Do You Actually Need Penetration Testing for SOC 2? A Practical Guide for Founders
Understanding what's required, what's recommended, and how to make the right security investment for your startup.
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If you're pursuing SOC 2 compliance, you've probably encountered conflicting information about penetration testing. Some vendors insist it's mandatory. Others treat it as an expensive add-on. Many founders discover unexpected pen testing costs only after months of working with their compliance platform.
Let’s clarify what you actually need to know about penetration testing and SOC 2, based on real experiences from startups going through this process.
What SOC 2 Actually Requires for Security Testing
SOC 2 Type 2 attestation doesn't explicitly mandate penetration testing. The framework requires you to demonstrate that you identify and address system vulnerabilities, but it doesn't prescribe specific testing methods.
However, this technical distinction often misleads founders. While you can theoretically achieve SOC 2 without pen testing, many auditors expect to see security testing as evidence of your vulnerability management controls. Without it, you'll need to provide alternative evidence, which can complicate your audit.
The SOC 2 framework is built off the AICPA’s Trust Services Criteria (TSC) which was published and revised in the 2017 AICPA Trust Services Criteria for Security, Availability, Processing Integrity, Confidentiality, and Privacy (with Revised Points of Focus – 2022) publication. There are 5 total TSC’s. Security is the only required criterion, implemented through the Common Criteria (dubbed “CC”) in the publication. The point in question around vulnerability assessment and penetration testing is CC7.1, of which the exact text is:
CC7.1
To meet its objectives, the entity uses detection and monitoring procedures to identify (1) changes to configurations that result in the introduction of new vulnerabilities, and (2) susceptibilities to newly discovered vulnerabilities.
Under CC 7.1, the fifth Point of Focus further discusses the requirement:
CC7.1 - POF 5 Conducts Vulnerability Scans
The entity conducts infrastructure and software vulnerability scans designed to identify potential vulnerabilities or misconfigurations on a periodic basis and after significant changes are made to the environment. Action is taken to remediate identified deficiencies in a timely manner to support the achievement of the entity’s objectives.
The only place the word “penetration test” is explicitly mentioned in the entire publication is in CC7.1 - POF 5:
CC7.1 - POF 5 Considers Different Types of Ongoing and Separate Evaluations
Management uses a variety of ongoing and separate risk and control evaluations to determine whether internal controls are present and functioning. Depending on the entity’s objectives, such risk and control evaluations may include first- and second-line monitoring and control testing, internal audit assessments, compliance assessments, resilience assessments, vulnerability scans, security assessment, penetration testing, and third-party assessments.
First, under SOC 2, an assessment of the Trust Services Criteria (what a SOC 2 audit is) does not require you to follow all Points of Focus, in fact the AICPA specifically states:
Some points of focus may not be suitable or relevant to the entity or to the engagement to be performed.
In such situations, management may customize a particular point of focus or identify and consider other characteristics based on the specific circumstances of the entity.
Further:
Use of the trust services criteria does not require an assessment of whether each point of focus is addressed.
Users are advised to consider the facts and circumstances of the entity and its environment in actual situations in relation to the entity’s objectives when evaluating the subject matter using the trust services criteria.
Notwithstanding all of that, the CC4.1-POF4 only lists penetration testing as a evaluation you may consider, and nothing further. SOC 2 is meant to be a very flexible framework that can be built around you and your risk landscape.
With that said however, your customers often care about security testing regardless of minimum compliance requirements. Enterprise security teams frequently request penetration testing reports during vendor evaluations. Companies without recent pen tests may face extended security reviews that can impact deal timelines.
The takeaway here is penetration testing isn't technically required for a valid SOC 2 report, and if your business doesn’t necessitate it or funds are tight - it can be pushed back until an enterprise requests it. It's often essential for the business outcomes you're trying to achieve through compliance.
How to Tell If You're Getting Real Penetration Testing or Just a Vulnerability Scan
Many founders discover too late that their compliance platform's "security testing" is actually just automated vulnerability scanning. Understanding this distinction helps you evaluate what you're actually getting for your investment.
Vulnerability scanning uses automated tools to check for known security issues in your systems. These scans identify outdated software, missing patches, and common misconfigurations. The process typically takes hours and requires minimal human involvement. Common providers are Tenable, Qualys, OpenVAS, Aikido Security, and more.
