SOC 2 and PCI DSS: How Fintech Companies Handle Both

One of the most common conversations we have with fintech clients starts the same way: "We just got our PCI DSS attestation — do we really need SOC 2 too?" The answer is almost always yes, and the good news is that a well-structured combined program is far less painful than running two separate compliance tracks.

Most fintech companies that process, store, or transmit payment card data need both SOC 2 and PCI DSS — and what we recommend is building a single compliance program that satisfies both frameworks simultaneously rather than running two independent programs. SOC 2 and PCI DSS share fifty to sixty percent of their technical security controls, which means in our experience, companies that map controls across both frameworks can reduce their combined compliance effort by thirty to forty percent compared to maintaining separate programs with separate evidence, separate policies, and separate audit timelines.

This guide explains the relationship between SOC 2 and PCI DSS for fintech companies, maps the overlapping controls in detail, provides guidance on scoping a combined program, addresses whether SOC 2 reports can reference PCI DSS controls, and offers practical strategies for running parallel audit timelines and leveraging shared evidence. The target audience is fintech CTOs, compliance managers, and security architects managing dual compliance obligations.

Why Fintech Companies Need Both Frameworks

PCI DSS and SOC 2 serve different stakeholders in the fintech ecosystem, and each is non-negotiable in its domain.

Framework	Required By	What It Demonstrates	Consequence of Non-Compliance
PCI DSS	Card networks (Visa, Mastercard, Discover, Amex) via acquiring banks	Cardholder data is protected according to card network standards	Loss of card processing privileges; fines; breach liability
SOC 2	Enterprise customers, partners, and financial institution buyers	Organizational security controls are designed and operating effectively	Disqualification from enterprise deals; inability to pass security reviews

PCI DSS is a contractual obligation enforced through the payment card ecosystem. Without PCI DSS compliance, you cannot process card payments. SOC 2 is a market-driven requirement enforced by enterprise procurement teams. Without SOC 2, enterprise financial institutions and large merchants may refuse to evaluate your platform as a vendor.

The two frameworks complement each other because PCI DSS demonstrates that your cardholder data environment is secure, while SOC 2 demonstrates that your broader organization — including systems, people, and processes outside the cardholder data environment — operates with security discipline.

Detailed Control Overlap Map

The following mapping shows where PCI DSS v4.0 requirements directly overlap with SOC 2 Trust Service Criteria, enabling shared controls and shared evidence.

Access Controls

PCI DSS Requirement	SOC 2 Criteria	Overlap Detail
Req 7: Restrict access to system components and cardholder data by business need to know	CC6.1-CC6.3: Logical access security	Both require role-based access, least privilege, and formal authorization before access is granted
Req 8: Identify users and authenticate access	CC6.1: Authentication mechanisms	Both require unique user identification and multi-factor authentication
Req 8.3.6: MFA for all access to the CDE	CC6.1: MFA enforcement	Both require MFA; SOC 2 extends MFA to all critical systems, not just CDE
Req 7.2: Access control systems configured by default to deny all	CC6.3: Access based on authorization	Both require default-deny access models

Shared evidence: User access lists, MFA enforcement reports, access provisioning approval records, role-based access configuration documentation.

Encryption and Data Protection

PCI DSS Requirement	SOC 2 Criteria	Overlap Detail
Req 3: Protect stored account data	CC6.1: Data protection at rest	Both require encryption of sensitive data at rest
Req 4: Protect cardholder data with strong cryptography during transmission	CC6.7: Transmission security	Both require TLS 1.2+ for data in transit
Req 3.5: Primary account number (PAN) secured wherever stored	CC6.1: Encryption mechanisms	Both require strong encryption (AES-256 or equivalent)

Shared evidence: Encryption configuration documentation, TLS certificate records, key management procedures.

