🎉 Welcome to our newly redesigned site!If you notice any issues, pleaselet us know.
SOC 2 Document Templates - Get compliant faster with proven templates and guidance

How to Write a SOC 2 System Description That Actually Passes Audit

Master the most overlooked part of SOC 2 compliance with this detailed guide to crafting a clear, accurate system description that satisfies auditors and streamlines your certification.

Back to Blog
SOC 2 Compliance

How to Write a SOC 2 System Description That Actually Passes Audit

24 min read

Your auditor sends you a template for the system description section of your SOC 2 report, and you stare at it with a sinking feeling. The document asks for detailed descriptions of your infrastructure, your organizational structure, your security controls, and your operational processes. It's asking you to describe things you barely have documented anywhere else, and you're supposed to do it in a way that's comprehensive yet readable, technical yet accessible, detailed yet concise.

Here's what nobody tells you: the system description is where many SOC 2 audits go sideways. Companies treat it as a quick documentation exercise they can knock out in a few hours, only to discover during the audit that their system description doesn't match their actual implementation, creates inconsistencies with their other evidence, or is so vague that auditors can't understand what they're actually certifying.

The system description isn't just a formality—it's the foundation of your entire SOC 2 report. It defines what's being audited, establishes the context for all your controls, and serves as the reference point against which auditors will measure your actual practices. Getting it right early saves you significant pain later.

In this guide, we'll walk through exactly how to write a system description that passes muster with auditors, covers everything required by the SOC 2 framework, and accurately represents your actual systems and practices. We'll show you what goes into each section, common mistakes that create audit delays, and how to strike the balance between being thorough and being comprehensible.

What Is a System Description and Why It Matters

The system description is Section 3 of your SOC 2 report. It provides a comprehensive overview of your organization and the systems covered by the SOC 2 audit. Think of it as telling the story of your company's security program—who you are, what you do, how your systems work, and what controls you have in place to protect customer data.

Auditors use the system description to understand the scope of their audit and the context for evaluating your controls. They'll reference it constantly throughout the audit process. Customers who receive your SOC 2 report will read the system description to understand what was actually certified. And you'll use it as a reference document for your own compliance program going forward.

The system description isn't a marketing document. You're not trying to sell your security program—you're trying to accurately describe it in enough detail that readers can understand what you do and how you do it. Auditors have seen hundreds of system descriptions, and they can spot vague hand-waving or exaggerated claims instantly.

At the same time, the system description isn't a complete technical architecture document. You don't need to describe every database table, every API endpoint, or every line of code. You need to describe your systems at the level of detail necessary to understand your security controls and evaluate your compliance with SOC 2 criteria.

Getting this balance right—detailed enough to be meaningful, concise enough to be readable—is the central challenge of writing an effective system description.

The Five Main Components of a System Description

SOC 2 system descriptions follow a standard structure with five primary sections. Let's walk through each one and what you need to include.

Company Overview and Services Description

This section establishes who you are and what your business does. You're setting the stage for everything that follows by helping readers understand your company's purpose, your customer base, and the services you provide.

Start with basic company information. Your legal entity name, when you were founded, where you're headquartered, and how many employees you have. If you have multiple legal entities or operate in multiple countries, explain that structure clearly. Auditors need to understand the organizational scope of the audit.

Describe your services in business terms first, then technical terms. Explain what problems you solve for customers and what value you provide. A payments processing company might start by explaining that they enable e-commerce businesses to accept credit card payments securely, then dive into the technical details of how their API processes transactions.

Be specific about what's included in the audit scope versus what's excluded. If you offer multiple products but only one is included in your SOC 2 certification, state that explicitly. If you have services that aren't customer-facing and aren't part of the scope, mention them briefly and clarify they're out of scope. Ambiguity here creates confusion later.

Describe your customer base in general terms. What types of companies use your services? What industries do they represent? How many customers do you have? You don't need to name specific customers, but provide context about who relies on your services and what they use them for.

