SOC 2 vs NIS2: a customer report and an EU law
SOC 2 (Trust Services Criteria) · NIS2 Implementing Regulation (EU) 2024/2690 · data 2026-10-27
By Paul Gillet · Updated 2026-10-17
SOC 2 and NIS2 rarely get compared directly, but US-origin software companies expanding into the EU increasingly face both. SOC 2 is a voluntary attestation report customers ask for; NIS2 is EU law for essential and important entities, and for digital providers its measures are spelled out in Implementing Regulation (EU) 2024/2690.
Going from SOC 2 to NIS2, nearly every requirement point maps to a SOC 2 criterion in our data: governance, risk assessment, access control, change management, incident response, vendor management and business continuity all line up. What SOC 2 doesn't give you is NIS2's legal machinery: the 24-hour, 72-hour and one-month incident reports, management training and liability, and registration with the national authority.
Going from NIS2 to SOC 2, the gaps are SOC 2's optional categories, Privacy and Processing Integrity, which NIS2 doesn't cover. Every SOC 2 link here is ControlMapping editorial, since no openly licensed SOC 2 crosswalk exists.
Key takeaways
- A SOC 2 control set is a good base for NIS2 measures; the legal obligations are the new work.
- Add a significant-incident reporting procedure with 24-hour and 72-hour deadlines.
- Check which national law applies to you and whether you must register.
Of 49 NIS2 Implementing Regulation (EU) 2024/2690 requirements, 47 map to something in SOC 2, 1 are only loosely related, and 1 have no mapping in our data.
NIS2 here is the technical measures of Implementing Regulation (EU) 2024/2690, which applies directly to digital-infrastructure and ICT-service providers; other NIS2 entities follow their country's transposition of Article 21. Incident reporting deadlines (Article 23) are not in scope. ENISA's mapping is non-binding.
Likely new work: NIS2 requirements with no mapping to SOC 2 (1)
| NIS2 | Requirement | Match | SOC 2 | Evidence |
|---|---|---|---|---|
| 12. Asset management · 1 | ||||
| 12.5 | Deposit, return or deletion of assets upon termination of employment | No mapping in our data | — | No mapping to SOC 2 in our data. |
Check these: only loosely related (a shared CSF outcome, not a mapping) (1)
| NIS2 | Requirement | Match | SOC 2 | Evidence |
|---|---|---|---|---|
| 10. Human resources security · 1 | ||||
| 10.1 | Human resources security | CC1.4CC2.2 | Only shares CSF PR.AT-02: related, not a mapping | |
Mapped (47)
| NIS2 | Requirement | Match | SOC 2 | Evidence |
|---|---|---|---|---|
| 1. Policy on the security of network and information systems · 2 | ||||
| 1.1 | Policy on the security of network and information systems | Editorial | CC1.1CC5.3 | Same topic: Governance Policy (editorial pick) |
| 1.2 | Roles, responsibilities and authorities | Editorial | CC1.2CC1.3CC1.5 | Same topic: Roles & Responsibilities (editorial pick) |
| 2. Risk management policy · 3 | ||||
| 2.1 | Risk management framework | Editorial | CC3.1CC3.2CC3.3+3 | Same topic: Risk Management, Risk Assessment (editorial pick) |
| 2.2 | Compliance monitoring | Editorial | CC4.1CC4.2 | Same topic: Compliance (editorial pick) |
| 2.3 | Independent review of information and network security | Editorial | CC4.1CC4.2 | Same topic: Compliance (editorial pick) |
| 3. Incident handling · 6 | ||||
| 3.1 | Incident handling policy | Editorial | CC7.3CC7.4 | Same topic: Incident Response (editorial pick) |
| 3.2 | Monitoring and logging | Editorial | CC7.2CC7.3 | Same topic: Cont. Monitoring, Logging & Audit, Intrusion Detection, SIEM / SOC (editorial pick) |
| 3.3 | Event reporting | Editorial | CC2.3 | Same topic: Reporting (editorial pick) |
| 3.4 | Event assessment and classification | Editorial | CC7.2CC7.3 | Same topic: Anomaly Detection, SIEM / SOC (editorial pick) |
