Your SOC 2 in progress, and what to tell customers

A buyer wants a report you do not have yet. There is a truthful answer that keeps the deal moving, and there is the version that costs you the account later.

Yes, you can tell customers your SOC 2 is underway. Say which stage you are in, who is examining you, and when you expect the report, and call that date an expectation. You cannot say the company is SOC 2 compliant or certified, or show a SOC 2 logo, until a report has been issued.

The three blocks below are ready to copy: the email to the customer, the paragraph for your security page, and the answer to “Do you have a SOC 2 report?” on a questionnaire. Use the same facts in all three.

A prospect asks for your report. You do not have one. The work has started, which feels like it should count for something, and the temptation is to describe it in the warmest language that is technically defensible. Resist that. A security reviewer is reading for one thing: whether a report exists, and if not, when.

The four states, and which ones you may describe

Saying a SOC 2 is in progress can mean four quite different things depending on where you actually are. A vague claim invites the follow-up question you were hoping to avoid. Say which one is true.

Readiness work, no firm engaged
You are closing gaps and collecting evidence. Nothing is under examination. Describe it as readiness work, never as an audit, and do not name a report date you have no engagement to support.
Engaged, examination not started
A licensed CPA firm has been engaged and the scope is agreed. You may say an examination is engaged and give the planned start. You may not describe a period as being examined until it is.
Fieldwork running
The firm is testing. This is the strongest honest position short of a report, and it is the one worth stating precisely: the report type, the date or period under examination,1 and the expected issuance.
Report issued
Now you have a document. Everything above stops being necessary, and the only questions left are distribution and the period it covers.

Three blocks to copy

Each block is built so a reader can paste it into their own file without editing it. Change the bracketed parts and nothing else. The SOC 2 in progress notice template has all three as a Word and PDF download, with a one page customer notice and a filled example. If no CPA firm is engaged yet, replace the sentence about the examination with: “We are doing SOC 2 readiness work and have not engaged a CPA firm yet. We plan to engage one by [month].” That sentence is true, and the other version would not be.

The email to the customer

Email, from the account owner

Subject: Our SOC 2 status

Hi [name], thanks for sending the security review. We do not have a SOC 2 report yet. We are in a SOC 2 Type 1 examination performed by an independent licensed U.S. CPA firm, covering the Security criteria for [product], with a control date of [date]. We expect the report in [month]. That is our expectation rather than a commitment, because the firm decides when it issues.

Until then we can share our control matrix, our written security policies and a walkthrough with [name, role]. We will send the report the day it is issued.

The paragraph for your security page

Security or trust page

SOC 2. We are undergoing a SOC 2 Type 1 examination by an independent licensed U.S. CPA firm, covering the Security criteria for [product]. We expect the report in [month]. We have not received a SOC 2 report yet, and we will update this page when we do. Customers and prospects can request our control matrix and security policies at [email].

The questionnaire answer

Do you have a SOC 2 report?

Not yet. A SOC 2 Type 1 examination by an independent licensed U.S. CPA firm is in progress, covering the Security criteria for [product], with a control date of [date]. Expected report date: [month], subject to the firm’s issuance. Available now: our control matrix mapped to the Trust Services Criteria, our written security policies and a walkthrough call. We will provide the report on issuance.

Each block carries five facts in the same order: what is happening, who is doing it, what it covers, when, and what you can offer today. The sentence about issuance being the firm’s decision is the one that protects you if the date slips. The rest of that spreadsheet is covered row by row in how to answer a security questionnaire before you have a report.

What you can say now, and what has to wait

Every sentence in the left column is a claim about a document that does not exist yet. The right column says the same thing truthfully. Polara Labs is not a CPA firm. SOC 2 examinations are performed by independent licensed U.S. CPA firms.

Cannot say yetCan say now
We are SOC 2 compliantWe are under a SOC 2 Type 1 examination, with a control date of [date]
We are SOC 2 certifiedSOC 2 produces an examination report rather than a certificate, and ours is expected in [month]
A SOC 2 badge or the AICPA SOC logo on the siteSOC 2 Type 1 examination in progress, as plain text on the security page
Our SOC 2 is done, the report is just being writtenFieldwork is complete and the report has not been issued
We will have the report by the 30thWe expect the report in [month], and issuance is the firm’s decision
Our auditors have signed offTesting is complete. Nothing is signed until the report is issued, and we will send it that day
We passed our SOC 2 readiness assessmentOur readiness assessment shows [n] open gaps and a plan to close them by [date]

The certified row is the one a security reviewer reads as a warning. SOC 2 is an attestation engagement and the deliverable is a report carrying an opinion,2 so there is no certificate to hold up.

Can you market SOC 2 before the report is final?

You can market the engagement. You cannot market the result.

A sentence saying an independent CPA firm is examining your controls, with the expected report date, is a fact you can prove with the engagement letter. A sentence saying you are SOC 2 compliant is a claim about an opinion nobody has issued. The Federal Trade Commission puts the general rule plainly: advertising must be truthful and not deceptive, advertisers need evidence for their claims, and claims on the internet are held to the same standard.4 A homepage banner, a launch post and a sales deck are all advertising for that purpose.

The logo has its own rule. The AICPA offers a SOC logo for service organizations, and its own page says the logo may be used by a service organization that has received a SOC 1, SOC 2 or SOC 3 report from a licensed CPA.5 No report, no logo. The same goes for a home-made badge that looks like one: it tells a visitor something has been issued when it has not.

