Start Free Trial
Home/Regulations/SOC 2 / ISO 27001 — Regulatory Reference
Regulatory Reference
Technology Industry Standard high

SOC 2 / ISO 27001 — Regulatory Reference

SOC 2 Type II and ISO 27001 certification evidence — AutoPIL audit chain and access controls are direct evidence artifacts for auditor review, not supporting documentation.

Key Provisions

Trust Services Criteria — Security (Common Criteria CC6)

SOC 2 is an auditing framework developed by the AICPA based on Trust Services Criteria. The Security category (Common Criteria) is the only required category for SOC 2 certification; Availability, Confidentiality, Processing Integrity, and Privacy are optional additions. Type II certification covers a defined period — typically 6 to 12 months — and requires demonstrating that controls were operating effectively throughout, not just at a point in time.

AI agents represent a growing gap in Type II evidence packages. Auditors increasingly ask how organisations govern non-human identities accessing production systems, and most enterprise security controls — MFA, PAM vaults, SSO — were designed for human users. An AI agent that queries a customer database, a financial ledger, or a healthcare record is accessing production data without passing through any of those controls. AutoPIL closes this gap by placing a policy enforcement and audit logging layer in front of every AI agent data access, producing evidence that directly addresses auditor questions about non-human access governance.

CC6.1 — Logical Access Security Measures

The entity implements logical access security software, infrastructure, and architectures over protected information assets to protect them from security events. Requirements include unique identification and authentication before access is granted, restriction based on need-to-know, and prevention of unauthorised changes to system configurations.

For AI agents, CC6.1 requires that each agent be uniquely identified and that its data access be restricted to what it actually needs — not what the service account connecting it happens to have access to. AutoPIL's agent registry assigns a unique agent_id to each registered agent and the policy engine enforces source-level access restrictions at retrieval time. An agent authorised to access aggregated transaction summaries cannot retrieve individual transaction records, even from the same database. Every decision is logged, producing the CC6.1 evidence trail auditors require.

CC6.2 — Prior to Issuing System Credentials

Before issuing system credentials and granting access, the entity registers and authorises new internal and external users whose access is administered by the entity. There must be a documented approval workflow, and access must be tied to a verifiable identity.

The gap for AI agents is that most organisations do not have a formal registration and authorisation workflow for agents — they are deployed as part of an application release without a distinct access governance step. AutoPIL requires every agent to be registered in the registry with role assignment and policy binding before any data access is permitted. The registration record — including who created it, when, and under which policy — serves as the CC6.2 approval documentation for auditors.

CC6.3 — Role-Based Access Control

The entity authorises, modifies, or removes access to data, software, functions, and other protected information assets based on roles, responsibilities, or the system design. Least privilege and segregation of duties must be considered.

AI agents often inherit overly broad roles because they are deployed under service accounts that existed before agent-specific access governance was in place. A fraud detection agent and a customer service agent may share the same service identity despite having fundamentally different data access needs. AutoPIL enforces role-level access at the policy layer — a fraud_investigator role has access to transaction signals and watchlist data; a customer_service role is restricted to account summaries and contact information. These restrictions apply at every runtime call, not just at provisioning time, and the audit chain records the role used in each decision.

CC6.6 — Logical Access Restrictions Over External Communication Channels

The entity implements logical access security measures to protect against threats from sources outside its system boundaries. This applies to any external communication path — APIs, webhooks, integration endpoints.

AI agents increasingly operate across external boundaries — calling third-party LLMs, retrieving data from partner APIs, or using MCP-style tool servers. Each of these connections is an external communication channel within CC6.6 scope. AutoPIL authenticates every agent call via API key or mTLS certificate before the governance decision is made, and logs every cross-boundary access event. For integration scenarios — such as a webhook from a security platform triggering an AI governance check — all access to AutoPIL's endpoints is authenticated and auditable.

ISO/IEC 27001:2022 — Annex A Controls

ISO 27001 is a certifiable information security management system standard. The 2022 revision reorganised controls into four themes: Organisational, People, Physical, and Technological. For AI agent governance, the relevant Annex A controls are A.5.15 (Access Control), A.5.16 (Identity Management), A.8.2 (Privileged Access Rights), and A.8.5 (Secure Authentication).

ISO 27001 requires that access controls be implemented, monitored, and reviewed — it is not a point-in-time certification. AutoPIL's policy versioning and audit chain provide the ongoing monitoring and review evidence ISO 27001 requires. When a policy changes, the change is versioned and all subsequent audit events reference the new version, providing a continuous evidence record rather than a snapshot.


How AutoPIL Enforces It
  • CC6.1: Pre-retrieval enforcement + unique agent_id = logical access control directly auditable for Type II evidence
  • CC6.2: Agent registration workflow with policy binding = documented authorisation before credential issuance
  • CC6.3: Per-role sensitivity ceilings and source restrictions = least privilege enforced at runtime, not just at provisioning
  • CC6.6: API key + mTLS authentication on all external access + audit logging of cross-boundary calls
  • ISO 27001 A.5.15 / A.5.16: Agent registry as identity management system for non-human identities
Policy EngineAudit LogSensitivity LabelsAgent RegistryKey ScopingAlert Rules
AutoPIL Policy IDs
TEC-SOC2-CC61-001Logical Access for AI Agents
TEC-ISO27K-A515-001Access Control Implementation
CROSS-SOC2-CC61-001AI Agent Identity Verification Before Access
CROSS-SOC2-CC61-002Pre-Retrieval Enforcement as Logical Access Control
CROSS-SOC2-CC62-001Agent Registration and Authorization Workflow
CROSS-SOC2-CC63-001Role-Based Sensitivity Ceilings
CROSS-SOC2-CC63-002Least Privilege Enforcement at Data Source Level
CROSS-SOC2-CC66-001External Integration Access Logging
Official Sources

This page is a working reference and not a substitute for qualified legal review. Verify against official sources before use in compliance artifacts.

