TSC-CC6.1 Guidance

TSC-CC6.1 requires you to implement and operate logical access security software, infrastructure, and architectures that enforce who can access systems and data, under what conditions, and with what monitoring. To operationalize it fast, define your access control standard, deploy core technical controls (SSO/MFA, IAM, network segmentation), and keep audit-ready evidence that these controls ran effectively throughout the SOC 2 period.

Key takeaways:

• Document the logical access architecture (identity, authentication, authorization, network controls) and map it to in-scope systems.
• Prove operation with system configurations, access logs, and review records tied to the audit period.
• Build a repeatable monitoring and periodic assessment cadence so CC6.1 stays effective as systems and third parties change.

CC6.1 is one of the SOC 2 Common Criteria that auditors use to evaluate whether your organization has implemented logical access controls as real, working technical mechanisms, not just a policy statement. The requirement is broad by design: it expects security software (like IAM, SSO, MFA, PAM), infrastructure (like network boundaries, secure endpoints, hardened cloud configurations), and architecture decisions (like segmentation, trust zones, and centralized identity) that collectively prevent unauthorized access.

For a CCO, GRC lead, or security/compliance operator, the fastest path to passing CC6.1 is to treat it as an “access control stack” requirement. You need (1) a defined standard for how identities and access are managed, (2) consistent implementation across in-scope environments, and (3) evidence that access controls were operating during the audit window. Auditors commonly fail teams on CC6.1 because the technical controls exist, but aren’t consistently deployed, aren’t tied to a documented standard, or can’t be evidenced cleanly for the period under review.

Target keyword: tsc-cc6.1 guidance requirement

Regulatory text

Requirement (excerpt): “The entity implements logical access security software, infrastructure, and architectures.” ¹

Operator interpretation (what you must do)

You must implement technical access controls that enforce logical access rules across the systems in your SOC 2 scope. “Implements” is the key word: auditors expect to see deployed tools/configurations (not only policy), and they expect those controls to be appropriate for your environment (cloud, on-prem, SaaS), your workforce model (remote/admin access), and your data sensitivity.

A practical way to interpret CC6.1 is:

• Software: IAM/SSO/MFA, device management, secrets management, PAM, EDR, SIEM, logging.
• Infrastructure: hardened endpoints/servers, network boundaries, secure cloud baseline, secure connectivity.
• Architecture: identity-centric design, segmentation, centralized logging, privileged access separation, secure admin paths.

Plain-English requirement (what “good” looks like)

If someone tries to access an in-scope system (application, database, cloud console, production environment), your environment should:

1. Identify who they are (unique identity; no shared accounts for normal users).
2. Authenticate them strongly (MFA where appropriate; strong credential handling).
3. Authorize least-privilege access (role/group-based access; controlled elevation).
4. Restrict pathways (network segmentation, admin access through controlled channels).
5. Record and review access activity (logs exist, are retained, and are reviewed).

Who it applies to

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

Operational context:

• In-scope production systems, supporting infrastructure, and the corporate environment that administers them (identity provider, admin endpoints, CI/CD systems where relevant).
• Internal workforce users, contractors, and third parties with logical access (including managed service providers with console or VPN access).
• Privileged users (cloud admins, DBAs, SREs), and non-human identities (service accounts, API keys) where they can access in-scope data or systems.

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

Use this as a minimum viable execution sequence for the tsc-cc6.1 guidance requirement.

1) Define the logical access architecture standard (documented)

• Write a short Logical Access Control Standard (separate from a high-level policy) that states:
  • Source of truth for identities (IdP)
  • Authentication requirements (MFA rules, password rules if applicable)
  • Authorization model (RBAC/ABAC, group management, joiner/mover/leaver linkage)
  • Privileged access approach (separate admin accounts, PAM, break-glass)
  • Network access approach (VPN/ZTNA, segmentation, admin paths)
  • Logging requirements (what logs, retention expectations, review responsibilities)
• Map the standard to your in-scope systems list.

