The entity implements logical access security measures to protect against threats from sources outside its system boundaries

To meet the “the entity implements logical access security measures to protect against threats from sources outside its system boundaries requirement,” you must put enforceable controls at every external entry point (network, identity, apps, APIs, and admin paths) and prove they work over time. Auditors will look for a clear boundary definition, layered preventative controls, and operating evidence tied to your SOC 2 system description ¹.

Key takeaways:

• Define “system boundaries” in scope first, then protect every path crossing that boundary ¹.
• Implement layered logical access controls: strong authentication, network restrictions, secure remote/admin access, and monitoring ¹.
• Retain operating evidence that the controls ran consistently across the audit period, not just at a point in time ¹.

This requirement is a perimeter-and-entry-points control objective. Your auditor is not asking whether you own a firewall or an SSO tool. They are asking whether you have logical access security measures that materially reduce the likelihood that an external attacker can gain unauthorized access to in-scope systems, data, and services, and whether you can prove those measures operated throughout the period.

The fastest way to operationalize TSC-CC6.6 is to treat it as a mapping exercise: (1) define your system boundary for SOC 2 scope, (2) list every external-to-internal access path that crosses it (internet to app, third party to API, employee to VPN, engineer to cloud console, CI/CD runner to production), and (3) apply layered controls to each path with owners and evidence.

Because this is a requirement-level expectation, documentation and evidence matter as much as technical correctness. Most SOC 2 findings here come from gaps like “we have controls, but they’re inconsistently enforced,” “controls exist in one environment but not another,” or “we can’t show the settings and logs for the whole period.” This page gives you a practical build plan and an evidence checklist aligned to the requirement text ¹.

Regulatory text

Requirement (SOC 2 Trust Services Criteria): “The entity implements logical access security measures to protect against threats from sources outside its system boundaries” (TSC-CC6.6) ¹.

Operator interpretation: You must (a) define the boundary of the SOC 2 system, then (b) implement controls that restrict, authenticate, and monitor access attempts coming from outside that boundary. The control set must cover user access, administrative access, service-to-service access, and third-party access routes that can reach in-scope components ¹.

Plain-English interpretation (what this means day-to-day)

External threats reach you through predictable doors:

• Public endpoints (web apps, APIs, CDN origins)
• Remote access (VPN/ZTNA, RDP/SSH bastions, VDI)
• Identity planes (SSO, cloud consoles, privileged access tools)
• “Hidden” paths (misconfigured security groups, public storage, exposed admin panels)
• Third-party connections (support tools, MSP access, integrations, webhook receivers)

This requirement expects you to close unnecessary doors, harden the doors you keep, and keep records that show the doors stayed hardened ¹.

Who it applies to (entity + operational context)

Applies to: Service organizations undergoing SOC 2 that host, process, transmit, or can affect customer data and services in the SOC 2 scope ¹.

Operational contexts where auditors focus:

• SaaS and API platforms with internet-exposed services
• Cloud-managed infrastructure (AWS/Azure/GCP) and admin consoles
• Remote workforce and contractor access
• Production support and incident response access paths
• Third parties with any logical connection into in-scope environments (support portals, monitoring agents, managed services)

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

Step 1: Define “system boundaries” in writing (scope anchor)

1. Document in-scope components: applications, APIs, databases, queues, object storage, CI/CD, identity provider, logging stack.
2. Document boundary crossings: what is “outside” (internet, customer networks, third parties, employee home networks).
3. Tie boundary to your SOC 2 system description so the auditor can trace controls to in-scope assets ¹.

Deliverable: “System Boundary & Entry Points” diagram + inventory.

Step 2: Build an external entry-point inventory (control surface)

Create a table of all inbound access paths into in-scope systems:

Entry point	Example	AuthN/AuthZ control	Network restriction	Monitoring owner
Public web app	app.company.com	SSO/MFA for admin, session controls	WAF/CDN rules	SecOps
Public API	api.company.com	OAuth/JWT/API keys, rate limits	Allowlist where possible	Platform
Admin console	Cloud provider console	SSO + MFA, role-based access	Conditional access	IT/Sec
Remote access	VPN/ZTNA	MFA + device posture	IP restrictions	IT
Bastion/SSH	Jump host	MFA + short-lived creds	No direct internet	Infra

Deliverable: Entry-point register with owners.

