SOC 2 vs PCI DSS: What Payment Platforms Need for Bank Deals

US payment platforms seeking bank partnerships may need both SOC 2 reporting and PCI DSS compliance, but the two serve different purposes. SOC 2 provides independent assurance about an organisation's controls relevant to security and other trust services, while PCI DSS establishes technical and operational requirements for protecting payment card account data. The appropriate combination depends on how the platform operates, whether it stores, processes, or transmits cardholder data, and what its prospective bank or payment partners require.

For payment processors, payment gateways, fintech companies, and embedded payment providers, these distinctions matter during vendor due diligence and partnership negotiations. A bank may request a SOC 2 report to evaluate a service provider's control environment, while PCI DSS validation may be necessary when the provider's activities fall within the payment card industry's requirements. Neither automatically replaces the other.

This article compares SOC 2 vs PCI DSS for payment platforms in the United States, explains how the standards apply to payment processors, and outlines the factors that determine whether a business needs one or both.

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Understanding SOC 2 vs PCI DSS for Payment Platforms

SOC 2 and PCI DSS address overlapping security concerns, but they differ in purpose, scope, and how organisations demonstrate conformity. Understanding these differences helps payment platforms determine which evidence may be relevant to a bank partnership.

What Is SOC 2?

SOC 2 is an attestation framework developed by the American Institute of Certified Public Accountants (AICPA). It enables a service organisation to obtain an independent CPA firm's report on controls relevant to the Trust Services Criteria: Security, Availability, Processing Integrity, Confidentiality, and Privacy.

The Security criterion is included in a SOC 2 examination. The other criteria are included when relevant to the service organisation's objectives and the scope of the examination.

Payment platforms often consider SOC 2 because they handle sensitive business information, operate cloud-based services, integrate with financial institutions, or provide technology used in payment operations. A SOC 2 report can describe controls relating to access management, risk mitigation, system monitoring, incident response, and other areas within the examination's scope.

There are two main SOC 2 report types. A Type I report evaluates the design of controls at a specified point in time. A Type II report evaluates the design and operating effectiveness of controls over a specified period. The report's scope, exceptions, testing period, and system description are important when a bank evaluates the evidence.

SOC 2 is not a government-issued certification or a universal legal requirement for every payment platform. It is an independent attestation report that organisations may use to demonstrate the operation of relevant controls to customers, banks, and other business partners.

What Is PCI DSS?

The Payment Card Industry Data Security Standard (PCI DSS) establishes security requirements for organisations that store, process, or transmit payment card account data, as well as entities that can affect the security of the cardholder data environment.

PCI DSS is maintained by the PCI Security Standards Council (PCI SSC), which was founded by major payment card brands. The standard applies according to an organisation's role in payment card processing and its relationship with the card payment ecosystem.

PCI DSS requirements address areas such as network security, secure system configuration, protection of stored account data, encryption during transmission, vulnerability management, access controls, logging, monitoring, and security testing.

Payment platforms may fall within PCI DSS scope when they process card transactions, operate payment gateways, store account data, or provide services that can affect the security of cardholder data. Outsourcing payment processing does not automatically remove every PCI DSS obligation from a business. The remaining scope depends on the actual data flows, systems, services, and responsibilities involved.

PCI DSS validation methods vary according to the entity's role, transaction volume, payment brand or acquiring bank requirements, and applicable validation programme. Depending on the circumstances, validation may involve a Self-Assessment Questionnaire (SAQ), a Report on Compliance (ROC), a Qualified Security Assessor (QSA), or other prescribed evidence.

PCI DSS is not interchangeable with a SOC 2 report. It addresses payment card data security through a defined set of industry requirements.

Key Differences Between SOC 2 and PCI DSS

The main difference between SOC 2 and PCI DSS is their objective. SOC 2 provides an independent CPA firm's attestation regarding controls within the agreed examination scope. PCI DSS defines security requirements for protecting payment card account data.

For a US payment platform, SOC 2 may be relevant to a bank's evaluation of the organisation's broader technology and operational controls. PCI DSS is relevant when the organisation's payment card activities bring it within the standard's scope.

