SOC 2 Control Implementation Guide

Service Commitments

Commitment Approval for SOC 2

New or changed customer-facing commitments are reviewed by business, legal, security, engineering, and service owners before external use.

Use this guide to put the control into operation, decide what records to retain, and check that an auditor can trace the evidence back to the work your team performed.

Maintained by GreenHat Security · Reviewed August 21, 2026

What this control should accomplish

New or changed customer commitments are checked by the people who understand the legal, security, product, engineering, and service implications before the company relies on or publishes them.

First SOC 2 program

A credible starting point

Use a single deal or content-review ticket that includes the exact proposed wording and approval from the relevant business, legal, security, and technical owners. Reserve deeper review for promises that differ from the company’s approved position.

As the company scales

Make it repeatable

Embed risk-based approval paths into contract, sales, and publishing systems, automatically route nonstandard promises to subject-matter owners, and transfer approved obligations into the commitment register and operational backlog.

How to implement Commitment Approval

  1. 1

    Capture the exact proposed commitment

    Open a review record containing the proposed language, source document, customer or audience, due date, affected service, and request owner.

    You should end up with: A dated intake record tied to the exact version under review.

  2. 2

    Identify material differences

    Compare the wording with approved company positions and flag new guarantees, tighter timelines, broader scope, unusual remedies, or claims that depend on future work.

    You should end up with: A marked review record showing standard and nonstandard commitments.

  3. 3

    Route to accountable reviewers

    Send each material statement to the functions able to validate it, including service, engineering, security, privacy, legal, support, or finance as applicable.

    You should end up with: Named approvals, requested changes, or rejection from the necessary subject-matter owners.

  4. 4

    Resolve conditions before use

    Revise unsupported wording, document an approved exception, or complete the required operational work before the commitment is signed or published.

    You should end up with: A final disposition with resolved comments and links to any prerequisite work.

  5. 5

    Approve the final version

    Confirm that the approved language is the same version used externally and preserve the final document and approval trail.

    You should end up with: A final version linked to dated approvals and the external-use record.

  6. 6

    Transfer the obligation

    Add the approved commitment to the register, notify the operational owner, and create any monitoring, reporting, or delivery tasks needed to fulfill it.

    You should end up with: A commitment record linked to an owner, supporting control, and any required operational action.

Evidence to keep, and what it should prove

Build the evidence set in three layers: what defines the control, who approved or reviewed it, and what proves it operated. Collect operating records when the work happens so they remain dated, attributable, correctly scoped, and traceable to the underlying activity.

Before sharing, remove unrelated personal or customer data, never expose passwords, tokens, or secret values, preserve enough source context to authenticate the record, and use the secure exchange approved for the engagement.

Policy / design artifacts

Documents that define the control, its scope, ownership, and expected way of working.

Approval workflows

  • Confirm what the record proves

    Proposed customer commitments are routed to the business, legal, security, engineering, and service reviewers needed for the specific wording before external use.

  • Include this context

    request and document identifier

  • Include this context

    exact version reviewed

  • Include this context

    required reviewer roles

  • Include this context

    review decisions and timestamps

  • Include this context

    final disposition

Weak evidence to avoid

A deal ticket marked approved by Sales Ops with no attached wording, technical reviewer, legal decision, timestamps, or link to the final customer version.

Approval / review evidence

Records showing that an accountable person reviewed, approved, challenged, or accepted the work.

reviewed RFP responses

  • Confirm what the record proves

    Material security and service assertions in customer questionnaires or bid responses were checked against current company capabilities before submission.

  • Include this context

    customer and response identifier

  • Include this context

    response version

  • Include this context

    material assertions flagged

  • Include this context

    subject owner reviewer

  • Include this context

    review date and disposition

Weak evidence to avoid

A submitted response file with broad encryption and availability claims but no reviewer comments, approval trail, or evidence that the final answers were validated.

contract/SOW review notes

  • Confirm what the record proves

    Reviewers identified and resolved nonstandard security, availability, support, data, or delivery obligations in the relevant contract or statement of work.

  • Include this context

    agreement and customer

  • Include this context

    clause or obligation reviewed

  • Include this context

    reviewer and function

  • Include this context

    comment or requested change

  • Include this context

    resolution and final location

Weak evidence to avoid

A comment stating looks fine on an early agreement draft without the clauses considered, reviewer function, resolved wording, or final signed document.

security/legal sign-offs

  • Confirm what the record proves

    Authorized security and legal reviewers accepted the final material commitment language, including any deviation and its rationale, before it was used.

  • Include this context

    document and final version

  • Include this context

    security approver

  • Include this context

    legal approver

  • Include this context

    approval timestamp

  • Include this context

    conditions or accepted deviations

Weak evidence to avoid

Two approval emojis in chat with no document link, version, approver identity, decision date, or record of an accepted nonstandard obligation.