Monitoring and Logging

PCI DSS Requirement	SOC 2 Criteria	Overlap Detail
Req 10: Log and monitor all access to system components and cardholder data	CC7.1-CC7.2: Monitoring and anomaly detection	Both require comprehensive logging and regular review
Req 10.4: Audit logs are reviewed to identify anomalies	CC7.2: Anomaly evaluation	Both require systematic log review and investigation
Req 10.7: Audit log retention	CC7.1: Monitoring infrastructure	Both require log retention (PCI DSS specifies twelve months; SOC 2 is principle-based)

Shared evidence: Log aggregation configuration, alerting rules, log review records, retention policy documentation.

Vulnerability Management

PCI DSS Requirement	SOC 2 Criteria	Overlap Detail
Req 6.3: Security vulnerabilities identified and addressed	CC7.1: Vulnerability identification	Both require vulnerability scanning and remediation
Req 6.2: Bespoke and custom software developed securely	CC8.1: Change management controls	Both address secure development practices
Req 11.3: External and internal penetration testing	CC7.1: Security testing	Both expect regular penetration testing

Shared evidence: Vulnerability scan reports, penetration test reports, remediation tracking records.

Network Security

PCI DSS Requirement	SOC 2 Criteria	Overlap Detail
Req 1: Install and maintain network security controls	CC6.6: External threat protection	Both require network segmentation and firewall controls
Req 1.2: Network security controls configured and maintained	CC6.6: Network security	Both require documented network architecture with security controls

Shared evidence: Network diagrams, firewall rules, segmentation documentation.

Incident Response

PCI DSS Requirement	SOC 2 Criteria	Overlap Detail
Req 12.10: Incident response plan immediately available	CC7.3-CC7.5: Incident management	Both require documented incident response procedures
Req 12.10.2: Incident response plan tested annually	CC7.3: Incident testing	Both expect regular incident response testing

Shared evidence: Incident response plan, tabletop exercise documentation, incident records.

Where the Frameworks Diverge

Despite significant overlap, each framework has requirements the other does not address.

PCI DSS Requirements Not Covered by SOC 2

PCI DSS Unique Requirement	Description
Req 3.4: PAN rendered unreadable wherever stored	Specific requirement for PAN masking/truncation/tokenization/hashing
Req 3.6-3.7: Cryptographic key management	Detailed key management lifecycle requirements specific to cardholder data
Req 9: Physical access to cardholder data	More prescriptive physical security requirements for CDE
Req 11.1: Wireless access points management	Specific wireless security requirements
Req 11.4: External and internal network scanning (ASV)	Approved Scanning Vendor (ASV) quarterly scanning requirement
Req 12.8: Service provider compliance management	Specific requirements for service provider PCI DSS compliance tracking

SOC 2 Requirements Not Covered by PCI DSS

SOC 2 Unique Requirement	Description
CC1: Control environment governance	Formal organizational commitment to security, ethics, and competence
CC3.3: Fraud risk assessment	Specific fraud risk assessment requirement
CC4: Monitoring activities	Formal ongoing evaluation of controls and deficiency communication
CC9: Broader vendor management	Security assessment of all vendors, not just payment service providers
System description	Formal documentation of services, infrastructure, and boundaries
Management assertion	Written management statement that controls meet TSC
Independent CPA attestation	SOC 2 requires CPA firm report; PCI DSS uses QSA or SAQ

Scoping a Combined Compliance Program

Define the Cardholder Data Environment (CDE)

Your PCI DSS scope is determined by the CDE — systems that store, process, or transmit cardholder data and connected systems. We recommend mapping your CDE carefully because it defines what PCI DSS controls apply to.

Define the SOC 2 System Boundary

Your SOC 2 scope covers the services, infrastructure, and processes described in your system description. This is typically broader than the CDE because it includes your entire service delivery platform, not just the payment-related components.

Identify the Overlap Zone

The overlap zone is where both frameworks apply — typically the CDE and any infrastructure that supports both payment processing and broader service delivery. Controls in the overlap zone satisfy both frameworks simultaneously.

