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Security questions from your first large customer, and when you need SOC 2

A large customer may check a supplier's security before it signs, with a questionnaire and a request for a SOC 2 report. The AICPA, the body of US certified public accountants, writes that customers and business partners often request a SOC 2 report from a service provider. This page explains what a SOC 2 report covers, what ISO/IEC 27001 certification is, what the Cloud Security Alliance's questionnaire asks, which answers depend on your AI model provider's data terms, and Reveneau's view on when a startup should start the SOC 2 work.

Published October 26, 2026. Editorial.

Key takeaways

  • The AICPA writes that customers and business partners often request a SOC 2 report, which covers controls relevant to security, availability, processing integrity, confidentiality or privacy.
  • The AICPA's pages name two types of SOC 2 report, type 1 and type 2, and its SOC 2 guide covers both. The AICPA also tells companies to evaluate SOC services thoroughly.
  • ISO/IEC 27001 sets requirements for an information security management system. ISO says certification is optional and asks companies to cite the year: certified to ISO/IEC 27001:2022.
  • The Cloud Security Alliance's CAIQ v4.1, released January 27, 2026, is a set of yes or no questions a customer may ask a cloud provider.
  • Your model provider's terms are part of your answers: OpenAI keeps abuse logs up to 30 days, Anthropic deletes API data within 30 days with exceptions, and Google keeps abuse data 55 days.

A large customer often checks a supplier before it signs. Its security team may want evidence that your company will protect its data, in the form of a questionnaire, a report from a CPA firm, or a certificate. This page explains each one from the bodies that publish them, then covers the questions that are specific to an AI product. It is part of the guide on building your AI product after you raise.

What a SOC 2 report is

SOC stands for System and Organization Controls. The AICPA, the professional body of US certified public accountants (CPAs), describes SOC as "a suite of service offerings CPAs may provide in connection with system-level controls of a service organization or entity-level controls of other organizations" [1]. A service organization is a company that provides a service to other companies, such as a software product. Controls are the rules and checks a company uses to protect its systems, such as who can access data and how changes are approved.

A SOC 2 report is the result of an examination by a CPA firm. The AICPA's guide describes it as "an examination of controls at a service organization relevant to security, availability, processing integrity, confidentiality, or privacy" [2]. It explains why customers ask for it: "customers and business partners usually need information about the design, operation, and effectiveness of controls within the service organization's system", and "To support their information needs, customers and business partners often request a SOC 2 report from the service organization" [2].

The five areas in that list come from the Trust Services Criteria, which the AICPA describes as "control criteria established by the AICPA's Assurance Services Executive Committee (ASEC)" for evaluating "controls over the security, availability, processing integrity, confidentiality, or privacy of information and systems used to provide products or services" [3]. A criterion is a standard that each control is judged against.

The AICPA's SOC 2 guide was updated on October 15, 2022, and the AICPA says it "Has been fully updated to reflect new requirements and guidance of SSAE No. 20 and SSAE No. 21" [2]. SSAE is the name of a series of AICPA standards that auditors follow in these examinations. The AICPA also publishes an illustrative report for a "SOC 2 type 2 examination" and notes that similar changes "may also need to be made to SOC 2 type 1 or other SOC reports" [4]. So there are two types of SOC 2 report. This guide does not define them, because the AICPA's definitions are in its SOC 2 guide, a paid publication. Ask the customer which type it accepts, and read the AICPA's guide or ask a CPA firm, before you choose.

Choose the firm that prepares the report with care

The firms that sell SOC services include compliance vendors as well as the CPA firms that perform the examination. The AICPA's SOC page carries a notice: "The AICPA is looking into allegations published anonymously about the business practices of a compliance vendor that offers Systems and Organization Control (SOC) services" [1]. It adds: "we continue to emphasize that SOC services should be thoroughly evaluated by service organizations and CPA firms" [1]. The AICPA does not name the vendor. Before you hire anyone for SOC 2 work, find out which CPA firm will sign the report and check that firm.

ISO/IEC 27001

Some customers ask for ISO/IEC 27001 instead of SOC 2 or alongside it. ISO describes ISO/IEC 27001 as "the world's best-known standard for information security management systems (ISMS)", which is ISO's own claim about its standard, and says "It defines requirements an ISMS must meet" [5]. An information security management system is the set of policies, processes and people a company uses to manage information security. ISO says the standard "preserves the confidentiality, integrity and availability of information by applying a risk management process" [5].

