SOC 2 Control Implementation Guide

Vendor Risk

Third-Party Access Governance for SOC 2

Vendor access follows least privilege, MFA where feasible, approved connection methods, logging, and prompt revocation when no longer needed.

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 ยท Reviewed August 21, 2026

What this control should accomplish

Third parties receive only the systems and privileges needed for an approved purpose, use controlled authentication and connection methods, leave useful activity records, and lose access promptly when the need ends.

First SOC 2 program

A credible starting point

Require a named company sponsor and ticket for every vendor account or connection. Use individual accounts, least privilege, multifactor authentication where feasible, a defined expiration date, and a simple quarterly review of all third-party access.

As the company scales

Make it repeatable

Centralize vendor identities through the identity provider or privileged-access platform, automate time-bound provisioning and revocation from approved requests and contract status, monitor privileged sessions, and run risk-based access certification with system owners.

How to implement Third-Party Access Governance

  1. 1

    Inventory third-party access paths

    Identify vendor user accounts, privileged sessions, support connections, virtual private network access, API keys, service accounts, integrations, and physical access where applicable.

    You should end up with: A vendor-access inventory linked to the vendor, sponsor, system, privilege, and connection method.

  2. 2

    Require a scoped request

    Document the business purpose, requested systems and privileges, named users, data exposure, duration, sponsor, and system-owner approval before provisioning.

    You should end up with: An approved access request that supports every active vendor access path.

  3. 3

    Provision controlled access

    Use individual identities where possible, apply least privilege, enable strong authentication, restrict connection routes, set expiration, and avoid persistent administrative access unless justified.

    You should end up with: Configuration evidence showing identity, privilege, authentication, restrictions, and activation date.

  4. 4

    Log and monitor activity

    Retain authentication and relevant administrative activity, alert on unusual or unauthorized behavior, and define who investigates vendor-access events.

    You should end up with: Access and activity logs, alert configuration, and linked investigations where applicable.

  5. 5

    Review continued need

    Have the company sponsor and system owner periodically confirm the vendor relationship, named users, business need, privilege, and access method.

    You should end up with: A dated access review population with decisions and completed removals or changes.

  6. 6

    Revoke promptly

    Remove vendor identities, privileges, keys, integrations, sessions, and network paths when work ends, a user leaves, a contract terminates, or risk becomes unacceptable.

    You should end up with: Revocation records tied to the triggering event and verified across all known access paths.

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.

Approval / review evidence

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

Vendor access requests

  • Confirm what the record proves

    Each vendor identity or connection has a current business purpose, company sponsor, named user or workload, scoped privilege, duration, and system-owner approval before provisioning.

  • Include this context

    request and vendor identifier

  • Include this context

    named user or workload

  • Include this context

    business purpose and sponsor

  • Include this context

    system and requested privilege

  • Include this context

    start and expiration dates

  • Include this context

    approvers and timestamps

Weak evidence to avoid

A ticket asking to give vendor support access with no named vendor user, target system, privilege, sponsor, duration, data exposure, or owner approval.

access review records

  • Confirm what the record proves

    Business sponsors and system owners periodically assessed both continued need and least-privilege scope for every vendor access path and completed removals.

  • Include this context

    review identifier and period

  • Include this context

    reviewed access population

  • Include this context

    sponsor and system owner

  • Include this context

    retain, modify, or remove decision

  • Include this context

    decision date

  • Include this context

    completion evidence

Weak evidence to avoid

A manager certifies VendorCo still used without seeing individual accounts, roles, API keys, integrations, or evidence that removal decisions were completed.

Operating / technical evidence

Dated proof that the control actually ran, such as tickets, logs, settings, exports, reports, and test results.

MFA evidence

  • Confirm what the record proves

    Applicable vendor human identities use multifactor authentication, and any infeasible use has an approved, time-bounded alternative safeguard.

  • Include this context

    vendor identity

  • Include this context

    target system

  • Include this context

    authentication method

  • Include this context

    MFA enrollment or enforcement state

  • Include this context

    effective date

  • Include this context

    exception reference if applicable

Weak evidence to avoid

A global identity-provider settings screenshot that does not identify the vendor accounts, enforcement scope, enrollment state, date, or excluded connection method.

access listings

  • Confirm what the record proves

    The complete current population of vendor human and nonhuman access can be connected to a vendor, sponsor, system, privilege, creation date, and status.

  • Include this context

    identity, key, or integration identifier

  • Include this context

    vendor and sponsor

  • Include this context

    system and privilege

  • Include this context

    identity type

  • Include this context

    created and last-used dates

  • Include this context

    status and expiration

Weak evidence to avoid

An application user list with external email addresses but no vendor association, sponsor, role detail, service-account coverage, creation date, or expiration.

revocation tickets

  • Confirm what the record proves

    Access removal was triggered and completed across accounts, sessions, credentials, integrations, and connection paths when the approved need ended.

  • Include this context

    ticket and trigger identifier

  • Include this context

    vendor identity or connection

  • Include this context

    systems and access paths

  • Include this context

    requested and completed times

  • Include this context

    implementer

  • Include this context

    verification result

Weak evidence to avoid

A closed disable vendor ticket that names no accounts, keys, integrations, target systems, completion timestamps, or verification from authoritative access listings.

