TSC-CC9.1 Guidance

The tsc-cc9.1 guidance requirement is a SOC 2 Common Criteria expectation focused on resilience: you must anticipate business disruptions and put practical mitigations in place before an incident forces improvisation. Auditors typically look for two things: (1) a repeatable method for identifying disruption scenarios that matter to your services, and (2) a control set that reduces likelihood and impact, backed by proof it actually ran.

“Business disruptions” is broader than disasters. It includes cloud outages, ransomware, key staff loss, third-party failures, software defects, supply chain issues, and sudden demand spikes. For a CCO or GRC lead, the fastest path is to structure this like a control system: define disruption risk scenarios, select mitigations aligned to each scenario (prevent, detect, respond, recover), operationalize via owners and workflows, then retain evidence.

This page gives requirement-level implementation guidance you can hand to operators. It prioritizes what auditors ask for, where programs commonly break, and how to get to “audit-ready” in one quarter without turning business continuity into a shelf document.

Regulatory text

Requirement (excerpt): “The entity identifies, selects, and develops risk mitigation activities for risks arising from business disruptions.” ¹

What the operator must do

You must (1) identify disruption-related risks that could materially affect the services in scope for SOC 2, (2) select mitigation activities that address those risks, and (3) develop/implement those activities so they operate consistently, with evidence. Auditors will expect a clear link from “risk” → “mitigation activity” → “proof it ran” across the audit period. ¹

Plain-English interpretation (what CC9.1 is really asking)

CC9.1 is asking whether your resilience posture is intentional and testable. If a disruption happens tomorrow, do you already have:

• planned controls that reduce the chance of disruption (preventative),
• controls that catch it quickly (detective),
• response processes that contain and communicate (response),
• recovery mechanisms to restore service within defined objectives (recovery)?

A strong CC9.1 implementation reads like an engineering plan, not a policy statement. It also recognizes that disruptions often originate in dependencies you do not directly control: cloud platforms, managed service providers, payment processors, and other third parties.

Who it applies to (entity and operational context)

Applies to: any organization undergoing a SOC 2 audit against the AICPA Trust Services Criteria where the in-scope services could be disrupted. ¹

Operationally, it touches:

• Security & IT operations: incident response, monitoring, endpoint security, IAM break-glass access.
• SRE/Engineering: deployment safety, rollback, capacity management, backup/restore, DR architecture.
• Business continuity: BCP/DR planning, crisis management, tabletop exercises.
• Third-party risk management: dependency mapping, resiliency expectations in contracts, contingency planning for provider outages.
• GRC/Compliance: control design documentation, evidence collection, testing, exceptions management.

Most relevant for: SaaS, fintech, healthcare tech, managed services, and any company with contractual uptime/availability commitments.

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

Use this sequence to move from requirement text to operating controls.

Step 1: Define “business disruption” for your in-scope services

1. List in-scope products/services and supporting components (apps, cloud accounts, data stores, CI/CD, support tooling).
2. Define disruption categories you will cover (examples: cyber incident, infrastructure outage, data corruption, people/process failure, third-party outage).
3. Confirm scope with service owners and your SOC 2 auditor early to avoid building controls for the wrong boundary.

Deliverable: “Service Resilience Scope” one-pager (services, key components, key dependencies, in/out of scope).

Step 2: Build a disruption risk register (scenario-based)

Create scenarios that connect a cause to an operational impact. Keep it concrete.

• “Primary cloud region outage prevents customer logins.”
• “Ransomware encrypts production file shares.”
• “Third-party email provider outage blocks customer notifications.”
• “Bad deployment causes sustained error rate increase.”

For each scenario capture:

• impacted service(s)
• likely trigger(s)
• impact (customer, regulatory, revenue, safety)
• existing controls
• residual risk rating
• required mitigations (gaps)

Tip: Auditors rarely reward overly complex scoring. They reward traceability and action.

