- Home
- Compliance
- SOC 2 Compliance
- Sampling & deviations
How auditors test
One control, followed through a SOC 2 operating test.
Sampling makes more sense once you watch a single control move through fieldwork. This page tracks an illustrative quarterly access review from the auditor's request to the conclusion, then widens out to the rules that apply to every recurring control.
Back to SOC 2 services01 · A worked example
Illustrative: tracing a quarterly access review
Request, list, selection, inspection, conclusion.
- The system description says team leads review production access every quarter. That one sentence tells the auditor what to expect: four reviews per in-scope system across a twelve-month window.
- The firm's request list asks for every review performed in the window, together with the user listing each reviewer worked from.
- Before opening the reviews, the auditor checks that those user listings were complete, for instance by comparing them with an export from the identity provider.
- With so few occurrences, the auditor may inspect most or all of them. With many systems, the firm chooses a selection of system and quarter pairs.
- Each chosen review is inspected: dated inside the right quarter, signed by the right person, and every removal it flagged actually carried out.
- If one review cannot be found, the auditor looks into the cause and decides what that means for the criterion.
02 · Your lists get tested
Why your spreadsheet is checked before your evidence
A selection only means something if it came from a complete list.
Populations usually come from you: a ticket-system query, an export of HR leavers, a report from the code host. The attestation standards treat material like this as information produced by the entity, and the service auditor must be satisfied it is reliable enough before leaning on it. In practice the firm asks how each list was made, may watch the query being run, and compares totals with a second source.
- Query kept. Save the filter or query behind each list so it can be run again in front of the auditor.
- Source named. Record which system produced the list and the date it was drawn.
- Totals reconciled. Tie the count to another record, such as new joiners against accounts created.
- Nothing removed. Hand over the whole list. Taking out awkward items, or offering a few favourite examples, defeats the test.
03 · Frequency and size
How often a control runs drives how many items are picked
Firms size selections with their own method, usually keyed to frequency.
AICPA guidance leaves the size of a selection to the service auditor's professional judgement. Most firms keep an internal table keyed to how often a control operates and how much they plan to rely on it. Selections are commonly non-statistical, chosen to spread across the window rather than drawn by formula, so results are not projected with a stated confidence level.
| How often it runs | Occurrences in twelve months | What that means for you |
|---|---|---|
| Annual | 1 | There is nothing to sample around. One miss is the entire population. |
| Quarterly | 4 | Expect most or all to be examined. One gap is a quarter of the list. |
| Monthly | 12 | A handful are commonly chosen, spread across the year. |
| Weekly | About 52 | A larger selection, often touching every part of the window. |
| Daily or per event | Hundreds or more | The largest selections, and the best reason to keep records inside the tool. |
A shorter window shrinks the lists, not the standard. In a six-month Type 2 a quarterly control occurs twice, so a single miss is half of everything there is to test. On longer windows, many firms test part of each list at an interim visit and select from the remaining months once the window closes.
04 · Automated rules
When the system enforces the rule
One test can stand for the whole window, if the surroundings hold.
A configured rule, such as a minimum password length or branch protection that blocks merges without approval, behaves the same way every time it fires. The auditor may inspect the setting and test it once, then rely on change management and restricted administrator access to show nobody altered it during the window. If those supporting controls have problems of their own, the shortcut disappears and the configured rule needs wider testing.
05 · After a miss
From one failed item to the wording in the report
A deviation sets off questions. The answers decide what gets written.
The standards ask the service auditor to look into the nature and cause of each deviation. What follows usually lands in one of three places.
- Within what was planned for
- The miss fits the rate the firm allowed for, and follow-up shows it was isolated. It is still described in the test results.
- Testing widened
- The firm selects more items, or examines a sub-group such as one team or region, to learn how far the problem reaches.
- Control not effective
- The misses show the control did not work well enough for its criterion. That can reach the opinion when no other control covers the same risk.
- A written root cause: what happened and why the control missed.
- Evidence of the fix and the date it took effect.
- Any other control that would have caught the same risk.
- A short management response, which the report can print beside the finding.
How findings shape the auditor's opinion is covered in our guide to opinions and exceptions.
06 · Nothing to test
When the trigger never happened
No events means no operating test, and the report says so.
Some controls only act on a trigger: an emergency change, a security incident, a new subservice organization. If the trigger never occurred, there is nothing to test for operating effectiveness. The auditor confirms the list is truly empty, for example by searching the change system for emergency tags, and the report records that no occurrences arose. The design of the control can still be assessed.
Sources: AICPA, AT-C section 205 (examination engagements), on the reliability of information produced by the entity and on investigating deviations; AICPA Guide, SOC 2 Reporting on an Examination of Controls at a Service Organization; AICPA Audit Guide, Audit Sampling (sampling risk and tolerable rate of deviation).
Questions about how items get picked
Will the auditor tell us the selections in advance?
Usually not.
Selections are made after you hand over the full list. Knowing the picks early would let anyone tidy only those items, which is why the population comes first.
Does an interim selection still count if a control fails later?
It covers only the months it came from.
The firm still needs comfort over the remaining months, normally through a further selection after the window ends. A later failure shows up in those results.
Is every deviation reported as an exception?
Usually it is described; the wording depends on the evaluation.
A deviation is an item that failed the test. Firms commonly describe deviations in the test results, and their evaluation decides whether the control is called ineffective.
Can we fix a missed control before it is sampled?
You can fix the process, not the history.
Running a late review shows the gap is closed, but the original miss stays in the list. Back-dating a record is misrepresentation, and system timestamps make it obvious.
Related guides
See your lists the way the auditor will.
A SOC 2 readiness assessment rebuilds your populations and tests a selection from each control the way a CPA firm would, before fieldwork begins.