By Editorial team · Published · Last updated
Fintech companies face SOC 2 complexity around transaction integrity, PCI DSS, and SOC 1 questions. This guide covers the terrain and helps you choose the right auditor.
Fintech companies aren't a monolith for SOC 2 purposes. A B2B lending analytics platform, a card issuing infrastructure provider, and a consumer neobank have almost nothing in common from a compliance scope perspective. The mistake fintech founders make is treating SOC 2 as a single standard to procure rather than a flexible framework to scope correctly for their specific technical and regulatory context.
Security TSC (CC series) is baseline for every fintech. Beyond Security, the most common additions are:
SOC 1 covers controls over financial reporting (ICFR). SOC 2 covers operational controls (security, availability, etc.). Fintech companies often receive requests for both from different parts of a customer organization: the customer's auditors requesting SOC 1 and the customer's security team requesting SOC 2. These are different engagements under different AICPA standards and require different auditor scoping.
If your product processes transactions that flow into a customer's financial statements — payment processing, payroll, accounts payable automation — expect SOC 1 requests. If you don't touch anything that affects a customer's financial statements, SOC 2 is almost certainly the only report you need.
The qualifying questions for a fintech auditor: Have they audited payment processors, lenders, or BaaS platforms specifically? Do they hold QSA credentials for combined SOC 2 + PCI DSS engagements? Can they speak to SOC 1 scoping for financial transaction services? Schellman and A-LIGN have well-documented fintech practices covering all three. Among boutiques, BARR Advisory has fintech and financial services experience. For Series A fintech companies, a boutique with documented fintech experience often outperforms a large firm on responsiveness and fixed-fee predictability.
Fintech companies operate in a two-audience compliance environment: banking partners and card networks on one side, enterprise software buyers on the other. These audiences have different requirements and different review processes. Your SOC 2 Type II satisfies the enterprise software buyer. Your banking partner will often run an independent security review with its own checklist, which may include penetration test results, network segmentation diagrams, business continuity testing evidence, and sometimes a SOC 1. Build your compliance program with both audiences in mind from the start rather than retrofitting banking-partner requirements after your first partnership review. The controls overlap significantly — the same access management, encryption, and monitoring evidence that supports your SOC 2 also supports a banking partner review. What differs is presentation and scope documentation.
Fintech companies often grow quickly between audit cycles, adding new product lines, new cloud environments, or new banking partners. Each of these changes can affect your SOC 2 scope boundary and your PCI DSS cardholder data environment. Establish a change management procedure specifically for compliance-relevant changes: any new cloud environment, payment processing integration, or third-party data processor should trigger a scope review before going live in production. This review should be documented and available during fieldwork. Auditors testing CC8.1 (change management) will ask for evidence that significant system changes were evaluated for their compliance impact — a compliance scope review log satisfies this requirement.