Include a brief company history if relevant to understanding your current state. If you recently underwent a major re-architecture, merged with another company, or significantly changed your business model, mention it. Auditors need to understand major transitions that might affect your control environment.

Avoid marketing language. Don't describe yourself as "the leading provider" or claim to be "revolutionizing the industry." Stick to factual descriptions of what you do and who uses your services.

System Description and Infrastructure

This is the technical heart of your system description. You're explaining how your systems actually work from an infrastructure and architecture perspective.

Start with your infrastructure model. Are you running on AWS, Google Cloud, Azure, or a combination? Do you use managed services or self-hosted infrastructure? Describe your hosting approach at a high level before diving into details.

Explain your system architecture using a layered approach. Describe your presentation layer (web applications, APIs), application layer (business logic, processing services), and data layer (databases, storage systems). You don't need to list every microservice, but provide enough detail that readers understand how data flows through your system.

Include a system architecture diagram. A visual representation of your infrastructure is worth thousands of words. Show how different components connect, where data is stored, how external systems interact with yours, and where security boundaries exist. Keep the diagram at a logical level—you're showing the architecture, not every server instance.

Describe your data storage approach. Where do you store customer data? What databases do you use? How is data organized? Explain your approach to data segregation if you have multi-tenant architecture. Auditors pay close attention to how you store and protect customer data, so be thorough here.

Detail your network architecture and security zones. Do you use VPCs or similar network isolation? How do you segment production from non-production environments? What network controls prevent unauthorized access? Describe your approach to network security without listing every firewall rule.

Explain your deployment architecture. How do you deploy application changes? What environments do you maintain (development, staging, production)? How are environments separated and secured? This helps auditors understand your change management controls.

Describe third-party integrations and dependencies. What external services does your system rely on? Payment processors, email providers, authentication services, analytics platforms—list them and explain how they integrate with your system. This is important for understanding your service organization boundaries.

Include information about data centers and physical infrastructure. Even if you're fully cloud-based, you should note that you rely on your cloud provider's physical security controls and reference their SOC 2 reports.

Organizational Structure and Security Roles

SOC 2 is ultimately about people and processes, not just technology. This section describes your organizational structure and how security responsibilities are distributed.

Provide an organizational chart showing your company's structure. You don't need to include every employee, but show major departments and reporting relationships. Highlight where security and compliance responsibilities sit in your organization.

Identify key security roles and responsibilities. Who is your CISO, security lead, or compliance officer? Even if these are part-time responsibilities or performed by someone with another primary role, document who owns security. Describe what each security role is responsible for.

Explain your security team structure. Do you have dedicated security personnel, or is security distributed across engineering and operations teams? How many people spend significant time on security activities? Be honest about your staffing situation—auditors understand that small companies don't have large security teams.

Describe your governance structure for security decisions. Who approves security policies? Who reviews and approves security changes? How are security incidents escalated? Document your decision-making processes and approval hierarchies.

Detail your employee onboarding and offboarding processes from a security perspective. How do new employees get access to systems? What security training do they receive? How is access revoked when employees leave? These processes are fundamental SOC 2 controls.

Explain your vendor management approach. Who evaluates third-party security? How do you onboard new vendors? What security requirements do you impose on vendors? This demonstrates your control over your service organization's boundaries.

Describe your board or executive oversight of security. How often do security topics get reviewed at leadership levels? Who receives security reports? This demonstrates management's commitment to security, which is a key SOC 2 principle.

Security Principles, Policies, and Procedures

This section describes your security program at a policy and process level. You're explaining what security controls you have in place and how you implement them.

Start with your security principles or philosophy. What are your core beliefs about security? Many companies articulate principles like "defense in depth," "least privilege access," or "security by design." These principles inform your specific controls.

Describe your policy framework. Do you have an information security policy? What other security policies do you maintain? You don't need to reproduce your entire policy library, but list your major policies and explain what each one covers. This demonstrates that you have documented security requirements.

