TSC-CC1.5 Guidance

The tsc-cc1.5 guidance requirement is about making accountability real: people must know their internal control responsibilities, leadership must reinforce them, and your organization must show that it follows through when responsibilities are missed. In SOC 2, this sits in the “Common Criteria” and is evaluated through your governance, policies, role definitions, and the evidence trail that shows controls were performed and reviewed. ¹

This requirement is easy to “say” and hard to “prove.” Many teams can produce a policy and an org chart, but auditors look for operational signals: named control owners, consistent completion of control activities, timely remediation of exceptions, and consequences (or documented coaching) when expectations are not met. The standard does not demand punitive HR actions; it demands a functioning accountability system aligned to internal control responsibilities. ¹

If you own SOC 2 readiness, focus on two outcomes: (1) every in-scope control has an accountable owner with documented responsibilities, and (2) you can produce period evidence showing those owners performed, reviewed, and corrected control issues. Tools like Daydream can help by tracking control owners, collecting evidence, and preserving an audit trail that ties performance to accountability.

Regulatory text

Excerpt (TSC-CC1.5): “COSO Principle 5: The entity holds individuals accountable for their internal control responsibilities.” ¹

Operator meaning: You must implement a governance and people-management mechanism that assigns internal control duties to specific roles, confirms those roles understand the duties, monitors completion and quality, and documents follow-up when duties are not met. Auditors will test whether your accountability approach is designed and operating during the audit period. ¹

Plain-English interpretation (what “accountable” means in SOC 2)

Accountability, for SOC 2 purposes, looks like:

• Clarity: People can explain what they are responsible for (access reviews, change approvals, incident response steps, vendor/third-party due diligence steps, etc.).
• Authority: The owner has the ability to perform the task or escalate when blocked.
• Measurement: You track completion and exceptions (missed reviews, overdue tasks, failed controls).
• Follow-through: Exceptions trigger documented remediation, coaching, or escalation.
• Evidence: You can prove all of the above with artifacts from the audit period. ¹

Who this applies to (entity and operational context)

Applies to: Any organization undergoing a SOC 2 audit that includes the Common Criteria. ¹

Operationally relevant for:

• Security and IT operations (access management, logging/monitoring, vulnerability management)
• Engineering/product (SDLC controls, change management, incident response participation)
• GRC/compliance (control design, evidence collection, testing, remediation tracking)
• HR and management (role definitions, onboarding, training, performance management tie-ins)
• Procurement / third-party risk (where third parties support in-scope systems and controls)

If you have a material reliance on third parties (cloud providers, MSSPs, payroll processors), CC1.5 still lands internally: your people must be accountable for third-party oversight controls such as reviews of SOC reports, contract/security addenda, and ongoing monitoring.

What you actually need to do (step-by-step)

Use this sequence to implement the tsc-cc1.5 guidance requirement with audit-ready outputs.

Step 1: Define the control accountability model (RACI, with teeth)

1. List all in-scope SOC 2 controls and control activities.
2. Assign, at minimum, these roles per control:
   • Control Owner (Accountable): ultimately responsible for completion and outcomes.
   • Control Operator (Responsible): performs the task (may be same as owner).
   • Reviewer/Approver (Independent where possible): validates performance/quality.
3. Document escalation paths (manager, CISO/CTO, CCO, steering committee).

Practical tip: Avoid “IT team” or “Security” as an owner. Auditors want a role or named position that maps to a person during the period. ¹

Step 2: Write the policy/procedure layer that ties responsibilities to controls

Create or update documentation that makes internal control responsibilities explicit:

• Information Security Policy (or control framework overview)
• Control-specific SOPs (e.g., access reviews, change approvals, incident response)
• Control matrix mapping each control to an owner, frequency, evidence, and reviewer

This is where “Document formal policy or procedure” becomes concrete: each control should state who does what, when, and what proof is retained. ¹

Step 3: Operationalize ownership through onboarding + acknowledgments

Implement a repeatable mechanism so owners/operators know their duties:

• Add “control ownership” to onboarding for security/IT/engineering leads.
• Require documented acknowledgment of key policies and role responsibilities.
• Train backups to avoid single points of failure.

Auditor mindset: knowledge must be institutional, not trapped in one person’s head. ¹

Step 4: Run monitoring and review that detects missed responsibilities

Implement a monitoring cadence that can be evidenced:

• A control performance dashboard (completion status, exceptions, aging)
• Regular control owner check-ins (GRC-led, security-led, or joint)
• Management review for high-risk controls and recurring failures

This aligns to “Establish monitoring and review process.” Monitoring must result in action when tasks are missed. ¹

Step 5: Keep an audit trail that proves accountability actions happened

Accountability requires traceability. Build a defensible audit trail:

• Ticketing evidence (Jira/ServiceNow) showing tasks assigned and completed
• Review sign-offs (PR approvals, access review approvals, change approvals)
• Meeting minutes showing follow-up on overdue items
• Exception logs with remediation and closure approvals

This aligns to “Maintain audit trail of activities.” ¹

Step 6: Test control effectiveness and fix the system, not just the evidence

Plan periodic testing (by GRC, internal audit, or control owners with independent review):

• Sample completed controls and verify evidence quality
• Verify reviewer independence where required by your control design
• Track findings, owners, due dates, and closure evidence

This is where “Conduct periodic assessments” becomes a habit, not an annual scramble. ¹

Step 7: Add consequences and escalation (proportionate, documented)

