How a Series A FinTech Achieved SOC2 Type II in 3 Weeks
A 12-person FinTech startup had just closed their $5M Series A. The ink was barely dry when their sales team hit a wall: their best enterprise prospect — a regional bank with $2B in assets — would not sign until the startup produced a SOC2 Type II report.
They had no security team. No written policies. No access review process. Their CTO had been meaning to "get to compliance" for six months, but between shipping features and closing the funding round, it kept sliding down the list.
The $200K contract was on hold. The prospect's procurement team gave them 60 days.
We got them audit-ready in 21.
The Starting Point: A Realistic Audit of What Existed
Before writing a single policy, we ran a gap assessment against the SOC2 Trust Services Criteria. The picture was typical of a fast-moving early-stage startup:
- No formal information security policy
- No access review process (ex-contractors still had active credentials in three systems)
- Production database accessible from developer laptops with shared credentials
- No centralized log aggregation — CloudWatch logs existed but weren't being monitored
- No incident response plan
- No vendor risk management process
- CI/CD pipeline deploying directly to production with no approval gates
None of this was negligence. It was a team that had correctly prioritized shipping over process. But SOC2 Type II requires you to demonstrate that controls have been operating consistently over an observation period — typically 3 to 12 months. That meant we needed to get controls in place fast, then begin accumulating evidence.
Week 1: Policies, Access Controls, and Killing Technical Debt
The first week was the most intensive. We focused on the two categories that block most audits: missing documentation and access control gaps.
Policy documentation is less about writing essays and more about accurately describing what you actually do — then making sure you actually do it. We produced a core policy set covering:
- Information Security Policy (master document, maps to TSC)
- Access Control and User Provisioning Policy
- Incident Response Plan with defined severity levels and communication runbooks
- Change Management Policy covering production deployments
- Vendor and Third-Party Risk Assessment template
- Business Continuity and Disaster Recovery overview
Each policy was written to be auditor-readable but also operationally real. Policies that don't match actual behavior are a liability, not an asset.
Access control remediation was the highest-risk item. We audited every SaaS tool and infrastructure component:
- Revoked 11 stale credentials across AWS IAM, GitHub, Stripe, Intercom, and their database
- Enforced MFA on all production systems (some team members had it off "for convenience")
- Moved from shared database credentials to per-user IAM roles with least-privilege policies
- Documented the access provisioning and de-provisioning process in the HR onboarding checklist
CI/CD hardening came next. Their GitHub Actions pipeline was deploying to production on any push to main with no review gate. We added:
- Required pull request reviews before merge to main
- Branch protection rules on main and staging
- Secrets scanning via GitHub's native tooling plus a secondary pass with TruffleHog
- Dependency vulnerability scanning via Dependabot with auto-merge blocked for high/critical findings
- A deployment approval step for production releases (two-person rule)
Week 2: Monitoring, Logging, and Evidence Infrastructure
SOC2 Type II is not about having controls. It's about proving controls operated continuously over the observation period. That means evidence — and evidence means logging.
We built a log aggregation pipeline using AWS CloudWatch Logs with structured log forwarding to an S3 bucket with object-lock enabled (immutable audit trail). Key events instrumented:
- All IAM authentication events (console logins, API key usage, role assumptions)
- Failed authentication attempts with alerting on thresholds
- Data access logs for the production database (pgAudit enabled on RDS PostgreSQL)
- Application-level audit events: user logins, data exports, admin actions
- Infrastructure change events via CloudTrail (already enabled but not being reviewed)
For alerting, we configured PagerDuty integration with tiered escalation: P1 (breach indicators, mass data access) pages the on-call engineer immediately; P2 (anomalous login patterns, failed deploys) creates a ticket for next-business-day review.
We also built a lightweight evidence collection workflow. Every month, an automated script pulls:
- User access lists from all connected systems
- CloudTrail summaries for the period
- Vulnerability scan outputs
- Dependency audit reports
These land in a shared folder that their auditor can access directly. No scrambling for evidence during audit prep.
Vulnerability management was the final Week 2 deliverable. We ran an initial scan using AWS Inspector for infrastructure findings and OWASP ZAP for their web application. Critical findings (two, both in dependencies) were patched and documented before the observation period began. The remaining medium findings were triaged with remediation timelines — which is what auditors actually want to see.
