SOC 2 for Payment Processing Companies

If your payment platform already has PCI DSS locked down but enterprise deals keep stalling at the security review stage, we've seen this pattern dozens of times — and SOC 2 is almost always the missing piece. Here's how we guide payment processing companies through it.

Payment processing companies, payment gateways, and merchant services platforms need SOC 2 in addition to PCI DSS because the two frameworks serve fundamentally different audiences. PCI DSS satisfies card network requirements and demonstrates cardholder data protection. SOC 2 satisfies enterprise buyer trust requirements and demonstrates that your organization's broader security controls — access management, change management, incident response, vendor oversight, and operational monitoring — are designed and operating effectively. For payment companies selling to enterprise merchants, platforms, or financial institutions, SOC 2 has become a standard procurement requirement alongside PCI DSS.

This guide covers how to build a SOC 2 compliance program specifically for payment processing companies that already maintain PCI DSS compliance. We walk through the SOC 2 and PCI DSS overlap (which reduces your incremental effort), the Trust Service Criteria most relevant to payment platforms, scoping challenges unique to tokenization vaults and settlement systems, processing integrity controls that are critical for transaction accuracy, and how enterprise buyers in the payments industry evaluate SOC 2 reports.

Why Payment Companies Need Both SOC 2 and PCI DSS

PCI DSS and SOC 2 are complementary — not interchangeable — frameworks. Understanding why enterprise buyers require both helps you prioritize and communicate your compliance position.

Different Audiences, Different Purposes

Dimension	PCI DSS	SOC 2
Who requires it	Card networks (Visa, Mastercard, etc.) and acquiring banks	Enterprise merchants, platforms, and financial institution partners
What it covers	Cardholder data environment (CHD and SAD)	Entire service delivery system including people, processes, and technology
Focus	Protecting payment card data specifically	Demonstrating organizational security maturity broadly
Assessment type	Self-assessment or QSA assessment	CPA firm attestation
Report format	Report on Compliance (ROC) or SAQ	SOC 2 Type I or Type II report
Buyer usage	Verified during onboarding; rarely reviewed in depth by merchants	Read in detail by security teams during procurement evaluation

The Gap PCI DSS Does Not Fill

PCI DSS is scoped specifically to the cardholder data environment — the systems, networks, and processes that store, process, or transmit cardholder data. It does not evaluate your broader organizational security practices: how you manage employee access across all systems, how you handle change management for non-payment infrastructure, whether you conduct risk assessments beyond the CDE, or how you manage third-party vendors who do not touch cardholder data.

In our experience working with payment companies, this gap is where enterprise deals get stuck. Enterprise buyers — particularly large merchants, e-commerce platforms, and financial institutions — need assurance that your entire organization operates with security discipline, not just the payment-processing components. SOC 2 provides this broader view. We regularly see payment companies with PCI DSS but no SOC 2 struggle to close enterprise deals where the buyer's security team evaluates vendor security holistically.

SOC 2 and PCI DSS Control Overlap

Organizations already maintaining PCI DSS compliance have a significant head start on SOC 2. In our experience, approximately fifty to sixty percent of SOC 2 controls overlap with PCI DSS requirements, particularly in technical security areas. We tell our clients this is one of the best leverage points in compliance — you've already done the hardest technical work.

Overlap Map

Control Area	PCI DSS Requirement	SOC 2 Equivalent	Overlap Level
Access management	Req 7: Restrict access by business need	CC6.1-CC6.3: Logical access controls	High
Authentication	Req 8: Identify users, authenticate access	CC6.1: Authentication mechanisms	High
Encryption (transit)	Req 4: Encrypt transmission over open networks	CC6.7: Transmission security	Full
Encryption (at rest)	Req 3: Protect stored cardholder data	CC6.1: Data protection	High
Logging and monitoring	Req 10: Log and monitor access	CC7.1-CC7.2: Monitoring and anomaly detection	High
Vulnerability management	Req 6: Develop secure systems	CC7.1: Vulnerability identification	Moderate
Network segmentation	Req 1: Network security controls	CC6.6: External threat protection	Moderate
Physical security	Req 9: Restrict physical access	CC6.4: Physical access controls	Moderate
Incident response	Req 12.10: Incident response plan	CC7.3-CC7.5: Incident management	Moderate
Security policies	Req 12: Security policies and programs	CC1-CC2: Control environment, communication	Moderate

