Every fintech founder we work with asks the same question: "How fast can we get this done?" The answer, in our experience, is faster than you probably think -- if you know where your existing controls already overlap with SOC 2 and where the real gaps hide.
Fintech companies consistently achieve SOC 2 compliance faster than the average technology company — while the typical first-time SOC 2 timeline runs four to eight months from project initiation to report issuance, fintech companies frequently complete the process in three to five months. This acceleration is not coincidental. Fintech companies face unique pressures that create urgency: bank partners require SOC 2 reports before approving integrations, enterprise financial institutions demand compliance documentation during procurement, and regulatory expectations in financial services create a compliance-forward culture from the company's earliest stages. These external pressures, combined with the fact that many fintech companies already implement strong security controls to satisfy PCI DSS, banking partner requirements, or state money transmitter regulations, mean that fintech organizations often have a head start on SOC 2 — their existing security infrastructure, access management practices, and encryption implementations already satisfy a significant portion of SOC 2 Trust Service Criteria. The challenge for fintech companies is not building security from scratch but rather documenting and formalizing the security practices they already follow, filling specific gaps in areas like formal risk assessment, vendor management, and change management documentation, and selecting an audit approach that leverages their existing compliance investments rather than treating SOC 2 as a standalone effort.
This case study analyzes common patterns in how fintech companies accelerate SOC 2 compliance, including the advantages they start with, strategies that reduce timeline, platform selection patterns, PCI DSS control reuse, and lessons learned from fintech implementations.
The Fintech SOC 2 Advantage
Why Fintech Starts Ahead
| Advantage | How It Helps SOC 2 | Time Saved |
|---|
| PCI DSS controls already in place | Encryption, access management, logging, and vulnerability management controls overlap significantly with SOC 2 | 4-8 weeks of control implementation |
| Bank partner security requirements | Partner due diligence has already driven implementation of security controls (MFA, encryption, access reviews) | 2-4 weeks of gap remediation |
| Regulatory compliance culture | Teams are accustomed to compliance processes, documentation, and evidence collection | Faster stakeholder buy-in; reduced organizational resistance |
| Strong authentication infrastructure | Financial services requirements demand MFA, SSO, and strong credential management | CC6.1 requirements often already met |
| Encryption by default | Financial data handling requires encryption at rest and in transit as baseline | CC6.7 requirements often already met |
| Audit logging practices | Regulatory and partner requirements drive comprehensive logging | CC7.1-CC7.2 monitoring controls often partially addressed |
| Incident response maturity | Financial services incident response requirements exceed general technology norms | CC7.3-CC7.4 controls often already documented |
Common Starting State for Fintech SOC 2
| Control Area | Typical Fintech Starting State | Typical General SaaS Starting State | Fintech Advantage |
|---|
| Access management | MFA enforced; SSO implemented; RBAC partially configured | MFA partially deployed; SSO planned but not implemented | 60-80% already compliant |
| Encryption | All data encrypted at rest and in transit; key management established | Encryption at transit; at-rest encryption varies | 80-90% already compliant |
| Logging and monitoring | Comprehensive logging; SIEM or log aggregation in place | Basic logging; no centralized monitoring | 50-70% already compliant |
| Change management | Code review required; deployment procedures documented | Informal code review; deployment procedures not documented | 40-60% already compliant |
| Vendor management | Third-party risk assessment for financial partners | No formal vendor management process | 30-50% already compliant |
| Risk assessment | Regulatory risk assessment performed | No formal risk assessment | 30-50% already compliant |
| Policies and documentation | Some policies exist for regulatory compliance | Few or no formal policies | 20-40% already compliant |
| Business continuity | DR/BCP for financial operations; regulatory requirement | No formal BCP/DR | 30-50% already compliant |
Acceleration Strategies
Strategy 1: PCI DSS Control Reuse
| PCI DSS Requirement | Overlapping SOC 2 Criteria | Reuse Approach |
|---|
| Requirement 2: Secure configurations | CC6.8, CC8.1 | System hardening documentation applies to SOC 2 with minimal modification |
