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Does SOC 2 CC6.1 recognize software identities?
Yes. CC6.1 says an organization implements logical-access security software, infrastructure, and architectures over protected information assets. Its points of focus include inventorying information assets, restricting logical access, managing access points, identifying and authenticating persons, infrastructure, and software, and managing credentials for infrastructure and software. They also address removing credentials and disabling access when it is no longer required or when the software or infrastructure is no longer in use.
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That language makes the claim that CC6.1 only recognizes humans inaccurate. An AI agent can be analyzed as software within the system, with an identity and an access path. The evidence challenge is whether the organization’s inventory, approvals, access reviews, and logs actually represent that identity and the authority delegated to it. That is an implementation risk, not a finding that the criterion excludes agents.
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An agent can act through a workload identity, service account, token, tool connection, or a person’s session. A record that shows only a human operator may leave unclear which mechanism made a particular request, what permissions it had, or whether the person approved that specific action. Conversely, a service-account name alone may not establish which agent run used it or under whose authority.
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AICPA defines a system through its infrastructure, software, people, processes, and data, and defines security events to include actual or attempted unauthorized access or use by internal or external parties. That system-based framing supports documenting the agent as a component and making the responsible human roles visible; it does not transfer organizational accountability to the software.
What should an auditable agent evidence trail contain?
The following is practical control-design guidance inferred from CC6.1’s language, not a mandatory AICPA checklist. Fit the evidence to the system described, the organization’s stated control objectives, and its risk assessment.
1. Inventory the agent and its execution identity
For each in-scope agent, record its owner, business purpose, environment, material model and tool components, and the service account or workload identity it uses. Name the human sponsor who authorizes its use. Connect the entry to the system boundary and the information assets the agent can reach. This makes an agent’s software identity and access points visible alongside the people and processes already included in the system description.
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2. Document delegated authority separately from identity
Record what the agent is permitted to do, which credentials or tokens it can use, how permissions are scoped, and whether authority comes from a person, a workload, or both. Note which approvals gate higher-impact actions. Identity answers which principal is acting; authority describes the actions and resources available to it. Keeping those facts distinct helps avoid treating an operator’s login as sufficient evidence of the agent’s own access path.
3. Preserve attributable action-level records
Design event records to connect the initiating identity, relevant human approval or policy decision, target system, action, timestamp, result, and a correlation or run identifier. Protect records from unauthorized alteration and retain them under documented organizational policies. These fields are a recommended evidence design, not a list prescribed by CC6.1. Their purpose is to let a reviewer trace an action from authority to outcome rather than infer it from disconnected logs.
4. Review access and material changes
Show that permissions and tool connections are reconsidered when the agent’s purpose, owner, model, integrations, or risk changes. Set review timing through the organization’s risk assessment and policies; CC6.1 does not establish a universal agent-review cadence. When an agent is retired or no longer needs access, disable its access and remove its credentials, consistent with CC6.1’s focus on credentials for software and infrastructure no longer in use.
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5. Connect incidents to containment
Define how authorized responders can suspend an agent, revoke its tokens, stop tool execution, preserve relevant records, and determine whether data or systems were affected. Tie those actions to the organization’s incident process and control objectives. CC6.1 does not prescribe a particular kill switch or containment design.
6. Keep control ownership attributable to people
Identify who approves deployment and permission changes, who reviews exceptions, and who can halt or remediate the system. Automation may perform actions, but the organization should be able to identify the people responsible for governing the agent and operating the controls.
How do SOC 2 and ISO/IEC 27001 differ for agent governance?
They are different assurance mechanisms, not interchangeable checklists. SOC 2 is an examination of a service organization’s system description and controls against applicable Trust Services Criteria. ISO/IEC 27001:2022 is a requirements standard for an information security management system (ISMS), using risk management to protect confidentiality, integrity, and availability.
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| Question | SOC 2 | ISO/IEC 27001 |
|---|---|---|
| What is assessed? | The fairness of management’s system description and the suitability of control design; a Type 2 examination also addresses operating effectiveness. | The organization’s ISMS against the standard’s requirements, including its risk-management approach. |
| What does the result represent? | An examination report, not a certification label. | An organization may seek certification through an accredited conformity assessment body; certification is optional. |
| What should agent evidence support? | The described system, applicable criteria, stated objectives, and— for Type 2—the operation of controls over the examination period. | The organization’s risk-based ISMS decisions and the operation of controls it has selected and documented. |
| Does the cited public material specify agent-specific controls? | CC6.1 covers software and infrastructure identity and access, but the cited criterion does not prescribe an AI-agent evidence checklist. | ISO’s public description of ISO/IEC 27001:2022 does not specify AI-agent controls; an agent design is a risk-based application of the ISMS, not a direct quotation of an agent-specific clause. |
| Which assurance need may fit? | A customer-facing SOC 2 report where an examination report is the requested assurance. | An ISMS and, if the organization chooses, an ISMS certificate where that form of assurance is needed. |
A policy or inventory document can describe intended controls, but it does not by itself demonstrate that controls operated. For a Type 2 examination, evidence needs to support operating effectiveness over the relevant period. No single artifact guarantees a particular report outcome.
What has AICPA said about AI in SOC examinations?
AICPA published TQA Section 9561, “SOC Examinations: Effect of the Service Organization’s Use of AI on SOC 1 and SOC 2 Examinations,” on September 11, 2026. The public landing page identifies the guidance as addressing how a service organization’s use of AI affects SOC examinations, but the full document is behind a free-account gate. Its detailed requirements or conclusions cannot be established from the landing page alone. Organizations making examination decisions should consult the text rather than infer specific auditor procedures from its title.
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- Established: CC6.1’s access-control points of focus refer to persons, infrastructure, and software, and include credential management for software and infrastructure.
- Not established by that wording: a universal agent-specific checklist, a required log schema, a prescribed review frequency, or a specific containment mechanism.
- Established: ISO describes ISO/IEC 27001:2022 as an ISMS requirements standard grounded in risk management. Its public page does not set out agent-specific controls.
- Not established: that using an agent inherently violates CC6.1 or ISO/IEC 27001, or that a particular evidence platform automatically produces compliance.
ISO calls ISO/IEC 27001 the “world’s best-known standard for information security management systems.” Separately, the ISO Survey 2022 reported more than 70,000 certificates across 150 countries and sectors. Those figures indicate the standard’s reach; they do not measure AI deployments or the quality of agent evidence.
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How to make the evidence useful in an examination
Start with the actual system boundary: identify where agents run, what software and infrastructure they use, which information assets they can access, and which human roles govern them. Then map the identity, delegated permissions, approvals, action records, reviews, and incident response to the controls and objectives the organization has chosen to describe. The test is not whether an organization has a document titled “AI agent policy”; it is whether its evidence explains the access path and supports the control claims in its system description.
That approach keeps the conclusion proportionate: CC6.1 already has room for software identity, while ISO/IEC 27001 supplies a risk-management framework. Neither cited public source supplies a ready-made agent audit recipe. The organization must make agent identity and authority legible within its own system and show how its controls work.
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