FD Solutions Security testing

Guide

The penetration test SOC 2 and ISO 27001 auditors ask for

What the frameworks actually require, what they do not, and what your auditor needs to see in the document.

Short answer

Neither SOC 2 nor ISO 27001 names penetration testing as a mandatory control, but both expect evidence that you test for technical vulnerabilities, and auditors ask for a report in practice. What they check is scope, date, independence and whether findings were remediated and retested — not the name of the firm.

Neither SOC 2 nor ISO 27001 contains a line saying "you must buy a penetration test". Both are written in terms of outcomes, and both are almost always satisfied in practice by producing one. Knowing the difference saves you money and stops you buying the wrong thing.

What the frameworks actually say

SOC 2 is a set of Trust Services Criteria, not a checklist. The relevant ones — CC4.1 on monitoring and CC7.1 on identifying vulnerabilities — require you to evaluate whether your controls work, and to detect vulnerabilities in a timely way. Auditors accept independent penetration testing as evidence for both, and in practice ask for it. Your scope, your cadence and your risk assessment decide what is enough.

ISO 27001:2022 puts it in Annex A control 8.8, on management of technical vulnerabilities, supported by 8.29 on security testing in development. Again the standard describes an outcome; the certification body decides whether your evidence supports it.

The practical consequence: you are not buying a certificate, you are buying evidence. A report that clearly states scope, method, dates, findings and remediation is evidence. A scanner PDF with no coverage statement is not, whatever it cost.

What the auditor actually reads

In roughly this order: the coverage statement — what was in scope, what was excluded, which roles were tested and when; the methodology — which recognised standard was followed, named; the dates, because a report from two years and four releases ago evidences very little; the findings, with severities; and then the part most vendors skimp on, the evidence of remediation.

That last one is where engagements fail an audit. A report listing eleven findings and nothing else says you found problems and leaves open whether you fixed them. A retest appendix showing each one closed, verified and dated is what closes the control.

Common and expensive mistakes

Testing the wrong scope. Your audit boundary and your test scope should match. Testing the marketing site while the audit covers the platform helps nobody.

Leaving it until the observation window has started. SOC 2 Type II evidences a period. Test early enough that the fixes and the retest also fall inside it.

Buying a PCI ASV scan by mistake. That is a different, narrower, quarterly product for card environments. It does not substitute for a penetration test, and a penetration test does not substitute for it. If someone is selling you one as the other, stop.

Assuming the cloud provider covers you. AWS and Azure secure the infrastructure. Your application logic, your access control and your configuration are yours, and that is where findings come from.

What each framework points at, and what satisfies it
FrameworkWhere it landsWhat auditors accept
SOC 2CC4.1, CC7.1Independent test, documented scope and method, dated findings, evidence of remediation
ISO 27001:2022A.8.8, A.8.29The same, plus how testing feeds your risk treatment plan
PCI DSSReq. 11.3 / 11.4Annual penetration test AND separate quarterly ASV scans — different products
GDPRArticle 32(1)(d)Regular testing and evaluation of technical measures. No format prescribed

What each framework points at, and what satisfies it

Questions

Do you provide a certificate?
No, and neither does anybody honest — there is no such thing as a certificate of security. You get a signed report and a one-page completion letter with dates, scope, standards and outcome, which is the document auditors and enterprise buyers actually ask for.
Does the tester need to be certified?
No framework requires a specific certification. Some enterprise customers ask, and CREST or OSCP satisfies them. What every auditor requires is independence: the test must not be run by the people who built the thing.
Is an automated scan enough for SOC 2?
For continuous vulnerability monitoring it can contribute. As the only evidence of security testing it is routinely challenged, because it has no coverage statement and no human judgement behind the severities. Most auditors want a test with a person in it.

Next step

Send us a URL. Get a price today.

One reply from the engineer who would run the test — the engagement that fits, the fixed price, and the earliest window.

WhatsApp Get a price