expectations for the upcoming audit period. Discuss any changes to your environment and confirm the audit window. Early coordination prevents surprises on both sides.
The Compliance Drift Problem
Even with good intentions, organizations experience compliance drift — the gradual degradation of compliance practices between audits. It starts small. An access review gets postponed because the team is busy shipping a feature. A policy acknowledgment reminder gets snoozed. An incident report gets triaged verbally but never documented.
Individually, each missed task seems minor. Collectively, they compound into a pattern that auditors recognize immediately: the organization treats compliance as a project with a deadline rather than an operational practice. When your auditor samples ten access review records and finds three missing, that's not three minor gaps — that's a systemic finding about your monitoring program.
Compliance drift is also expensive to fix retroactively. Reconstructing evidence months after the fact is unreliable and time-consuming. You can't meaningfully recreate an access review that didn't happen. You can't backdate a policy acknowledgment. The only sustainable approach is preventing drift through consistent, manageable routines rather than heroic catch-up efforts before each audit.
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Building Compliance into Daily Operations
The organizations that maintain SOC 2 compliance without stress share a common pattern: they've embedded compliance into their existing workflows rather than running it as a separate program.
Shared ownership across teams
SOC 2 compliance isn't a security team responsibility alone. HR owns onboarding and offboarding controls. Engineering owns change management and deployment controls. IT owns access provisioning and infrastructure monitoring. Operations owns business continuity testing. When every team understands which controls they own and what evidence they need to produce, compliance becomes distributed rather than bottlenecked.
The compliance function's role shifts from doing the work to orchestrating and verifying it — ensuring that every team's compliance activities actually happen on schedule and produce usable evidence.
Automated evidence collection
Manual evidence collection is the primary cause of compliance drift. When someone has to remember to take a screenshot, export a log, or save a report, it doesn't happen consistently. Automated evidence collection from your infrastructure — AWS, GCP, GitHub, Cloudflare, and other platforms — eliminates this failure mode. Evidence flows into your compliance platform automatically, timestamped and traceable, without anyone needing to remember.
The shift from manual to automated collection doesn't just improve consistency — it fundamentally changes the evidence quality. Automated evidence is contemporaneous (captured when the event happened), complete (no gaps from missed collection dates), and tamper-evident (generated by the source system, not reconstructed later).
Daily compliance guidance
One of the hardest aspects of year-round compliance is knowing what to focus on today. With dozens of controls, multiple review cycles, and evidence requirements spanning the entire organization, it's easy to lose track of what's urgent versus what can wait.
This is exactly the problem Humadroid's Compliance Daily solves. Instead of a traditional dashboard that shows you status percentages and leaves you to figure out priorities, the Compliance Daily tells you what to work on today. It uses themed focus days, urgency-based prioritization, and velocity tracking to surface the most important compliance tasks each day — transforming year-round maintenance from an overwhelming obligation into a manageable daily routine. When your compliance platform actively guides your daily work instead of passively reporting status, maintaining continuous compliance stops being a discipline problem and becomes a workflow.
Audit Frequency by Company Stage
The right monitoring intensity depends on your organization's size, complexity, and customer expectations.
Early-stage startups (under 50 employees) typically rely on one Type II audit per year combined with lightweight monthly and quarterly reviews. The focus is on establishing consistent habits before scaling them. At this stage, the founder or CTO often serves as the compliance coordinator, making Compliance Daily-style guidance particularly valuable for staying on track without a dedicated compliance hire.
Scaling companies serving enterprise customers maintain the annual external audit but add more rigorous quarterly internal assessments, often with formal assessment reports. As the customer base grows and contract requirements become more specific, the cost of compliance drift increases because individual customers may request evidence of specific controls mid-year.
Enterprises with multiple products or business units typically run monthly or quarterly internal audits across departments, with a dedicated compliance or internal audit team. The annual external audit is the baseline, but continuous monitoring is genuinely continuous — often with real-time dashboards and automated alerting on control deviations.
Regardless of stage, the principle is the same: the annual external audit is a verification event, not a compliance program. The program is everything you do between audits.
What Auditors Actually Look For
Understanding your auditor's perspective helps you maintain the right evidence throughout the year. Type II auditors don't just check that controls exist — they test whether controls operated effectively during the entire audit period. This means they're sampling evidence from throughout the year, not just from the weeks before the audit.
Auditors pay particular attention to consistency. If your policy says you review access quarterly, they'll look for four reviews, evenly spaced, with documented results. If your change management process requires approval before deployment, they'll sample deployments from different months to verify the pattern holds. Sporadic evidence — three reviews in December and none the rest of the year — signals the exact compliance drift pattern that undermines Type II reports.