A SOC 2 report does not establish that an organisation meets all PCI DSS requirements. Likewise, PCI DSS validation does not demonstrate that every control a bank wants to evaluate through SOC 2 has been examined.

The two can complement each other. A payment platform may use a SOC 2 report to communicate its control environment and maintain appropriate PCI DSS validation for its card payment activities. The bank or payment partner ultimately determines what evidence it requires, subject to applicable contractual, regulatory, and payment network obligations.

SOC 2 vs PCI DSS for Payment Processors

Payment processors often operate systems that handle transaction information, connect merchants with acquiring banks, or facilitate payment authorisation and settlement. Their compliance obligations depend on the services they provide, the systems they operate, and their role in protecting payment account data.

SOC 2 and PCI DSS can address different aspects of these relationships. A SOC 2 report may provide banks with evidence about controls over the processor's services, while PCI DSS validation addresses applicable payment card security requirements. The required evidence should be confirmed with the relevant bank, acquirer, payment brand, or other contractual stakeholder.

SOC 2 Requirements for Payment Processors

SOC 2 does not prescribe one identical set of controls for every payment processor. The examination is based on the applicable Trust Services Criteria, the service organisation's system description, and the agreed scope.

Payment processors seeking SOC 2 reports commonly evaluate controls in areas such as identity and access management, change management, system monitoring, incident response, risk management, data confidentiality, and service availability. The specific controls examined depend on the organisation's services and the criteria included in the engagement.

For example, a payment orchestration platform may connect merchants with several payment service providers without directly storing cardholder data. A bank evaluating that platform may still want to understand how it manages access to transaction systems, protects sensitive information, monitors service disruptions, and responds to security incidents.

A SOC 2 Type II report can provide evidence about control design and operating effectiveness over the period covered by the examination. Banks and enterprise customers may review the report's scope, testing period, exceptions, complementary user entity controls, and any subservice organisations relevant to the services they use.

SOC 2 does not automatically establish PCI DSS compliance. If a processor falls within PCI DSS scope, a SOC 2 report alone is not a substitute for the applicable PCI DSS validation.

PCI DSS Requirements for Payment Processors

PCI DSS applies to payment processors that store, process, or transmit payment card account data, as well as service providers whose activities can affect the security of payment account data. This can include payment gateways, payment service providers, hosted payment environments, and certain technology providers.

The standard's requirements depend on the systems and services within scope. Relevant areas include network security, secure configurations, account data protection, vulnerability management, access restrictions, logging, monitoring, and regular security testing.

Payment processors must also establish clear responsibilities with merchants and other service providers. When a third party performs a security function or operates a service that affects the cardholder data environment, the parties need to understand which applicable requirements each organisation is responsible for meeting.

The PCI Security Standards Council explains that a service provider can fall within PCI DSS scope even when it does not directly store, process, or transmit payment account data. Access to a customer's cardholder data environment, the ability to affect its security, and the nature of the services provided can all influence the assessment scope. The required validation method depends on the organisation's role and the applicable payment brand or acquirer programme. Payment processors should confirm whether a Self-Assessment Questionnaire, a Report on Compliance, an Attestation of Compliance, or another prescribed form of evidence is applicable to their circumstances.

How SOC 2 and PCI DSS Apply to Payment Processing

Consider a US fintech company that provides an API for merchants to initiate payments through multiple payment providers. It maintains customer accounts, manages API access, records transaction events, and monitors the availability of its platform.

A bank evaluating this company may request a SOC 2 report to examine the controls over the platform's services. If the company's systems also store, process, or transmit cardholder data, or can affect the security of payment account data, PCI DSS may apply as well.

Now consider a company that provides fraud monitoring software to payment processors. It may not directly handle cardholder data, but its access to transaction systems or its role in security functions could bring relevant services and systems within PCI DSS scope. The precise scope must be determined from the actual service and environment.

These examples demonstrate why payment platforms should not choose between SOC 2 and PCI DSS based solely on their company name or business category. The decision must reflect the services provided, the data handled, system access, and the expectations of the organisations involved in the partnership.

