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Can I Do SOC 2 Without an Auditor? (Non-US CPAs Too)

By Editorial team · Published · Last updated

No. A SOC 2 report only exists if a licensed CPA firm issues it. Anything else is a self-attestation, which most enterprise buyers will reject.

Short answer: no. SOC 2 is an attestation engagement under AICPA AT-C 205. By definition, only a licensed CPA firm can perform it and issue a report. Anything else is something else — useful, sometimes, but not SOC 2.

Why the auditor is structurally required

SOC 2 is regulated by the AICPA, the same professional body that regulates financial audits. The framework requires an independent third-party CPA who: holds an active state CPA license, follows AICPA SSAE 18 attestation standards, carries professional liability insurance, and is subject to AICPA peer review every three years. This structure is what makes a SOC 2 report meaningful to enterprise buyers — there is a licensed party whose practice can be sanctioned if they sign off on bad work.

Things that look like SOC 2 but are not

What you can do without an auditor

  1. Run a readiness assessment against the SOC 2 Trust Services Criteria. Most GRC platforms ship this out of the box.
  2. Implement controls — access reviews, vendor risk, encryption, change management, incident response — and collect evidence on autopilot.
  3. Issue a self-attestation or trust center page describing the controls in plain English. This satisfies many SMB diligence requests.
  4. When enterprise demand triggers it, hire a CPA firm to convert your accumulated evidence into an actual SOC 2 Type I or Type II report.

Pre-audit: how long the platform-only state lasts

Most startups run 6 to 18 months on a GRC platform without a real SOC 2 report — long enough to satisfy investors, channel partners, and SMB customers. The trigger to actually engage an auditor is usually a single enterprise deal worth more than the cost of the audit. Once you cross that threshold, the math is straightforward: an audit costs $15,000 to $40,000 all-in for a startup, and the deal it unlocks is typically worth multiples of that.

Choosing the auditor when the time comes

Boutique CPA firms (Prescient Assurance, Insight Assurance, BARR Advisory, Johanson Group) typically charge $12,000 to $25,000 for a SOC 2 Type II at startup scale. Mid-tier firms (Schellman, A-LIGN) charge $30,000 to $60,000. Big Four firms (Deloitte, PwC, KPMG, EY) start above $80,000 and are rarely the right call for a first audit. We have a separate guide on how to choose between them.