Why SOC 2 Compliance is becoming critical to Public Sector oversight

Why Recent Incidents Are Changing the Oversight Conversation

Across decades of working with UK government departments, publicly funded bodies, and regulated organisations, the teams at UBDS Group have seen the same pattern emerge repeatedly. Public sector vulnerability is rarely accidental.

It is not caused by an absence of frameworks, policies, or compliance activity. In reality, public sector organisations operate under significant governance and assurance demands. What creates vulnerability is the complexity of the environment in which government now delivers services. Legacy systems sit alongside modern digital platforms. Delivery depends on extensive supplier ecosystems. Accountability is public, political, and enduring.

In this context, oversight is rarely lost through a single decision or failure. It weakens gradually as people move roles, teams are restructured, services evolve, and checks that were once routine are no longer applied with the same consistency. This does not happen because attention disappears, but because priorities shift and assumptions go unchallenged over time.

Controls are put in place, risks are assessed, and compliance requirements are met. Over time, however, confidence in those controls can replace evidence that they continue to operate effectively. When weaknesses eventually come to light, it is often through an incident, an audit finding, or external scrutiny. Not because controls were never designed, but because organisations can no longer demonstrate, with confidence, that those controls are still working as intended.

This is why discussions around SOC 2 compliance, and SOC compliance more broadly, are beginning to resonate across the public sector. Not as another framework to add to an already crowded landscape, but as a way of strengthening visibility, restoring discipline, and re-establishing evidence-based oversight over governance arrangements that already exist, but are too often taken on trust.

The Compliance Paradox: Frameworks Everywhere, Assurance Gaps Remain

Public sector organisations typically align to multiple frameworks, including ISO 27001, NCSC guidance, CAF, GovAssure, NIS2, and internal audit requirements. These frameworks are necessary and valuable, but alignment alone does not guarantee that controls continue to operate as intended.

What we often observe is a growing gap between governance intent and day-to-day evidence. Compliance activity becomes routine, while oversight becomes fragmented across teams, programmes, and suppliers. The result is confidence without clarity.

Access Controls: When Restrictions Are Not Reviewed

Access control is a fundamental governance discipline, yet one of the easiest areas for oversight to weaken. Systems are configured correctly at a point in time, but access is rarely reviewed with the same rigour as services evolve.

The long-running data exposure at the Illinois Department of Human Services is a clear example. Sensitive citizen data remained accessible for years due to a misconfiguration that went unnoticed, as reported publicly by state authorities and the media. The issue was not the absence of controls, but the absence of ongoing, evidenced review.

SOC 2 compliance focuses attention on whether access controls are actively reviewed, monitored, and corrected over time, rather than simply defined.

Change Management: Governance in a Constantly Changing Environment

Public sector services change continuously. Platforms are upgraded, suppliers are replaced, and new functionality is layered onto existing systems. Yet governance processes often assume stability.

The New South Wales Department of Communities and Justice court registry incident highlighted how changes can unintentionally weaken controls when oversight does not keep pace. Approvals existed, but visibility of risk did not, as reported by mainstream media following the department’s public disclosure.

SOC 2 compliance reinforces the link between change management, monitoring, and accountability, requiring organisations to demonstrate how changes are assessed, tracked, and evidenced.

Unclear Ownership: Diffused Accountability

Public sector delivery models rely on collaboration across internal teams and external suppliers. While effective for delivery, this can blur accountability for control oversight.

Audit findings frequently highlight excessive privileges or weak segregation of duties, not because principles are misunderstood, but because responsibility for ongoing oversight is unclear.

SOC 2 compliance introduces clarity by requiring named control owners and defined review responsibilities.

Supplier and Third-Party Risk: Oversight Beyond Organisational Boundaries

Modern public services depend heavily on suppliers. While operational responsibility is shared, accountability remains with the public body. A clear example is the 2020 ransomware attack on Hackney Council, where a third-party supplier relationship formed part of the wider digital ecosystem affected by the incident, leading to prolonged service disruption and significant data loss. The incident and subsequent findings were reported by the Information Commissioner’s Office and mainstream UK media, highlighting the challenges of maintaining effective oversight across supplier arrangements.

SOC 2 compliance provides a common assurance language for setting expectations with suppliers and assessing whether third-party controls are operating as promised.

Reactive Assurance: Learning Only After Failure

Across the UK, both public and private sector incidents continue to demonstrate the same pattern: weaknesses are often identified only after services are disrupted. Recent high-profile incidents affecting organisations such as M&S, Co-op, and Jaguar Land Rover have reinforced that even well-resourced organisations can lose visibility of control effectiveness over time, with issues surfacing only once operational or reputational impact is unavoidable. Reporting by the National Audit Office and mainstream UK media shows that this reactive dynamic is not limited to one sector but reflects a broader challenge in sustaining effective oversight.

SOC 2 Type II places emphasis on controls operating consistently over time, shifting assurance away from post-incident discovery and towards earlier identification of control breakdowns, before disruption occurs.

Why SOC 2 Compliance Matters for the Public Sector, and Why Now

SOC 2 does not replace UK frameworks. Its value lies in reinforcing operational discipline and evidencing oversight where assurance is required by boards, regulators, and external partners. In practice, this brings several advantages for public sector organisations:

• It shifts assurance from point-in-time compliance to evidence that controls are operating consistently over time.
• It helps surface control drift early, before weaknesses are exposed through incidents or external scrutiny.
• It creates clearer accountability by linking controls to named owners and defined review cycles.
• It provides a common, evidence-based language for engaging boards, auditors, regulators, and third-party suppliers.
• It supports more confident and defensible decision-making for senior leaders by replacing assumption with demonstrable insight.

SOC 2 compliance responds to these pressures by focusing on evidence, operation over time, and clarity of accountability.

Leadership Perspective: Defensible Oversight

For Accounting Officers, SROs, and boards, oversight failures are not abstract. They carry personal, reputational, and political consequences. Senior leaders are expected to demonstrate that they have taken reasonable, proportionate steps to understand and manage risk.

Evidence-based assurance supports defensible decision-making. It provides clarity on what is working, where gaps exist, and where further attention is required, reducing reliance on assumption or retrospective explanation.