| 3.5 | Incident response | Editorial | CC7.3CC7.4 | Same topic: Incident Response, Forensics, Mitigation (editorial pick) |
| 3.6 | Post-incident reviews | Editorial | CC7.5 | Same topic: Lessons Learned (editorial pick) |
| 4. Business continuity and crisis management · 3 | ||||
| 4.1 | Business continuity and disaster recovery plan | Editorial | A1.1A1.2A1.3+2 | Same topic: Business Continuity, Disaster Recovery, Recovery Planning (editorial pick) |
| 4.2 | Backup management | Editorial | A1.2A1.3 | Same topic: Backup & Recovery, Disaster Recovery (editorial pick) |
| 4.3 | Crisis management | Editorial | A1.1A1.2CC2.3+2 | Same topic: Business Continuity, Communication, Comms & Restore (editorial pick) |
| 5. Supply chain security · 2 | ||||
| 5.1 | Supply chain security policy | Editorial | CC9.2 | Same topic: Supply Chain Risk, Vendor Risk Mgmt (editorial pick) |
| 5.2 | Directory of suppliers and service providers | Editorial | CC9.2 | Same topic: Vendor Risk Mgmt (editorial pick) |
| 6. Security in acquisition, development and maintenance · 10 | ||||
| 6.1 | Security in acquisition of ICT services, ICT systems or ICT products | Editorial | CC9.2 | Same topic: Supply Chain Risk, Cloud Security, Vendor Risk Mgmt (editorial pick) |
| 6.2 | Secure development life cycle | Editorial | CC8.1 | Same topic: Secure Development (editorial pick) |
| 6.3 | Configuration management | Editorial | CC5.2CC7.1 | Same topic: Secure Config (editorial pick) |
| 6.4 | Change management, repairs and maintenance | Editorial | CC8.1 | ControlMapping editorial: Change management: SOC 2 requires changes to be authorised, tested and approved; NIS2 point 6.4 requires change management, repairs and maintenance procedures. |
| 6.5 | Security testing | Editorial | CC7.1 | Same topic: Vulnerability Mgmt (editorial pick) |
| 6.6 | Security patch management | Editorial | CC7.1 | Same topic: Patch Management (editorial pick) |
| 6.7 | Network security | Editorial | CC6.6 | Same topic: Firewall / Net Seg (editorial pick) |
| 6.8 | Network segmentation | Editorial | CC6.6 | Same topic: Firewall / Net Seg, Zero Trust (editorial pick) |
| 6.9 | Protection against malicious and unauthorised software | Editorial | CC6.8 | Same topic: Endpoint Protection, Email Security (editorial pick) |
| 6.10 | Vulnerability handling and disclosure | Editorial | CC7.1 | Same topic: Vulnerability Mgmt (editorial pick) |
| 7. Assessing the effectiveness of cybersecurity risk-management measures · 1 | ||||
| 7.1 | Policies and procedures to assess the effectiveness of cybersecurity risk-management measures | Editorial | CC3.1CC5.1CC9.1 | Same topic: Risk Management (editorial pick) |
| 8. Basic cyber hygiene practices and security training · 2 | ||||
| 8.1 | Awareness raising and basic cyber hygiene practices | Editorial | CC1.4CC2.2 | Same topic: Awareness & Training (editorial pick) |
| 8.2 | Security training | Editorial | CC1.4CC2.2 | Same topic: Awareness & Training (editorial pick) |
| 9. Cryptography · 1 | ||||
| 9.1 | Cryptography | Editorial | CC6.1CC6.7 | Same topic: Encryption (editorial pick) |
| 10. Human resources security · 3 | ||||
| 10.2 | Verification of Background | Editorial | CC1.4 | ControlMapping editorial: Background verification: SOC 2's commitment to competence includes screening; NIS2 point 10.2 requires background checks where appropriate. |
| 10.3 | Termination or change of employment procedures | Editorial | CC6.2 | ControlMapping editorial: Leavers and movers: SOC 2 requires access to be removed when no longer needed; NIS2 point 10.3 covers termination or change of employment. |
| 10.4 | Disciplinary process | Editorial | CC1.5 | ControlMapping editorial: Accountability: SOC 2 holds people accountable for their responsibilities; NIS2 point 10.4 requires a disciplinary process for violations. |
