PCI DSS vs. SOC 2 Evidence: What Documentation Can You Actually Reuse?

If you are already PCI DSS compliant, you might assume you are 90% of the way to SOC 2. You aren't. While the controls overlap significantly, the evidence requirements often differ in granularity and scope.

PCI DSS is prescriptive: it tells you exactly what the setting must be (e.g., "passwords must be 12 characters"). SOC 2 is descriptive: it asks you to define a policy and prove you followed it.

This fundamental difference creates a trap for teams trying to reuse evidence. A screenshot that passes PCI DSS (showing a specific config value) will usually satisfy SOC 2, but a screenshot that passes SOC 2 (showing a general process) often fails PCI DSS.

Automating evidence collection for both frameworks requires capturing the stricter version of the evidence—usually the PCI version—to satisfy both auditors. This article breaks down exactly which screenshots, logs, and documentation artifacts can be reused and where you need to collect separate evidence.

What Evidence Overlaps Between PCI DSS and SOC 2?

In practice, about 60-70% of the raw evidence artifacts can be reused if you scope your audit correctly. The overlap is strongest in technical infrastructure controls (access, logging, change management) and weakest in organizational controls (HR, risk management).

Here is how the evidence maps across the two frameworks:

Evidence Category	PCI DSS v4.0 Requirement	SOC 2 Criteria (TSC)	Can You Reuse Evidence?
Access Control	Req 7 & 8 (MFA, unique IDs)	CC6.1 (Logical Access)	Yes. Screenshots of MFA configurations and user lists satisfy both.
Change Management	Req 6.4 & 6.5 (Change Control)	CC8.1 (Change Mgmt)	Yes. Jira tickets showing approval and CI/CD logs showing tests are valid for both.
Logging & Monitoring	Req 10 (Audit Trails)	CC7.2 (Security Monitoring)	Yes. Screenshots of log retention settings and NTP sync configs apply to both.
Vulnerability Mgmt	Req 11 (Scans & Pen Tests)	CC7.1 (Vulnerability Scanning)	Yes. Clean scan reports and pen test executive summaries are accepted by both.
Encryption	Req 3 & 4 (Data Protection)	CC6.1 & CC6.7	Partial. PCI requires specific evidence of PAN truncation (Req 3.4) which SOC 2 doesn't explicitly demand but accepts.
Policy Documentation	Req 12 (InfoSec Policy)	CC5.1 (COSO Principles)	Partial. SOC 2 requires broader organizational policies; PCI focuses heavily on CDE security.

Why Can't I Just Give My SOC 2 Auditor My PCI ROC?

A common misconception is that handing your SOC 2 auditor your PCI Report on Compliance (ROC) counts as evidence. It does not.

Your SOC 2 auditor cannot rely on the opinion of your QSA (Qualified Security Assessor). Under AICPA standards, the SOC 2 auditor must perform their own "inquiry, observation, and inspection."

They don't want to see the report saying you do change management; they want to see the raw Jira tickets and GitHub Pull Requests that prove it. You can reuse the artifacts you gathered for the QSA, but you cannot use the QSA's report as a shortcut.

How Do Evidence Requirements Differ for Access Control?

Access control is the area with the highest reuse potential, but PCI DSS is far less forgiving about format.

The PCI Evidence Standard (Stricter)

For PCI DSS Requirement 8, you must prove specific configurations exist. An auditor will ask for a screenshot of your IDP (Okta/Google Workspace) settings showing:

• Minimum password length is 12 characters (Req 8.3.6)
• MFA is enforced for all non-console access into the CDE (Req 8.4.2)
• Idle session timeouts are set to 15 minutes (Req 8.2.8)

The SOC 2 Evidence Standard (Flexible)

For SOC 2 CC6.1, the auditor just wants to verify you are enforcing some logical access standards that match your policy. If your policy says "8 characters," a screenshot showing an 8-character setting is a pass for SOC 2.

The Reuse Strategy: Configure your systems to meet the PCI standard (12 characters, 15-minute timeout). Capture that screenshot. It will automatically pass SOC 2. If you only configure for SOC 2 (e.g., 8 characters), that evidence is useless for PCI.

What Change Management Evidence Can Be Reused?

Both frameworks want to see that code doesn't go to production without approval.