Detail your access control approach. How do you manage user access to systems? What authentication methods do you use? Do you require multi-factor authentication? How often do you review access rights? This is one of the most scrutinized areas in SOC 2 audits, so be thorough.

Explain your data protection controls. How do you encrypt data at rest and in transit? What data classification approach do you use? How do you ensure customer data is handled appropriately? Cover both technical controls and procedural requirements.

Describe your security monitoring and incident response capabilities. How do you monitor for security events? What alerting do you have in place? What's your process when security incidents occur? Explain both your detective controls and your response procedures.

Detail your vulnerability management process. How often do you scan for vulnerabilities? How do you prioritize and remediate findings? What's your patching cadence? This demonstrates your proactive approach to security risk management.

Explain your security awareness and training program. What training do employees receive? How often is training conducted? How do you measure training effectiveness? Include information about role-specific security training if relevant.

Describe your backup and disaster recovery procedures. How often do you back up data? How are backups protected? How often do you test recovery? What's your recovery time objective? This demonstrates your resilience controls.

Cover your change management process. How do application and infrastructure changes get approved? What testing occurs before production deployment? How do you track changes? This shows you have controlled change processes.

Explain your physical security controls, even if you're fully cloud-based. If you rely on cloud providers for physical security, reference their SOC 2 reports. If you have physical offices where employees work, describe security measures like badge access or visitor management.

Complementary Controls and Service Organizations

This is where you explain what's your responsibility versus what you rely on others for. SOC 2 recognizes that modern companies rely on third-party service providers, and you need to document those dependencies clearly.

Start by explaining the concept of complementary user entity controls if applicable. These are controls that your customers must implement for security to be effective. For example, if you provide an API service, you might note that customers must properly secure their API keys. Be specific about what customers need to do.

List all significant third-party service organizations you rely on. Focus on services that are material to your security controls or that process customer data. Common examples include:

Cloud infrastructure providers like AWS, Google Cloud, or Azure. Note that you rely on their physical security, data center controls, and infrastructure security. Reference their SOC 2 reports.

Authentication providers like Okta or Auth0 if you use them for SSO or customer authentication. Explain how you use these services and reference their certifications.

Payment processors if you handle financial transactions. Describe your integration approach and note their PCI compliance or SOC 2 certifications.

Monitoring and security tools that process your data. If you use security services like endpoint detection or SIEM platforms, mention them.

For each service organization, describe what services they provide, what data they access, and what controls you rely on them for. Auditors need to understand your dependencies to properly scope the audit and determine if they need to review subservice auditor reports.

Explain how you evaluate and monitor third-party security. Do you review SOC 2 reports from vendors? Do you conduct security assessments? How do you ensure vendors maintain appropriate security? This demonstrates you have vendor management controls.

Be clear about what's in scope versus out of scope based on your service organization relationships. If you use a third-party email provider but don't include their infrastructure in your SOC 2 scope, state that explicitly.

Writing Style and Tone Guidelines

Beyond content, how you write your system description matters. Auditors read dozens of these documents, and clear writing makes their job easier while demonstrating your professionalism.

Use clear, direct language. Avoid jargon when possible, and define technical terms when you must use them. Write for an audience that understands security concepts generally but may not be familiar with your specific technology stack.

Be precise without being verbose. Each sentence should convey meaningful information. Cut filler words and vague statements. "We take security seriously" conveys nothing. "We enforce multi-factor authentication for all administrative access" conveys specific control implementation.

Use active voice rather than passive voice. "The security team conducts vulnerability scans weekly" is clearer than "Vulnerability scans are conducted weekly." Active voice makes your controls and responsibilities clearer.

Maintain consistency in terminology. If you call something "production environment" in one section, don't call it "prod infrastructure" or "live systems" elsewhere. Consistent terminology prevents confusion.

Structure paragraphs logically with clear topic sentences. Each paragraph should address a single topic or closely related set of topics. Use topic sentences that tell readers what the paragraph covers, then provide supporting details.

Use headers and subheaders generously. Break up long sections with descriptive subheaders that help readers navigate the document. Your system description might be 20-30 pages long, and good structure makes it much more usable.