Which records should you prepare for the audit?

Type 1

Evidence at the as-of date

The configured commitment-approval workflow, reviewer decision rules, approved standard positions, and one recent completed approval showing final-version control as of the examination date.

Type 2

Evidence across the review period

Every customer-facing contract, statement of work, questionnaire or bid response, service description, and assurance-content change submitted for commitment review during the review period, including rejected and withdrawn requests.

Completeness check

Reconcile submitted sales assurance responses and executed or published customer content to approval records, then compare initial and final versions for a sample to confirm the approved wording is the wording used externally.

Build the record set from

  • contract lifecycle management system
  • customer relationship management system
  • sales assurance platform
  • approval ticketing system

Keep these fields for each record

  • request identifier and content type
  • customer or audience
  • submitted and final version
  • request and decision dates
  • required and actual reviewers
  • nonstandard commitment flag
  • final disposition and external-use link

How an auditor may test this control

Use this checklist to prepare for procedures an auditor may perform. The exact steps and sample selection depend on your engagement scope and the service auditor's professional judgment.

  • Confirm the intended control outcome

    Determine whether the control is designed to achieve this result: New or changed customer commitments are checked by the people who understand the legal, security, product, engineering, and service implications before the company relies on or publishes them.

  • Confirm ownership and operating cadence

    Compare the documented owner with the intended role (Service Owner / Legal / CISO), then compare dated records with the stated cadence: Ongoing; review at least annually.

  • Establish the complete audit record set

    Reconcile submitted sales assurance responses and executed or published customer content to approval records, then compare initial and final versions for a sample to confirm the approved wording is the wording used externally.

  • Prepare the as-of-date evidence for a Type 1 engagement

    The configured commitment-approval workflow, reviewer decision rules, approved standard positions, and one recent completed approval showing final-version control as of the examination date.

  • Prepare period evidence for a Type 2 engagement

    Every customer-facing contract, statement of work, questionnaire or bid response, service description, and assurance-content change submitted for commitment review during the review period, including rejected and withdrawn requests.

  • Inspect the policy / design artifacts

    Documents that define the control, its scope, ownership, and expected way of working.

    • Inspect Approval workflows

      For each selected record, confirm it demonstrates Proposed customer commitments are routed to the business, legal, security, engineering, and service reviewers needed for the specific wording before external use.

      • request and document identifier
      • exact version reviewed
      • required reviewer roles
      • review decisions and timestamps
      • final disposition
  • Inspect the approval / review evidence

    Records showing that an accountable person reviewed, approved, challenged, or accepted the work.

    • Inspect reviewed RFP responses

      For each selected record, confirm it demonstrates Material security and service assertions in customer questionnaires or bid responses were checked against current company capabilities before submission.

      • customer and response identifier
      • response version
      • material assertions flagged
      • subject owner reviewer
      • review date and disposition
    • Inspect contract/SOW review notes

      For each selected record, confirm it demonstrates Reviewers identified and resolved nonstandard security, availability, support, data, or delivery obligations in the relevant contract or statement of work.

      • agreement and customer
      • clause or obligation reviewed
      • reviewer and function
      • comment or requested change
      • resolution and final location
    • Inspect security/legal sign-offs

      For each selected record, confirm it demonstrates Authorized security and legal reviewers accepted the final material commitment language, including any deviation and its rationale, before it was used.

      • document and final version
      • security approver
      • legal approver
      • approval timestamp
      • conditions or accepted deviations
  • Trace the control from design to operation

    Use the categories that apply to this control: connect any policy or design artifact to its approval or review record, then trace a selected operating record through execution, result, and any exception or remediation.

Common implementation and evidence gaps

  • Customer-facing language is sent before technical and service owners validate whether it is achievable.
  • Approval is captured for a draft, while a materially different final version is used externally.
  • Reviewers approve an entire document without identifying the specific nonstandard commitments they considered.
  • A future capability is described as current without a prerequisite, owner, or delivery date.
  • Approved obligations remain in the deal record and never reach the team expected to operate or measure them.

Before you call this control ready

  • Can the final customer-facing wording be traced to the exact approval record?
  • Do approval paths include every function needed to validate the type of commitment being made?
  • Are nonstandard promises explicitly identified instead of hidden inside a full-document approval?
  • Are unsupported statements revised, rejected, or tied to completed operational work before external use?
  • Does every approved material commitment reach both the register and its operational owner?

Trust Services Criteria references

These identifiers help you navigate related Trust Services Criteria. They do not reproduce the criteria or prove that this control fully addresses them in your environment.

  • CC2.3
  • CC3.1
  • CC5.1
  • CC5.3

Confirm final scope, mappings, and testing expectations with your service auditor. SOC 2® is an AICPA trademark; GreenHat Security is not affiliated with or endorsed by AICPA.