TSC-CC5.1 Guidance

TSC-CC5.1 is a control-activity requirement. It is where many SOC 2 programs either become defensible or fall apart, because it forces you to prove that your risk assessment is not a slide deck. A mature program shows that identified risks drive concrete, repeatable control activities across security, availability, processing integrity, confidentiality, and privacy (as scoped), and that those activities operate consistently during the audit period.

For a Compliance Officer, CCO, or GRC lead, the operational goal is straightforward: build and maintain a controls layer that mitigates risk in practice, not in theory. That means (1) defining the control activity with enough precision that someone can execute it the same way every time, (2) assigning ownership and frequency, (3) collecting evidence as a byproduct of operations, and (4) testing and remediating gaps before your auditor finds them.

This page provides requirement-level implementation guidance for the tsc-cc5.1 guidance requirement, with a focus on what to do, what to retain, and where audits commonly get stuck.

Regulatory text

Excerpt (TSC-CC5.1): “COSO Principle 10: The entity selects and develops control activities that contribute to the mitigation of risks.” ¹

What this means for an operator

You must be able to show, for in-scope systems and processes, that:

1. You identified relevant risks (typically via a risk assessment or equivalent).
2. You selected control activities that plausibly mitigate those risks (preventive and/or detective).
3. You developed those activities into defined controls (who does what, when, using what criteria).
4. You operated them during the period, kept evidence, and addressed exceptions.
5. You tested that controls worked (internally or via another assurance function) and tracked remediation.

Auditors will not accept “we rely on our people being careful” as a control activity. They also will not accept a policy without proof of operation.

Plain-English interpretation (what you’re being asked to prove)

TSC-CC5.1 asks: Did you translate your risks into real controls that run on a schedule and reduce the chance or impact of bad outcomes? If you claim you manage access risk, show access provisioning approvals and periodic access reviews. If you claim you manage change risk, show PR approvals, testing evidence, and production change logs tied to tickets.

A practical way to think about this criterion: every high-priority risk should have at least one strong control activity, and every control activity should produce evidence without heroics.

Who it applies to (entity and operational context)

Applies to: Organizations undergoing a SOC 2 audit using the Trust Services Criteria common criteria. ¹

Operational scope: Anything inside your SOC 2 system boundary that impacts the applicable trust service categories you’ve scoped (for example, Security is almost always in scope; others depend on your report).

Teams typically involved:

• GRC / Compliance (control definition, evidence program, audit coordination)
• Security (technical controls, monitoring, incident processes)
• Engineering / DevOps (change management, CI/CD controls, logging)
• IT (endpoint, identity, onboarding/offboarding)
• HR / People Ops (background checks if applicable, onboarding triggers)
• Business system owners (customer support platforms, billing, data pipelines)

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

Step 1: Lock the risk-to-control mapping

Create (or refresh) a simple mapping table that ties each key risk to one or more control activities.

Minimum fields (recommended):

• Risk statement (clear, specific)
• In-scope system/process
• Control ID / name
• Control objective (what it mitigates)
• Control type (preventive/detective, manual/automated)
• Owner (person + role)
• Frequency (event-based/daily/weekly/monthly/quarterly)
• Evidence produced (what artifact proves operation)
• Tool/system of record (ticketing, IAM, SIEM, HRIS)

Example (condensed):

• Risk: Unauthorized access to production data
  Control: Access requests require approval + least privilege enforced in IAM
  Evidence: Access tickets + IAM audit log entries + approved role assignments

Step 2: Define each control activity so it is executable

For each control, write a procedure that answers:

• Trigger: What starts the control (new hire, code merge, monthly cadence)?
• Inputs: What data/tools are used (Okta, Jira, GitHub, AWS CloudTrail)?
• Steps: Exact actions the operator takes.
• Criteria: Pass/fail rules (what counts as “approved,” “complete,” “reviewed”).
• Outputs/evidence: The artifact created and where it’s stored.
• Exception handling: What happens when it fails (ticket, escalation, timeline).

This is where many teams under-document. A one-line control description rarely survives audit sampling.

Step 3: Implement a monitoring and review loop

TSC-CC5.1 is about selecting and developing control activities, but auditors usually expect you to also demonstrate the controls are managed, not forgotten. Put in place:

• A control calendar (what evidence is due and when)
• An exception log (missed controls, failed reviews, overdue remediation)
• A review cadence (GRC lead reviews control operation status; owners attest)

If you use Daydream, treat it as your evidence spine: control library, ownership, collection workflows, and an exceptions register that stays current during the audit period.

Step 4: Run the controls and collect evidence as you go

Operationalize evidence so it is:

• Generated by systems where possible (logs, reports, exports)
• Time-stamped and attributable to an individual or service account
• Tamper-resistant (read-only exports, immutable logs, restricted folders)
• Consistent (same format each period)

Avoid end-of-period evidence scrambles. Auditors can detect backfilled evidence patterns quickly.

Step 5: Test control effectiveness (and fix what you find)

Build a lightweight internal testing program:

• Select samples (e.g., a set of access requests, changes, incidents)
• Reperform the control (verify approvals, verify review occurred, verify criteria met)
• Record results (pass/fail, notes, evidence links)
• Open remediation tickets for failures and track closure

You don’t need a huge team, but you do need repeatable testing results and follow-through.