Include enough detail to be meaningful but not so much detail that you create maintenance burdens. You'll need to update your system description periodically as your systems evolve. Avoid documenting every server hostname or specific configuration setting that might change frequently.

Proofread carefully. Typos and grammatical errors undermine your credibility and make the document harder to read. Have multiple people review the system description before submitting it to your auditor.

Common Mistakes That Create Audit Problems

We've seen system descriptions that create significant problems during audits. Here are the most common pitfalls and how to avoid them.

Describing aspirational controls rather than actual implementation. Your system description must accurately represent how your systems and controls actually work today, not how you wish they worked or plan for them to work in the future. If you describe multi-factor authentication as required but it's only required for some systems, you've created an inconsistency that auditors will catch. Be honest about your current state.

Being too vague about infrastructure and architecture. Generic statements like "we use industry-standard security practices" or "data is stored securely" tell auditors nothing. They need specific information about what systems you use, how they're configured, and what controls are in place. Vague descriptions force auditors to spend more time investigating, which increases your audit cost and timeline.

Inconsistency between system description and other evidence. If your system description says you conduct quarterly access reviews but your access review logs show monthly reviews, auditors will question which is accurate. Ensure your system description matches your actual practices and aligns with your policy documents and evidence.

Failing to update the system description when systems change. Your system description needs to reflect the state of your systems during the audit period. If you migrated from one cloud provider to another or implemented a major architectural change mid-period, your system description needs to address this. Document significant changes and explain timelines.

Including too much detail about things that don't matter for SOC 2. You don't need to describe your marketing website architecture if it doesn't process customer data. You don't need to explain your internal HR system if it's not part of the audit scope. Focus on what's relevant to the controls being audited.

Ignoring the boundaries between your organization and service organizations. Be clear about what controls you implement directly versus what you rely on third parties for. If you use AWS, you can't claim to implement AWS's physical data center security—you rely on AWS for that. Understanding and documenting these boundaries properly is critical.

Using marketing language or making unsupported claims. "We provide the most secure platform in the industry" is a marketing claim, not a system description statement. Stick to factual descriptions of what controls you have implemented. Let the controls speak for themselves rather than making subjective claims about their quality.

Forgetting to describe manual processes and procedures. SOC 2 isn't just about technology. If you have manual processes for reviewing access, investigating security events, or responding to incidents, document them. Auditors need to understand your human processes as much as your technical controls.

Describing controls you don't actually perform consistently. If you say you conduct security awareness training annually but you've only done it once in your company's history, that's a problem. Only describe controls and processes that you actually perform regularly and can provide evidence for.

The Review and Approval Process

Your system description shouldn't be written in isolation and finalized in a single draft. A solid review process ensures accuracy and catches problems before they become audit issues.

Start with a cross-functional drafting approach. Have someone with deep technical knowledge draft the infrastructure and architecture sections. Have your security or compliance lead draft the security controls sections. Have leadership review the company overview sections. Different perspectives produce more accurate and complete descriptions.

Conduct a technical accuracy review where engineers verify that the system description matches actual implementation. Have developers review the application architecture description. Have operations review the infrastructure description. Catch inaccuracies early rather than during the audit.

Perform a completeness review against the SOC 2 criteria. For each Trust Service Criterion you're being audited against, ensure your system description addresses relevant controls. If you're including Availability criteria, make sure you describe your uptime monitoring and redundancy. If you're including Confidentiality, ensure you describe data protection controls.

Have your auditor review a draft before you finalize it. Most audit firms will provide feedback on your system description structure and content before the formal audit begins. Take advantage of this to catch issues early and save time during the audit itself.

Get executive approval before submitting the final version. Your CEO or equivalent should review and approve the system description since they'll ultimately be signing the SOC 2 report. Their approval also demonstrates management ownership of the security program.

Plan to update the system description annually or whenever significant changes occur. Your system description becomes a living document that evolves with your company. Budget time each year to review and revise it.

