SOC 2 for API companies and developer tools

An API changes the scope, the uptime question and where your change evidence comes from.

SOC 2 for API companies covers the system that serves the API, not the API alone. That means production, the pipeline that deploys to it, the secrets it runs on, and the people who can change any of the three. Open source code does not take the repository out of scope.

Two decisions are particular to selling an API: whether an uptime promise puts Availability in scope, and where customer payloads end up once you log requests.

Everything else is the same examination every software company sits for. The criteria do not change for developer tools. What changes is which ones your facts make loud, and which artifacts already exist in the tools your engineers use every day.

What sits inside the boundary

The system description has to say what is in scope and what is not.1 For an API business, draw it around four things.

  • Production. The infrastructure that answers requests, its databases, and the cloud accounts they live in.
  • The continuous integration and delivery (CI/CD) pipeline. Whatever can build and deploy is a path into production, so its permissions and its runners are in scope.
  • Secrets. Database credentials, signing keys and the provider tokens your pipeline uses. A leaked deploy token is a production access problem.
  • The repository that ships. Public or private.

Open source does not change that. Public read access says nothing about write access, and write access to the branch that deploys is a logical access control like any other. Branch protection can require approving reviews and passing status checks before a merge.2 That configuration, and who can change it, is what gets tested.

A public repository brings one free control with it. GitHub runs secret scanning on public repositories automatically.3 It does not replace a secrets manager. It does give you an alert log to point at.

Uptime promises and the Availability category

Security is the one category every SOC 2 includes. Availability is optional, and it tests capacity planning, backup and recovery infrastructure, and recovery testing.4 The question for an API company is whether you have promised availability in writing.

Read your contracts, not your marketing. A service level agreement (SLA) with an uptime figure and service credits is a commitment. A status page is a disclosure of how you are doing; on its own it promises nothing. If customer agreements carry an uptime commitment, the scoping tool will tell you Availability may belong, and how many criteria a SOC 2 covers shows what adding it costs in controls.

Be clear about our limit here. Polara G.R.C. scopes Security only, fixed rather than a setting. A Security only report does not test your uptime commitments. If a contract needs Availability tested, a firm that runs that scope directly is the right route.

Change evidence from pull requests

Change management asks that changes are authorized, designed, tested and approved before they reach production.4 If you ship through pull requests, that record already exists. It lives in the pull request.

A merged pull request with a required approving review, passing checks, and a linked ticket is one change, fully evidenced. The auditor asks for the population of merges to the production branch in the period, picks a sample, and opens each one. Merges that bypassed protection are the exceptions, so admin overrides need their own record.

Two edge cases deserve a written answer before fieldwork. Emergency fixes need a path that is fast and still reviewed afterwards. Dependency bumps from a bot are changes too. The GitHub integration collects the branch protection settings, meaning required reviews and status checks. The list of merges for the period is an export you take from GitHub yourself. A change management policy should name both edge cases.

Customer payloads in your logs

An API that logs requests and responses is storing customer data in a second place. Often a third and a fourth: the log pipeline, the observability vendor, the error tracker. Each copy has its own retention and its own access list.

Decide three things and write them down. Which fields are logged at all. How long logs are kept, with a setting you can show. Who can read them, which should be a shorter list than who can deploy. SOC 2 log retention covers the defaults in the usual cloud services, and a logging and monitoring policy is where the answers belong.

Cloud, observability and model providers

Your cloud host is a subservice organization. So is any vendor your service commitments depend on: the observability platform holding your logs, the queue, the email provider for account notices, and any model provider your API calls.5 A small company carves them out, names them, and states the controls it relies on each one to run.

Those statements are complementary subservice organization controls, and how to word CUECs and CSOCs shows the difference between a useful one and a decorative one. If your API wraps a model, the guide for AI companies covers prompts as customer data and what each provider publishes about its own report. If your API moves money, the guide for fintech covers what a bank partner reviews.