Required evidence and artifacts to retain

Auditors usually want artifacts that prove design and operation. Maintain a single evidence index so you can respond fast.

Design evidence (what the control is)

• Control inventory / control matrix mapped to risks
• Policies and procedures tied to the control activities
• Role definitions and responsibility assignments (RACI is fine)
• System configurations that implement controls (where applicable)

Operating evidence (proof it ran)

• Approvals and reviews (tickets, sign-offs, workflow logs)
• System logs and reports (IAM logs, change logs, monitoring alerts)
• Meeting minutes or review attestations for governance controls
• Exception records and remediation tickets with closure evidence

Testing evidence (proof it worked)

• Test plan / test scripts (even lightweight)
• Sampling methodology (what you tested and why)
• Test results with evidence links
• Root cause notes and remediation tracking

Common exam/audit questions and hangups

Auditors often focus on traceability and repeatability. Expect questions like:

• “Show me how your top risks map to controls for the SOC 2 system.”
• “Who performs this control, and how do you know it happened each time?”
• “Where is the evidence stored, and can you produce it for the full period?”
• “How do you handle exceptions? Show an example from the period.”
• “What changed in controls this year, and was change approved?”
• “How do you test control operating effectiveness before we arrive?”

Hangup pattern: controls are described at a policy level, but evidence is inconsistent, missing for certain months, or not tied to the population (for example, access reviews exclude a key system).

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails under TSC-CC5.1	Fix
Control statements are vague (“access is reviewed regularly”)	Auditor can’t determine frequency, criteria, or evidence	Add owner, cadence, pass/fail criteria, and evidence location
Risk assessment exists but doesn’t drive controls	Breaks the “mitigate risks” requirement 1	Build a risk-to-control map and keep it updated after major changes
Evidence is collected manually at audit time	High risk of gaps and backfill concerns	Automate exports and schedule evidence pulls during the period
Exceptions are handled ad hoc	No proof that failures were identified and corrected	Maintain an exception log tied to remediation tickets
No testing or only informal testing	Hard to show controls are effective	Establish periodic testing with documented results

Enforcement context and risk implications

SOC 2 is an audit framework rather than a regulatory enforcement regime. The risk is commercial and contractual: weak TSC-CC5.1 execution can drive SOC 2 qualifications, delayed reports, failed customer security reviews, and higher ongoing audit effort because your auditor expands sampling or performs more substantive procedures. ¹

30/60/90-day execution plan

First 30 days: Stabilize the control layer

• Confirm SOC 2 scope and in-scope systems/processes.
• Build/refresh the risk-to-control mapping table.
• Normalize control write-ups for the controls that mitigate the highest risks (start with access, change management, logging/monitoring, incident response).
• Stand up an evidence index (folder structure or GRC tool) with naming conventions and owners.
• Draft an exception log template and assign triage ownership.

Days 31–60: Make operation repeatable

• Put controls on a calendar and align owners on due dates.
• Automate evidence collection where practical (scheduled exports, system reports, ticket workflows).
• Run at least one full cycle of recurring controls and validate evidence quality.
• Start internal testing on a small set of key controls; document results and remediation actions.
• Train control owners on what “good evidence” looks like (screenshots alone often fail without context).

Days 61–90: Prove consistency and close gaps

• Expand internal testing to cover remaining high-impact controls.
• Perform a management review of exceptions, overdue items, and remediation status.
• Tighten control narratives where auditors will probe (population definition, system boundaries, role definitions).
• Prepare an “audit-ready” binder: control matrix, risk mapping, evidence index, and testing results.
• If using Daydream, finalize workflows so evidence requests route automatically to owners with reminders and an audit trail.

Frequently Asked Questions

How do I know if a “control activity” is strong enough for TSC-CC5.1?

A strong control activity has a clear owner, trigger, frequency, criteria, and durable evidence. If another person could execute it the same way using your procedure and reproduce the evidence, it is usually specific enough for audit.

Do we need automated controls to satisfy TSC-CC5.1?

No. Manual controls can satisfy the requirement, but they must be repeatable and evidenced. Auditors often prefer automated evidence sources because they reduce ambiguity about timing and completeness.

What’s the minimum documentation set auditors expect?

Expect to provide a control inventory mapped to risks, documented procedures for key controls, and operating evidence for the full audit period. Testing results and an exceptions/remediation trail make the control environment easier to defend. ¹

Our teams keep screenshots as evidence. Is that acceptable?

Sometimes, but screenshots often miss context: date/time, system population, reviewer identity, and what was concluded. Pair screenshots with exports, tickets, or system logs that show the underlying record and reviewer action.

How do we handle missed control executions during the period?

Record the miss in an exception log, assess impact, perform a catch-up execution when appropriate, and open a remediation ticket that prevents recurrence. Auditors typically care more about detection and correction than perfection, but they need proof.

Can we reuse ISO 27001 or NIST control documentation for TSC-CC5.1?

Yes, if you translate it into SOC 2 control language: risk linkage, defined activity, operating evidence, and testing. Crosswalks help, but auditors still need period-specific evidence tied to the SOC 2 scope. 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