HITRUST CSF vs SOC 2: Evidence Requirements Compared

HITRUST CSF and SOC 2 are the two dominant information security frameworks for SaaS and healthcare companies, but their evidence requirements differ fundamentally in scope, rigor, and volume. While SOC 2 allows for auditor judgment and sampling, HITRUST r2 assessments are prescriptive, requiring specific documentation and screenshots to prove maturity levels across 19 control domains. Understanding these differences and leveraging automation to capture evidence is critical to avoiding the "audit fatigue" that often derails dual-framework initiatives.

What Is the Difference Between HITRUST and SOC 2 Evidence?

Answer: The primary difference lies in prescriptiveness and scoring. SOC 2 is an attestation where an auditor reviews a sample of evidence to form an opinion on whether a control is "operating effectively." Evidence is often binary (Pass/Fail). HITRUST CSF is a certification based on a maturity model. You must provide distinct evidence for Policy, Procedure, and Implementation (and optionally Measured and Managed) for every applicable requirement. A single missing screenshot can drop a control's score below the certification threshold.

Comparison Table: SOC 2 vs HITRUST Evidence

The table below outlines the structural differences in how evidence is collected and evaluated.

Feature	SOC 2 (Type II)	HITRUST (r2 Validated)
Framework Nature	Attestation (Auditor Opinion)	Certification (Scored Assessment)
Control Count	~60-80 Criteria (Flexible)	~200-800+ Requirements (Prescriptive)
Evidence Scoring	Pass / Exception	5 Maturity Levels (0-100% Score)
Evidence Depth	Samples (e.g., "Show me 5 new hires")	100% Population or Statistically Valid Sample
Implementation Proof	Screenshots & Logs	Screenshots, Configs, and Process Docs
Documentation Platform	Drata, Vanta, Secureframe	MyCSF Portal (Mandatory)
Automation Level	High (Infrastructure APIs)	Moderate (Requires Application Evidence)

Detailed Evidence Requirements: SOC 2

For SOC 2, evidence collection focuses on the Trust Services Criteria (TSC). Auditors generally request evidence that falls into three buckets:

Configurations: JSON/YAML exports showing MFA is on, encryption is enabled, etc.
Populations & Samples: Lists of all new hires, changes, or incidents, from which the auditor selects a sample (e.g., "Show me evidence for hire #4 and #12").
Observation: Screenshots showing a setting in the UI that cannot be exported via API (e.g., a specific Jira workflow transition screen).

Common Automation Gap: While tools like Drata or Vanta automate configuration evidence, they often cannot automate the "Observation" evidence—specifically screenshots of application-level controls like custom user provisioning flows or manual change approval screens.

Detailed Evidence Requirements: HITRUST CSF

HITRUST evidence is far more granular. For a standard r2 Validated Assessment, you typically need to prove the first three maturity levels for every control to achieve certification.

Level 1: Policy

Requirement: Do you have a written policy?
Evidence: A PDF of the policy document, approved by management, with version history.
Automation: Managed via GRC policy modules.

Level 2: Procedure

Requirement: Do you have a documented process for how the policy is executed?
Evidence: Standard Operating Procedures (SOPs), playbooks, or knowledge base articles explaining the "who, what, when, and how."

Level 3: Implemented (The Heavy Lift)

Requirement: Is the control actually working as described on all systems?
Evidence: This is where screenshots and workflow recordings are mandatory.
- Example: For Control 01.b (User Registration), you cannot just show a policy. You must provide screenshots of the actual admin panel showing the user creation form, the role assignment dropdown, and the audit log of a created user.
- Coverage: Evidence must cover all in-scope platforms (e.g., AWS, Azure, and your internal admin tool).

Level 4 (Measured) & Level 5 (Managed)

Requirement: Do you test the control and improve it?
Evidence: Automated reports, metrics dashboards, and evidence of corrective actions taken based on those metrics. Most organizations do not pursue these levels for initial certification, but automation makes them accessible.

Example: Access Control Evidence (SOC 2 vs HITRUST)

Let's look at how evidence requirements differ for a single concept: removing a terminated employee.

SOC 2 (Control CC6.2)

Auditor Ask: "Provide a list of employees terminated in Q3. I pick 'John Doe'. Show me proof his access was revoked."
Evidence: A screenshot of the ticket requesting revocation and a screenshot from the IdP (Okta/Google) system log showing the account was deactivated.