Penetration testing involves certified security professionals manually attempting to compromise your systems using real attack techniques. Testers combine multiple vulnerabilities, test business logic, and explore attack paths that automated tools cannot detect. A penetration test for a typical SaaS application requires 20-25 hours of skilled human analysis for a small startup, and up to 100 for a larger companies.
The difference matters for both security and compliance. Automated scans catch surface-level issues but miss the complex vulnerabilities that lead to actual breaches. When enterprise customers request "penetration testing reports," they're looking for evidence of manual security testing, not automated scan results.
Some vendors blur this distinction in their pricing, offering "penetration testing" that's actually just vulnerability scanning with a manual review. You should clarify whether you're getting actual manual testing hours from certified professionals.
Why Enterprise Customers Care About Your Penetration Testing Reports
A common axiom is that compliance ≠ security. There are Minimum Compliance Requirements (MCR) and Discretionary Security Requirements (DSR) and ideally, your security program creates compliance as a by-product of it’s existence and enforcement. Penetration testing falls into the DSR side, but improves your security posture and compliance positioning.
Enterprise sales cycles often move faster when you can immediately provide comprehensive pen testing reports. Companies with recent pen tests may be able to skip extended security assessments.
The compound benefits become clear over time. Each pen test builds on previous findings, helping you develop stronger security practices. Your engineering team learns to anticipate security issues. Your security posture improves beyond mere compliance. This maturity shows in customer conversations and can accelerate future security reviews.
Consider penetration testing as product development for security. Just as you wouldn't launch features without testing, you shouldn't ingest sensitive data and set up controls without validating they actually work.
What Penetration Testing Really Costs (Including Hidden Expenses)
Understanding the full cost of penetration testing helps you make informed decisions and prevents budget surprises.
Direct costs vary significantly. Standalone pen tests from reputable firms typically range from thousands to tens of thousands of dollars for a standard SaaS application. Some compliance platforms charge additional fees as an add-on. Others include testing in their base price. The variation often reflects differences in testing quality and depth.
Hidden costs can exceed the testing fees. Coordination requires significant time from your team for scoping, providing access, answering questions, and reviewing findings. Remediation adds engineering hours to fix discovered issues. Retesting to verify fixes may incur additional charges. Some vendors limit retests, forcing you to choose between fixing all issues immediately or accepting failed retests.
The timing of costs matters for budget planning. Vendors who charge separately for pen testing often reveal this after you've committed to their platform. If annual testing is part of your security program, these costs recur. Over three years, annual pen tests can add significant costs to your total compliance investment.
When evaluating platforms, ask about all testing-related costs upfront. Understand what's included in base pricing versus add-ons. Clarify retest policies and any recurring requirements. Factor in your team's time for coordination and remediation. This complete picture helps you compare options accurately.
How to Choose the Right Penetration Testing Approach for Your Startup
Your approach to penetration testing should align with your business goals, customer requirements, and security maturity.
Start by understanding your customers' expectations. If you're selling to enterprises, regulated industries, or security-conscious markets, plan for comprehensive pen testing from the beginning. These customers often ask for recent reports and may expect regular testing. Building this into your compliance strategy prevents delays later.
Consider your internal capabilities. Small teams often benefit from integrated pen testing that includes remediation support. Larger teams with security expertise might prefer managing standalone tests. Your choice should reflect both current capabilities and growth plans.
Evaluate vendors based on transparency and alignment with your needs. Ask specific questions about testing methodology, tester certifications, hours included, and retest policies. Vendors who include comprehensive testing in base pricing often provide better overall value than those positioning it as an add-on.
Think beyond your first audit. If you plan to conduct regular testing as part of your security program, your initial decision impacts ongoing costs and operations. Platforms that integrate testing into their workflow reduce coordination overhead over time. This efficiency becomes valuable as your team grows and compliance requirements expand.
Questions to Ask Before Signing Any Compliance Platform Contract
Before committing to any compliance platform, get clear answers to these specific questions about penetration testing.
Testing Specifics:
- Is manual penetration testing included in your base price or an add-on?
- How many hours of actual manual testing do you provide?
- What certifications do your penetration testers hold?
- Do you provide vulnerability scanning, penetration testing, or both?
- Can you provide a clear scope of work of what will be done? Does it cover the OWASP Top 10?
Logistics and Timeline:
- When in the compliance process can we start penetration testing?
- How much notice do you need to schedule testing?
- What's the typical turnaround time for receiving the final report?
- Can testing happen in parallel with audit preparation?
Costs and Retesting:
- What are all costs associated with penetration testing
- How many retests are included?
- What happens if we need additional retests?
