SOC 2 · CC - Common Criteria (Security)
SOC 2 CC3.4: CC3.4 Identifying and assessing significant changes (COSO principle 9)
SOC 2 CC3.4 covers CC3.4 Identifying and assessing significant changes (COSO principle 9). The held text names 5 evidence records for it, the first being Risk assessment updates triggered by acquisitions, new products or major system changes. The common gap an assessor flags is Major platform migration not reflected in the risk assessment.
Changes that could significantly affect the system of internal control are identified and assessed. Points of focus: changes in the regulatory, economic and physical environment; changes to the business model such as new lines, acquisitions, divestments, rapid growth, geographic reliance and new technology; changes in leadership and their attitudes to control; changes in the organisation's systems and technology environment; and changes in vendor and partner relationships. The 2022 revision adds that the process also tracks shifts in internal and external threats and in the weaknesses of system components, and how those shifts change the likelihood and size of risks.
What evidence supports CC3.4?
- Change riskRisk assessment updates triggered by acquisitions, new products or major system changes
- Change riskRegulatory change log and impact assessments
- Change riskManagement review minutes discussing leadership or strategic changes
- Change riskVendor onboarding or exit triggering a risk review
- Change riskThreat intelligence or vulnerability trend reviews feeding risk register updates
Where this requirement comes from
This is our own statement of SOC 2 CC3.4, read from the copy we hold (issuer free complete copy) and stated in our words, not the standard verbatim. The framework as we hold it.
Common gaps an assessor flags
- Major platform migration not reflected in the risk assessment
- New regulations applicable to the service never assessed
- Change of key vendor with no risk review
- Emerging threat campaigns against the sector never reflected in risk ratings
How it maps to ISO 27001:2022
No reviewed link is held for this control.
A link is a topical overlap with a confidence and a reason. It does not establish that meeting one requirement satisfies the other, and it is not certification.