Step 3: Implement layered logical access security measures per entry point

Your goal is defense in depth. For each path, implement controls in these categories (tailor to your architecture):

1. Strong authentication

   • Centralize workforce authentication in an IdP.
   • Enforce MFA for workforce access, especially admin access.
   • Prefer short-lived credentials for service/admin workflows where feasible.

2. Authorization and least privilege

   • Implement role-based access control (RBAC) for admin functions.
   • Separate production admin roles from non-production roles.
   • Remove shared accounts; require unique identities for workforce users.

3. Network-level restrictions

   • Default-deny inbound network access; allow only required ports/services.
   • Restrict admin interfaces to private networks, bastions, or ZTNA.
   • Review cloud security groups, NACLs, firewall rules for unintended exposure.

4. Application-layer protections

   • Protect public apps and APIs with rate limiting and abuse controls.
   • Use WAF/CDN controls where appropriate.
   • Disable or restrict “debug,” “test,” and legacy admin endpoints.

5. Secure third-party access

   • Require third parties to authenticate through your standard access path (SSO/ZTNA) where possible.
   • Time-box and approve privileged third-party access.
   • Monitor third-party sessions and actions in admin environments.

6. Monitoring and alerting

   • Log authentication attempts, privilege changes, and admin actions.
   • Alert on high-risk events: repeated failed logins, impossible travel (if used), new admin role grants, new inbound firewall openings.
   • Route alerts to an on-call or ticketing workflow with documented triage steps.

Deliverable: Control design document that maps each entry point to the specific measures in place ¹.

Step 4: Operationalize with ownership, cadence, and exceptions

1. Assign owners for each control family (Identity, Infrastructure, Application Security, SecOps).
2. Set a review cadence for:
   • Public exposure checks (cloud posture, DNS, certificates)
   • Access pathways (VPN/ZTNA/bastion configs)
   • WAF/CDN policies and exceptions
3. Define an exception process:
   • Business justification
   • Compensating control
   • Approval
   • Expiration date and revalidation

Deliverable: Access security standard + exception register.

Step 5: Prove control operation with evidence (audit readiness)

Auditors will test whether controls were in place and operating throughout the period ¹. Design your evidence so it is repeatable and timestamped.

Required evidence and artifacts to retain

Keep evidence in an audit folder organized by control theme and period:

Boundary + inventory artifacts

• System boundary diagram and narrative (in-scope systems, trust boundaries) ¹
• External entry-point register (public endpoints, admin paths, remote access, third-party connections)

Configuration evidence (screenshots are acceptable, exports are better)

• IdP settings: MFA enforcement, conditional access policies, admin role protections
• Cloud perimeter configs: security groups/firewall rules, load balancer listeners, private/public subnet design
• Remote access configs: VPN/ZTNA requirements, bastion settings, SSH/RDP restrictions
• WAF/CDN policies and change history (where available)
• API gateway/auth configs (token validation, key rotation approach, rate limits)

Operating evidence (the “show it ran” set)

• Access logs showing authentication and authorization events for in-scope systems
• Alert/ticket samples for suspicious external access attempts with triage notes
• Change management records for perimeter-related changes (rule updates, exposure changes)
• Periodic review records (public exposure scans, access path reviews), including exceptions and remediation actions

Policy/procedure artifacts

• Logical access policy and remote access standard
• Privileged access management procedure (even if lightweight)
• Third-party access procedure for support/operations

Common exam/audit questions and hangups

Auditors tend to ask the same questions because they are tracing boundary crossings ¹:

• “Show me your system boundary. What is outside vs. inside?”
• “List all internet-exposed endpoints in scope.”
• “How do admins access production? Show MFA and the path.”
• “Do third parties have access? How is it approved, time-boxed, and monitored?”
• “Provide evidence for the whole period, not a screenshot from today.”
• “How do you detect and respond to external brute-force or credential-stuffing attempts?”

