5 SOC 2 Pitfalls UK Public Sector & Regulated Organisations Must Avoid

Practical Lessons from UBDS Digital Cyber Governance and GRC.

Yet another framework.

That’s the first thought many assurance leads have when SOC 2 comes up, usually in a tender pack, a supplier questionnaire, or a board conversation that starts with, “Can we evidence this?”

Because from where you’re sitting, it often does look like more of the same: another set of control statements to interpret, another evidence tracker to maintain, another calendar of reviews, screenshots and signoffs to chase. ISO. NCSC guidance. CAF. Sector obligations. Internal risk committees. Each one is defensible in isolation, but together they can create a system where you spend more time proving you’re doing the right things than actually improving them.

And here’s the part that really grates. Even organisations surrounded by standards can still have incidents, control drift, or simply discover that when scrutiny arrives, they can’t consistently prove what’s happening across services, suppliers and teams.

That’s why SOC 2 is appearing more often in UK due diligence and procurement conversations. Not because it replaces what you already do, but because it offers a recognisable structure for a basic question:

Are your controls consistent, and is the evidence easy to produce and trust?

SOC 2 is organised around the AICPA Trust Services Criteria (Security, Availability, Confidentiality, Processing Integrity, Privacy).

In the UK, governance expectations are also moving in one direction: clearer accountability for cyber risk at senior levels, not less. The UK Cyber Governance Code of Practice is explicit about board and director responsibility for governing cyber security risk.

Below are five pitfalls that turn SOC 2 into “yet another compliance project”, and what to do instead.

1) Treating SOC 2 as “Just a SaaS Thing”.

The pitfall

Many public sector, central government, education, finance, legal, and enterprise IT teams assume SOC 2 is only relevant to US-based SaaS providers.

Why it’s a problem

When SOC 2 appears in a tender or due diligence pack, it is rarely about geography. It is about assurance in a format stakeholders can compare quickly. If you dismiss it as irrelevant until procurement forces the issue, you lose time and you end up bolting controls and evidence later.

What to do instead

• Recognise SOC 2 as a flexible assurance framework that can sit alongside ISO, NCSC guidance, UK assessment approaches, and sector standards.
• Use it as a governance tool, not a document exercise. SOC 2 can help you explain your control environment to boards, regulators and major customers in a structured language.

2) Starting Without a Clear Gap Analysis.

The pitfall

Jumping straight into policy writing and tool buying without understanding where you actually stand.

Why it’s a problem

This is how SOC 2 becomes “more paperwork” instead of “better control.” You risk duplicating controls you already operate, buying tools to solve the wrong problems, and still missing key requirements because nobody traced the full line from control intent to operation to evidence.

What to do instead

• Begin with a structured SOC 2 gap analysis against the Trust Services Criteria and your current frameworks.
• Produce a prioritised roadmap that separates:
  • what’s already good enough
  • what needs tightening
  • what’s missing entirely

• Align it to risk appetite, budget and timelines so readiness is achievable, not theoretical.

3) Over-Engineering Controls for the Audit.

The pitfall

Designing controls to impress auditors rather than to work in your real environment.

Why it’s a problem

Over-complex controls are where good intentions go to die. They create friction, get bypassed, and turn evidence into an annual scavenger hunt. The people doing the work start to view security as an obstacle and assurance becomes a fragile performance.

What to do instead

• Right-size controls to your culture, technology and regulatory reality.
• Keep policies usable, written for the people operating them, not just the people reviewing them.
• Make evidence a by-product of BAU: tickets, logs, baselines and reports produced routinely, not assembled under pressure.

(If you are using NCSC Cloud Security Principles to assess cloud services, the same “operational not theatrical” principle applies. Strong assurance relies on what you actually do and how you configure and run services, not just what you document.

4) Ignoring Existing Frameworks and Duplicating Effort.

The pitfall

Treating SOC 2 as separate from ISO 27001, NCSC guidance, CAF, or sector standards.

Why it’s a problem

This is the fastest route to framework fatigue: parallel control libraries, overlapping documents, confused ownership, and conflicting “sources of truth” that undermine confidence when scrutiny arrives.

In UK environments, the NCSC Cyber Assessment Framework (CAF) can be a useful anchor because it focuses on outcomes. Mapping SOC 2 into an outcome-led view helps you avoid rebuilds and reduces duplicated effort.

What to do instead

• Map SOC 2 to what you already operate.
• Reuse existing policies, risk assessments and technical controls wherever possible.
• Rationalise into one coherent control environment.

Relief line that matters in practice: one control library, many assurance outputs. Your procurement packs, board reporting, audit evidence, and customer due diligence should all draw from the same underlying control set.

5) Leaving Readiness to the Last Minute.

The pitfall

Treating the SOC 2 audit as a date in the diary, not a process to prepare for.

Why it’s a problem

Last-minute evidence collection, unclear control descriptions and inconsistent practices create stress, delays, and findings that could have been avoided. It also pulls delivery teams away from operational priorities at exactly the wrong time.

What to do instead

• Run a readiness phase well before the audit window.
• Do a mock audit to test controls, documentation and evidence paths.
• Clarify ownership and evidence locations:
  • who owns each control
  • what “good operation” looks like
  • where proof lives (tickets, logs, configs, reports)
  • how often it is produced and reviewed

Readiness is not busywork. It is how you convert “we think we do this” into “we can prove we do this, consistently.”

How UBDS Digital Can Help.

UBDS Digital Cyber Governance and GRC supports UK public sector, central government, education, finance, legal, and enterprise IT organisations to:

• Conduct pragmatic SOC 2 gap analyses
• Design and implement right-sized controls that work in regulated environments
• Align SOC 2 with existing frameworks and obligations
• Prepare for assurance with readiness reviews and mock audits

If SOC 2 is starting to appear in your tenders, contracts, or board discussions, now is the time to get ahead of it.