Outcome: auditors can see you have an intentional architecture, not a collection of tools.

2) Inventory in-scope access enforcement points (where access is controlled)

Create a table that lists, for each in-scope system:

• System name / environment (prod, staging, corp)
• Access method (SSO, local accounts, SSH keys, cloud console, database auth)
• MFA coverage (yes/no; compensating control if no)
• Privileged access path (PAM, separate admin role, break-glass)
• Logging source (where access events are captured)

This becomes your CC6.1 “control plane map.”

3) Implement baseline technical controls consistently

Minimum set most auditors expect to see, adapted to your environment:

• Centralized identity with SSO for workforce access where feasible.
• MFA for remote access, administrative access, and high-risk applications.
• Least privilege authorization using roles/groups; remove direct grants.
• Privileged access separation (admin roles/accounts separated; controlled elevation).
• Secure network access (restricted admin interfaces; segmentation between trust zones).
• Centralized logging for authentication and admin actions; time synchronization for correlation.

If you have exceptions (legacy apps, constraints), document them with compensating controls and a remediation plan.

4) Establish monitoring and review (prove “operating effectiveness”)

Auditors commonly test whether you monitored access controls, not only whether you configured them.

• Set up alerting for high-risk access events (new admin assignment, MFA disabled, suspicious sign-ins).
• Run periodic access reviews for privileged roles and critical applications.
• Review “break-glass” use and ensure it is rare, approved, and logged.

Tie every review to a dated record.

5) Maintain audit trails and make evidence easy to pull

For the SOC 2 period, you need to be able to show:

• What the control is (documentation)
• That it was configured as stated (configuration evidence)
• That it ran during the period (logs, review tickets, screenshots/exports with timestamps)
• That issues were addressed (exceptions, remediation tickets)

A practical approach: create a CC6.1 evidence folder with a monthly subfolder and drop exports consistently.

6) Conduct periodic assessments (control health checks)

Run a lightweight assessment that asks:

• Are all in-scope systems integrated with the IdP as planned?
• Do any systems still have local admin users or shared credentials?
• Are service accounts controlled and rotated?
• Are access logs still flowing to the SIEM/log store?
• Have new third parties gained admin connectivity without being captured?

Document findings and fixes.

Required evidence and artifacts to retain

Auditors vary, but CC6.1 evidence usually clusters into four buckets.

A) Documentation (what you said you do)

• Logical Access Control Policy and/or Standard
• Access control architecture diagram (identity flows + admin pathways)
• System inventory with access methods and control coverage
• Role definitions for privileged and sensitive roles

B) Configurations (what is implemented)

• IdP configuration exports (SSO settings, MFA policies, conditional access rules)
• Cloud IAM screenshots/exports (role assignments, organization policies, SCP equivalents if used)
• Network controls evidence (security groups/firewall rules, segmentation diagrams)
• PAM configuration evidence (vault policies, approval workflows) if applicable

C) Operational records (proof it operated during the audit period)

• Authentication logs (SSO sign-in events, MFA challenges)
• Privileged activity logs (cloud audit logs, admin action logs)
• Access review records (tickets, sign-offs, reviewer notes)
• Alert review evidence (SIEM alerts triage notes, incident tickets)

D) Testing and assessment results

• Internal control testing workpapers for CC6.1
• Periodic assessment results and remediation tickets
• Exception register (legacy systems, compensating controls, target dates)

Common exam/audit questions and hangups

Auditors often press on these points because they reveal whether the control is designed and operating:

1. Scope clarity: “Which systems are in scope, and where is access enforced for each?”
2. MFA consistency: “Show MFA enforcement for administrative access and remote access.”
3. Privileged access: “Who has admin rights? How do you approve, monitor, and remove it?”
4. Shared accounts: “Do any teams share credentials for operations or third-party support?”
5. Logging: “Where are authentication and admin logs stored, retained, and reviewed?”
6. Change over time: “How do you ensure new systems and third parties follow the same access architecture?”

