Glossary · SOC and attestation

AT-C 320 is the rulebook a CPA firm follows when it writes a SOC 1.

The AICPA attestation section that governs a SOC 1 examination of a service organization's controls relevant to its clients' financial reporting.

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01 · In plain words

In plain words

The AICPA attestation section that governs a SOC 1 examination of a service organization's controls relevant to its clients' financial reporting.

The AICPA groups its attestation rules into numbered sections. AT-C 320 is the one written for a single job: examining a service provider whose work feeds its clients' financial statements. When a CPA firm issues a SOC 1 report, this is the section it follows.

Spelled out: AT-C Section 320, Reporting on an Examination of Controls at a Service Organization Relevant to User Entities' Internal Control Over Financial Reporting.

02 · Why it matters

Why it matters

Who cares about this, and what depends on it.

The section decides what kind of report you get. Because AT-C 320 is about financial reporting, the report is built on control objectives that management writes, and its intended readers are your clients and their financial auditors. A SOC 2 runs under a different route, the general examination section AT-C 205 with the Trust Services Criteria, and serves a wider readership interested in security. Picking the wrong one is an expensive mistake: a payroll bureau with a SOC 2 may still be asked for a SOC 1 by a client's auditor, because only the AT-C 320 report addresses what that auditor needs to rely on.

03 · Where you meet it

Where you will meet it

The documents, meetings and reports where it appears.

The opinion paragraph of a SOC 1
The service auditor states the examination was conducted under the attestation standards established by the AICPA; the engagement letter names AT-C 320 directly.
A client's audit planning memo
The user auditor records whether a SOC 1 is available and which period it covers.
Scoping workshops
Where you decide which processes touch client ledgers and so belong in an AT-C 320 examination.
Requests for proposal
Finance-heavy buyers sometimes name the standard rather than the report.

04 · An example

A worked example

An illustration, not a real client.

Illustrative: a Pune payroll bureau serving a US subsidiary

A payroll bureau in Pune runs salary calculations for the Indian arm of a US-listed group. The group's external auditor asks for a report under AT-C 320. The bureau's sales team offers its ISO 27001 certificate, which the auditor cannot use for this purpose. The bureau then scopes a SOC 1 around pay calculation, statutory deductions and bank file transfer, writes control objectives for each, and engages a CPA firm to examine them under AT-C 320.

05 · Easy to mix up

Easy to mix up with

Neighbouring terms that mean something different.

AT-C 205
The general section for examination engagements. SOC 2 work runs under it, with the Trust Services Criteria. AT-C 320 is the specialised section for controls relevant to clients' financial reporting.
SSAE 18
The statement that codified the attestation standards, including AT-C 320. SSAE 18 is the book; AT-C 320 is one chapter in it.

06 · What to do

What to do with it

Practical steps, and the guides that go deeper.

  • List which of your services change a number in a client's books; those are the candidates for an AT-C 320 scope.
  • Ask a client's finance team whether their auditor needs a SOC 1 before you commit to a SOC 2.
  • Draft control objectives early, since AT-C 320 expects management to define them.

Sources: AICPA SSAE 18; AT-C section 320; AT-C section 205; AICPA guide on SOC 1 reporting; AICPA SOC suite descriptions.

Questions about AT-C Section 320

Does AT-C 320 apply to SOC 2 reports?

No.

SOC 2 examinations are performed under AT-C 205 together with the AICPA's SOC 2 guide and the Trust Services Criteria. AT-C 320 is reserved for controls relevant to user entities' internal control over financial reporting, which is the SOC 1 space.

Does AT-C 320 allow both Type 1 and Type 2 reports?

Yes.

A Type 1 covers the fairness of the description and the suitability of design at a point in time. A Type 2 adds the operating effectiveness of controls over a period. Most user auditors prefer a Type 2 because it shows the controls actually ran.

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