SOC 2 vs PCI DSS for Bank Partnerships

Banks evaluate third-party payment platforms according to the risks associated with the proposed relationship. The review may consider cybersecurity, operational resilience, data protection, service availability, incident management, regulatory obligations, and the responsibilities assigned to each party.

Neither SOC 2 nor PCI DSS automatically guarantees that a bank will approve a partnership. Each provides evidence relevant to a different set of security considerations, and banks may request additional information according to their vendor risk management processes.

Bank Partnership Security Expectations for Payment Platforms

US banks and financial institutions generally need to understand the risks created by third-party technology providers before entering into or expanding a business relationship. The depth of the review depends on factors such as the criticality of the service, access to sensitive information, integration with banking systems, and the potential effect of a security incident.

A bank may examine a payment platform's information security policies, access controls, incident response arrangements, business continuity measures, vulnerability management, subcontractor relationships, and independent assurance reports. It may also request evidence of PCI DSS validation when the platform's services involve payment card data security.

SOC 2 and PCI DSS can contribute to this review, but neither necessarily covers every concern a bank may have. A SOC 2 report is limited to its stated system, criteria, and examination period. PCI DSS validation focuses on applicable payment card security requirements rather than the entire scope of a bank's third-party risk review.

Payment platforms should therefore identify the evidence requested for the specific partnership instead of assuming that one report will satisfy every contractual or security requirement.

When Banks Require SOC 2 Reports

A bank may request a SOC 2 report when a payment platform provides a technology service, operates a critical application, processes sensitive business information, or connects to systems used in banking operations.

The report can give the bank an independent view of the service organisation's controls within the examination scope. It may be particularly relevant when a fintech company provides cloud-hosted payment software, transaction management services, merchant dashboards, or APIs used by financial institutions.

Whether the bank requests SOC 2 Type I or Type II depends on its vendor assessment criteria and the nature of the relationship. A Type I report describes control design and implementation at a specified date, while a Type II report also examines operating effectiveness over a defined period.

Some banks may require a current Type II report for particular service providers. Others may accept different evidence depending on the provider's risk classification and the contract. There is no universal rule that every US bank requires SOC 2 from every payment platform.

Payment platforms should confirm the bank's reporting expectations, including the relevant systems, Trust Services Criteria, examination period, and treatment of identified exceptions.

When Banks Require PCI DSS Compliance

PCI DSS becomes relevant when a payment platform's activities fall within the standard's scope or when its acquiring bank, payment brand, or contractual arrangements require validation.

For example, a payment processor that stores, processes, or transmits cardholder data may need to demonstrate compliance with applicable PCI DSS requirements. A technology provider that can affect the security of a cardholder data environment may also fall within scope even if it does not directly handle the account data.

The PCI Security Standards Council states that payment brands and acquirers determine applicable validation and reporting methods for merchants and service providers within their compliance programmes. These methods can include a Report on Compliance or a Self-Assessment Questionnaire, depending on the organisation and applicable requirements. Banks may request an Attestation of Compliance or other evidence to verify that the relevant services are covered. A payment platform should confirm that the evidence relates to the services being provided, rather than relying on a generic statement that the organisation is PCI DSS compliant. PCI DSS validation is not a guarantee of complete cybersecurity, and it does not replace the bank's broader review of operational and technology risks.

Do Payment Platforms Need SOC 2 and PCI DSS?

Payment platforms may need both SOC 2 and PCI DSS when they must demonstrate broader service organisation controls and meet applicable payment card security requirements. However, neither framework applies identically to every business. The correct combination depends on the platform's role, its systems and data flows, and the requirements established by its bank and payment partners.

Payment Platforms That Need SOC 2

SOC 2 may be relevant to payment platforms that provide services to banks, fintech companies, merchants, or enterprise customers that require independent assurance over security and related controls.

Examples include:

• Payment orchestration platforms that connect multiple payment providers.
• Cloud-based payment software companies that host transaction applications.
• Fintech platforms that manage customer accounts or transaction workflows.
• Payment technology providers that integrate with bank systems or expose APIs.
• Service organisations whose customers request SOC 2 reports during vendor due diligence.