- Are there any circumstances where additional fees apply?
Ongoing Requirements:
- Is annual penetration testing part of your recommended security program?
- What are the costs for testing in subsequent years?
- Can we use external penetration testing firms if preferred?
- How do you handle remediation support?
How to Choose the Right Penetration Testing Approach for Your Startup
Your approach to penetration testing should align with your business goals, customer requirements, and security maturity.
Start by understanding your customers' expectations. If you're selling to enterprises, regulated industries, or security-conscious markets, plan for comprehensive pen testing from the beginning. These customers often ask for recent reports and may expect regular testing. Building this into your compliance strategy prevents delays later.
Consider your internal capabilities. Small teams often benefit from integrated pen testing that includes remediation support. Larger teams with security expertise might prefer managing standalone tests. Your choice should reflect both current capabilities and growth plans.
Evaluate vendors based on transparency and alignment with your needs. Ask specific questions about testing methodology, tester certifications, hours included, and retest policies. Vendors who include comprehensive testing in base pricing often provide better overall value than those positioning it as an add-on.
Think beyond your first audit. If you plan to conduct regular testing as part of your security program, your initial decision impacts ongoing costs and operations. Platforms that integrate testing into their workflow reduce coordination overhead over time. This efficiency becomes valuable as your team grows and compliance requirements expand.
How to Build Security That Actually Protects Your Business
The question isn't whether you need penetration testing for SOC 2 compliance. The real question is how to build security practices that serve your business goals while meeting compliance requirements.
Smart founders recognize that penetration testing, while not technically mandatory for SOC 2, is often valuable for the business outcomes compliance enables. Enterprise deals, customer trust, and genuine security all benefit from comprehensive testing integrated into your compliance journey.
Your choice of compliance platform should reflect this reality. Vendors who include penetration testing in their base offering align their success with yours. They're invested in your security outcomes, not just checking compliance boxes.
At Delve, we include 25 hours of manual penetration testing by SANS GWAP certified professionals because we believe real security shouldn't require separate negotiations or surprise invoices. Your compliance journey should strengthen your security posture, not just document it. We provide three retests within 90 days of your first test to ensure you have time to properly address any findings.
Ready to see how integrated penetration testing accelerates both compliance and security? Let's discuss your specific requirements and show you a path to SOC 2 that actually makes your company more secure.
If you're pursuing SOC 2 compliance, you've probably encountered conflicting information about penetration testing. Some vendors insist it's mandatory. Others treat it as an expensive add-on. Many founders discover unexpected pen testing costs only after months of working with their compliance platform.
Let’s clarify what you actually need to know about penetration testing and SOC 2, based on real experiences from startups going through this process.
What SOC 2 Actually Requires for Security Testing
SOC 2 Type 2 attestation doesn't explicitly mandate penetration testing. The framework requires you to demonstrate that you identify and address system vulnerabilities, but it doesn't prescribe specific testing methods.
However, this technical distinction often misleads founders. While you can theoretically achieve SOC 2 without pen testing, many auditors expect to see security testing as evidence of your vulnerability management controls. Without it, you'll need to provide alternative evidence, which can complicate your audit.
The SOC 2 framework is built off the AICPA’s Trust Services Criteria (TSC) which was published and revised in the 2017 AICPA Trust Services Criteria for Security, Availability, Processing Integrity, Confidentiality, and Privacy (with Revised Points of Focus – 2022) publication. There are 5 total TSC’s. Security is the only required criterion, implemented through the Common Criteria (dubbed “CC”) in the publication. The point in question around vulnerability assessment and penetration testing is CC7.1, of which the exact text is:
CC7.1
To meet its objectives, the entity uses detection and monitoring procedures to identify (1) changes to configurations that result in the introduction of new vulnerabilities, and (2) susceptibilities to newly discovered vulnerabilities.
Under CC 7.1, the fifth Point of Focus further discusses the requirement:
CC7.1 - POF 5 Conducts Vulnerability Scans
The entity conducts infrastructure and software vulnerability scans designed to identify potential vulnerabilities or misconfigurations on a periodic basis and after significant changes are made to the environment. Action is taken to remediate identified deficiencies in a timely manner to support the achievement of the entity’s objectives.
The only place the word “penetration test” is explicitly mentioned in the entire publication is in CC7.1 - POF 5:
CC7.1 - POF 5 Considers Different Types of Ongoing and Separate Evaluations
Management uses a variety of ongoing and separate risk and control evaluations to determine whether internal controls are present and functioning. Depending on the entity’s objectives, such risk and control evaluations may include first- and second-line monitoring and control testing, internal audit assessments, compliance assessments, resilience assessments, vulnerability scans, security assessment, penetration testing, and third-party assessments.