| Requirement 3: Protect stored data | CC6.7, C1.1 | Encryption implementation and key management evidence directly applicable |
| Requirement 6: Secure development | CC8.1 | SDLC documentation and code review evidence applies to change management |
| Requirement 7: Restrict access | CC6.1, CC6.2, CC6.3 | RBAC and access management controls directly transferable |
| Requirement 8: Identify users | CC6.1 | Authentication controls (MFA, unique IDs) directly applicable |
| Requirement 10: Monitor access | CC7.1, CC7.2 | Logging and monitoring infrastructure provides SOC 2 evidence |
| Requirement 11: Test security | CC4.1, CC7.1 | Vulnerability scanning and penetration testing satisfy both frameworks |
| Requirement 12: Security policies | CC1.1, CC5.3 | Information security policies serve both PCI DSS and SOC 2 with minor additions |
Strategy 2: Bank Partner Readiness as Accelerant
| Partner Requirement | How It Accelerates SOC 2 | Evidence Reuse |
|---|
| Partner security assessment | Completed security questionnaires document existing controls | Questionnaire responses inform SOC 2 system description |
| API security requirements | Secure API design (authentication, encryption, rate limiting) satisfies CC6.6, CC6.7 | API security documentation applies to SOC 2 |
| Data handling agreements | Data classification and handling procedures already defined | Data handling documentation supports CC6.5, C1.1 |
| Incident notification requirements | Incident response and notification procedures established | Incident response plan applicable to CC7.3, CC7.4 |
| Business continuity requirements | DR/BCP developed for partner compliance | BCP/DRP documentation satisfies A1.2, A1.3 |
Strategy 3: Platform Selection for Speed
| Platform Approach | Timeline Impact | Best For |
|---|
| Vanta with financial services template | Reduces initial setup by 2-3 weeks; pre-configured financial controls | Fintech companies wanting fastest time-to-compliance |
| Drata with PCI DSS cross-mapping | Enables simultaneous PCI DSS and SOC 2 management | Fintech companies managing both frameworks |
| Secureframe with rapid deployment | Quick integration setup; streamlined evidence collection | Fintech startups prioritizing speed |
| Thoropass (platform + audit bundle) | Combined platform and audit reduces coordination time | Fintech companies wanting single-vendor simplicity |
Strategy 4: Auditor Selection for Fintech
| Auditor Selection Factor | How It Accelerates | Recommended Approach |
|---|
| Financial services experience | Auditor understands fintech controls and PCI DSS overlap; less time explaining context | Select auditors with explicit fintech or financial services practice areas |
| PCI DSS and SOC 2 capability | Same firm can assess both frameworks; shared understanding of controls | Engage a firm that can perform both PCI DSS and SOC 2 if both are needed |
| Startup familiarity | Auditor calibrated for growth-stage companies; does not impose enterprise-scale expectations | Avoid large firms that primarily serve Fortune 500; select firms experienced with growth-stage companies |
| Efficient fieldwork | Auditor uses evidence from compliance platform; does not require manual evidence packaging | Confirm auditor is comfortable reviewing evidence directly from your compliance platform |
Timeline Comparison
Fintech SOC 2 Timeline vs General Technology
| Phase | Fintech Timeline | General Technology Timeline | Fintech Acceleration Factor |
|---|
| Gap assessment | 1-2 weeks | 2-4 weeks | Fewer gaps due to existing financial controls |
| Remediation | 2-4 weeks | 4-10 weeks | Many controls already implemented; remediation focuses on documentation gaps |
| Policy development | 1-2 weeks | 2-4 weeks | Some policies exist from regulatory requirements; templates fill remaining gaps |
| Platform configuration | 1-2 weeks | 2-3 weeks | Integrations are standard; financial services configurations available |
| Type I audit (if applicable) | 2-4 weeks | 3-6 weeks | Cleaner environment; fewer findings to address |
| Observation period (Type II) | 3-6 months | 3-12 months | Some fintech choose shorter initial period; accelerated based on control maturity |
| Type II fieldwork | 2-4 weeks | 3-6 weeks | Fewer exceptions; controls well-documented; evidence collection automated |
| Total (gap to Type II report) | 4-7 months | 6-14 months | 30-50% faster overall |
Fintech-Specific Acceleration Milestones
| Milestone | Typical Fintech Timeline | Key Action |
|---|
| Week 1-2 | Gap assessment complete | Map existing PCI DSS/regulatory controls to SOC 2 criteria |
| Week 3-4 | Platform configured; core integrations connected | Connect cloud, IdP, HRIS, code repository to compliance platform |
| Week 4-6 | Policy gaps filled; documentation complete | Write remaining policies using platform templates; customize for fintech context |
| Week 6-8 | Remediation complete; all controls operational | Address remaining gaps (typically vendor management, formal risk assessment, change management documentation) |