Deliverable: Disruption Risk Register with owners and last review date.

Step 3: Map each risk to mitigation activities (control library)

For each disruption scenario, choose mitigations across prevent/detect/respond/recover. Examples:

• Prevent: change management, SAST/DAST, hardening baselines, least privilege, network segmentation.
• Detect: centralized logging, alerting thresholds, integrity monitoring, synthetic checks.
• Respond: incident response plan, on-call rotations, escalation trees, comms templates.
• Recover: backups, restore testing, DR runbooks, alternate providers, manual fallback procedures.

Then specify control attributes auditors expect:

• control owner (role + named backup)
• frequency (event-driven, daily, weekly, per release)
• systems/tools used
• evidence produced
• what “success” looks like
• exception path (what happens if the control fails)

Deliverable: Resilience Mitigation Matrix (risk → control(s) → evidence).

Step 4: Operationalize controls in real workflows (tickets, pipelines, monitoring)

Make controls hard to bypass:

• Put required checks into CI/CD (approvals, test gates, deployment logs).
• Route operational tasks through ticketing (backup review, access review for break-glass, DR test tasks).
• Standardize incident documentation (timeline, root cause, corrective actions, comms).

Practical standard: if a control does not produce an artifact naturally, it will be painful at audit time. Design evidence in from day one.

Deliverable: Control procedures embedded into tooling (Jira/ServiceNow, Git, cloud audit logs, monitoring platform).

Step 5: Establish monitoring, review, and periodic assessment

CC9.1 expects you to keep the program current as the business changes. Set a cadence to:

• review the disruption risk register (new dependencies, architecture changes, incident learnings)
• review whether mitigations are still effective (post-incident reviews, recurring control failures)
• track remediation to closure

Deliverable: quarterly resilience review agenda + minutes + action log.

Step 6: Test effectiveness and keep results

Testing closes the loop. Examples:

• tabletop exercise for a ransomware scenario
• restore test for critical backups
• DR failover rehearsal (even partial)
• incident response drill focused on comms and escalation

Deliverable: test plan, test results, issues found, and remediation evidence.

Required evidence and artifacts to retain (audit-ready set)

Auditors will typically sample evidence across the audit period. Keep:

• Policies/procedures
  • business continuity / disaster recovery policy and/or standard operating procedures
  • incident response plan and escalation criteria
• Risk and control documentation
  • disruption risk register (with version history)
  • mitigation matrix linking risks to controls and owners
• Operational evidence (time-stamped)
  • tickets showing backups reviewed, restores performed, DR tasks completed
  • monitoring/alert configurations and alert history
  • change/deployment records (approvals, rollbacks, incident links)
  • incident reports and post-incident reviews with corrective actions
• Testing artifacts
  • tabletop agendas, attendee lists, outcomes, lessons learned
  • restore/DR test results and remediation tracking
• Management oversight
  • meeting minutes showing review of disruptions, metrics, and remediation progress

If you use Daydream to run your GRC program, set CC9.1 up as a requirement with a mapped control set, then collect evidence directly from the systems where it’s generated (ticketing, cloud logs, monitoring). The goal is one source of truth for traceability from risk to control to artifact.

Common exam/audit questions and hangups

Auditors commonly probe:

• “Show me how you identified disruption risks for the services in scope.” (Expect your register and a walkthrough.)
• “How did you decide which mitigations to implement?” (Expect decision logic and prioritization.)
• “Which controls address third-party outages?” (Expect dependency mapping and contingency plans.)
• “Prove the controls operated during the period.” (Expect dated artifacts, not narratives.)
• “How do you know the controls are effective?” (Expect test results and corrective actions.)

Hangups that delay audits:

• controls described at a high level with no procedure
• evidence stored across personal drives and Slack with no retention plan
• DR/backup claims without a restore test record
• risk register exists, but mitigations are not tied to owners or tracked to closure

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Treating BCP/DR as a document-only exercise.
   Fix: Convert the plan into repeatable tasks (runbooks, tickets, on-call procedures) with artifacts.