First, under SOC 2, an assessment of the Trust Services Criteria (what a SOC 2 audit is) does not require you to follow all Points of Focus, in fact the AICPA specifically states:
Some points of focus may not be suitable or relevant to the entity or to the engagement to be performed.
In such situations, management may customize a particular point of focus or identify and consider other characteristics based on the specific circumstances of the entity.
Further:
Use of the trust services criteria does not require an assessment of whether each point of focus is addressed.
Users are advised to consider the facts and circumstances of the entity and its environment in actual situations in relation to the entity’s objectives when evaluating the subject matter using the trust services criteria.
Notwithstanding all of that, the CC4.1-POF4 only lists penetration testing as a evaluation you may consider, and nothing further. SOC 2 is meant to be a very flexible framework that can be built around you and your risk landscape.
With that said however, your customers often care about security testing regardless of minimum compliance requirements. Enterprise security teams frequently request penetration testing reports during vendor evaluations. Companies without recent pen tests may face extended security reviews that can impact deal timelines.
The takeaway here is penetration testing isn't technically required for a valid SOC 2 report, and if your business doesn’t necessitate it or funds are tight - it can be pushed back until an enterprise requests it. It's often essential for the business outcomes you're trying to achieve through compliance.
How to Tell If You're Getting Real Penetration Testing or Just a Vulnerability Scan
Many founders discover too late that their compliance platform's "security testing" is actually just automated vulnerability scanning. Understanding this distinction helps you evaluate what you're actually getting for your investment.
Vulnerability scanning uses automated tools to check for known security issues in your systems. These scans identify outdated software, missing patches, and common misconfigurations. The process typically takes hours and requires minimal human involvement. Common providers are Tenable, Qualys, OpenVAS, Aikido Security, and more.
Penetration testing involves certified security professionals manually attempting to compromise your systems using real attack techniques. Testers combine multiple vulnerabilities, test business logic, and explore attack paths that automated tools cannot detect. A penetration test for a typical SaaS application requires 20-25 hours of skilled human analysis for a small startup, and up to 100 for a larger companies.
The difference matters for both security and compliance. Automated scans catch surface-level issues but miss the complex vulnerabilities that lead to actual breaches. When enterprise customers request "penetration testing reports," they're looking for evidence of manual security testing, not automated scan results.
Some vendors blur this distinction in their pricing, offering "penetration testing" that's actually just vulnerability scanning with a manual review. You should clarify whether you're getting actual manual testing hours from certified professionals.
Why Enterprise Customers Care About Your Penetration Testing Reports
A common axiom is that compliance ≠ security. There are Minimum Compliance Requirements (MCR) and Discretionary Security Requirements (DSR) and ideally, your security program creates compliance as a by-product of it’s existence and enforcement. Penetration testing falls into the DSR side, but improves your security posture and compliance positioning.
Enterprise sales cycles often move faster when you can immediately provide comprehensive pen testing reports. Companies with recent pen tests may be able to skip extended security assessments.
The compound benefits become clear over time. Each pen test builds on previous findings, helping you develop stronger security practices. Your engineering team learns to anticipate security issues. Your security posture improves beyond mere compliance. This maturity shows in customer conversations and can accelerate future security reviews.
Consider penetration testing as product development for security. Just as you wouldn't launch features without testing, you shouldn't ingest sensitive data and set up controls without validating they actually work.
What Penetration Testing Really Costs (Including Hidden Expenses)
Understanding the full cost of penetration testing helps you make informed decisions and prevents budget surprises.
Direct costs vary significantly. Standalone pen tests from reputable firms typically range from thousands to tens of thousands of dollars for a standard SaaS application. Some compliance platforms charge additional fees as an add-on. Others include testing in their base price. The variation often reflects differences in testing quality and depth.
Hidden costs can exceed the testing fees. Coordination requires significant time from your team for scoping, providing access, answering questions, and reviewing findings. Remediation adds engineering hours to fix discovered issues. Retesting to verify fixes may incur additional charges. Some vendors limit retests, forcing you to choose between fixing all issues immediately or accepting failed retests.
The timing of costs matters for budget planning. Vendors who charge separately for pen testing often reveal this after you've committed to their platform. If annual testing is part of your security program, these costs recur. Over three years, annual pen tests can add significant costs to your total compliance investment.
