SOC 2 Exceptions: What They Mean & How to Handle Them

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In Accenture’s 2024 Risk Study, 27% of risk leaders flagged compliance as an urgent concern, and 44% admitted to struggling with risk visibility before audits.

One area where these challenges often come to light is during SOC 2 audits, where even minor gaps in risk management and controls can lead to exceptions.

These exceptions refer to control failures flagged by auditors during a SOC 2 Type 2 assessment. They often stem from unnoticed gaps in controlling day-to-day operations. It could be missed access reviews, untracked vendor risks, or conflicting evidence collection across different teams.

Part of the problem is the mindset.

Many businesses still view SOC 2 Type 2 audits as a pass-fail event, with “exceptions” treated like a black mark. But SOC 2 exceptions are manageable if you understand what they are, why they happen, and how to respond.

Ahead, we’ll break down the responding SOC 2 exceptions to passing those and even best practices to stay clear.

What is a SOC 2 Exception?

SOC 2 exception refers to any instance where an implemented control didn’t operate as intended during the audit period. It’s flagged in the audit report when your auditor identifies control exceptions. 

These exceptions can have multiple causes, such as incomplete automation, human oversight, mid-cycle process changes, or controls that were only partially implemented.: 

They don’t always mean your entire program is flawed, but they do impact how your auditor assesses your overall compliance.

Types of SOC 2 Exceptions

Understanding the types of SOC 2 exceptions helps overcome apprehensions by focusing on avoiding those that can significantly impact your audit opinion.

Most exception flags have three broad categories:

1. Control not implemented

It’s when the auditor determines that a required control was not implemented during the audit period.

For example, a control exception is when the policy mandates quarterly vulnerability scans, but none were run.

2. Partially implemented

The existing control is not consistently applied. For instance, vulnerability scans were set up, but two out of four required scans were missed during the audit window.

3. Failed test

It’s when the implemented control failed during testing. For example, you conducted access reviews, but one user with excessive privileges that were never removed.

Difference: Exception vs. Audit Finding

There are different audit terminologies, such as audit exception, audit finding, or control exception audit. 

To avoid any confusion, let’s break down the two major ones.

• Audit exception
  A specific instance where a control didn’t operate effectively during the audit period. It’s a factual observation of what failed and goes directly into your SOC 2 report.
  
• Audit finding
  A broader insight or observation from the auditor may include highlighting one or more exceptions, or other risks or weaknesses. 

Every finding may not be an exception.

Audit Exception	Audit Finding
Direct control failure (missed scan, failed access review)	Broader observation on control design, process gaps, and recurring issues
Documented as a formal exception in the report	May or may not trigger a formal exception
Impacts the audit opinion if material	May guide remediation or future audits, but not always opinion-impacting

Examples of SOC 2 Audit Exceptions

We’ll go through a few real-world examples of SOC 2 exceptions that can help your team spot potential gaps early.

1. Missed access review

Let’s say you documented quarterly access reviews, but only did two in the last year.

The auditor would check your calendar, review your sign-off evidence, and flag a gap, leading to a control exception under the security or confidentiality criteria.

• Why it happens: No alerting mechanism, vacation cycles, or staff churn.
• Fix: Automate calendar tasks + evidence capture in your GRC tool.

2. Unrevoked access after termination

An employee who left the company still has admin access to AWS or GitHub active for 15+ days. That’s a red flag if your policy states a 48-hour revocation.

• Why it happens: HR and IT systems aren’t synced, or access deprovisioning is manual.
• Fix: Connect HRIS to IAM and automate offboarding.

3. Missing vulnerability scans

You’ve committed to monthly scans but skipped January and May due to workload. Your scanner logs prove it as a test failure, and it’s a partially implemented control.

• Why it happens: Probably because of issues like shared responsibility across DevSecOps, and no one owns the control.
• Fix: Assign ownership and set up scan result audits within Sprinto.

4. No evidence of employee training

What if you conduct privacy and security training but have no records of who completed it successfully? Without proof, your auditor has to assume it didn’t happen.

• Why it happens: Relying on Slack/Google Forms instead of a proper LMS or audit-traceable system.
• Fix: Adopting platforms to track acknowledgment, timestamps, and completion.

How Exceptions Impact the Audit Opinion

Check how exceptions show up, where they occur, and how you can handle them. Usually, the exception impact will have two primary outcomes:.

1. Unqualified (Clean) Opinion

It’s an outcome every company wants, suggesting your auditor found no material control failures during the audit period. There may be minor exceptions like a missed review, a partial test, etc. But there won’t be questions about the operating effectiveness of your control system.

2. Qualified Opinion

A qualified opinion means your auditor identified one or more material exceptions. These represent gaps serious enough to affect how they view the effectiveness of your controls. You haven’t failed the audit, but the report now includes a formal caveat.

3. How Exceptions Influence Your Audit Opinion

An exception doesn’t automatically damage your audit outcome.

What matters is how the exception occurred, how widespread it is across systems or processes, and what part of your environment it affects. 

Especially if it touches sensitive data, and how effectively you responded to contain its impact and demonstrate control.

These are four key ways in which exceptions influence the final call.

A. Severity of the control exception

Control exceptions may arise due to different issues.

