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HATS / SOC 2 Crosswalk

Document: H33-XWALK-SOC2-001
Version: 1.0
Date: 2026-05-22
Framework: SOC 2 Type II (AICPA Trust Service Criteria 2017, updated 2022)
Editor: Eric Beans, H33.ai, Inc.

1. Scope

This crosswalk maps HATS capabilities to SOC 2 Trust Service Criteria (TSC) as defined by the AICPA. SOC 2 Type II evaluates the operating effectiveness of controls over a defined period. HATS continuous attestation directly addresses the "over a period of time" requirement by producing cryptographically bound, timestamped evidence of control effectiveness at every attestation event.

This crosswalk is a technical mapping. It does not constitute a SOC 2 audit opinion or replace the assessment of an independent CPA firm.

2. CC1 -- Control Environment

TSC ControlHATS CapabilityEvidence TypeVerification Method
CC1.1 Integrity and ethical valuesGovernance ReplayPolicy attestation receipts recording active governance policiesReplay governance decisions to verify policy enforcement was consistent with stated values
CC1.2 Board independence and oversightIndependent VerificationGovernance decision receipts verifiable by third partiesBoard delegates verify governance receipts using public keys without system access
CC1.3 Management structure and authorityAgent AttestationPer-action attestation receipts binding actions to authenticated identities and rolesVerify tenant_id and role fields against organizational authority matrix
CC1.4 Competence commitmentEvidence ChainsTraining and qualification attestation chainsVerify chain integrity and temporal coverage of competence attestations
CC1.5 AccountabilityContinuous AttestationComplete attestation receipt chain attributing every operation to an identityTraverse evidence chain to confirm no un-attributed operations exist

3. CC2 -- Communication and Information

TSC ControlHATS CapabilityEvidence TypeVerification Method
CC2.1 Information quality for internal controlEvidence ChainsCryptographically linked attestation chains with predecessor hashesVerify chain integrity; confirm no receipts modified, inserted, or removed
CC2.2 Internal communication of objectivesGovernance ReplayPolicy distribution attestation receiptsReplay policy distribution events; verify each policy version attested at distribution time
CC2.3 External communicationIndependent VerificationExternally verifiable attestation receiptsExternal parties verify receipts using published public keys

4. CC3 -- Risk Assessment

TSC ControlHATS CapabilityEvidence TypeVerification Method
CC3.1 Suitable objectivesGovernance ReplayRisk objective attestation receiptsReplay risk assessment decisions under documented governance
CC3.2 Risk identificationEvidence ChainsRisk assessment event attestation chainVerify temporal coverage; confirm predecessor hash continuity
CC3.3 Fraud risk considerationContinuous Attestation + Agent AttestationAnomaly detection attestation receipts; agent behavior attestationVerify attestation stream for fraud-relevant events; confirm individual agent action attestation
CC3.4 Change identificationEvidence ChainsChange management attestation receipts linked to evidence chainsTraverse evidence chain to identify and verify attestation of configuration changes

5. CC4 -- Monitoring Activities

TSC ControlHATS CapabilityEvidence TypeVerification Method
CC4.1 Ongoing evaluationsContinuous AttestationReal-time attestation receipt stream with sub-second granularityVerify receipt stream continuity; confirm frequency meets monitoring requirements
CC4.2 Communication of deficienciesGovernance Replay + Independent VerificationDeficiency notification attestation receiptsVerify deficiency receipts were generated and communicated within SLA

6. CC5 -- Control Activities

TSC ControlHATS CapabilityEvidence TypeVerification Method
CC5.1 Control selection and developmentGovernance ReplayControl selection decision attestation receiptsReplay control selection decisions; verify governance context
CC5.2 Technology general controlsContinuous AttestationConfiguration and infrastructure attestation receiptsVerify continuous attestation of technology controls throughout assessment period
CC5.3 Deployment through policiesEvidence ChainsPolicy deployment attestation chainVerify chain integrity from policy creation through enforcement

7. CC6 -- Logical and Physical Access

TSC ControlHATS CapabilityEvidence TypeVerification Method
CC6.1 Logical access securityContinuous AttestationPer-access attestation receipts with identity bindingVerify each access event attested with authenticated identity
CC6.2 Credential issuanceAgent AttestationCredential issuance attestation receiptsVerify identity verification preceded credential issuance
CC6.3 Authorization-based accessContinuous AttestationAuthorization check attestation receiptsVerify each access preceded by authorization attestation
CC6.6 External threatsEncrypted ComputationFHE computation receipts demonstrating data never exposed in plaintextVerify computation_type field indicates FHE operation
CC6.7 Access restriction and removalEvidence ChainsAccess revocation attestation receiptsVerify revocation receipts exist for all terminated access
CC6.8 Unauthorized software preventionContinuous AttestationSoftware inventory attestation receiptsVerify attestation continuity for software state

8. CC7 -- System Operations

TSC ControlHATS CapabilityEvidence TypeVerification Method
CC7.1 Infrastructure change detectionContinuous AttestationInfrastructure state attestation receiptsCompare successive receipts to detect state changes
CC7.2 Anomaly monitoringContinuous Attestation + Evidence ChainsAnomaly detection attestation receiptsVerify stream completeness; confirm anomaly events attested within SLA
CC7.3 Security event evaluationGovernance ReplaySecurity event evaluation decision receiptsReplay event evaluation decisions; verify governance context
CC7.4 Incident responseEvidence Chains + Governance ReplayIncident response evidence chain with decision attestationTraverse response chain; replay decisions; verify causal linkage

9. CC8 -- Change Management

TSC ControlHATS CapabilityEvidence TypeVerification Method
CC8.1 Changes to infrastructure, data, softwareEvidence Chains + Continuous AttestationPre- and post-change state attestation receipts bracketing each change eventVerify pre-change and post-change attestations bracket each change; confirm chain integrity

10. CC9 -- Risk Mitigation

TSC ControlHATS CapabilityEvidence TypeVerification Method
CC9.1 Business disruption riskEvidence Chains + Governance ReplayBusiness continuity attestation chain with governance bindingVerify continuity coverage; replay mitigation decisions
CC9.2 Vendor and partner riskIndependent Verification + Evidence ChainsVendor attestation receipts verifiable by business partnersPartners verify receipts using public keys; traverse vendor-specific chains

11. Type II Operating Effectiveness

SOC 2 Type II requires evidence that controls operated effectively over a defined period (typically 6 or 12 months). HATS continuous attestation directly addresses this requirement. The attestation receipt chain provides a cryptographically linked, tamper-evident record of every control-relevant operation throughout the assessment period.

An auditor can traverse the evidence chain from the assessment start date to the end date, verifying: (1) no gaps exist in attestation coverage, (2) each receipt is cryptographically linked to its predecessor, (3) all three post-quantum signatures verify on each receipt, and (4) the governance context is consistent with the stated control objectives.

This approach replaces or supplements point-in-time sampling with continuous, cryptographically verifiable evidence. The auditor does not need to rely on management representations; the evidence is independently verifiable.