PCI DSS Requirement 6.5.1 requires that changes are tested for vulnerabilities prior to deployment. SOC 2 CC8.1 requires that changes are authorized and tested.

The Shared Artifact

A screenshot or PDF export of a Pull Request (PR) in GitHub or GitLab is the gold standard here. To satisfy both, the PR evidence must show:

1. Branch Protection: A screenshot showing that the main branch requires at least one review.
2. The Approval: The specific PR showing a green checkmark from a peer reviewer.
3. The CI/CD Status: Evidence that automated tests (SAST/DAST) ran and passed.

If your evidence pack for a change includes the Jira ticket, the PR approval, and the build log, you can submit the exact same file to both your QSA and your SOC 2 auditor.

Where Does Evidence Re-Use Fail?

There are specific areas where you cannot reuse evidence because the scope or intent is too different.

1. The Scope Difference (CDE vs. Organization)

PCI DSS only cares about the Cardholder Data Environment (CDE). If you have a separate corporate network that doesn't touch card data, PCI ignores it. SOC 2 covers the "System" described in your report, which usually includes your entire production environment and often corporate tools.

• Scenario: You capture evidence that MFA is enabled for your CDE bastion hosts.
• PCI Result: Pass.
• SOC 2 Result: Fail (or Exception), because the auditor also wants to see MFA on your corporate email and HR systems, which might be out of scope for PCI.

2. Data Retention vs. Data Deletion

PCI DSS Requirement 3.2.1 strictly prohibits storing sensitive authentication data (SAD) like CVV codes after authorization, even if encrypted. Evidence here is often a "data discovery scan" proving the absence of data. SOC 2 CC6.1 focuses on data protection. It doesn't explicitly ban storing CVV codes (though it's a terrible idea), it just requires they be protected.

Evidence of "secure deletion" is critical for PCI but often a minor detail for SOC 2.

3. Physical Security

Unless you are a data center or have a call center, physical security for SOC 2 is often minimal (cloud-hosted companies rely on AWS/GCP evidence). For PCI DSS, if you have any physical interaction with card data (e.g., a card writer in the office, or paper forms), the evidence requirements for physical access logs (Req 9) are intense and specific.

Where Traditional GRC Automation Stops

Most GRC platforms (like Drata or Vanta) are excellent at mapping controls. They will show you that "PCI Req 8.2" is linked to "SOC 2 CC6.1".

However, these tools often rely on API integrations that check for binary status ("Is MFA on?"). They struggle with the visual inspection evidence that PCI auditors demand.

For example, PCI Requirement 3.4 requires PAN (Primary Account Number) to be unreadable anywhere it is stored. An API check can tell you that "Encryption is ON" for an RDS database. It cannot tell you if a developer accidentally logged a full credit card number to a text file in S3.

To prove compliance, a human (or an advanced agent) needs to:

1. Run a query or scan.
2. Take a screenshot of the masked results (e.g., 4111-XXXX-XXXX-1111).
3. Submit that visual proof.

GRC tools don't automate these "inspection" proofs; they usually leave a placeholder ticket for you to upload the screenshot manually.

How to Automate Evidence Collection for Both Frameworks

To build an automated evidence pipeline that serves both PCI and SOC 2, follow these rules:

1. Adopt the Stricter Standard: Align your password policies, encryption standards, and change workflows to PCI DSS v4.0.
2. Scope for the Widest Net: When collecting user lists or asset inventories, collect them for the entire SOC 2 scope. You can filter down for the PCI auditor, but you can't expand a PCI-only list for the SOC 2 auditor.
3. Automate Screenshots, Not Just JSON: Use tools that capture actual screenshots of configurations and workflows. QSAs are traditional; they trust what they can see. A screenshot of a "Deny" firewall rule is often more persuasive to a QSA than a JSON dump of the rule config.

By treating PCI DSS as the baseline for your evidence quality and SOC 2 as the baseline for your evidence scope, you can generate a single set of artifacts that satisfies both audits without doubling your workload.

Learn More About SOC 2 Evidence Automation

For a complete guide to automating the collection of these artifacts, see our guide on automating SOC 2 evidence collection in 2025, which details how to capture the screenshots and logs required for rigorous audits.