HITRUST (Requirement 01.c)

Assessor Ask: "Demonstrate the implementation of access revocation procedures."
Evidence Required:
1. Policy: Access Control Policy (PDF).
2. Procedure: HR Offboarding SOP (PDF).
3. Implementation:
  - Screenshot of the HR system termination record.
  - Screenshot of the IdP deactivation log.
  - AND: Screenshot of the internal admin panel showing the user status is "Inactive" (often missed by API integrations).
  - AND: Screenshot of physical badge revocation logs (if applicable).

The Challenge: HITRUST requires this depth for hundreds of controls. Manual screenshots become unmanageable.

Where Traditional Automation Stops

Most compliance automation platforms (GRC tools) are optimized for SOC 2. They connect to AWS, GitHub, and Okta APIs to pull configuration data.

The HITRUST Gap:

Application-Level Evidence: HITRUST often requires evidence from systems that don't have public APIs (e.g., legacy healthcare apps, custom portals, EHRs). GRC tools cannot "see" into these.
Visual Verification: HITRUST assessors are trained to look for specific visual indicators in screenshots (e.g., "Does the screen show the date? Does it show the URL?"). API JSON dumps are often rejected as "insufficient implementation evidence" if the assessor cannot visually verify the context.
Process Documentation: GRC tools track that a control exists, but they don't automatically generate the procedure documentation (Level 2) or the visual proof of the workflow (Level 3).

How to Automate HITRUST Evidence with Screenshots

To bridge the gap between SOC 2 automation and HITRUST rigor, organizations use AI evidence agents like Screenata.

Step 1: Map Controls to Workflows

Identify the high-friction HITRUST domains—usually Access Control, Configuration Management, and Audit Logging. Map these to specific user workflows (e.g., "Granting Admin Access").

Step 2: Record the "Implemented" Evidence

Instead of manually taking screenshots for Level 3 evidence:

Run the workflow (e.g., perform a user access review).
The AI agent records the session, capturing every click and screen state.
It automatically generates a timestamped, tamper-evident PDF containing the required screenshots.

Step 3: Align with MyCSF

HITRUST requires evidence to be uploaded to the MyCSF portal. Automated tools can bundle evidence into organized ZIP files labeled by requirement (e.g., 09.aa_Audit_Logs_Q3.zip), saving weeks of manual renaming and uploading.

Frequently Asked Questions

Can I use my SOC 2 report as evidence for HITRUST?

Partially. HITRUST allows you to "inherit" certain controls from a SOC 2 report if the scope and testing dates align perfectly. However, you generally cannot just upload a SOC 2 report to satisfy a HITRUST requirement. You must extract the specific testing evidence (screenshots and logs) used for the SOC 2 audit and map them to HITRUST requirements.

Does HITRUST require more screenshots than SOC 2?

Yes. Because HITRUST is a scored maturity model, assessors need visual proof that a control is "Implemented" (Level 3) across the entire system. This often requires screenshots of configurations, error messages (negative testing), and user interfaces that SOC 2 auditors might skip or sample lightly.

What is the "MyCSF" portal?

MyCSF is the SaaS platform provided by HITRUST where you must document your assessment. Unlike SOC 2, where you might use a Google Drive or a GRC tool like Drata/Vanta to share evidence, HITRUST requires evidence to be linked to specific requirements within MyCSF.

How often do I need to collect evidence for HITRUST?

For an r2 Validated Assessment, evidence generally needs to cover the 12-month reporting period. However, unlike SOC 2's "period of time," HITRUST focuses heavily on the current state of maturity. Regular automated collection (e.g., monthly) is best practice to ensure you don't discover a "Level 3" gap two weeks before the assessment submission.

Key Takeaways

✅ SOC 2 is opinion-based and flexible; HITRUST is scored, prescriptive, and rigorous.
✅ Evidence Depth: HITRUST requires separate evidence for Policy, Procedure, and Implementation for every control.
✅ The Manual Gap: Traditional GRC tools struggle with the visual "Implementation" evidence required for HITRUST Level 3 maturity.
✅ Automation Strategy: Use GRC tools for Level 1 (Policy) and AI agents (like Screenata) for Level 3 (Implementation/Screenshots).
✅ Outcome: Automating HITRUST evidence collection can reduce assessment preparation time from 6+ months to 6-8 weeks.

Learn More About HITRUST r2 Certification Evidence Automation

For a comprehensive guide on streamlining your assessment, see our guide on automating HITRUST r2 evidence collection, including detailed strategies for mapping evidence to MyCSF requirements.