Frequently Asked Questions
What do SOC 2 auditors require for AI agent access governance?
SOC 2 Type II auditors increasingly ask how organisations govern non-human identities accessing production systems. Traditional controls — MFA, PAM vaults, SSO — were designed for human users and provide no coverage for AI agents querying databases or financial records. The relevant criteria are CC6.1 (logical access security), CC6.2 (registration and authorisation before credential issuance), and CC6.3 (role-based access control with least privilege). Auditors require evidence that each agent has a unique identity, that its access is restricted to a defined scope, and that every access decision was logged throughout the coverage period — not just at a point in time. Most organisations currently have no answer to this question.
How does AutoPIL produce SOC 2 Type II evidence for AI agent access controls?
AutoPIL maps directly to the Common Criteria controls auditors review. For CC6.1, it enforces pre-retrieval access restrictions and assigns a unique agent_id to each registered agent — producing a decision log that serves as the logical access control evidence trail. For CC6.2, agent registration requires role assignment and policy binding before any data access is permitted; the registration record timestamps who authorised the agent and under which policy. For CC6.3, the policy engine enforces per-role source restrictions and sensitivity ceilings at every runtime call. Every decision is written to a tamper-evident audit chain, providing the continuous Type II evidence record — not a point-in-time snapshot — that auditors require.
What does ISO 27001:2022 require for AI agent identity and access management?
The 2022 revision of ISO 27001 reorganised controls into four themes. For AI agent deployments, the directly relevant Annex A controls are A.5.15 (Access Control), A.5.16 (Identity Management), A.8.2 (Privileged Access Rights), and A.8.5 (Secure Authentication). ISO 27001 requires that access controls be implemented, monitored, and reviewed on an ongoing basis — it is not a point-in-time certification. Most AI agent deployments lack a formal identity management system for non-human actors. AutoPIL's agent registry functions as the identity management system for agents, and policy versioning ensures that every audit event references the exact policy version that governed the decision, providing the continuous monitoring and review evidence ISO 27001 requires.
Does SOC 2 compliance cover AI agents calling external APIs or LLMs?
Yes. CC6.6 requires logical access security measures for threats from outside system boundaries, and it applies to any external communication channel — including AI agents calling third-party LLMs, retrieving data from partner APIs, or using MCP-style tool servers. Each of these connections is within CC6.6 scope. AutoPIL authenticates every agent call via API key or mTLS certificate before the governance decision is made, and logs every cross-boundary access event. This means the audit record captures not only internal data access but every external integration point the agent touches, giving auditors the CC6.6 evidence trail for cross-boundary access.
Does AutoPIL evidence satisfy both SOC 2 and ISO 27001 requirements, or do they need separate controls?
AutoPIL's audit chain and access controls map to both frameworks from a single implementation. SOC 2 Common Criteria and ISO 27001 Annex A controls share overlapping requirements around access restriction, identity management, and access logging. Because AutoPIL enforces policy at the retrieval layer and writes every decision to a tamper-evident log with policy version references, the same evidence package satisfies CC6.1–CC6.3 for SOC 2 and A.5.15, A.5.16, A.8.2, and A.8.5 for ISO 27001. ISO 27001 tends to dominate in EU and APAC procurement; SOC 2 dominates in North America. Organisations pursuing both certifications do not need separate AI agent governance implementations.
Covered Industries

SOC 2 Type II and ISO 27001 apply to any organisation that stores, processes, or transmits customer or sensitive data — which includes every industry deploying AI agents against production systems. Both certifications are increasingly a procurement gate: enterprise buyers require evidence before onboarding AI vendors or AI-enabled systems.

Technology →
SaaS and enterprise technology companies face SOC 2 Type II as a hard procurement requirement from enterprise buyers. AI agents accessing customer data, usage analytics, or support records must be governed under the same CC6 criteria as human operators — and most Type II evidence packages have no coverage for non-human identities.
Financial Services →
Financial services firms pursuing SOC 2 or ISO 27001 alongside sector-specific regulation face the same gap: AI agents querying transaction records, customer profiles, or trading data are not covered by MFA or PAM controls. CC6.1 and CC6.3 require per-agent access restriction and a continuous audit record that most deployments cannot produce without a dedicated governance layer.
Healthcare →
Healthcare technology vendors selling to covered entities must hold SOC 2 Type II or ISO 27001 to clear procurement review. AI agents accessing clinical records, patient identifiers, or billing data fall under CC6.1 and ISO 27001 A.5.15 — auditors require unique agent identity, source-level access restriction, and a tamper-evident log of every access decision.
Insurance →
Insurance carriers and MGAs deploying AI agents for underwriting, claims processing, or fraud investigation must demonstrate logical access controls over sensitive policyholder and claims data to pass SOC 2 or ISO 27001 audits. CC6.3 least-privilege requirements are particularly relevant when multiple agent roles access the same underlying data platform.
AutoPIL Governance Platform

Enforce this regulation today

AutoPIL intercepts every AI agent data access call, enforces your policy, and writes a tamper-evident audit record — before sensitive data enters the agent context window.

Start Free Trial View All Industries