Financial Services HITRUST Certification: Complete Evidence Guide
Financial services firms pursuing HITRUST r2 certification face rigorous evidence requirements across 19 control domains. This guide details the exact documentation, screenshots, and operational logs assessors require and explains how to automate evidence collection to reduce audit preparation time.
Achieving HITRUST r2 certification in the financial services sector demands a level of rigor that far exceeds standard SOC 2 audits. Assessors require comprehensive evidence proving that controls are not just defined in policy but fully implemented and measured. For banks, fintechs, and insurance firms, this means gathering thousands of screenshots, configuration logs, and workflow recordings across 19 HITRUST CSF control domains. This guide outlines the specific evidence requirements for financial institutions and explains how automation can streamline the collection of assessor-ready documentation.
What Evidence Do HITRUST Assessors Require for Financial Services?
Answer: HITRUST assessors require evidence mapped to the five levels of maturity in the PRISMA model: Policy, Procedure, Implemented, Measured, and Managed. For a standard r2 Validated Assessment, financial institutions must primarily provide "Implemented" evidence.
This means you cannot simply show a policy document stating "we encrypt data." You must provide operational evidence: screenshots of database encryption settings, logs showing active encryption keys, and workflow recordings demonstrating that unencrypted traffic is blocked. For financial services specifically, assessors also look for evidence satisfying inherited requirements from GLBA, NYDFS 23 NYCRR 500, and PCI DSS.
The Financial Services HITRUST Evidence Checklist
The HITRUST CSF (Common Security Framework) unifies regulations like HIPAA, NIST, and ISO. For financial services, the focus intensifies on access control, audit logging, and third-party risk.
1. Access Control (Domain 01)
Critical for preventing unauthorized access to financial data.
| HITRUST Requirement | Specific Financial Service Context | Required Evidence (Artifacts) | Automation Method |
|---|---|---|---|
| 01.b User Registration | Verify distinct IDs for traders/admins; no shared accounts. | Screenshots of IDM (Okta/Azure AD) user lists; tickets for new user provisioning. | Screenata / Workflow Recorder |
| 01.c Privilege Management | "Least Privilege" for core banking systems. | Screenshots of role definitions; "Access Denied" test results for non-privileged users. | Workflow Recorder (Negative Testing) |
| 01.j Session Time-out | 15-minute timeout for financial terminals. | Screenshot of session configuration settings; video of auto-logout occurring. | Console Screenshot |
2. Audit Logging & Monitoring (Domain 09)
Essential for fraud detection and forensic analysis.
| HITRUST Requirement | Specific Financial Service Context | Required Evidence (Artifacts) | Automation Method |
|---|---|---|---|
| 09.aa Audit Logging | Logs must capture all financial transactions and admin actions. | Export of SIEM logs showing specific event IDs; screenshot of log retention policy settings (e.g., 7 years). | API Monitor + Log Export |
| 09.ab Monitoring System Use | Detection of anomalous transfers or access patterns. | Screenshots of alert configurations in monitoring tools (e.g., Datadog, Splunk). | Console Screenshot |
3. Data Protection & Privacy (Domain 06, 13)
Aligns with GLBA and privacy mandates.
| HITRUST Requirement | Specific Financial Service Context | Required Evidence (Artifacts) | Automation Method |
|---|---|---|---|
| 06.d Cryptographic Controls | Encryption of NPI (Non-Public Personal Information) at rest/transit. | Screenshots of TLS 1.2+ enforcement; database encryption status (TDE enabled). | API + Console Screenshot |
| 13.c Protection of Records | Secure disposal of customer data. | Evidence of secure deletion workflows; screenshots of S3 Object Lock or retention policies. | Workflow Recorder |
4. Third-Party Security (Domain 15)
Focus on supply chain risk (FinTech partnerships).
| HITRUST Requirement | Specific Financial Service Context | Required Evidence (Artifacts) | Automation Method |
|---|---|---|---|
| 15.b Supplier Service Delivery | Monitoring vendor SLA and security posture. | Screenshots of vendor risk management dashboard; evidence of annual vendor review completion. | Console Screenshot |
Where Traditional HITRUST Assessment Automation Falls Short
Many financial institutions rely on GRC platforms like Drata, Vanta, or the MyCSF portal itself to manage assessments. While these tools are excellent for mapping controls and storing policies, they struggle with the "Implementation" maturity level.