When evaluating platforms, ask about all testing-related costs upfront. Understand what's included in base pricing versus add-ons. Clarify retest policies and any recurring requirements. Factor in your team's time for coordination and remediation. This complete picture helps you compare options accurately.
How to Choose the Right Penetration Testing Approach for Your Startup
Your approach to penetration testing should align with your business goals, customer requirements, and security maturity.
Start by understanding your customers' expectations. If you're selling to enterprises, regulated industries, or security-conscious markets, plan for comprehensive pen testing from the beginning. These customers often ask for recent reports and may expect regular testing. Building this into your compliance strategy prevents delays later.
Consider your internal capabilities. Small teams often benefit from integrated pen testing that includes remediation support. Larger teams with security expertise might prefer managing standalone tests. Your choice should reflect both current capabilities and growth plans.
Evaluate vendors based on transparency and alignment with your needs. Ask specific questions about testing methodology, tester certifications, hours included, and retest policies. Vendors who include comprehensive testing in base pricing often provide better overall value than those positioning it as an add-on.
Think beyond your first audit. If you plan to conduct regular testing as part of your security program, your initial decision impacts ongoing costs and operations. Platforms that integrate testing into their workflow reduce coordination overhead over time. This efficiency becomes valuable as your team grows and compliance requirements expand.
Questions to Ask Before Signing Any Compliance Platform Contract
Before committing to any compliance platform, get clear answers to these specific questions about penetration testing.
Testing Specifics:
- Is manual penetration testing included in your base price or an add-on?
- How many hours of actual manual testing do you provide?
- What certifications do your penetration testers hold?
- Do you provide vulnerability scanning, penetration testing, or both?
- Can you provide a clear scope of work of what will be done? Does it cover the OWASP Top 10?
Logistics and Timeline:
- When in the compliance process can we start penetration testing?
- How much notice do you need to schedule testing?
- What's the typical turnaround time for receiving the final report?
- Can testing happen in parallel with audit preparation?
Costs and Retesting:
- What are all costs associated with penetration testing
- How many retests are included?
- What happens if we need additional retests?
- Are there any circumstances where additional fees apply?
Ongoing Requirements:
- Is annual penetration testing part of your recommended security program?
- What are the costs for testing in subsequent years?
- Can we use external penetration testing firms if preferred?
- How do you handle remediation support?
How to Choose the Right Penetration Testing Approach for Your Startup
Your approach to penetration testing should align with your business goals, customer requirements, and security maturity.
Start by understanding your customers' expectations. If you're selling to enterprises, regulated industries, or security-conscious markets, plan for comprehensive pen testing from the beginning. These customers often ask for recent reports and may expect regular testing. Building this into your compliance strategy prevents delays later.
Consider your internal capabilities. Small teams often benefit from integrated pen testing that includes remediation support. Larger teams with security expertise might prefer managing standalone tests. Your choice should reflect both current capabilities and growth plans.
Evaluate vendors based on transparency and alignment with your needs. Ask specific questions about testing methodology, tester certifications, hours included, and retest policies. Vendors who include comprehensive testing in base pricing often provide better overall value than those positioning it as an add-on.
Think beyond your first audit. If you plan to conduct regular testing as part of your security program, your initial decision impacts ongoing costs and operations. Platforms that integrate testing into their workflow reduce coordination overhead over time. This efficiency becomes valuable as your team grows and compliance requirements expand.
How to Build Security That Actually Protects Your Business
The question isn't whether you need penetration testing for SOC 2 compliance. The real question is how to build security practices that serve your business goals while meeting compliance requirements.
Smart founders recognize that penetration testing, while not technically mandatory for SOC 2, is often valuable for the business outcomes compliance enables. Enterprise deals, customer trust, and genuine security all benefit from comprehensive testing integrated into your compliance journey.
Your choice of compliance platform should reflect this reality. Vendors who include penetration testing in their base offering align their success with yours. They're invested in your security outcomes, not just checking compliance boxes.
At Delve, we include 25 hours of manual penetration testing by SANS GWAP certified professionals because we believe real security shouldn't require separate negotiations or surprise invoices. Your compliance journey should strengthen your security posture, not just document it. We provide three retests within 90 days of your first test to ensure you have time to properly address any findings.
Ready to see how integrated penetration testing accelerates both compliance and security? Let's discuss your specific requirements and show you a path to SOC 2 that actually makes your company more secure.
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