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails audits	Fix
Policy-only control (“We require MFA”)	Auditors need evidence of implementation and operation	Export IdP policies + show sign-in logs that reflect enforcement
Partial SSO/MFA rollout	Creates holes; auditors sample the exceptions	Maintain an exceptions list with compensating controls and owners
Privileged access spread across many tools	Hard to review; access reviews become incomplete	Centralize privileged roles in IAM/PAM; standardize naming and groups
Logging exists but isn’t reviewed	CC6.1 expects monitoring as part of access security architecture	Create a review schedule and keep dated review tickets
Weak evidence hygiene	Teams scramble for screenshots after the fact	Monthly evidence captures aligned to the audit period

Enforcement context and risk implications

SOC 2 is an audit framework rather than a public enforcement regime. ¹ The operational risk is still real: weak logical access architecture increases the likelihood of unauthorized access, privilege misuse, and failures to detect suspicious authentication activity. For most organizations, CC6.1 gaps also cascade into customer security reviews, procurement delays, and higher third-party risk ratings.

30/60/90-day execution plan

Days 1–30: Baseline and visibility

• Confirm audit scope and produce the in-scope systems/access enforcement inventory.
• Publish the Logical Access Control Standard (short, technical, enforceable).
• Identify top gaps: systems without SSO/MFA, uncontrolled admin paths, missing logs.
• Stand up an evidence repository and start capturing monthly exports.

Days 31–60: Implement and normalize

• Roll out MFA and conditional access rules for admins and remote access.
• Standardize privileged access: define admin roles, separate accounts if needed, implement approvals for elevation.
• Centralize logs for sign-ins and admin actions; verify timestamps and retention settings.
• Run the first privileged access review and document it end-to-end.

Days 61–90: Prove operating effectiveness

• Run a second cycle of access reviews (privileged + critical apps) and show remediation.
• Perform a targeted assessment against your standard (exceptions, new systems, third-party admin access).
• Prepare an “auditor packet” for CC6.1: narrative + system inventory + evidence index mapped to each control activity.

Where Daydream fits naturally

If your bottleneck is evidence collection and repeatable reviews across many systems and third parties, Daydream can act as the system-of-record for control narratives, evidence requests, and period-based evidence packs. The practical win is fewer last-minute exports and a cleaner linkage from CC6.1 requirements to artifacts and review tickets.

Frequently Asked Questions

Do we need a specific tool (SSO, PAM, SIEM) to meet CC6.1?

CC6.1 does not mandate brand-name tools, but you must implement logical access security software and architecture appropriate to your environment. If you avoid common tools, document the alternative controls and keep strong evidence of operation. ¹

Are service accounts and API keys part of CC6.1?

Yes, if they provide logical access to in-scope systems or data. Treat them as identities with ownership, controlled permissions, and auditable activity logs consistent with your access architecture. ¹

What’s the fastest way to produce audit-ready evidence for CC6.1?

Build a system inventory that shows access methods and control coverage, then collect configuration exports and logs on a recurring cadence through the audit period. Auditors accept organized exports and tickets more readily than one-off screenshots. ¹

We have a legacy app that cannot support SSO/MFA. Is that an automatic fail?

Not automatically, but you need a documented exception, compensating controls (restricted network access, strong monitoring, limited admin rights), and a plan to remediate or replace it. Expect auditors to sample it. ¹

How should we handle third-party access (MSPs, contractors) under CC6.1?

Route third-party access through the same identity and access pathways as employees where possible, and restrict/administer it with least privilege and logging. Keep contracts and access approval records aligned to your joiner/mover/leaver process. ¹

What do auditors mean by “architecture” in CC6.1?

They want to see intentional design: where identity is managed, how authentication is enforced, how network trust boundaries work, and how privileged access is separated and monitored. A simple diagram plus a control narrative usually satisfies this if it matches the implemented reality. 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 Trust Services Criteria 2017