Framework deep-dive · SOC 2 + AI

SOC 2, with AI controls stapled on.

Every enterprise buyer already has SOC 2. The 2017 Trust Services Criteria don't name AI; auditors are inventing the questions anyway. Here's what they ask, what the CSA AI Controls Matrix adds, and the AI addendum you append to your Type II.

TLDR

01 / Why this question, why now

SOC 2 didn't ask. Buyers started asking under the same letterhead.

SOC 2 examinations are scoped against the AICPA's Trust Services Criteria (TSC) 2017. That document predates ChatGPT. It does not name "AI" once. So when an enterprise buyer in 2026 asks "how do you govern employee AI use?" inside a SOC 2 review, the auditor has to choose where the question lives. They map it to the closest existing criteria, normally CC6.1 (logical access controls to system data) and CC7.2 (system monitoring for anomalies and events).

The result: SOC 2 Type II reports increasingly carry an AI controls evidence appendix that didn't exist two years ago. Some auditors call it a "supplemental control narrative." Others fold it into expanded testing under CC6.1. Either way, the customer is being asked to produce something most companies do not have: a continuous, defensible record of which AI tools their workforce uses and how access is governed.

The shortcut some vendors have taken is to write a one-pager: "we have a written AI usage policy." Auditors stopped accepting that in 2026. They want evidence the policy is enforced.

02 / The control surface auditors actually invoke

Two TSC controls. One CSA matrix.

CC6.1 · Logical and physical access controls. The criterion that asks "the entity implements logical access security software, infrastructure, and architectures over protected information assets." When the protected information asset is "data customers share with us," and the access surface is "any AI tool an employee can paste data into," CC6.1 is the umbrella the question lives under.

CC7.2 · System operations monitoring. The criterion that asks "the entity monitors system components and the operation of those components for anomalies." Auditors apply it to "monitor AI-tool usage for unusual data exposure." A Notion doc doesn't satisfy continuous monitoring. A monthly screenshot doesn't either.

The Cloud Security Alliance AI Controls Matrix. Released to fill the AICPA gap. Roughly two dozen control objectives covering AI inventory, data classification at capture time, third-party AI risk management, and AI-specific incident response. Auditors increasingly cross-reference CSA when expanding SOC 2 scope into AI.

03 / Control mapping

How Northbeams evidences SOC 2 + AI.

16 controls in the SOC 2 + AI pack today: 2 TSC and 14 CSA. AUTO means Northbeams telemetry alone proves it; ATTEST means a named human signed; scoped-out means out of scope with a written reason.

ControlSubjectStatusEvidence source
CC6.1Logical access to AI toolsAUTOPer-tool allow / warn / block + audit log
CC7.2Monitoring of AI system activityAUTOContinuous event log, daily re-evaluation
CSA AI-01AI system inventoryAUTODiscovery refreshed continuously across 4 surfaces
CSA AI-04Data classification at captureAUTOOn-device classifier output (label, never raw text)
CSA AI-07Sensitive-data exposure preventionAUTOPer-prompt sandbox / block decisions
CSA AI-09Third-party AI riskATTESTVendor security review record
CSA AI-11AI incident responseATTESTIR runbook + tabletop record
CSA AI-15Workforce AI literacy trainingATTESTLMS completion record
CSA AI-22Model output bias monitoringSCOPEDOut of scope for deployer-side use

Full 16-row mapping is in the Evidence Pack itself. The table above is the abbreviated cover.

04 / How it lands at the audit

Annex, do not re-audit.

The Type II report your auditor will issue at the end of the period covers a defined examination period (usually 6 or 12 months). You do not need to start a separate engagement for AI; you need to extend the existing one.

Three things to ask your auditor at the kickoff:

Most Big-4 and mid-market firms in 2026 accept the annex pattern. Smaller firms occasionally ask for the parallel structure; the Evidence Pack supports either layout via the scope statement.

How Northbeams produces this evidence.

Northbeams catches AI activity on browser, desktop, CLI, and MCP. The on-device classifier labels each prompt at capture (PII, credentials, source code, customer data, contracts). Per-tool policy enforces allow / warn / block. Every action lands on a hash-chained append-only event log.

The SOC 2 + AI Evidence Pack reads from that log, maps to the 16 controls, samples events for the appendix, and ships as a signed PDF you staple to your Type II.

The Type II is already happening. Annex the AI evidence to it.

Forward the sample pack to your SOC 2 firm. Ask them what's missing. We iterate the format with auditors who want a real answer to the AI question.