| 11. Access control · 7 | ||||
| 11.1 | Access control policy | Editorial | CC6.1CC6.2CC6.3+1 | Same topic: Access Control (editorial pick) |
| 11.2 | Management of access rights | Editorial | CC6.1CC6.2CC6.3 | Same topic: Access Control (editorial pick) |
| 11.3 | Privileged accounts and system administration accounts | Editorial | CC6.3 | Same topic: Privileged Access (editorial pick) |
| 11.4 | Administration systems | Editorial | CC6.3 | Same topic: Privileged Access (editorial pick) |
| 11.5 | Identification | Editorial | CC6.1CC6.2CC6.3 | Same topic: Access Control (editorial pick) |
| 11.6 | Authentication | Editorial | CC6.1CC6.6 | Same topic: Multi-Factor Auth, Zero Trust (editorial pick) |
| 11.7 | Multi-factor authentication | Editorial | CC6.1 | Same topic: Multi-Factor Auth (editorial pick) |
| 12. Asset management · 4 | ||||
| 12.1 | Asset classification | Editorial | C1.1 | Same topic: Data Classification (editorial pick) |
| 12.2 | Handling of assets | Editorial | C1.2CC6.5 | Same topic: Data Protection (editorial pick) |
| 12.3 | Removable media policy | Editorial | C1.2CC6.5CC6.7 | Same topic: Data Protection, DLP (editorial pick) |
| 12.4 | Asset inventory | Editorial | CC6.1 | Same topic: Asset Management (editorial pick) |
| 13. Environmental and physical security · 3 | ||||
| 13.1 | Supporting utilities | Editorial | CC6.4 | Same topic: Physical Security (editorial pick) |
| 13.2 | Protection against physical and environmental threats | Editorial | CC6.4 | Same topic: Physical Security (editorial pick) |
| 13.3 | Perimeter and physical access control | Editorial | CC6.4 | Same topic: Physical Security (editorial pick) |
Of 61 SOC 2 (Trust Services Criteria) requirements, 37 map to something in NIS2, 0 are only loosely related, and 24 have no mapping in our data.
AICPA's SOC 2 mappings aren't openly licensed, so every SOC 2 link here is ControlMapping editorial: criteria we haven't mapped can't match. Processing-integrity (PI) criteria and most privacy (P) criteria have no equivalent in security frameworks.
Likely new work: SOC 2 requirements with no mapping to NIS2 (24)
| SOC 2 | Requirement | Match | NIS2 | Evidence |
|---|---|---|---|---|
| CC2 Communication and information · 1 | ||||
| CC2.1 | Quality information to support internal control | No mapping in our data | — | No mapping to NIS2 in our data. |
| P Privacy · 18 | ||||
| P1.1 | Privacy notice | No mapping in our data | — | No mapping to NIS2 in our data. |
| P2.1 | Choice and consent | No mapping in our data | — | No mapping to NIS2 in our data. |
| P3.1 | Collection limited to privacy objectives | No mapping in our data | — | No mapping to NIS2 in our data. |
| P3.2 | Explicit consent where required | No mapping in our data | — | No mapping to NIS2 in our data. |
| P4.1 | Use limited to privacy objectives | No mapping in our data | — | No mapping to NIS2 in our data. |
| P4.2 | Retention of personal information | No mapping in our data | — | No mapping to NIS2 in our data. |
| P4.3 | Disposal of personal information | No mapping in our data | — | No mapping to NIS2 in our data. |
| P5.1 | Data subject access | No mapping in our data | — | No mapping to NIS2 in our data. |
| P5.2 | Correction of personal information | No mapping in our data | — | No mapping to NIS2 in our data. |
| P6.1 | Disclosure to third parties with consent | No mapping in our data | — | No mapping to NIS2 in our data. |
| P6.2 | Record of authorized disclosures | No mapping in our data | — | No mapping to NIS2 in our data. |
| P6.3 | Record of unauthorized disclosures | No mapping in our data | — | No mapping to NIS2 in our data. |
| P6.4 | Privacy commitments from third parties | No mapping in our data | — | No mapping to NIS2 in our data. |