Common areas where organizations get tripped up include access reviews that were performed but not documented, incidents that were handled but not formally logged, policy updates that were made but acknowledgments weren't re-collected, and vendor assessments that were completed informally but lack written records. The theme is consistent: the work happened, but the evidence doesn't prove it.
Your control points should be specific enough that the required evidence is obvious. When a control is vague, the evidence requirement is ambiguous, and ambiguity creates gaps.
Additional Resources
SOC 2 Continuous Monitoring of Controls — Deep dive into monitoring activities and implementation
What Is SOC 2 Compliance? — Foundational guide for founders starting the SOC 2 journey
Steps to Achieve SOC 2 Compliance — The 8-step process from scope to certification
SOC 2 Type I vs Type II for SMBs — Decision framework for choosing your report type
Your Compliance Daily — How daily compliance guidance replaces dashboard fatigue
Ready to Streamline Your Compliance?
Discover how Humadroid can simplify your compliance management process.
February 2026 update: This guide has been substantially expanded with AICPA monitoring requirements (COSO Principles 16-17), a practical year-round compliance checklist broken into weekly, monthly, quarterly, and annual activities, compliance drift prevention strategies, auditor expectations for evidence consistency, and references to automated evidence collection and daily compliance guidance features.
Frequently Asked Questions
SOC 2 Type II audits are typically conducted annually, covering a review period of six to twelve months. Most organizations align each new audit period to start immediately after the previous one ends, ensuring continuous coverage with no gaps. While there's no regulatory mandate specifying exact frequency, annual audits are the industry standard because SOC 2 reports are generally treated as valid for 12 months after the audit period ends. Some companies add quarterly internal reviews and semi-annual readiness checks between external audits, particularly before major client renewals or fundraising rounds.
A SOC 2 report is generally considered valid for 12 months after the end of the audit period — not 12 months from when the report was issued. For example, if your audit covered January through December 2025 but the report was issued in March 2026, customers still expect a new report covering 2026 by early 2027. There is no formal expiration date stamped on the report, but major changes like system migrations, acquisitions, or significant security incidents may prompt customers to request an updated report before the 12-month mark.
Continuous monitoring plays a critical role in SOC 2 because the AICPA's Trust Service Criteria explicitly require it — it's not optional. Based on COSO Principles 16 and 17, your organization must independently verify that controls are present and functioning through ongoing evaluations, and communicate any deficiencies to responsible parties in a timely manner. In practical terms, this means regularly testing controls, sampling evidence, and documenting results throughout the year. Auditors will look for evidence of consistent monitoring during the entire audit period, not just activity in the weeks before the audit.
Maintaining SOC 2 compliance between audits requires a structured cadence of activities: weekly evidence spot-checks to verify automated collection is working, monthly access reviews and policy acknowledgment tracking, quarterly internal control assessments with evidence sampling and risk register updates, and annual pre-audit readiness assessments and scope reviews. The key principle is that compliance work should be distributed throughout the year rather than concentrated before the audit. Automated evidence collection from your infrastructure eliminates the most common failure mode — manual evidence gathering that gets forgotten during busy periods.
A SOC 2 bridge letter (also called a gap letter) is a management assertion signed by your organization's leadership stating that no material changes have occurred to your control environment since the last audit period ended. Bridge letters are used when there's a coverage gap between the end of one audit period and the issuance of the next report. They're not a substitute for a new audit, but they can satisfy customer requirements during transitional periods. Your auditor can advise whether a bridge letter is appropriate for your specific situation.
Compliance drift is the gradual degradation of compliance practices between audits. It starts small — a delayed access review, a skipped policy acknowledgment, an undocumented incident triage — and compounds into systemic gaps that auditors catch through evidence sampling. To prevent it, break compliance maintenance into manageable recurring tasks (weekly, monthly, quarterly) rather than treating it as an annual project. Automated evidence collection eliminates the most common drift cause (manual evidence gathering), while daily compliance guidance tools keep tasks visible and prioritized so nothing falls through the cracks.
SOC 2 Type II auditors sample evidence from throughout the entire audit period to verify controls operated consistently — not just at the time of the audit. They pay particular attention to: evidence consistency (quarterly reviews that actually happened quarterly, not four reviews crammed into December), documentation completeness (access reviews that were performed AND documented, not just performed), policy-practice alignment (whether what you do matches what your policies say), and monitoring segregation (that the person verifying a control isn't the same person performing it). The most common findings involve work that was done but not properly documented as evidence.