For example, missing a quarterly access review may be flagged as a low-severity exception. But if you did not comply with NIST password guidelines (not implementing multi-factor authentication) across all production accounts, then errors may easily escalate to a high-severity exception under the Security and Confidentiality criteria.

B. Frequency and recurrence

If auditors encounter multiple isolated errors, they raise red flags, highlighting that the exceptions are present across multiple controls. For instance, missing the same check for three months in a row can make auditors flag it as a systemic weakness.

C. Response during the audit

Auditors look at how you responded when exceptions were discovered.

Did you acknowledge it, fix it, and show process changes? Or did it take weeks to clarify, with poor documentation?

A remediation plan and audit readiness influence whether the exception becomes a mark against you or simply a note for future cycles.

How to Respond to and Remediate Exceptions?

A flagged SOC2 exception requires showing audit readiness and process maturity to course-correct in real time.

This happens when you:

• Respond with clarity and fix with intent
• Remediate so that it doesn’t happen again.

How to Respond to a SOC 2 Exception?

The response starts when the auditor flags the exception. Acknowledge the gaps, assess the risk, and preserve trust by showing that the issue is understood, contained, and already being addressed.

– Acknowledge, don’t deflect

Whether the miss was procedural or technical, call it out. Auditors want clarity, so avoid reframing a failure as a misinterpretation.

– Show scope and impact

Is it a one-off? A process miss? A config error in a non-critical system? Support your case with logs, screenshots, timelines, or policy references to prove it’s not systemic.

– Outline next steps immediately.

Share what you’re doing right now to re-execute the control, isolate the risk, and notify affected teams. Next is when you’ll commit to a remediation timeline.

How to Remediate a SOC 2 Exception?

Remediation requires fixing the broken link in your control system and ensuring it won’t fail again. It’s a move from damage control to operational maturity, proving that the exception was an edge case, not a pattern.

– Pinpoint what broke

Identify the issue that causes SOC 2 exceptions to come up.

Was the control itself unclear? Did no one own it? Or was automation only partially executed? Until you get to the root of the failure, applying a surface fix only delays the next exception.

– Strengthen the control

Eliminate fragility by tightening your setup. For this, adjust the tooling, redefine SLAs, or enforce automation wherever human error creeps in.

Controls should be built to run right every time, not rely on someone remembering what to do.

– Re-run and record

Execute the fixed control again, capture clean evidence, and keep a record of exactly what changed and when. It provides auditors a clear remediation timeline backed by action, not just intent.

– Document the fixed path

Lay it all out: what went wrong, why it happened, how you solved it, and what policy updates now prevent it. The more precise your remediation log, the faster you restore confidence with your auditor and your board.

Can You Pass SOC 2 with Exceptions?

Yes, you can pass SOC 2 Type 2 with exceptions, but only if they don’t materially impact your ability to meet the Trust Services Criteria.

Auditors assess the nature, frequency, and impact of exceptions. One-off misses with a clear remediation plan usually won’t block you from getting a clean (unqualified) opinion. But if there are multiple exceptions that show a pattern, such as poor documentation or unresolved risks, they can lead to a qualified audit opinion.

Best Practices to Avoid Common Exceptions

SOC 2 exceptions build up through delays that no one tracks. Working to hit product and sales milestones may deprioritize SOC 2 exceptions. To avoid common SOC 2 exceptions, you could adopt some of these best practices.

1. Build automation into control execution

Tasks can be missed if someone has to remember them. Use tools to automate recurring tasks: vulnerability scans, access reviews, and evidence collection.

2. Assign control owners and publicize them

Every control must have one owner, which should be known to everyone. So, if something fails, there’s no confusion since you already know who to ask.

3. Monitor control status in real time

Adopt dashboards showing which controls are live, what’s overdue, and what evidence is missing to detect early warnings.

4. Run quarterly audit rehearsals

Avoid waiting till the end to check if you’re ready for an audit. Instead, every quarter, pick a set of key controls, test them, and check the evidence to spot drift early when it’s fixable.

5. Write down what breaks

Document failed controls, mention what changed, and how you’ll stop it from failing again to be audit-ready.

Managing SOC 2 exceptions faster

Managing SOC 2 exceptions requires your team to know how to respond, what to fix, and how to prove it.

Sprinto detects SOC 2 exceptions in real time, auto-logs them, triggers remediation workflows, and collects audit-ready evidence throughout the process. It ensures your response isn’t just reactive but systematized—so you stay compliant, even when things go off-script.

Book a demo and see how your team can respond faster, prove fixes, and run cleaner audits with Sprinto.

Frequently asked questions

1. What is the most common SOC 2 exception?

Missed or delayed access reviews and training acknowledgment tracking are among the most frequent exceptions.

2. Will one exception lead to a qualified opinion?

Not necessarily. If it’s isolated, low-risk, and well-managed, you can still receive a clean opinion.

3. What’s the difference between SOC 2 audit exceptions and findings?

Exceptions are specific control failures. Findings may include exceptions or broader observations about risk posture.

4. Can you fix the exception after the audit period?

You can fix it, but it won’t change the audit period outcome. Still, your fix might influence how the auditor frames the issue in the report.

5. Do GRC tools help reduce exceptions?

Yes. While they don’t guarantee compliance, they help control execution and evidence collection.