These examples indicate potential business relevance, not an automatic requirement. A company may pursue a SOC 2 examination because a bank requires it, because enterprise customers expect it, or because the organisation wants independent evidence of its control environment.

The scope should reflect the actual services provided to customers. A report that excludes a critical application or service may not meet a prospective bank's requirements.

Payment Platforms That Need PCI DSS

PCI DSS is relevant to entities that store, process, or transmit payment card account data, and to service providers whose activities can affect payment account data security.

Common examples include payment processors, payment gateways, certain merchant service providers, and technology companies that operate systems connected to a cardholder data environment.

The standard may also apply to providers that perform security functions on behalf of a customer or have access that can affect the customer's card payment environment. The PCI Security Standards Council distinguishes between directly handling account data and providing services that can influence its security.

Businesses that outsource card processing should not assume that outsourcing eliminates all obligations. Merchants can retain responsibilities for selecting appropriate service providers, maintaining relevant agreements, monitoring provider compliance, and validating their own applicable requirements.

The appropriate PCI DSS scope and validation method should be confirmed with the relevant acquirer, payment brand, or other organisation responsible for accepting compliance evidence.

When Payment Platforms May Need Both

A payment platform may need both SOC 2 and PCI DSS when it provides technology services that banks want to evaluate through an independent controls report and also falls within PCI DSS scope.

For instance, a US payment processor may operate a transaction platform, manage merchant integrations, store cardholder data, and provide services to banks and enterprise customers. The bank may request a SOC 2 Type II report to evaluate the controls over the service organisation's system. Separately, the processor may need to demonstrate PCI DSS compliance for its applicable payment card activities.

The two reports provide different evidence. SOC 2 can address the controls included in its examination, while PCI DSS validation addresses the applicable payment card security requirements.

Organisations should avoid assuming that overlapping controls mean the same evidence can be used interchangeably. A control examined under SOC 2 does not automatically satisfy a corresponding PCI DSS requirement, and the PCI DSS assessment does not necessarily cover all the criteria included in a SOC 2 examination.

The most appropriate approach is to establish the scope of each examination or assessment around the services, systems, and obligations relevant to the business.

SOC 2 or PCI DSS for Fintech Companies

For fintech companies in the United States, choosing between SOC 2 and PCI DSS should begin with the business model and the obligations attached to the services offered. SOC 2 is often relevant when banks and enterprise customers want independent assurance over a service organisation's controls. PCI DSS is relevant when the fintech's activities fall within the payment card security standard's scope.

The two frameworks can overlap in areas such as access management, vulnerability management, monitoring, and incident response. However, shared security practices do not make the resulting reports interchangeable.

Choosing SOC 2 for Security Assurance

SOC 2 may be a priority for fintech companies that provide cloud services, financial technology applications, payment APIs, transaction management platforms, or other services to banks and enterprise customers.

A SOC 2 report gives prospective partners an independent CPA firm's opinion on controls within the examination scope. This can be valuable during vendor due diligence, particularly when a bank needs evidence about how a technology provider manages access, protects information, monitors systems, and addresses security incidents.

Fintech companies should consider which Trust Services Criteria are relevant to the services they provide. Security is included in a SOC 2 examination, while Availability, Processing Integrity, Confidentiality, and Privacy may be included according to the organisation's circumstances and examination objectives.

SOC 2 Type II may be particularly relevant when a bank wants evidence about the operating effectiveness of controls over a defined period. However, the bank's vendor requirements determine the report type and scope it will accept.

SOC 2 is not a substitute for sector-specific or contractual obligations. A fintech company that also falls within PCI DSS scope must address those requirements separately.

Choosing PCI DSS for Payment Card Security

PCI DSS should be a priority when a fintech company stores, processes, or transmits payment card account data, or provides services that can affect its security.

Examples include payment gateways, card payment processors, merchant service providers, and certain companies operating payment infrastructure. The applicable requirements depend on the organisation's role, the systems and services involved, and the scope of its card payment activities.

PCI DSS provides defined security requirements covering areas such as network protection, account data security, access restrictions, vulnerability management, logging, and monitoring. The organisation must determine the applicable validation method under the relevant payment brand or acquirer programme.

