Between two reports

SOC 2 bridge letters, written so they hold up.

A Type 2 report tests a fixed window that ends on a fixed date. Buyers read it later, sometimes much later. A bridge letter is how management speaks to the months in between. It is useful, it is common, and it carries no auditor's assurance at all. This page covers what to put in one, what to keep out, and when it stops being enough.

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01 · The gap

Why the gap exists at all

The opinion stops at the period end date. Your customer's question doesn't.

A Type 2 opinion speaks to a defined observation period, say an illustrative 1 April to 31 March. The CPA firm then needs time to finish testing, write the report and issue it. By the time a buyer opens the PDF, the period may have ended weeks or months ago, and nothing in the report speaks to those weeks.

Where the letter sitsThe report covers its period. The letter covers the stretch from the period end to the date on the letter, in management's words only.

If your periods abut, the gap is always closed in the end: the next report covers it. The letter is a stopgap for today's buyer, not a patch for the record.

02 · Who signs it

Management writes it; the CPA firm doesn't vouch for it

A bridge letter is a representation, not an attestation.

Author
Your organization. Usually drafted by whoever runs compliance or security.
Signer
An officer who can speak for the company, such as the CEO, CTO, CISO or head of compliance.
CPA firm
Not a party. It has performed no procedures on the gap and expresses no opinion on it.
Reader
The same customers and prospects entitled to the report, under the same confidentiality terms.

Bridge letters are a market practice, not a document the attestation standards define. That is why the signer, not an auditor, carries the full weight of every sentence.

03 · What it states

Five things every bridge letter states

If one is missing, a careful reader will ask for it.

  • The report it bridges. Report type (Type 1 or Type 2), the system covered, the categories in scope, the period or as-of date, and the issuing firm.
  • The gap, with dates. From the day after the period end to a stated date, normally the letter date.
  • Changes to the system or controls. Either “no significant changes” or a plain list: new infrastructure, a new subservice organization, a retired control, a re-organization.
  • Known failures and incidents. Any control that did not operate as described, and any incident that affected the system's commitments, with what was done about it.
  • The caveat. That the letter is management's statement and has not been examined by the CPA firm.

04 · Its limits

What a bridge letter cannot do

It narrows the unknown. It doesn't extend anything.

It can

  • Tell a buyer whether anything material changed since the period end
  • Disclose an incident or failure before the buyer hears of it elsewhere
  • Point to the next period already under way

It cannot

  • Stretch the tested period by a single day
  • Carry the CPA firm's name as if the firm agreed
  • Turn a Type 1 into evidence of operating effectiveness
  • Replace a report that is simply too old

Events between the period end and the report date may already be addressed in the report itself. The letter picks up from there.

05 · How buyers read it

How buyers treat a letter, and when it stops being enough

A short, clean gap is routine. A long or eventful one isn't.

  1. Length of the gapA letter over a short gap is routinely accepted. As the gap grows, reviewers start asking for the next report instead.
  2. Material changeA new hosting provider, a rebuilt product or a merger means the tested system and today's system differ. The letter can disclose that; it can't cover it.
  3. An incidentA significant incident in the gap moves the conversation from the letter to the incident: what happened, what changed, what the next report will show.
  4. Next period statusA letter that names an abutting period already running, with an expected report window, reads very differently from one with no next step.

There is no official limit

No standard says how long a gap a letter may cover. In practice many reviewers are comfortable with roughly a quarter, and grow uneasy beyond that. Each buyer's own vendor policy is the rule that actually applies to you.

06 · Safe wording

Wording that is safe, and wording to avoid

Every sentence is a statement an officer signs.

AvoidWhySafer wording
“Our SOC 2 remains valid through December.”Reports don't carry a validity date; this invents one.“The report covers 1 April to 31 March. This letter addresses 1 April to 30 June.”
“Our auditors confirm controls are still effective.”The CPA firm has done no work on the gap.“This letter has not been examined by our service auditor.”
“There have been no changes.”Almost no system goes months without any change.“There have been no changes we consider significant to the system described in the report.”
“All controls operated effectively.”That is an opinion only testing supports.“We are not aware of any control that did not operate as described.”
“We remain SOC 2 certified.”A SOC 2 is a CPA firm's examination report. Nobody certifies you.“We have a SOC 2 Type 2 report for the period stated above.”
“Our next report will be issued in August.”Issue dates belong to the CPA firm.“Our next observation period began on 1 April and is in progress.”

07 · Template outline

An illustrative outline

Illustrative only. Adapt it to your facts; don't sign a template.

  1. Header: company name, date, addressed to “customers and prospective customers” with access to the report.
  2. Purpose: one sentence on why the letter exists: to address the period after the report.
  3. The report: type, system name, categories, period, issuing CPA firm, date of the report.
  4. The gap: the exact dates this letter speaks to.
  5. Changes: “no significant changes” or a short list with dates.
  6. Exceptions and incidents: none known, or a factual summary with remediation status.
  7. Next period: whether the next observation period has started and when it began.
  8. Caveat: management's statement; not examined by the service auditor; read with the report.
  9. Signature: name, title, date.

08 · Before you sign

Checks to run before the letter is signed

Say only what you've verified, as of the date you sign.

  • Change records. Review change tickets and architecture changes since the period end.
  • Vendors. Any subservice organization added, removed or swapped.
  • Incidents. The incident log and any customer notifications sent in the gap.
  • Control owners. Ask each owner in writing whether their control ran as described.
  • Open exceptions. Status of every exception the report disclosed.
  • People. Departures or new hires in roles the description names.
  • Next period. Confirm the start date of the current observation period with the CPA firm.

Sources: AICPA SSAE 18 and the attestation standards AT-C 105 and AT-C 205; AICPA SOC 2 guide (Reporting on an Examination of Controls at a Service Organization Relevant to Security, Availability, Processing Integrity, Confidentiality, or Privacy); AICPA DC 200 description criteria. Bridge-letter practice described from our own engagement reasoning.

Bridge letter questions

Can our CPA firm sign the bridge letter for us?

It shouldn't, and usually won't.

The firm has performed no procedures on the gap, so its signature would imply assurance that doesn't exist. The letter is yours. A letter that seems to come from the auditor is a reason for a buyer to ask questions.

Do we issue a new letter every month?

Issue one when someone needs it, dated that day.

Each letter speaks up to its own date. Many teams refresh it on request, or on a fixed rhythm while waiting for the next report, rerunning the checks each time.

We had an incident in the gap. Do we have to mention it?

If it was significant, yes.

Leaving out a significant incident makes the letter misleading, and it will very likely surface in the next report's description anyway. State it factually, with what changed afterwards.

Can a bridge letter follow a Type 1 report?

It can, but it bridges a single date.

A Type 1 speaks to design as of one day. A letter after it covers the time since that day; it adds no evidence that controls operated over time.

Is a bridge letter confidential?

Treat it like the report.

It refers to the report's contents and your control environment. Share it with the same audience and under the same terms as the report.

Write a letter you can stand behind.

We help management check the facts behind a bridge letter and plan the next period so the gap stays short.