SOC 2 Type I vs Type II for AI companies: what they are and how to get a report
Understand the CPA attestation process, Trust Services Criteria, system description, evidence period, exceptions, and the difference between a point-in-time Type I and period-based Type II report.
Overview
Understand the CPA attestation process, Trust Services Criteria, system description, evidence period, exceptions, and the difference between a point-in-time Type I and period-based Type II report.
What it is
SOC 2 is an AICPA assurance engagement in which an independent CPA reports on controls relevant to selected Trust Services Criteria. Type I addresses design as of a specified date; Type II also tests operating effectiveness over a stated period.
Why it matters
AI vendors handle valuable prompts, customer data, model access, and critical workflows. Buyers use the restricted-use report to understand security governance, test results, exceptions, and dependencies before trusting the service.
How to obtain it or demonstrate compliance
- Define customers, scope, system description, subservice organizations, and applicable Trust Services Criteria.
- Perform readiness work, document controls, assign owners, and remediate gaps.
- Choose an independent licensed CPA firm with relevant SOC and technology experience.
- For Type I, prepare evidence as of the examination date; for Type II, operate and evidence controls throughout the period.
- Support auditor sampling, walkthroughs, testing, exception analysis, management assertion, and representation.
- Receive the final report, remediate exceptions, manage distribution, and plan the next examination.
What to review
- Call it a SOC 2 report or examination—not a government certification.
- Select security and any relevant availability, confidentiality, processing integrity, or privacy criteria.
- Define the AI service boundary, infrastructure, model/API vendors, people, data, software, procedures, and complementary customer controls.
- For Type I, identify the specified date; for Type II, define the review period and maintain operating evidence throughout it.
- Read the auditor’s opinion, management assertion, tests, results, exceptions, subservice treatment, and report restrictions.
- Share the confidential report under appropriate access controls and never claim systems outside its scope are covered.
What to do next
A Type I report can provide an earlier design snapshot; enterprise buyers often seek Type II evidence that controls operated over time. Only a properly licensed CPA firm can perform the SOC examination under the applicable professional standards.
Official sources and further reading
- System and Organization Controls: SOC Suite of Services — AICPA & CIMA
This article provides general educational information and is not legal advice. Rules and outcomes depend on your facts and jurisdiction. Consult a qualified local professional before acting.
Jurisdiction
International and cross-border assurance; scope, accreditation, and legal effect depend on the scheme and market
Review status
Editorially reviewed by the LegalGPT Editorial Team. Not independently reviewed by a licensed attorney.