So the honest version of a SOC 2 announcement before the report is the security page paragraph above, posted where buyers look, and updated the day the report lands. If a buyer wants to see what the finished document will contain, point them at what a finished SOC 2 report looks like rather than anything of yours, and once yours exists they can check that a SOC 2 report is real before relying on it.

What readiness work proves, and what it does not

Readiness work is real work. It is not evidence to a third party, and the distinction matters more to your buyer than it does to you.

A readiness assessment is your own measurement of your own controls against the Trust Services Criteria.3 It tells you which controls exist, which are only described, and which have nothing behind them. It carries no opinion from an independent firm, so it proves nothing about whether a control operated. Share it as a gap list and a plan if the buyer wants detail. Do not present it as a substitute for a report.

If you have not measured yet, that is the first thing to fix, because you cannot give a date without it. The free SOC 2 readiness assessment scores your answers against the same criteria an examination uses and returns the gap list, which is what turns a vague in-progress claim into a defensible one. The SOC 2 evidence checklist shows what the firm will ask you to produce once it starts.

A date you cannot support is worse than no date at all.

When you can first hand over a real report

A Type 1 is an opinion on whether your controls were suitably designed as of a single date. No period of operation has to elapse first, so the constraint is your own readiness and the firm’s schedule rather than the calendar. Once you know your gaps, plan on being audit-ready starting at about a week of focused work.

A Type 2 is different in kind. It covers a window during which controls actually operated, and the window has a floor, so no amount of urgency compresses it. That is the honest answer to a buyer pressing for a Type 2 inside a quarter, and how long SOC 2 takes lays out what each date really depends on. When a contract date is the real constraint rather than the report, a customer asking for a SOC 2 report you do not have is the page for that conversation.

Polara Labs sells the Type 1 path at published prices: Star is $2,000 one time for onboarding, and a SOC 2 Type 1 report by an independent licensed U.S. CPA firm is $2,000 more. What the same report costs elsewhere, with the auditor fee separated out, is on how much SOC 2 costs.

The one that comes back

Never send a draft of your own report or an unsigned opinion, even with a watermark. A reader who has seen one circulated draft treats everything else you send as provisional, and the firm whose name is on it has a legitimate objection to it existing at all.

After the report lands

The in-progress problem does not end at issuance. It comes back every time your report period ends and the next examination has not closed, which is a narrower version of the same question with a standard answer attached to it. That answer is the bridge letter, and the rule underneath it is the one on this page: say what you know, date it, and do not assert anything nobody examined.

Two habits are worth building now. Keep the three blocks above as one living document rather than rewriting them under pressure each time. And log every date you give a buyer, so you can tell them yourself when one moves. A slipped date you report first is a schedule change. One the buyer discovers is a trust problem.

Questions

Can I market my SOC 2 compliance before the report is final?
You can market the engagement, not the result. Saying that a SOC 2 examination by an independent CPA firm is underway, with the date you expect the report, is a true statement you can back up. Saying the company is SOC 2 compliant or certified before a report is issued is a claim nobody has examined yet, and advertising claims, including on a website, have to be truthful and backed by evidence.
How do I announce that our SOC 2 is in progress?
Say which stage you are in, who is performing the examination, what it covers and when you expect the report, and mark the date as an expectation. Use the same wording in the customer email, on the security page and in questionnaire answers so the three never disagree. All three versions are on this page to copy.
Can I put a SOC 2 badge on my website before the report?
No. The AICPA offers its SOC logo to service organizations that have received a SOC 1, SOC 2 or SOC 3 report from a licensed CPA, so a company still under examination does not qualify. A line of plain text saying the examination is in progress is the honest substitute until the report is issued.
Can I tell customers my SOC 2 is in progress?
Yes, as long as the engagement really has started. Name the state you are actually in: readiness work underway, an examination engaged with a CPA firm, or fieldwork running. Give the date you expect a report and say it is an expectation rather than a commitment. What you cannot do is describe the company as compliant, certified or covered before a report exists.
Does a readiness assessment count as a SOC 2?
No. A readiness assessment is your own view of where you stand against the criteria. It has no opinion from an independent CPA firm behind it, and it is not an examination. It is useful to share as a gap list and a plan, and it is not evidence that any control operated.
When can I first hand a buyer an actual report?
A Type 1 report can be issued once the examination of your control design as of a single date is finished, so there is no waiting period built into it. A Type 2 covers a window of operation, which is why it cannot be produced quickly no matter how ready you are.
What if the customer will not accept work in progress?
Ask what would satisfy the review instead. Usually it is a Type 1 with a date, a written commitment to a Type 2 date, a signed questionnaire, or a contract clause. You can put any of the four in writing this week, and knowing which one they need is worth more than another status email.

Sources

  1. Statements on Standards for Attestation Engagements AICPA. The attestation standards a SOC 2 examination is performed under.
  2. SOC 2 Report AICPA. What a SOC 2 report is and who may issue one.
  3. 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.
  4. Advertising FAQ's: A Guide for Small Business Federal Trade Commission. Advertising, including on the internet, must be truthful and backed by evidence.
  5. SOC Logos for Service Organizations: Registration and Guidelines AICPA. The logo is for a service organization that has received a SOC 1, SOC 2 or SOC 3 report from a licensed CPA.

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