2. Mistake: No linkage between risk and control.
   Fix: Require every top disruption scenario to map to at least one preventative and one recovery control, with an owner.

3. Mistake: Ignoring third-party disruption paths.
   Fix: Maintain a dependency list for each service and document failover/fallback options for critical third parties.

4. Mistake: Evidence is “we can show it live.”
   Fix: Store point-in-time exports/screenshots/log extracts or tool-native audit logs under an evidence retention process.

5. Mistake: No periodic review cadence.
   Fix: Put quarterly reviews on the calendar and treat missed reviews as exceptions with documented remediation.

Enforcement context and risk implications

SOC 2 is an audit framework, not a regulatory enforcement regime. ¹ The practical risk is commercial and operational:

• failed or qualified SOC 2 opinions
• delayed sales cycles and security reviews
• higher incident impact due to weak preparation and slow recovery

CC9.1 gaps often surface after an incident, because the organization cannot prove mitigations existed before the disruption or cannot show they operated consistently.

A practical 30/60/90-day execution plan

Days 1–30: Get the structure in place

• Confirm in-scope services and critical dependencies (including third parties).
• Draft disruption categories and build the first version of the disruption risk register.
• Create the mitigation matrix and identify control gaps.
• Assign owners and define evidence outputs for each control.
• Stand up an evidence repository with naming conventions and retention expectations.

Exit criteria: risk register + mitigation matrix approved by service owners; owners understand what evidence they must produce.

Days 31–60: Operationalize controls and start collecting evidence

• Embed controls into workflows (CI/CD checks, ticket templates, monitoring alerts).
• Publish or update BCP/DR and incident response procedures to match reality.
• Run one tabletop focused on a high-impact disruption scenario.
• Begin periodic reviews (risk register review meeting with minutes and actions).

Exit criteria: at least one full “risk → control → evidence” thread per critical scenario, with dated artifacts.

Days 61–90: Prove effectiveness and close gaps

• Execute backup restore tests for critical systems and retain results.
• Run a targeted DR exercise (partial failover or component-level recovery).
• Review incidents from the period and confirm corrective actions are tracked to closure.
• Perform an internal “SOC 2 readiness” walkthrough: pick sampled controls and confirm evidence exists end-to-end.

Exit criteria: test results retained; remediation tickets progressing; audit evidence package is sample-ready.

Frequently Asked Questions

Do we need a formal disaster recovery site to meet TSC-CC9.1?

CC9.1 requires mitigations for disruption risks, not a specific architecture. If a DR site is the mitigation you select for your risk profile, document it and keep evidence it is maintained and tested. ¹

How should we handle third-party outages under CC9.1?

Treat critical third parties as disruption scenarios in your risk register, then define mitigations such as alternate providers, manual fallbacks, contract SLAs, and comms playbooks. Keep evidence of dependency reviews and executed contingency tests where feasible.

What evidence is “good enough” for auditors?

Evidence should be time-stamped, attributable, and hard to tamper with: tickets, system logs, exported reports, meeting minutes, and test results. A policy alone rarely satisfies “operated effectively” expectations. ¹

How often do we need to review disruption risks?

Set a cadence that matches change velocity and document it in procedure, then follow it consistently. Many teams choose quarterly reviews plus event-driven updates after major incidents or architecture changes.

We’re a small team; can one person own multiple mitigations?

Yes, but document primary and backup responsibilities so absence is not a single point of failure. Auditors will challenge resilience controls that depend on one individual’s availability.

How does Daydream help with the tsc-cc9.1 guidance requirement?

Daydream helps you map disruption risks to specific controls, assign owners, and collect evidence with a consistent audit trail. The practical win is faster sampling: you can answer “show me proof it ran” without chasing artifacts across tools.

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Footnotes

1. AICPA Trust Services Criteria 2017, 2017