API keys and customer access

API keys are two controls in one object. Your half is the lifecycle: keys issued with a scope, stored hashed or in a secrets manager, rotatable by the customer, revocable at once, and logged when used. Admin access to the system that issues keys is production access, and gets reviewed like it. An access control policy sets those rules.

Your customer’s half is keeping the keys secret. That belongs in your description as a complementary user entity control. Without it, your report reads as if you guarantee something only the customer can do.

What a customer’s review is checking

A customer evaluating an API vendor may send its own questionnaire or a standard one. The Cloud Security Alliance publishes the Consensus Assessments Initiative Questionnaire (CAIQ) v4, a set of yes or no questions a cloud customer may ask a cloud provider.6 For an API vendor, its access, change management, logging and supply chain questions land on the sections above.

A SOC 2 report answers many of those with one document. The rest, such as data residency, are answered by your own written statements.

What it takes, and what it costs

Through Polara Labs it is audit-ready starting at about a week of focused work. Onboarding is $2,000 one time, then SOC 2 Type 2 is $600 a month on a 12-month term, and your first SOC 2 Type 2 audit is included in the term. A Type 1 report is optional: $2,000 added later, or $4,000 in total with onboarding, with the engagement fee for the independent partner auditor inside it. Polara Labs is not a CPA firm. SOC 2 examinations are performed by independent licensed U.S. CPA firms.

Questions

Does a public GitHub repository have to be in SOC 2 scope?
If the code in it is what deploys to production, yes. Public read access does not change who can merge to the branch that ships, and that write access is the control an auditor tests. Branch protection, required reviews and the deploy pipeline are in scope whether the repository is public or private.
Do API companies need the Availability category?
Only if a contract commits you to it. Security is the one category every SOC 2 includes. If your agreements promise an uptime figure or an SLA with service credits, Availability may belong in scope, and the scoping tool walks the decision. Polara Labs scopes Security only, so a wider scope means a firm that runs it directly.
Can pull requests be SOC 2 change management evidence?
Yes, when the repository enforces them. A merged pull request with a required approving review, passing status checks and a link to the ticket shows a change that was authorized, tested and approved before it reached production. An auditor samples from the population of merges in the period.
Are API keys a SOC 2 control?
Two of them. Your side is how keys are issued, stored, scoped, rotated and revoked. Your customer's side is keeping the keys you issue them secret, which belongs in your description as a complementary user entity control.
How long does SOC 2 take for an API company?
The work does not change with the product type. Through Polara Labs it is audit-ready starting at about a week of focused work, and a Type 2 adds a 3-month observation window before the audit. Polara Labs is not a CPA firm. SOC 2 examinations are performed by independent licensed U.S. CPA firms.

Sources

  1. 2018 SOC 2® Description Criteria (With Revised Implementation Guidance, 2022) AICPA. The benchmarks for preparing and evaluating the system description, DC 200. Checked 2 October 2026.
  2. About protected branches GitHub. Required reviews and status checks before a merge. Checked 2 October 2026.
  3. Secret scanning GitHub. Runs automatically on public repositories. Checked 2 October 2026.
  4. TSP Section 100, Trust Services Criteria for Security, Availability, Processing Integrity, Confidentiality, and Privacy AICPA. The criteria themselves, including the common criteria every SOC 2 report covers. Checked 1 August 2026.
  5. SOC 2 Report AICPA. What a SOC 2 report is and who may issue one. Checked 1 August 2026.
  6. STAR Level 1: Security Questionnaire (CAIQ v4) Cloud Security Alliance. Yes or no questions a cloud customer may ask a cloud provider. Checked 2 October 2026.

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The readiness assessment is free, with no payment and no card. Onboarding is $2,000 one time, then SOC 2 Type 2 is $600 a month on a 12-month term, and your first SOC 2 Type 2 audit is included in the term. You can be audit-ready starting at about a week.

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Polara Labs is not a CPA firm. SOC 2 examinations are performed by independent licensed U.S. CPA firms.