A fintech company should not assume that using a third-party processor removes its own responsibilities. Outsourcing can reduce the systems in scope, but the business may still have obligations relating to provider oversight, contractual responsibilities, and its own applicable PCI DSS validation.

Where PCI DSS applies, a SOC 2 report alone does not establish compliance with the standard. Payment platforms should obtain the specific evidence required by the relevant parties.

Factors That Determine Which Standard Applies

Several factors determine whether a fintech company needs SOC 2, PCI DSS, or both.

The first factor is payment card data handling. The company should establish whether it stores, processes, or transmits payment account data and whether its services can affect the security of a cardholder data environment. The second factor is the bank's vendor requirements. A bank may request a SOC 2 report, PCI DSS validation, or both. These expectations may vary according to the service, risk classification, and contractual terms.

The third factor is the company's operating model. A payment gateway, a cloud-hosted financial application, and a fraud analytics provider may have different data flows, access permissions, and security responsibilities. The fourth factor is the required evidence. The organisation should confirm the accepted report type, assessment scope, reporting period, and validation method before deciding which examinations or assessments are necessary.

Finally, the business should consider changes to its architecture and services. Introducing a new payment integration, changing a service provider, or expanding access to payment systems can affect PCI DSS scope and the relevance of an existing SOC 2 report.

How to Determine the Right Compliance Path for Bank Partnerships

Payment platforms can determine the appropriate compliance path by mapping their services, data flows, contractual obligations, and bank requirements before committing to a particular examination or assessment.

Assessing Payment Card Data Handling

The first step is to establish how payment information moves through the platform. This includes identifying where cardholder data enters the environment, which systems process it, where it is stored, and which third parties can access it.

The organisation should also identify systems and service providers that can affect the security of the cardholder data environment. This matters because PCI DSS scope is not limited to systems that directly store payment account data.

A payment platform that redirects customers to a third-party hosted payment page may have a different scope from one that operates its own card data environment. However, the redirect model alone does not determine the organisation's exact obligations. Its implementation, integrations, access, and other activities must also be considered.

The PCI Security Standards Council's published FAQ on service providers explains that relevant scope can include people, processes, and technology involved in services that affect payment account data security.

This review establishes whether PCI DSS applies and provides a clearer basis for determining the appropriate validation method.

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Identifying Bank and Payment Partner Requirements

The next step is to obtain the security and compliance requirements of the prospective bank, acquirer, payment brand, or other relevant partner.

These requirements may specify a SOC 2 Type II report, PCI DSS validation evidence, an Attestation of Compliance, or additional information about incident management, business continuity, and third-party risk.

The organisation should clarify which services and systems must be covered by the evidence. It should also determine whether the partner has requirements concerning report dates, testing periods, exceptions, subcontractors, or the frequency of future reviews.

A report should not be assumed acceptable simply because it exists. For example, a SOC 2 report that excludes the platform used in a proposed banking relationship may not meet the bank's expectations. Similarly, PCI DSS evidence that does not cover the relevant service may be insufficient for a payment partner.

Confirming these expectations early can reduce uncertainty during vendor due diligence and partnership negotiations.

Determining Whether SOC 2, PCI DSS, or Both Are Needed

Once the organisation understands its data flows and partner requirements, it can determine the appropriate combination.

• SOC 2: Relevant when independent assurance over the service organisation's controls is required or commercially important.
• PCI DSS: Relevant when the organisation's activities fall within the payment card security standard's scope and applicable validation obligations.
• Both: Relevant when the company must demonstrate broader service organisation controls and meet applicable payment card security requirements.

A fintech company that provides software to banks but does not handle payment card data may prioritise SOC 2 if its customers require that report. However, its actual services and access must be examined before concluding that PCI DSS does not apply.

A payment processor that handles cardholder data may need PCI DSS validation and may also pursue SOC 2 to meet bank or enterprise customer requirements.

For a platform that falls within both scopes, the organisation can identify overlapping security controls while maintaining the separate evidence and testing required by each framework. The objective is to establish a clear, defensible picture of the controls relevant to the banking relationship.

Read More:
PCI DSS Compliance for Banks: Requirements, Scope & Assessment
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