You do not need formal HR discipline for every miss. You do need consistency:

• First miss: documented reminder and retraining
• Repeated miss: management escalation, corrective action plan
• Chronic failure: role reassignment or performance management involvement (as appropriate)

Keep documentation lightweight but provable. Auditors test whether accountability exists in practice. ¹

Required evidence and artifacts to retain (audit-ready)

Keep artifacts that prove design and operation:

Design evidence (static):

• Control matrix with owners/operators/reviewers, frequency, evidence description
• Policies and SOPs referencing responsibilities (role-based where possible)
• Org chart or role descriptions for key control owners
• Training materials and policy acknowledgment process documentation ¹

Operating evidence (period-based):

• Completed control execution records (screenshots, exports, signed reviews, tickets)
• Exceptions log (missed/late controls) with documented follow-up and closure
• Meeting notes or governance minutes referencing control performance
• Control testing results and remediation tracking ¹

Daydream fit (practical): A GRC system like Daydream can centralize control ownership, automate evidence requests, and preserve a timestamped audit trail so you can show accountability without rebuilding history during fieldwork.

Common exam/audit questions and hangups

Auditors commonly probe:

• “Who is accountable for this control, by role and by person during the period?”
• “Show me how you ensure the owner knows their responsibility.”
• “What happens when a control is missed? Show an example.”
• “How do you monitor control completion and quality across teams?”
• “Where is the evidence that management reviews control performance?” ¹

Hangups that slow audits:

• Owners changed mid-period without documented handoff.
• Evidence exists, but reviewer sign-off is missing or unclear.
• Exceptions were handled informally in Slack with no retained record.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Responsibility assigned to a team, not a person/role.
   Fix: assign a role-based owner (e.g., “IAM Manager”) and map to incumbents per period. ¹

2. Mistake: Policies exist, but SOPs don’t specify evidence.
   Fix: each SOP includes “Evidence retained” and where it lives (ticket, report, system export). ¹

3. Mistake: Control performance tracked, but exceptions aren’t.
   Fix: maintain an exceptions log with owner, root cause, remediation, closure approval. ¹

4. Mistake: Testing happens at year-end only.
   Fix: run periodic assessments during the period so gaps are fixed while evidence can be generated. ¹

5. Mistake: Accountability equals punishment.
   Fix: make accountability equal follow-through. Document retraining, escalation, and role adjustments when needed.

Enforcement context and risk implications

SOC 2 is an audit framework, not a regulatory enforcement regime, so you should treat CC1.5 risk as audit opinion risk and customer trust risk, not fines. ¹ If accountability is weak, control failures tend to cluster: access reviews slip, changes bypass approvals, incidents lack postmortems, and third-party oversight becomes check-the-box. That can lead to SOC 2 exceptions, qualified opinions, delayed reports, and commercial friction during security reviews.

Practical 30/60/90-day execution plan

Days 0–30: Define ownership and fix documentation gaps

• Inventory in-scope controls and map each to owner/operator/reviewer.
• Update control narratives/SOPs to include responsibilities and evidence requirements.
• Stand up an evidence repository structure (by control, by month/quarter).
• Pick the monitoring mechanism (dashboard, weekly GRC check-in, ticket automation). ¹

Days 31–60: Start operating and capturing an audit trail

• Launch control owner training and policy acknowledgments.
• Run the first monitoring cycle; record misses and follow-up actions.
• Execute a small sample test of controls and evidence quality; log findings.
• Fix “proof problems” fast (missing sign-offs, unclear timestamps, no reviewer). ¹

Days 61–90: Prove effectiveness and stabilize accountability

• Expand testing coverage across major control families (access, change, incident, third-party oversight).
• Formalize exception escalation and management reporting.
• Conduct a retro on repeated misses; adjust roles, staffing, or automation.
• Prepare an auditor-ready “CC1.5 packet”: control ownership map, training evidence, monitoring evidence, exception examples, testing results. ¹

Frequently Asked Questions

Do we need formal HR disciplinary actions to satisfy CC1.5?

No specific HR action is mandated by the criterion. You need a consistent, documented approach that shows follow-up and escalation when internal control responsibilities are missed. ¹

Can one person be both control operator and reviewer?

Sometimes, but it raises independence and quality concerns. If separation is not feasible, document compensating review (for example, manager review of outputs) and keep evidence of that review. ¹

What evidence best proves “accountability” to auditors?

Evidence of operated controls plus evidence of follow-up on exceptions is the cleanest proof. Tickets, sign-offs, exception logs, and management review notes usually work well if they are dated and attributable. ¹

How do we handle control owner turnover during the audit period?

Document the handoff: effective date, new owner, and training/acknowledgment. Make sure evidence shows continuity of operation across the transition. ¹

Does CC1.5 apply to third-party risk management activities?

Yes, if third-party oversight controls are in scope, your staff must be accountable for performing and reviewing them (for example, SOC report reviews and contract/security requirement checks). CC1.5 focuses on internal accountability for those activities. ¹

What’s the fastest way to reduce CC1.5 audit risk?

Assign accountable owners for every control, define evidence expectations in SOPs, and run a monitoring cadence that produces a visible exception-and-follow-up trail. This closes the common gap between “policy exists” and “control operated.” ¹

Related compliance topics

• 2025 SEC Marketing Rule Examination Focus Areas
• Access and identity controls
• Access Control (AC)
• Access control and identity discipline
• Access control management

Footnotes

1. AICPA TSC 2017