Certification is optional. ISO says "companies implementing ISO/IEC 27001 can decide whether they want to go through a certification process", and that "Holding a certificate from an accredited conformity assessment body may bring an additional layer of confidence" [5]. An accredited conformity assessment body is a certification firm that has itself been checked and approved to issue certificates. ISO reports that, per the ISO Survey 2022, "over 70 000 certificates were reported in 150 countries" [5]. It also asks companies to state the version: "certified to ISO/IEC 27001:2022" and not just "certified to ISO 27001" [5]. ISO lists one amendment to the current version, ISO/IEC 27001:2022/Amd 1:2024 [5].

The Cloud Security Alliance questionnaire

A customer may send its own questionnaire or a published one. The Cloud Security Alliance (CSA), an industry group, publishes the Consensus Assessments Initiative Questionnaire (CAIQ). Version 4.1 was released on January 27, 2026 [6]. CSA says: "It provides a set of Yes/No questions a cloud consumer and cloud auditor may wish to ask of a cloud provider to ascertain their compliance to the Cloud Controls Matrix (CCM)" [6]. The Cloud Controls Matrix is CSA's list of security controls for cloud services. CSA describes the CAIQ as "an industry-accepted way to document what security controls exist in IaaS, PaaS, and SaaS services" [6]. SaaS, software as a service, is software sold as an online subscription, which describes an AI product sold online. A company can also submit its completed CAIQ to CSA's STAR Registry [6].

Filling in the CAIQ once, honestly, gives you a written set of answers to reuse when a customer sends its own form.

Document Who produces it What it is Source
SOC 2 report A CPA firm An examination of controls for security, availability, processing integrity, confidentiality or privacy AICPA [2]
ISO/IEC 27001 certificate A certification body Certification that the company's information security management system meets the standard ISO [5]
CAIQ v4.1 The company itself Yes or no answers on security controls, mapped to the Cloud Controls Matrix Cloud Security Alliance [6]

The questions that depend on your model provider

An AI product sends customer data to a model provider, so the customer's security team may ask what that provider does with it. Your answer depends on your provider's terms. Here are the figures from each provider's own pages, read on 26 October 2026.

Customer's question OpenAI Anthropic Google (Gemini API)
How long does the provider keep our data? Abuse monitoring logs up to 30 days by default [7] Inputs and outputs deleted within 30 days, with listed exceptions [8] 55 days for abuse monitoring [9]
Can retention be turned off? Zero data retention needs OpenAI's prior approval [7] Separate agreements such as zero data retention are listed as exceptions [8] Not covered in the pages read
Is our data used to train models? Not as of March 1, 2023, unless you opt in [7] Commercial terms forbid training on customer content [11] Free use: yes, to improve products; paid use: no [12]

The page choosing a model provider: terms and data use has the full detail and the sources for every cell. Keep a one-page summary of your provider, model, tier and terms, dated, with your security documents. Update it each time you change model or provider.

Other questions are specific to AI. Prepare answers on which model the product uses, where the model runs, whether customer data is used to improve the product, how prompts and outputs are logged in your own systems, and how the product is tested before each release. A written eval suite, the set of repeatable tests of the product's answers, is the evidence for the last one. The guide on why AI evals matter explains it.

Open-source software

Open-source code is also checked in due diligence. Lawyers at Morgan Lewis, writing in June 2026 about due diligence for a company sale, say "Buyers frequently assess whether a company maintains a written OSS policy governing the use of OSS" and that diligence typically "requires a scan of the company's software" [10]. OSS is open-source software. Write the policy and run the scan once, and you have an answer ready if a customer asks about open-source code as well.

When a startup needs SOC 2

No source opened for this guide sets a stage or a revenue level at which a startup needs a SOC 2 report. The AICPA's statement that customers often request one [2] is the practical answer: you need it when your customers ask for it.

Reveneau's view is that a seed-stage company should answer its first security questionnaire honestly, with the controls it has, and start the SOC 2 work when a customer contract depends on the report. Before that day, put these controls in place:

  1. Two-step login, a password plus a code from a phone or a key, for every system the team uses.
  2. Access to customer data limited to named people, with a written record of who has it.
  3. Every change to the code reviewed and tested before release, with the record kept.
  4. A written plan for what happens when there is a security incident.
  5. A list of suppliers, including the model provider, with their terms.
  6. Backups that have been restored once to prove they work.