| P6.5 | Notification by third parties of unauthorized disclosures | No mapping in our data | — | No mapping to NIS2 in our data. |
| P6.6 | Breach notification to affected individuals | No mapping in our data | — | No mapping to NIS2 in our data. |
| P6.7 | Accounting of disclosures to data subjects | No mapping in our data | — | No mapping to NIS2 in our data. |
| P7.1 | Quality of personal information | No mapping in our data | — | No mapping to NIS2 in our data. |
| P8.1 | Handling privacy inquiries, complaints and disputes | No mapping in our data | — | No mapping to NIS2 in our data. |
| PI1 Processing integrity · 5 | ||||
| PI1.1 | Information about processing objectives | No mapping in our data | — | No mapping to NIS2 in our data. |
| PI1.2 | Controls over system inputs | No mapping in our data | — | No mapping to NIS2 in our data. |
| PI1.3 | Controls over system processing | No mapping in our data | — | No mapping to NIS2 in our data. |
| PI1.4 | Controls over system outputs | No mapping in our data | — | No mapping to NIS2 in our data. |
| PI1.5 | Storing inputs, items in processing and outputs | No mapping in our data | — | No mapping to NIS2 in our data. |
Mapped (37)
| SOC 2 | Requirement | Match | NIS2 | Evidence |
|---|---|---|---|---|
| A1 Availability · 3 | ||||
| A1.1 | Capacity management to meet availability commitments | Editorial | 4.14.3 | Same topic: Business Continuity (editorial pick) |
| A1.2 | Environmental protections, backups and recovery infrastructure | Editorial | 4.14.24.3 | Same topic: Business Continuity, Disaster Recovery, Backup & Recovery (editorial pick) |
| A1.3 | Testing recovery plan procedures | Editorial | 4.14.2 | Same topic: Recovery Planning, Disaster Recovery (editorial pick) |
| C1 Confidentiality · 2 | ||||
| C1.1 | Identifying and protecting confidential information | Editorial | 12.1 | Same topic: Data Classification (editorial pick) |
| C1.2 | Disposing of confidential information | Editorial | 12.212.3 | Same topic: Data Protection (editorial pick) |
| CC1 Control environment · 5 | ||||
| CC1.1 | Commitment to integrity and ethical values | Editorial | 1.1 | Same topic: Governance Policy (editorial pick) |
| CC1.2 | Board independence and oversight of internal control | Editorial | 1.2 | Same topic: Roles & Responsibilities (editorial pick) |
| CC1.3 | Structures, reporting lines, authorities and responsibilities | Editorial | 1.2 | Same topic: Roles & Responsibilities (editorial pick) |
| CC1.4 | Commitment to attracting, developing and retaining competent people | Editorial | 8.18.210.2 | Same topic: Awareness & Training (editorial pick) |
| CC1.5 | Accountability for internal control responsibilities | Editorial | 1.210.4 | Same topic: Roles & Responsibilities (editorial pick) |
| CC2 Communication and information · 2 | ||||
| CC2.2 | Internal communication of objectives and responsibilities | Editorial | 8.18.2 | Same topic: Awareness & Training (editorial pick) |
| CC2.3 | Communication with external parties | Editorial | 3.34.3 | Same topic: Reporting, Communication, Comms & Restore (editorial pick) |
| CC3 Risk assessment · 4 | ||||
| CC3.1 | Objectives specified clearly enough to identify risks | Editorial | 2.17.1 | Same topic: Risk Management (editorial pick) |
| CC3.2 | Risk identification and analysis | Editorial | 2.1 | Same topic: Risk Assessment (editorial pick) |
| CC3.3 | Considering the potential for fraud | Editorial | 2.1 | Same topic: Risk Assessment (editorial pick) |
| CC3.4 | Identifying and assessing significant changes | Editorial | 2.1 | Same topic: Risk Assessment (editorial pick) |
| CC4 Monitoring activities · 2 | ||||
| CC4.1 | Ongoing and/or separate evaluations of controls | Editorial | 2.22.3 | Same topic: Compliance (editorial pick) |