Where SOC 2 Goes Beyond PCI DSS

SOC 2 requires several control areas that PCI DSS does not address (or addresses only minimally). We recommend our payment processing clients pay close attention to these gaps early, since they represent the bulk of your incremental work:

• Formal risk assessment methodology: SOC 2 requires a documented risk assessment process with risk registers and treatment plans beyond PCI DSS's risk assessment requirement
• Vendor management program: SOC 2 expects security assessments of all third-party vendors, not just those in the cardholder data environment
• Change management formalization: SOC 2 requires documented change management controls with approval workflows across all in-scope systems
• Employee lifecycle management: SOC 2 evaluates background checks, security training, and offboarding for all employees, not just those with CDE access
• Board/leadership security oversight: SOC 2 expects evidence that security is discussed at the organizational leadership level
• Business continuity and disaster recovery: SOC 2 evaluates broader continuity planning beyond PCI DSS's CDE-focused requirements
• Independent CPA attestation: SOC 2 requires a CPA firm report; PCI DSS uses QSA assessment or self-assessment

Trust Service Criteria for Payment Platforms

Choosing the right Trust Service Criteria is critical for payment processing companies. Enterprise buyers in the payments industry have specific expectations, and we advise our clients to think carefully about which criteria to include from day one.

Recommended Criteria

Criterion	Recommendation	Reasoning
Security (Common Criteria)	Required for all	Mandatory for every SOC 2 audit
Processing Integrity	Strongly recommended	Validates transaction accuracy, completeness, and authorization — core to payment platform value
Availability	Strongly recommended	Validates uptime and reliability commitments critical for payment processing
Confidentiality	Recommended	Validates protection of merchant data, transaction records, and business intelligence
Privacy	Situational	Required if you collect or process consumer PII directly (beyond card data)

Processing Integrity: The Critical Criterion for Payments

Processing Integrity is the criterion that distinguishes payment company SOC 2 reports from generic SaaS SOC 2 reports. It evaluates whether your system processing is complete, valid, accurate, timely, and authorized — precisely the assurances enterprise merchants need when routing transactions through your platform.

Processing Integrity controls specific to payment platforms:

• Transaction completeness: Controls that ensure all initiated transactions are processed and no transactions are lost, duplicated, or dropped
• Transaction accuracy: Validation that transaction amounts, currencies, merchant identifiers, and settlement figures are processed correctly
• Transaction authorization: Verification that every transaction is properly authorized before processing and that unauthorized transactions are rejected
• Settlement accuracy: Controls ensuring that merchant settlements reconcile accurately with processed transactions
• Error detection and correction: Automated systems that identify processing errors, transaction discrepancies, and reconciliation failures with defined correction procedures
• Processing audit trails: Complete, immutable records of every transaction from initiation through settlement

Without Processing Integrity, your SOC 2 report documents generic security controls but does not directly address what enterprise payment buyers care most about: whether your platform processes their transactions correctly and reliably. We strongly recommend every payment processing company include it.

Scoping Challenges for Payment Platforms

Payment processing infrastructure has unique characteristics that create scoping challenges for SOC 2 audits. We help our clients navigate these early so there are no surprises during the audit itself.

Tokenization Vaults

If your platform uses tokenization to protect cardholder data, the tokenization vault occupies a unique position in your SOC 2 scope:

• The vault itself is typically in scope for both PCI DSS and SOC 2
• Controls around vault access, key management, and token lifecycle management must be documented for both frameworks
• The benefit of tokenization for SOC 2 is that it reduces the sensitivity of data in other system components — non-vault systems handle tokens rather than cardholder data, which simplifies the SOC 2 data flow documentation

Payment Rails and Third-Party Processors

Payment platforms often connect to multiple payment rails (card networks, ACH, wire transfer systems) through third-party processors and financial institution partners. For SOC 2 scoping:

• Complementary User Entity Controls (CUECs): Document which security controls your merchants and partners must implement on their end
• Subservice organization considerations: If you rely on third-party processors for core transaction processing, their SOC 2 report (or lack thereof) affects your report. You must either use the inclusive method (incorporating their controls into your report) or the carve-out method (excluding them and noting the dependency)
• API security boundary: Your APIs that connect to payment rails must be in scope, with controls around authentication, rate limiting, input validation, and error handling

Settlement Systems

Settlement and reconciliation systems present scoping considerations because they handle financial data that directly affects merchant revenue:

• Settlement calculations must be in scope if Processing Integrity is included
• Reconciliation processes between transaction processing and merchant settlements should be documented as controls
• Settlement timing (daily, weekly, custom schedules) must be accurately described in the system description

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Enterprise Buyer Expectations in Payments

Enterprise merchants, platforms, and financial institutions evaluate payment vendor SOC 2 reports with specific expectations that differ from typical B2B SaaS procurement. Based on what we see across our payment processing clients, here is what those buyers focus on.

What Payment Buyers Look For

Buyer Expectation	What They Review	Why It Matters
Processing Integrity inclusion	Whether the PI criterion is in scope	Validates transaction accuracy and reliability
Availability commitments	SLA documentation and uptime evidence	Payment downtime directly impacts merchant revenue
Key management controls	Encryption key rotation, access restrictions, HSM usage	Critical for payment security infrastructure
Multi-tenancy isolation	Merchant data segregation controls	Ensures one merchant's data cannot be accessed by another
Incident response maturity	Response procedures, incident history, breach notification	Evaluates how the platform handles payment disruptions
Subservice organization treatment	How third-party processors are addressed in the report	Assesses supply chain risk in the payment flow

Financial Institution Partners

Banks and financial institutions that partner with payment platforms often have the most rigorous SOC 2 review processes. In our experience:

• They typically require Type II reports with twelve-month observation periods
• They expect all five Trust Service Criteria or at minimum Security, Processing Integrity, and Availability
• Their security review teams are experienced SOC 2 readers who examine exceptions closely
• They may require additional reporting beyond the standard SOC 2 report (questionnaires, on-site assessments)

Building a Unified PCI DSS + SOC 2 Program

The most efficient approach — and what we recommend to every payment processing client — is to build a single compliance program that satisfies both frameworks rather than managing them separately.

Step 1: Map Existing PCI DSS Controls to SOC 2

Review your current PCI DSS controls and map each one to the corresponding SOC 2 Trust Service Criteria. The overlap map above provides the starting point. For each PCI DSS control, determine whether it fully satisfies the SOC 2 requirement, partially satisfies it (requiring extension), or has no SOC 2 equivalent.

Step 2: Extend Controls Beyond the CDE

The primary gap between PCI DSS and SOC 2 is scope. PCI DSS controls are scoped to the cardholder data environment. SOC 2 requires these same types of controls applied across your entire service delivery system. Extension means applying access management, monitoring, and change control practices to non-CDE systems that are in your SOC 2 scope.

Step 3: Add SOC 2-Specific Controls

Implement the SOC 2 requirements that PCI DSS does not cover:

• Formal risk assessment with risk register and treatment plans
• Comprehensive vendor management program covering all third-party vendors
• Board/leadership security oversight documentation
• Enhanced business continuity and disaster recovery testing
• Formalized employee lifecycle management with background checks and annual training

Step 4: Use a Single GRC Platform

GRC platforms like Vanta, Drata, and Secureframe support both SOC 2 and PCI DSS frameworks. Controls implemented once are automatically mapped to both frameworks, evidence is shared, and compliance status is tracked across both programs on a single dashboard.

Step 5: Coordinate Audit Timing

Schedule PCI DSS and SOC 2 assessments to run consecutively or use overlapping timelines. Using the same or affiliated audit firms for both engagements reduces total interview and evidence review time. Some CPA firms that perform SOC 2 audits also have QSA certifications for PCI DSS, enabling a single firm to conduct both assessments.

Cost Efficiency

Organizations already maintaining PCI DSS typically spend twenty to forty percent less on their initial SOC 2 engagement compared to organizations starting from scratch. The savings come from existing technical controls (encryption, logging, access management), established security policies, and organizational familiarity with compliance processes.