Aligning Your System Description with Your Control Environment

Your system description doesn't exist in isolation—it's part of a larger control environment that includes your policies, procedures, and actual practices. Strong alignment between these elements makes audits smoother and demonstrates the maturity of your compliance program.

Start by ensuring your system description accurately reflects your security policies. If you have an Access Control Policy that specifies quarterly access reviews, your system description should mention quarterly access reviews. If your policies say one thing and your system description says another, auditors will question which is correct and whether controls are being followed.

Make sure your system description aligns with your evidence. If you describe weekly vulnerability scans in your system description, you need to be able to produce weekly vulnerability scan reports during the audit. Don't describe controls more frequently or comprehensively than you actually perform them.

Use your system description to guide your control implementation. As you write the system description, you may identify gaps where you're describing controls you should have but don't fully implement yet. Use these discoveries to strengthen your actual security program before the audit rather than inventing controls that don't exist.

Think of your system description as a contract with your auditor and your customers. You're explicitly stating what your systems do and what controls you have in place. Auditors will test whether you actually do what you've described. Customers will expect you to maintain the controls you've documented. Take this responsibility seriously.

Technical Detail: How Much Is Enough?

One of the hardest questions in writing system descriptions is determining the right level of technical detail. Too little detail makes the document meaningless. Too much detail makes it unreadable and difficult to maintain.

Here's a practical framework: provide enough detail that a knowledgeable security professional could understand your security posture and evaluate your controls, but not so much detail that a moderately technical person couldn't follow the description.

For infrastructure, describe your hosting model, major components, and security boundaries. Don't list every EC2 instance type or database parameter. Do explain whether you use managed services or self-hosted infrastructure, how you segment networks, and where customer data is stored.

For application architecture, describe your main system components and how they interact. Don't document every API endpoint or database table. Do explain your authentication approach, how data flows through your system, and what third-party integrations exist.

For security controls, describe what you do and how often you do it. Don't provide step-by-step procedures or configuration screenshots. Do explain whether you use multi-factor authentication, how you monitor for security events, and what your incident response process looks like.

When in doubt, ask yourself: "Would this level of detail help an auditor understand whether my controls are effective?" If yes, include it. If it's interesting but not necessary for control evaluation, leave it out.

Creating Supporting Documentation and Diagrams

Visual aids significantly improve system description clarity. Don't rely solely on text—supplement with diagrams and tables that make complex information more accessible.

A system architecture diagram is essentially mandatory. Show your major system components, how they connect, where data is stored, and where security boundaries exist. Use standard diagramming conventions (boxes for components, lines for connections, dashed lines for security boundaries). Keep it at a logical level rather than showing every server or container.

A network diagram helps illustrate your network security approach. Show VPCs, subnets, firewalls, and how different environments are separated. This is particularly important if you have complex network security architecture.

An organizational chart clarifies roles and responsibilities. Show your company structure and highlight where security responsibilities sit. You don't need to include every employee, but show major departments and security-relevant roles.

A data flow diagram can be helpful if you process customer data through multiple systems or hand data off to third-party services. Show how data enters your system, where it's stored, how it's processed, and where it exits.

Tables work well for repetitive information. If you have multiple third-party service providers, a table with columns for service name, purpose, data accessed, and security certifications is clearer than paragraphs for each provider.

Keep diagrams simple and focused. Don't try to show everything in one diagram. Create multiple targeted diagrams rather than one overwhelming comprehensive diagram. Update diagrams whenever you update the corresponding text.

Timeline and Effort Estimation

Writing a comprehensive system description takes significant time. Don't leave it until the last minute before your audit.

For a first-time system description, budget 40-60 hours of work across multiple people. Technical staff will spend 15-20 hours describing infrastructure and architecture. Security or compliance leads will spend 15-20 hours describing controls and policies. Leadership will spend 5-10 hours reviewing and approving. Additional time is needed for diagram creation and revisions.

