As AI becomes embedded in business operations, SOC 2 auditors are increasingly asking questions about how organizations govern AI systems. If AI touches your service delivery, expect it to be in audit scope.
AI in SOC 2 Scope
SOC 2 focuses on controls relevant to security, availability, processing integrity, confidentiality, and privacy. AI systems that process customer data, make decisions affecting service delivery, or access sensitive information fall within these criteria.
Auditors will ask: What AI systems do you use? What data do they process? How are they governed? The days of treating AI as a black box that exists outside normal IT controls are ending.
Security Controls for AI
- Access Management: Who can access AI systems? Who can modify prompts, fine-tune models, or change configurations? Role-based access should limit AI administration to authorized personnel.
- Data Protection: How is data protected when processed by AI? If using external AI APIs, what agreements are in place? For private deployments, how are model weights and training data secured?
- Logging and Monitoring: Can you demonstrate what your AI systems have done? Audit logs should capture interactions, and monitoring should detect anomalous behavior.
- Vulnerability Management: AI infrastructure requires patching and updates like any other system. Model updates should go through change management.
Processing Integrity for AI
This is where AI gets interesting for auditors. Processing integrity means system processing is complete, valid, accurate, and timely. For AI systems, this raises questions about accuracy, bias, and reliability.
- Validation: How do you verify AI outputs are accurate? What testing has been performed?
- Error Handling: How does the system handle AI failures or uncertain outputs?
- Human Oversight: For consequential decisions, is there human review?
- Documentation: Can you explain how the AI makes decisions at a level appropriate for the use case?
Confidentiality and Privacy
If AI processes confidential or personal data, auditors will scrutinize data handling.
For public AI APIs, demonstrate that appropriate agreements are in place, that data is encrypted in transit, and that provider commitments around data handling are documented. For private deployments, show that data remains within controlled boundaries.
Privacy considerations include: Is personal data used for AI training? How long is data retained? Can individuals request deletion? AI systems should fit within your broader privacy program.
Documentation Auditors Expect
- AI inventory listing systems, their purposes, and data processed
- Risk assessment covering AI-specific risks
- Policies for AI governance, acceptable use, and change management
- Evidence of testing, validation, and ongoing monitoring
- Vendor assessments for third-party AI services
- Incident response procedures that include AI-related scenarios
Preparing for AI-Inclusive Audits
Start by inventorying your AI usage. Many organizations have more AI touchpoints than they realize, from obvious chatbots to less visible automation in business processes.
Extend existing controls to cover AI. Access management, change control, logging, and monitoring frameworks should apply to AI systems. Do not treat AI as a separate category that exists outside normal governance.
We help organizations prepare AI systems for SOC 2 audits, from gap assessments to control implementation. Contact us if you are preparing for an audit that will include AI in scope.