Week 3: Audit Readiness, Penetration Test Coordination, and Evidence Review
Week 3 was about validation and rehearsal.
We ran a pre-audit evidence review — essentially a dry run of what the auditor would request. We walked through each SOC2 criterion, identified the evidence that maps to it, and found three gaps: no formal security training records for new hires, no documented DR test, and no vendor risk assessments for two critical vendors (their payment processor and their LLM API provider).
All three were addressed before the observation period was called complete:
- Security awareness training delivered via KnowBe4 with completion certificates stored per-employee
- A tabletop DR exercise conducted and documented (full live failover wasn't required, but testing the runbook was)
- Vendor risk questionnaires completed and filed for both vendors
We also coordinated a penetration test with a third-party firm — a requirement for many enterprise buyers even when not strictly mandated by SOC2. The test scope covered the web application and API surface. Two medium findings were identified (one IDOR in an admin endpoint, one missing rate limiting on the auth flow), patched, and re-tested within 72 hours. The clean re-test report became part of the audit package.
The observation period ran for the minimum viable window. The auditor reviewed the evidence package, conducted interviews with the CTO and two engineers, and issued the SOC2 Type II report.
The Result
The enterprise prospect received the report, procurement approved, and the $200K contract was signed — 47 days after we started.
The startup also reported two additional inbound enterprise inquiries in the 30 days following the report's availability, both citing SOC2 as a deciding factor in their evaluation.
More practically: the controls we built weren't theater for the audit. The access review process caught another orphaned admin account two months later. The alerting pipeline flagged a credential stuffing attempt in the first week it was live. The policies gave the team a framework for making decisions consistently instead of improvising each time a new vendor or employee showed up.
Frameworks Underpinning the SOC 2 Controls
SOC 2 doesn't prescribe specific technical implementations — it defines outcomes. The specific controls we implemented mapped to established security frameworks:
- OWASP Top 10 — The vulnerability scan and penetration test were structured around OWASP Top 10 risks. The IDOR finding in the admin endpoint (OWASP API1) and missing rate limiting on the auth flow (OWASP API4) were both standard OWASP Top 10 findings that appeared in what looked like a mature codebase. OWASP Top 10 should be part of every developer's baseline, not just the security team's checklist.
- NIST Cybersecurity Framework (CSF) — We documented the control set against NIST CSF to give the enterprise prospect's security team a framework-mapped overview, which is increasingly expected in vendor security questionnaires. The five NIST functions (Identify, Protect, Detect, Respond, Recover) map cleanly to the SOC 2 Trust Services Criteria.
- SANS/CWE Top 25 — SAST scanning via Semgrep was configured with CWE Top 25 rulesets, flagging dangerous software patterns in the existing codebase before they reached production. This became part of the CI/CD pipeline as a permanent control.
SOC 1 note: FinTech companies frequently encounter requests for SOC 1 (SSAE 18) reports in addition to SOC 2, particularly from prospects with their own audit obligations around financial reporting. If your platform processes transactions or financial data on behalf of customers, confirm early whether their procurement requires SOC 1 Type II as well — the observation period and audit scope differ from SOC 2. Our Security & SOC 2 Compliance Engineering team can scope both simultaneously where needed.
Automated VAPT: Manual penetration tests provide point-in-time validation but can't keep pace with a shipping team. We complement pen tests with automated VAPT integrated into the CI/CD pipeline — see VAPT automation workflows for the technical implementation pattern we use with FinTech clients.
What This Actually Takes
SOC2 Type II in three weeks is achievable for an early-stage startup if you have a few things in place: cloud-native infrastructure (AWS, GCP, or Azure), a CTO willing to prioritize the work, and a team that can implement changes without a six-week change management process.
It's not achievable through policy templates alone. The gap between a policies folder and audit-ready evidence is where most compliance projects stall. The work is in the implementation, the monitoring, and the evidence — not the documents.
If you're facing an enterprise deal blocked by SOC2 requirements, talk to us. We've done this sprint enough times to know exactly where the time goes — and how to compress it.
Related Resources
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- Healthcare SaaS: HIPAA + SOC 2 Compliance
- How to Pass Your SOC 2 Audit
- VAPT Automation Workflows
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