Map Controls Once

Control Area	PCI DSS Scope	SOC 2 Scope	Combined Approach
Access management	CDE systems	All in-scope systems	Implement one access management process across all systems; PCI-specific restrictions on CDE
Encryption	Cardholder data	Customer data broadly	Implement encryption across all sensitive data; PCI-specific requirements for PAN handling
Monitoring	CDE access and activity	All in-scope systems	Implement monitoring across all systems; PCI-specific alerting for CDE events
Change management	CDE systems and applications	All in-scope systems and applications	Single change management process applied universally
Incident response	Payment-related incidents	All security incidents	Single incident response plan with PCI-specific procedures for cardholder data breaches

Leveraging Shared Evidence

The practical benefit of a combined program is evidence reuse. When your auditor evaluates a control for SOC 2, the same evidence can satisfy the corresponding PCI DSS requirement.

Evidence That Serves Both Frameworks

Evidence Item	SOC 2 Control	PCI DSS Requirement
Quarterly access review records	CC6.1-CC6.3	Req 7
MFA enforcement report	CC6.1	Req 8.3.6
Encryption configuration documentation	CC6.1, CC6.7	Req 3, Req 4
Vulnerability scan reports	CC7.1	Req 6.3, Req 11
Penetration test report	CC7.1	Req 11.3
Incident response plan and test records	CC7.3-CC7.5	Req 12.10
Security awareness training records	CC1.4	Req 12.6
Network architecture diagrams	CC6.6	Req 1
Log aggregation and review records	CC7.1-CC7.2	Req 10
Change management records	CC8.1	Req 6.2

GRC Platform Support

Modern GRC platforms — Vanta, Drata, Secureframe, and Sprinto — support both SOC 2 and PCI DSS frameworks simultaneously. When you implement a control, the platform maps it to requirements in both frameworks automatically. Evidence collected once satisfies corresponding requirements across both programs.

Can a SOC 2 Report Reference PCI DSS Controls?

Yes, with specific limitations. Your SOC 2 report's system description can reference your PCI DSS compliance status as context for your control environment. The auditor can note that certain controls (encryption, access management, monitoring) are also maintained under PCI DSS requirements, providing additional assurance.

However, a SOC 2 report does not replace a PCI DSS Report on Compliance (ROC) or Self-Assessment Questionnaire (SAQ). The SOC 2 auditor (CPA firm) is not evaluating PCI DSS compliance — they are evaluating Trust Service Criteria. The reference to PCI DSS is informational, not a substitute for PCI DSS assessment.

Some CPA firms that also hold QSA certifications can conduct both assessments, which creates efficiency through shared understanding of your control environment.

Running Parallel Audit Timelines

Coordinated Timeline Approach

What we tell clients is that the most efficient approach schedules both assessments to overlap or run consecutively.

Phase	SOC 2	PCI DSS	Combined Efficiency
Evidence collection	Continuous (observation period)	Continuous (assessment period)	Align observation and assessment periods to the same dates
Fieldwork	2-4 weeks	2-6 weeks	Schedule consecutively to share interview and evidence review time
Report delivery	2-4 weeks after fieldwork	2-6 weeks after fieldwork	Stagger delivery to manage review workload

Using the Same Firm

If your CPA firm also holds QSA certification, they can conduct both the SOC 2 attestation and PCI DSS assessment. Benefits include:

• Single firm already familiar with your control environment
• Shared interviews — key personnel answer questions for both frameworks in combined sessions
• Evidence reviewed once serves both assessments
• Single point of contact for scheduling and coordination

Using Different Firms

If you use separate firms (common when your SOC 2 auditor is not also a QSA), we advise clients to coordinate by:

• Scheduling SOC 2 and PCI DSS fieldwork in adjacent weeks
• Preparing a shared evidence repository that both auditors can access
• Briefing your team once with combined preparation covering both frameworks
• Providing each auditor with the other's scope to prevent duplicative requests

Cost Efficiency of Combined Programs

Approach	Estimated Annual Cost	Cost Savings
Separate SOC 2 and PCI DSS programs	$80,000-$250,000 combined	Baseline
Combined program (shared controls, shared evidence)	$55,000-$180,000 combined	25-35% savings
Combined program with same firm for both	$50,000-$160,000 combined	30-40% savings

Savings come from reduced internal labor (one evidence collection process instead of two), reduced auditor fees (shared evidence review), and reduced consulting costs (one readiness assessment covering both frameworks).

Key Takeaways

• We see SOC 2 and PCI DSS sharing fifty to sixty percent of technical security controls, concentrated in access management, encryption, monitoring, vulnerability management, and incident response
• We recommend building a combined compliance program, which reduces total compliance effort by thirty to forty percent compared to separate programs
• PCI DSS covers the cardholder data environment specifically; SOC 2 covers the broader service delivery system — we advise fintech clients to pursue both
• Evidence collected for one framework (access reviews, pen test reports, encryption configs) can satisfy corresponding requirements in the other
• We recommend GRC platforms that support both frameworks to automate cross-framework control mapping and evidence sharing
• Using a single CPA/QSA firm for both assessments provides the greatest efficiency through shared interviews and evidence review
• PCI DSS unique requirements include PAN-specific protection, ASV scanning, and service provider compliance tracking
• SOC 2 unique requirements include formal governance documentation, management assertion, independent CPA attestation, and broader vendor management

Frequently Asked Questions

Which framework should fintech companies pursue first?

What we tell clients is this: if you process card payments, PCI DSS is typically in place first because it is a prerequisite for processing transactions. SOC 2 is then layered on top to satisfy enterprise buyer security requirements. If you do not yet process card data (pre-launch or in sandbox mode), we recommend pursuing SOC 2 first to enable enterprise sales conversations and adding PCI DSS when you are ready to go live with card processing.

Can a SOC 2 report substitute for PCI DSS compliance?

Based on what we see across our client base, the answer is definitively no. SOC 2 and PCI DSS are separate requirements from separate governing bodies. Card networks and acquiring banks require PCI DSS compliance to process card payments — a SOC 2 report does not satisfy this requirement. Similarly, enterprise security teams require SOC 2 reports for vendor evaluation — a PCI DSS ROC does not fully address their concerns about organizational security maturity. You need both.

How much additional effort does PCI DSS add if we already have SOC 2?

Based on what we see across our client base, if you already have a mature SOC 2 program, the incremental effort for PCI DSS focuses on CDE-specific requirements: PAN protection (masking, tokenization, or encryption), ASV quarterly scanning, specific key management procedures, and service provider compliance tracking. The incremental cost is typically thirty to fifty percent of a standalone PCI DSS engagement because fifty to sixty percent of requirements are already addressed by your SOC 2 controls.

Do fintech companies need Processing Integrity in their SOC 2?

What we tell clients is that Processing Integrity is strongly recommended for fintech companies that process financial transactions. It validates that system processing is complete, valid, accurate, timely, and authorized — directly addressing what enterprise financial institution buyers care about most. In our experience, companies that exclude Processing Integrity may face questions from sophisticated buyers about why transaction accuracy controls were not independently evaluated.

How do tokenization and encryption strategies affect the combined scope?

What we tell clients is that tokenization reduces PCI DSS scope by replacing cardholder data with tokens — systems that only handle tokens are not in the CDE. This can also simplify SOC 2 scoping because fewer systems contain sensitive payment data. Encryption strategies (at rest and in transit) satisfy requirements in both frameworks simultaneously. In our experience, well-designed tokenization architectures reduce the overlap zone between PCI DSS and SOC 2 scopes, making both programs simpler to manage.