| Week 8-10 | Auditor engaged; Type I fieldwork (optional) | Type I provides immediate compliance evidence for bank partners |
| Month 3-6 | Observation period for Type II | Controls operating; evidence collecting; compliance platform monitoring |
| Month 5-7 | Type II fieldwork and report issuance | Auditor tests controls; report issued within 2-4 weeks of fieldwork |
Common Fintech Gaps Despite Head Start
Where Fintech Companies Still Need Work
| Gap Area | Why It Exists Despite Financial Controls | Remediation Approach |
|---|
| Formal risk assessment | Financial regulatory risk assessments may not cover all SOC 2 criteria | Conduct SOC 2-specific risk assessment covering all Trust Service Criteria |
| Vendor management documentation | Partner assessments focus on financial vendors; general SaaS vendors may not be assessed | Expand vendor management to cover all in-scope vendors including SaaS tools |
| Change management documentation | Code review happens but formal change management (tickets, approvals, testing) may not be documented | Formalize change management with ticket-based tracking and documented approval |
| Employee security training | Compliance training focuses on financial regulations; general security awareness may be missing | Implement comprehensive security awareness training covering SOC 2 topics |
| Business continuity testing | DR exists but may not be tested regularly or documented | Schedule and document annual DR testing with results and remediation |
| Formal access review process | Access is managed but formal periodic review with manager certification may not exist | Implement quarterly access reviews with documented manager approval |
Remediation Priority for Fintech
| Priority | Gap | Timeline to Remediate | Effort Level |
|---|
| 1 (Highest) | Risk assessment | 1-2 weeks | Low — structured assessment using framework template |
| 2 | Vendor management | 2-3 weeks | Moderate — vendor inventory, assessment, and tracking |
| 3 | Change management documentation | 1-2 weeks | Low — formalize existing practices into documented procedures |
| 4 | Access review process | 1-2 weeks | Low — implement quarterly review process |
| 5 | Security awareness training | 2-3 weeks | Low — deploy training platform; assign training modules |
| 6 | DR testing documentation | 1-2 weeks | Low — schedule and document test; capture results |
Lessons Learned from Fintech SOC 2 Implementations
What Works
| Practice | Why It Works | Outcome |
|---|
| Map PCI DSS to SOC 2 before starting | Identifies existing controls that satisfy SOC 2; focuses effort on actual gaps | Reduces perceived scope; builds team confidence; avoids duplicate work |
| Engage bank partner-experienced auditor | Auditor understands financial controls context; fieldwork is efficient | Fewer questions; faster fieldwork; relevant testing approach |
| Use Type I as interim milestone | Type I report provides immediate compliance evidence for bank partners | Unlocks partnerships while Type II observation period continues |
| Automate evidence collection from day one | Compliance platform collects evidence throughout observation period | Clean, complete evidence when fieldwork begins; fewer auditor requests |
| Assign compliance champion from engineering | Engineering engagement ensures technical controls are properly documented | Reduces back-and-forth between compliance and engineering during audit |
What Does Not Work
| Anti-Pattern | Why It Fails | Alternative Approach |
|---|
| Treating SOC 2 as entirely separate from PCI DSS | Creates duplicate effort; misses opportunity to reuse existing controls | Map PCI DSS controls to SOC 2 criteria; identify reuse opportunities |
| Delaying until bank partner demands SOC 2 | Reactive approach creates compressed timelines; may delay partnership | Start SOC 2 proactively when bank partnerships are on the roadmap |
| Over-scoping the first SOC 2 | Including all products and all TSC criteria extends timeline unnecessarily | Start with the product most relevant to bank partners; expand scope in Year 2 |
| Choosing the cheapest auditor | Budget auditors may lack financial services context; create more work | Select auditors with fintech experience; efficiency savings offset fee premium |
| Manual evidence collection during observation | Evidence gaps discovered during fieldwork; scramble to backfill | Deploy compliance platform before observation period starts |
Key Takeaways
- We consistently see fintech companies achieve SOC 2 compliance thirty to fifty percent faster than general technology companies — typically four to seven months versus six to fourteen months — because existing PCI DSS controls, bank partner security requirements, and regulatory compliance culture provide a significant head start on access management, encryption, logging, and incident response controls