| CC4.2 | Communicating and remediating control deficiencies | Editorial | 2.22.3 | Same topic: Compliance (editorial pick) |
| CC5 Control activities · 3 | ||||
| CC5.1 | Control activities that mitigate risks | Editorial | 2.17.1 | Same topic: Risk Management (editorial pick) |
| CC5.2 | General controls over technology | Editorial | 6.3 | Same topic: Secure Config (editorial pick) |
| CC5.3 | Control activities deployed through policies and procedures | Editorial | 1.1 | Same topic: Governance Policy (editorial pick) |
| CC6 Logical and physical access · 8 | ||||
| CC6.1 | Logical access security over information assets | Editorial | 9.111.111.2+4 | Same topic: Encryption, Access Control (editorial pick) |
| CC6.2 | User registration, authorization and removal | Editorial | 11.111.211.5+1 | Same topic: Access Control (editorial pick) |
| CC6.3 | Role-based access, least privilege and segregation of duties | Editorial | 11.111.211.3+2 | Same topic: Access Control, Privileged Access (editorial pick) |
| CC6.4 | Physical access restrictions | Editorial | 13.113.213.3 | Same topic: Physical Security (editorial pick) |
| CC6.5 | Protection of data when assets are disposed of | Editorial | 12.212.3 | Same topic: Data Protection (editorial pick) |
| CC6.6 | Protection against threats from outside system boundaries | Editorial | 6.76.811.1+1 | Same topic: Firewall / Net Seg, Zero Trust (editorial pick) |
| CC6.7 | Restricting transmission, movement and removal of information | Editorial | 9.112.3 | Same topic: Encryption, DLP (editorial pick) |
| CC6.8 | Preventing or detecting unauthorized or malicious software | Editorial | 6.9 | Same topic: Endpoint Protection, Email Security (editorial pick) |
| CC7 System operations · 5 | ||||
| CC7.1 | Detecting configuration changes and new vulnerabilities | Editorial | 6.36.56.6+1 | Same topic: Secure Config, Vulnerability Mgmt, Patch Management (editorial pick) |
| CC7.2 | Monitoring system components for anomalies | Editorial | 3.23.4 | Same topic: Cont. Monitoring, Logging & Audit, Intrusion Detection, Anomaly Detection (editorial pick) |
| CC7.3 | Evaluating security events to determine if they are incidents | Editorial | 3.13.23.4+1 | Same topic: Incident Response, SIEM / SOC (editorial pick) |
| CC7.4 | Responding to identified security incidents | Editorial | 3.13.5 | Same topic: Incident Response, Forensics, Mitigation (editorial pick) |
| CC7.5 | Recovering from identified security incidents | Editorial | 3.64.14.3 | Same topic: Lessons Learned, Recovery Planning, Comms & Restore (editorial pick) |
| CC8 Change management · 1 | ||||
| CC8.1 | Change management for infrastructure, data and software | Editorial | 6.26.4 | Same topic: Secure Development (editorial pick) |
| CC9 Risk mitigation · 2 | ||||
| CC9.1 | Mitigating risks from business disruptions | Editorial | 2.14.14.3+1 | Same topic: Risk Management, Business Continuity (editorial pick) |
| CC9.2 | Managing vendor and business partner risk | Editorial | 5.15.26.1 | Same topic: Supply Chain Risk, Vendor Risk Mgmt, Cloud Security (editorial pick) |
By topic
Both cover (42):
Only SOC 2 (4):
Only NIS2 (1):
Questions
Does a SOC 2 report show NIS2 compliance?
It is useful evidence of security measures, but NIS2 compliance is judged by national authorities against the law, including reporting and governance duties SOC 2 doesn't test.
Crosswalk a published crosswalk (NIST, ENISA, CIS, PCI SSC) makes the link · Editorial ControlMapping's judgement where no crosswalk exists; the reason is shown · only shares a CSF 2.0 outcome: worth checking, not a mapping · No mapping in our data nothing mapped in our data; often new work, but check the coverage notes. Mapped = curated together in a ControlMapping topic, or linked directly. Crosswalks don't prove compliance. Methodology · Download the data · Report a mistake.