Hangup to plan for: If engineering says “we don’t have a single list of endpoints,” you will burn time. Make the entry-point register your source of truth.

Frequent implementation mistakes (and how to avoid them)

1. Undefined boundary = untestable control.
   Fix: Write the boundary and align it to what you claim is in scope ¹.

2. Relying on “security by VPC” while leaving admin paths public.
   Fix: Restrict admin interfaces to private access paths, enforce MFA, and log admin activity.

3. MFA enforced for humans, ignored for service accounts.
   Fix: Use strong service identity patterns (short-lived tokens, scoped roles, secret rotation) and document them.

4. Third-party access handled informally.
   Fix: Route third-party access through the same controls as employees, require approvals, and maintain logs.

5. Evidence gaps across the audit period.
   Fix: Automate evidence capture. Daydream can help by turning your entry-point register and control mappings into a recurring evidence checklist and collecting time-stamped exports from identity and cloud systems without relying on last-minute screenshots.

Enforcement context and risk implications

SOC 2 is an attestation framework, not a regulator, so “penalties” show up as report qualifications, sales friction, or contractual issues rather than framework-issued fines ¹. The practical risk is direct: external attackers target exposed endpoints, weak authentication, and unmonitored admin paths. If you cannot demonstrate layered access controls at the boundary, auditors may conclude the control is not suitably designed or not operating effectively for the period ¹.

Practical 30/60/90-day execution plan

First 30 days (stabilize scope and block obvious exposure)

• Publish system boundary definition and in-scope asset list.
• Build entry-point register for all external-to-internal access paths.
• Enforce MFA for workforce access to admin planes (IdP, cloud consoles, production tooling).
• Restrict or remove direct public access to admin endpoints (move behind ZTNA/bastion).
• Stand up baseline logging for authentication events and perimeter changes.

Days 31–60 (standardize controls and add monitoring)

• Implement RBAC and least-privilege for admin roles; remove shared accounts.
• Formalize third-party logical access procedure (request, approval, expiration, logging).
• Add WAF/CDN protections for public apps/APIs where appropriate.
• Implement alerting + ticket workflow for suspicious external access attempts and privilege changes.
• Start recurring exposure reviews and document findings/remediation.

Days 61–90 (make it auditable and repeatable)

• Convert configurations into written standards (remote access, admin access, public endpoint security).
• Automate evidence capture (config exports, logs, review records).
• Run an internal control test: sample endpoints and produce an “audit packet” per entry point.
• Close open exceptions or add compensating controls with explicit expirations.
• Use Daydream to maintain the control-to-evidence map so each review cycle produces the same artifacts auditors request.

Frequently Asked Questions

Do we need a firewall or WAF to meet this requirement?

The requirement is outcome-based: protect against external threats at boundary crossings ¹. A WAF or firewall is often part of the control set, but auditors mainly care that your chosen measures are appropriate for your exposed services and you can prove they operate.

What counts as “outside its system boundaries” in a cloud-native environment?

Treat any network or identity context you do not fully control as “outside,” including the public internet and third-party networks ¹. Define the boundary in your SOC 2 system description and map every access path that crosses it.

How do we handle third-party support access without failing the control?

Route third-party access through your standard access path (SSO/ZTNA or a controlled bastion), require approvals, and time-box elevated permissions. Keep logs and tickets that show who accessed what, when, and under what authorization.

What evidence is most likely to be requested by the auditor?

Expect a boundary diagram, an endpoint inventory, MFA/conditional access settings, network restriction configurations, and logs or tickets showing monitoring and response over the audit period ¹. Evidence that spans the period is more persuasive than a point-in-time screenshot.

We have multiple environments (dev/stage/prod). Do all need the same controls?

Apply the strongest controls to production and any environment that can affect production or contains sensitive data. Document differences explicitly so an auditor can see you made deliberate risk-based decisions tied to scope ¹.

How do we avoid scrambling at audit time for screenshots and exports?

Assign evidence owners and a recurring evidence calendar, then store exports centrally with timestamps. Tools like Daydream help by keeping the control design, owners, and evidence requests aligned so collection becomes a routine operating process instead of a one-time audit project.

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