- In our experience, PCI DSS control reuse is the most significant acceleration factor: eight of the twelve PCI DSS requirements have direct overlap with SOC 2 criteria, and we advise clients to systematically map their existing PCI DSS controls to SOC 2 criteria before starting the SOC 2 project to avoid weeks of redundant control implementation
- What we tell clients is that the most common gaps fintech companies face despite their head start are documentation-oriented rather than technical: formal risk assessment, vendor management for non-financial SaaS vendors, change management documentation, quarterly access reviews, and security awareness training — these gaps typically require two to six weeks to remediate, compared to four to ten weeks for general technology companies starting from scratch
- We advise clients to pursue a Type I as an interim milestone — a Type I report can be issued within two to four weeks of audit engagement, providing immediate compliance evidence for bank partners while the Type II observation period continues, and this approach unblocks partnerships months before the full Type II report is available
- We recommend selecting auditors with financial services experience because they understand PCI DSS overlap, bank partner expectations, and fintech-specific control patterns, resulting in faster fieldwork and fewer unnecessary evidence requests compared to auditors without financial services specialization
- At Agency, we help fintech companies design accelerated SOC 2 programs that leverage existing PCI DSS investments, select auditors with financial services experience, prioritize remediation for maximum impact, and structure the SOC 2 scope to satisfy bank partner requirements while minimizing time-to-report
Frequently Asked Questions
Can we get SOC 2 and PCI DSS assessed by the same audit firm simultaneously?
What we tell clients is: absolutely yes, and for most fintech companies we recommend it. Many audit firms offer combined SOC 2 and PCI DSS assessments, and this approach is increasingly common for fintech companies. A combined assessment allows the auditor to evaluate overlapping controls once (rather than twice), reduces total fieldwork time, and provides both reports from a single engagement. The key requirement is that the audit firm must have both CPA licensure (required for SOC 2) and PCI QSA certification (required for PCI DSS), and the assessment team must include qualified personnel for both frameworks. Not all firms have both capabilities, so confirm during auditor selection.
Should fintech companies include the Processing Integrity criteria?
In our experience advising fintech companies, Processing Integrity (PI) is strongly recommended if you perform financial calculations, transaction processing, or data transformations — which includes most fintech products. PI evaluates whether the system processes data completely, accurately, and in a timely manner, which directly aligns with the expectations of financial services partners and regulators. Bank partners evaluating a fintech vendor's SOC 2 report may specifically look for PI coverage. However, PI adds additional controls and audit scope, so we advise clients to evaluate whether the additional cost and complexity are justified by their specific business model and partner requirements.
How do we handle the observation period when bank partners need the report urgently?
Based on what we see working best, the most effective approach is to pursue a Type I report first (which does not require an observation period) while simultaneously beginning the Type II observation period. The Type I report can be issued within two to four weeks of audit engagement and provides bank partners with evidence that your controls are suitably designed, even though operating effectiveness has not yet been tested over time. Many bank partners accept a Type I report as an interim step while waiting for the Type II report. Once the Type II observation period is complete (minimum three months, with six to twelve months preferred), the Type II report supersedes the Type I and provides the full compliance evidence.
What is the typical cost of SOC 2 for a fintech company?
What we tell clients to budget for is a range of forty thousand to one hundred twenty thousand dollars for the first year, depending on company size, scope complexity, and whether PCI DSS is assessed concurrently. The breakdown includes compliance platform (ten thousand to thirty-five thousand dollars), audit fees (fifteen thousand to fifty thousand dollars), advisory support (five thousand to twenty thousand dollars), and internal labor (ten thousand to thirty thousand dollars in staff time). Fintech companies often realize cost savings by reusing PCI DSS controls and infrastructure, reducing the gap remediation effort that drives cost for organizations starting from scratch. Subsequent year costs are typically twenty to thirty percent lower as the renewal process is more efficient.