Plan for multiple drafts over several weeks. Your first draft will be incomplete and require significant revision. Budget time for review cycles, feedback incorporation, and auditor review. From starting your first draft to having an auditor-approved final version typically takes 4-6 weeks if you're working steadily.

If you're using our Complete Bundle with policy templates, you can reference those policies directly in your system description, which significantly reduces the time needed to describe your security program. Having well-documented policies makes the system description much faster to write.

For annual updates after your initial audit, plan for 10-20 hours of work depending on how much your systems have changed. Most of your system description will remain accurate, but you'll need to update sections that changed and ensure everything still aligns with your current state.

Working with Your Auditor on the System Description

Your auditor is your partner in creating an accurate, complete system description. Don't view the system description as something you create independently and then hand over. Collaborate with your auditor throughout the process.

Share a draft system description with your auditor early, ideally 4-6 weeks before your audit fieldwork begins. Most auditors will provide feedback on structure, completeness, and areas that need more detail. Incorporate this feedback before finalizing the document.

Ask your auditor about their preferences for format and level of detail. Some audit firms have specific templates or preferences for how system descriptions are structured. Understanding their preferences upfront saves revision time later.

Clarify the audit scope with your auditor before writing your system description. Make sure you agree on what's in scope versus out of scope, which systems are being audited, and which Trust Service Criteria apply. Your system description should align with the agreed audit scope.

Use the system description process as an opportunity to discuss your control environment with your auditor. If you're uncertain whether a control meets SOC 2 requirements or how to describe something, ask. Auditors would rather clarify expectations early than discover problems during fieldwork.

Expect your auditor to reference your system description constantly during the audit. They'll use it to understand what controls should exist, determine what evidence to request, and evaluate whether your implementation matches your description. This makes accuracy in the system description critical.

Beyond the Initial Audit: Maintaining Your System Description

Your system description isn't a one-time deliverable. It becomes a living document that evolves with your company and your systems.

Review your system description at least annually, even if you're not conducting a new audit. Systems change, organizations evolve, and controls mature. Your system description should reflect your current state, not your state from years ago.

Update your system description whenever significant changes occur. Major infrastructure migrations, organizational restructuring, new third-party service providers, or changes to your security control environment should trigger system description updates. Don't wait for your next audit to document major changes.

As you prepare for your SOC 2 Type II audit, your system description needs to accurately reflect how your systems and controls operated throughout the observation period. If systems changed during that period, document the timeline and what changed. Auditors need to understand the state of your systems when testing controls from different points in the observation period.

Use your system description as a reference for your team. New security or compliance team members can read the system description to understand your security program. It serves as documentation of your control environment that's useful beyond just audit purposes.

Consider creating an internal version of your system description with additional detail that you wouldn't include in the public version. The internal version can include specific configuration details, internal process documentation, and implementation notes that help your team but aren't necessary for auditors or customers.

Wrapping Up: Make Your System Description an Asset

The system description is often viewed as an audit requirement to be completed as quickly as possible. That's a missed opportunity. A well-written system description becomes a valuable asset that serves multiple purposes beyond SOC 2 compliance.

It provides clear documentation of your systems and security controls that your team can reference. It demonstrates to customers and prospects exactly what security measures you have in place. It guides your security program by making explicit commitments about controls you'll maintain. And yes, it makes audits significantly smoother by giving auditors a clear understanding of what they're evaluating.

Invest the time to write a system description that accurately represents your systems, clearly describes your controls, and aligns with your actual implementation. The upfront effort pays dividends throughout your compliance journey and beyond.

When you're ready to document the policies and procedures that your system description references, our Complete Bundle provides all the templates you need to build a comprehensive security program that aligns with your system description. Your system description tells the story of your security program—our templates help you actually build that program.

Good documentation is the foundation of sustainable compliance. Your system description is where that documentation starts.

Need SOC 2 Templates?

Save time with our professionally crafted SOC 2 compliance templates and documentation.

Browse Templates

Legal Disclaimer: These templates are starting points that require customization. Learn more about our legal disclaimer →