We help our clients build unified PCI DSS and SOC 2 programs from the ground up — mapping existing controls, closing gaps efficiently, and coordinating audit timelines so nothing is duplicated unnecessarily.

Key Takeaways

• We advise payment processing companies to pursue both PCI DSS and SOC 2 because they serve different audiences — card networks versus enterprise buyers — and neither substitutes for the other
• In our experience, PCI DSS and SOC 2 overlap fifty to sixty percent on technical security controls, giving PCI-compliant organizations a significant head start that we help clients leverage fully
• We strongly recommend including Processing Integrity as a Trust Service Criterion for payment platforms — it validates transaction accuracy, completeness, and authorization, which is what enterprise buyers care most about
• We also recommend Availability and Confidentiality alongside Security and Processing Integrity for a complete payment company SOC 2 report
• Scoping challenges we frequently navigate with clients include tokenization vault boundaries, payment rail dependencies, subservice organization treatment, and settlement system inclusion
• Enterprise payment buyers and financial institution partners expect mature SOC 2 reports with Processing Integrity, twelve-month observation periods, and detailed subservice organization documentation — we prepare clients for this level of scrutiny
• Building a unified PCI DSS + SOC 2 program managed through a single GRC platform is forty to fifty percent more efficient than maintaining separate programs, and it is the approach we recommend to every payment processing client
• Organizations already PCI DSS compliant typically spend twenty to forty percent less on initial SOC 2, and we help ensure that cost advantage is fully realized

Frequently Asked Questions

Does PCI DSS compliance mean we are already SOC 2 compliant?

What we tell clients is: PCI DSS gives you a tremendous head start, but it does not get you across the finish line on its own. PCI DSS covers cardholder data environment controls specifically, while SOC 2 evaluates your broader organizational security program. In our experience, approximately fifty to sixty percent of SOC 2 controls are already addressed by a solid PCI DSS program — but you still need to extend controls beyond the CDE, implement SOC 2-specific requirements like formal risk assessment, vendor management, and leadership oversight, and engage a CPA firm for the SOC 2 attestation. We treat PCI DSS and SOC 2 as complementary certifications, not substitutes.

Which should we pursue first — SOC 2 or PCI DSS?

Based on what we see with our payment processing clients, PCI DSS should come first if you process card payments — it is non-negotiable and a contractual requirement from card networks and acquiring banks. SOC 2 is a market requirement driven by enterprise buyer expectations. Most payment companies we work with establish PCI DSS compliance first (often required to begin processing), then add SOC 2 to expand their enterprise sales capabilities. That said, both frameworks can be pursued simultaneously using a GRC platform that supports dual-framework compliance, and we help clients do this when timelines demand it.

How much does adding SOC 2 cost on top of our existing PCI DSS program?

In our experience, for payment companies with established PCI DSS compliance, incremental SOC 2 costs typically range from $40,000-$100,000 in year one (including auditor fees, GRC platform, and internal effort) and $30,000-$80,000 annually thereafter. This is twenty to forty percent less than the typical SOC 2 cost for organizations without PCI DSS because existing technical controls, security policies, and compliance team experience reduce the implementation and audit effort. We help clients maximize that overlap so they are not paying for redundant work.

Do our merchants care whether our SOC 2 includes Processing Integrity?

What we consistently see is that enterprise merchants increasingly expect Processing Integrity in payment vendor SOC 2 reports. Smaller merchants may not review SOC 2 reports in detail, but enterprise merchants, platforms, and financial institution partners specifically look for Processing Integrity because it validates that your platform processes transactions accurately and reliably. Including Processing Integrity adds approximately ten to fifteen percent to auditor fees but significantly strengthens your SOC 2 report's relevance to the payments industry. We recommend it for every payment processing client.

Can we use the same auditor for both PCI DSS and SOC 2?

We advise clients to explore this option whenever possible. Some audit firms hold both CPA firm credentials (for SOC 2) and QSA certifications (for PCI DSS), enabling them to conduct both assessments. Using a single firm reduces total audit effort because the auditor already understands your control environment, infrastructure, and security practices. Even if you use different firms, we recommend coordinating the audit timelines so evidence collected for one assessment can be reused for the other.