Which records should you prepare for the audit?

Type 1

Evidence at the as-of date

Current third-party access standards, configured request and authentication controls, and a point-in-time vendor-access listing reconciled across authoritative systems as of the examination date. Inspect an applicable current access, review, or revocation record when that population exists; for any population with no occurrence, retain its complete zero-result query and walkthrough a representative request through provisioning, review, and verified revocation.

Type 2

Evidence across the review period

Every vendor human account, service account, key, integration, remote connection, and privileged session active at any time during the period, plus every vendor access request, modification, review decision, and revocation event in the period.

Completeness check

Reconcile vendor identities, keys, integrations, privileged accounts, and remote connections from authoritative systems to approved requests and the vendor inventory, then trace every remove decision and termination trigger to verified revocation.

Build the record set from

  • โ€ข identity provider
  • โ€ข privileged-access management system
  • โ€ข IT service-management system
  • โ€ข cloud identity and access logs
  • โ€ข application administration consoles
  • โ€ข vendor inventory

Keep these fields for each record

  • โ€ข identity or connection identifier
  • โ€ข vendor and sponsor
  • โ€ข system, privilege, and identity type
  • โ€ข approval, creation, and expiration dates
  • โ€ข authentication and MFA state
  • โ€ข review decision
  • โ€ข revocation trigger and completion time

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: Third parties receive only the systems and privileges needed for an approved purpose, use controlled authentication and connection methods, leave useful activity records, and lose access promptly when the need ends.

  • Confirm ownership and operating cadence

    Compare the documented owner with the intended role (Vendor Risk Owner / CISO / Legal), then compare dated records with the stated cadence: Prior to onboarding; periodic based on risk; at least annually for critical/high.

  • Establish the complete audit record set

    Reconcile vendor identities, keys, integrations, privileged accounts, and remote connections from authoritative systems to approved requests and the vendor inventory, then trace every remove decision and termination trigger to verified revocation.

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

    Current third-party access standards, configured request and authentication controls, and a point-in-time vendor-access listing reconciled across authoritative systems as of the examination date. Inspect an applicable current access, review, or revocation record when that population exists; for any population with no occurrence, retain its complete zero-result query and walkthrough a representative request through provisioning, review, and verified revocation.

  • Prepare period evidence for a Type 2 engagement

    Every vendor human account, service account, key, integration, remote connection, and privileged session active at any time during the period, plus every vendor access request, modification, review decision, and revocation event in the period.

  • Inspect the approval / review evidence

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

    • Inspect Vendor access requests

      For each selected record, confirm it demonstrates Each vendor identity or connection has a current business purpose, company sponsor, named user or workload, scoped privilege, duration, and system-owner approval before provisioning.

      • request and vendor identifier
      • named user or workload
      • business purpose and sponsor
      • system and requested privilege
      • start and expiration dates
      • approvers and timestamps
    • Inspect access review records

      For each selected record, confirm it demonstrates Business sponsors and system owners periodically assessed both continued need and least-privilege scope for every vendor access path and completed removals.

      • review identifier and period
      • reviewed access population
      • sponsor and system owner
      • retain, modify, or remove decision
      • decision date
      • completion evidence
  • Inspect the operating / technical evidence

    Dated proof that the control actually ran, such as tickets, logs, settings, exports, reports, and test results.

    • Inspect MFA evidence

      For each selected record, confirm it demonstrates Applicable vendor human identities use multifactor authentication, and any infeasible use has an approved, time-bounded alternative safeguard.

      • vendor identity
      • target system
      • authentication method
      • MFA enrollment or enforcement state
      • effective date
      • exception reference if applicable
    • Inspect access listings

      For each selected record, confirm it demonstrates The complete current population of vendor human and nonhuman access can be connected to a vendor, sponsor, system, privilege, creation date, and status.

      • identity, key, or integration identifier
      • vendor and sponsor
      • system and privilege
      • identity type
      • created and last-used dates
      • status and expiration
    • Inspect revocation tickets

      For each selected record, confirm it demonstrates Access removal was triggered and completed across accounts, sessions, credentials, integrations, and connection paths when the approved need ended.

      • ticket and trigger identifier
      • vendor identity or connection
      • systems and access paths
      • requested and completed times
      • implementer
      • verification result
  • 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

  • Multiple vendor personnel share one account, preventing individual accountability and clean revocation.
  • A remote connection grants broad network reach when access to one system or function would be sufficient.
  • Vendor service accounts, API keys, and integrations are excluded from access reviews focused only on human users.
  • The business sponsor confirms the vendor relationship but cannot assess whether technical privileges remain appropriate.
  • Contract termination is not connected to identity, key, integration, and network-access revocation.

Before you call this control ready

  • Can every active vendor account, key, integration, and connection be traced to a current sponsor and approved purpose?
  • Do system owners confirm both continued need and least-privilege scope during access reviews?
  • Is strong authentication used where feasible, and are any exceptions documented with safeguards and expiration?
  • Are privileged vendor actions logged and reviewable by the company?
  • Can a terminated relationship be traced to prompt revocation across identities, sessions, credentials, integrations, and network paths?

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.

  • CC6.1
  • CC6.2
  • CC6.3
  • CC9.2

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