How do fintech companies handle SOC 2 plus PCI DSS evidence?
March 6, 20262 min readBeyond SOC 2
SOC 2 + PCI DSS: The Overlap
About 40-50% of controls overlap between SOC 2 and PCI DSS. Both require access controls, encryption, change management, and logging. But PCI DSS has more prescriptive requirements — specific encryption algorithms, network segmentation rules, and vulnerability scanning frequencies.
Shared Controls
| Control Area | SOC 2 | PCI DSS | Shared Evidence |
|---|---|---|---|
| Access control | CC6.1 | Req. 7, 8 | User access reviews, MFA, RBAC |
| Encryption | CC6.7 | Req. 3, 4 | Encryption at rest and in transit |
| Change management | CC8.1 | Req. 6 | PR reviews, deployment controls |
| Logging | CC7.1-7.2 | Req. 10 | Audit trails, log monitoring |
| Vulnerability management | CC7.1 | Req. 5, 6, 11 | Scanning, patching |
| Incident response | CC7.3-7.5 | Req. 12 | IRP, incident documentation |
PCI DSS-Specific Requirements
| PCI Requirement | What It Adds Beyond SOC 2 |
|---|---|
| Cardholder Data Environment (CDE) scoping | Define exactly where card data flows |
| Network segmentation | Isolate systems handling card data |
| Specific encryption standards | TLS 1.2+, AES-256 for card data specifically |
| Quarterly ASV scans | External vulnerability scans by approved vendor |
| Annual penetration test | Required (not just recommended) |
| PAN masking/tokenization | Display only last 4 digits, or tokenize card numbers |
| Key management | Formal cryptographic key management procedures |
The Fintech Strategy
If You Use Stripe or Similar
If you use Stripe, Braintree, or another PCI-compliant payment processor, your PCI scope is minimal:
- You never touch cardholder data directly
- Stripe's SAQ-A or SAQ-A-EP applies (simplified self-assessment)
- Focus SOC 2 on your application security and customer data protection
- PCI effort: 1-2 days for the SAQ
If You Handle Card Data Directly
If your application processes, stores, or transmits cardholder data:
- Full PCI DSS assessment required
- Scope your CDE carefully to minimize the assessment boundary
- Network segmentation is critical for reducing scope
- Consider tokenization to remove card data from your environment
Evidence Organization
Use a unified evidence library tagged for both frameworks. A single access review screenshot satisfies SOC 2 CC6.1 and PCI DSS Requirement 7.1 — don't collect it twice.