The Automation Gap:
- Static vs. Dynamic: GRC tools can check if "MFA is enabled" via API. They cannot capture a screenshot of a specific user being denied access to a high-value transaction system (Negative Testing), which assessors often request to prove the control works in practice.
- Legacy Systems: Financial services often rely on mainframes or legacy banking cores that lack modern APIs. GRC tools cannot connect to them. Evidence must be captured visually via screenshots or terminal logs.
- Complex Workflows: Proving "Change Management" (Domain 06) requires showing the link between a Jira ticket, a GitHub PR, and a deployment pipeline. APIs rarely stitch this narrative together into a single evidence artifact.
This is where AI-driven evidence automation bridges the gap by "watching" the workflow and generating the requisite screenshots and audit trails automatically.
How to Automate HITRUST Evidence Collection for FinTechs
To reduce the HITRUST r2 timeline from 9-12 months down to a few weeks, automation must go beyond policy generation.
Step 1: Map Controls to Regulations
Ensure your HITRUST assessment scope includes the relevant regulatory factors (GLBA, NYDFS). This determines which evidence is mandatory.
Step 2: Deploy Workflow Recorders
For controls requiring "Implemented" evidence (Level 3), use an automation tool like Screenata.
- Target: Domain 01.b (User Registration).
- Action: The tool records the onboarding workflow: ticket creation → approval → provisioning in the core banking system.
- Output: A PDF containing timestamped screenshots of each step, satisfying the assessor's need to see the process in action.
Step 3: Automate "Sample Testing"
HITRUST assessors typically require a sample size of 25 items for manual controls (e.g., "Show me evidence for 25 new hires").
- Manual Way: Manually taking 25 sets of screenshots (hours of work).
- Automated Way: The tool iterates through a list of 25 users, captures the evidence for each, and compiles a zip file mapped to the control ID.
Step 4: Validate Against Maturity Levels
Before submission to MyCSF, verify that every piece of evidence supports the "Implemented" maturity level. Does the screenshot clearly show the configuration is active? Is the timestamp within the audit period?
Understanding HITRUST Maturity Levels for Evidence
Financial services firms often fail assessments because they provide "Policy" evidence when "Implemented" evidence is required.
| Maturity Level | Definition | Required Evidence Example (Access Control) |
|---|---|---|
| 1. Policy | A formal document exists. | PDF of "Access Control Policy" signed by the CISO. |
| 2. Procedure | Documented process steps. | Wiki page explaining "How to provision a new teller." |
| 3. Implemented | Control is functioning. | Screenshots of the active user list; logs of a user login. |
| 4. Measured | Testing effectiveness. | Report showing "99% of terminated users revoked within 24h." |
| 5. Managed | Continual improvement. | Meeting minutes discussing how to improve revocation time. |
Note: For r2 certification, Levels 1-3 are the primary focus. Levels 4-5 are optional for scoring but required for higher ratings.
Frequently Asked Questions
Is HITRUST mandatory for financial services?
No, it is not a legal mandate like SOX. However, it is increasingly becoming a contractual requirement for FinTechs selling to major banks or healthcare payers, as it acts as a "super-framework" covering NIST, ISO, and PCI.
Can I use SOC 2 evidence for HITRUST?
Yes, but with caveats. HITRUST is more prescriptive. A SOC 2 screenshot might just show "MFA is on." A HITRUST assessor might require that same screenshot to also show the specific configuration of the MFA (e.g., no SMS allowed, only authenticator apps), aligning with NIST SP 800-63.
How often must evidence be collected?
For an r2 assessment (valid for 2 years), evidence is collected during the "validated assessment" period (usually a 90-day window). However, you must perform an "Interim Assessment" at the 1-year mark, requiring fresh evidence to maintain certification.
Key Takeaways
- ✅ HITRUST r2 is the gold standard for financial services due to its mapping to GLBA, NYDFS, and NIST.
- ✅ Evidence must be operational, proving "Implementation" (Level 3) via screenshots, logs, and configurations.
- ✅ Financial data protection (encryption, audit logging) requires granular evidence that APIs often miss.
- ✅ Automation is essential for handling the sampling requirements (e.g., 25 samples) of a validated assessment.
- ✅ Legacy banking systems often require visual (screenshot-based) automation rather than API integrations.
Learn More About HITRUST r2 Certification Evidence Automation
For a deeper dive into streamlining your assessment, see our guide on automating HITRUST r2 evidence collection, including strategies for managing the MyCSF portal and mapping evidence across multiple regulatory frameworks.
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