For a finance product, the guide on SOC 2 for a financial software engineering process goes further.

Where Reveneau fits

Reveneau is an AI software development consultancy with offices in San Francisco and Vancouver. Reveneau says AI writes all of its code and every change must pass an eval suite written from the specification. It says it takes responsibility for the whole project through production and after release. To plan the security controls with the product, see AI development at Reveneau or contact Reveneau.

Common questions

What is a SOC 2 report?

A SOC 2 report is the result of an examination by a CPA firm of a service provider's controls relevant to security, availability, processing integrity, confidentiality or privacy, as the AICPA describes it. The AICPA writes that customers and business partners often request a SOC 2 report, because they need information about the design, operation and effectiveness of a provider's controls.

Who can perform a SOC 2 examination?

A SOC 2 examination is performed by certified public accountants. The AICPA describes SOC as a suite of service offerings that CPAs may provide on the controls of a service organization. The AICPA also tells companies to evaluate SOC services thoroughly, and its SOC page notes that it is looking into published allegations about one compliance vendor, which it does not name.

What are the Trust Services Criteria?

The Trust Services Criteria are control criteria set by the AICPA's Assurance Services Executive Committee for evaluating controls over the security, availability, processing integrity, confidentiality or privacy of information and systems. A SOC 2 examination judges a company's controls against them. The AICPA's download page lists the 2017 criteria with points of focus revised in 2022.

Is there more than one type of SOC 2 report?

There are two types, type 1 and type 2. The AICPA publishes an illustrative SOC 2 type 2 report under the SSAE-21 standard and notes that similar changes may be needed in SOC 2 type 1 reports. The AICPA's SOC 2 guide covers each type, and this guide does not define them. Ask your customer which type it accepts before you choose an auditor.

What is ISO/IEC 27001?

ISO/IEC 27001 is an international standard that sets the requirements for an information security management system, the policies, processes and people a company uses to manage information security. ISO calls it the world's best-known standard of its kind. ISO reports that over 70,000 certificates were reported in 150 countries in the ISO Survey 2022.

Does a startup need ISO 27001 certification?

ISO says certification is optional: companies implementing ISO/IEC 27001 can decide whether to go through a certification process. A certificate from an accredited body may add confidence for customers. If you certify, ISO asks you to state the version, for example certified to ISO/IEC 27001:2022. Whether you need it depends on what your customers ask for.

What is the CAIQ security questionnaire?

The CAIQ, the Consensus Assessments Initiative Questionnaire, is a set of yes or no questions published by the Cloud Security Alliance that a customer may ask a cloud provider, mapped to CSA's Cloud Controls Matrix. Version 4.1 was released on January 27, 2026. A company can submit its completed questionnaire to CSA's STAR Registry.

What will a customer ask about my AI model provider?

A customer may ask how long the model provider keeps its data, whether retention can be turned off, and whether its data trains models. As read on 26 October 2026, OpenAI keeps abuse monitoring logs up to 30 days, Anthropic deletes API inputs and outputs within 30 days with exceptions, and Google keeps abuse monitoring data for 55 days.

How should a startup choose a firm for its SOC 2 work?

A startup should find out which CPA firm will sign the SOC 2 report, and check that firm, before hiring anyone for the work. The AICPA's SOC page says SOC services should be thoroughly evaluated by service organizations and CPA firms, and notes that it is looking into anonymous allegations about the business practices of one compliance vendor offering SOC services.

How should a startup answer its first security questionnaire?

A startup should answer its first security questionnaire honestly, with the controls it has in place on the day, and attach its model provider's data terms. Reveneau's view is to start the SOC 2 work when a customer contract depends on the report. Completing the Cloud Security Alliance's CAIQ v4.1 once gives a written set of answers to reuse.

At what stage does a startup need SOC 2?

No source opened for this guide sets a stage or revenue level at which a startup needs SOC 2. The AICPA writes that customers and business partners often request a SOC 2 report, so the practical answer is when your customers ask. Before then, put basic controls in place, such as two-factor login, limited access to customer data and reviewed changes.

References

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