PCI DSS vs SOC 2: Differences Explained

The short answer: PCI DSS is mandatory if you handle payment card data. SOC 2 is voluntary but often required by enterprise customers. Many fintech companies need both.

Key Takeaways

Point	Summary
PCI DSS	Mandatory for payment card data, prescribed controls, validated via SAQ or QSA audit
SOC 2	Voluntary for customer trust, flexible controls, validated via CPA attestation
Overlap	60-70% control overlap for companies needing both
When you need PCI DSS	Any handling of credit card data
When you need SOC 2	Enterprise customers requesting security validation
Combined approach	Start with the one you need first; add the other efficiently

The Fundamental Difference

Aspect	PCI DSS	SOC 2
Mandated by	Card brands (Visa, Mastercard, etc.)	Customer requirements (voluntary)
Scope	Cardholder data environment only	Defined by your organization
Approach	Prescriptive requirements	Principles-based criteria
Output	Attestation of Compliance (AOC) or Report on Compliance (ROC)	Attestation report
Assessor	QSA or internal (via SAQ)	Licensed CPA firm
Penalty for non-compliance	Fines, loss of card processing ability	Lost deals, customer trust issues
"Certification"	No certification exists	Not a certification either

Key insight: PCI DSS tells you exactly what to do. SOC 2 tells you what to achieve and lets you decide how.

When You Need Each

You Need PCI DSS If:

• You store credit card numbers (even encrypted)
• You process card transactions through your systems
• You transmit card data between systems
• You're a service provider to companies that do the above
• You accept credit cards as payment

Even with modern payment processors like Stripe, you likely need some level of PCI DSS validation (typically SAQ A for properly implemented integrations).

You Need SOC 2 If:

• Enterprise customers are requesting your SOC 2 report
• You're losing deals to competitors with SOC 2
• Security questionnaires are taking significant time
• You handle sensitive customer data (any type, not just card data)
• You want third-party validation of your security controls

You Likely Need Both If:

• You're a fintech company handling payments
• You're a SaaS company with payment features selling to enterprises
• Your payment service provider clients require SOC 2
• You're a payment processor or gateway

Detailed Comparison

Scope Definition

Aspect	PCI DSS	SOC 2
What's in scope	All systems that store, process, or transmit CHD	You define the scope (typically your production service)
How scope is determined	Card data flow analysis	Risk-based, customer-driven
Scope reduction	Network segmentation, tokenization	Architecture decisions
Connected systems	Systems connected to CDE are in scope	Related to system description

PCI DSS scoping follows strict rules. If a system touches card data or connects to one that does, it's in scope. There's less flexibility here.

SOC 2 scoping gives you more control. You define your system boundaries in the "system description" and the auditor validates controls within that scope.

Control Requirements

Area	PCI DSS Requirement	SOC 2 Equivalent	Overlap
Access Control	Unique IDs, MFA, least privilege	CC6.1, CC6.2, CC6.3	High
Encryption	TLS for transmission, encryption at rest	CC6.1, CC6.7	High
Logging	Comprehensive audit trails	CC7.2, CC7.3	High
Vulnerability Management	Patching, scanning, pen testing	CC7.1	High
Network Security	Firewalls, segmentation	CC6.6	High
Physical Security	Data center controls	CC6.4, CC6.5	Medium
Incident Response	Documented plan and testing	CC7.4, CC7.5	High
Vendor Management	Service provider oversight	CC9.2	High
Change Management	Documented processes	CC8.1	High
Risk Assessment	Annual formal assessment	CC3.1, CC3.2	High

Estimated overlap: For a typical SaaS company implementing both, approximately 60-70% of controls serve both frameworks.

Assessment Process

Aspect	PCI DSS	SOC 2
Assessor type	QSA (for Level 1) or self-assessment (SAQ)	Licensed CPA firm
Assessment frequency	Annual	Annual
Observation period	Point-in-time or period-based	3-12 months for Type 2
Scanning requirements	Quarterly external ASV scans	Not required (but often included)
Pen testing	Annual requirement	Not required (but recommended)
Interim validation	Quarterly scans, ongoing compliance	Continuous monitoring expected

Output and Deliverables

PCI DSS delivers:

• Attestation of Compliance (AOC) - summary for sharing with partners
• Report on Compliance (ROC) - detailed assessment (Level 1 only)
• Self-Assessment Questionnaire (SAQ) - for lower levels
• Quarterly ASV scan reports

SOC 2 delivers:

• Type 1 Report: Control design at a point in time
• Type 2 Report: Control design and operating effectiveness over time
• Management assertion and auditor opinion
• System description and control testing details

Timeline and Investment

Factor	PCI DSS	SOC 2
First-time timeline	3-6 months (depends on scope)	4.5-6 months (Type 2)
Annual effort	Moderate (ongoing compliance)	Moderate (annual audit)
Investment	Varies widely by level and scope	Typically varies based on scope
Quarterly obligations	ASV scans required	None
Ongoing work	Evidence collection, scans, training	Evidence collection, control monitoring

Real-World Scenarios

Scenario 1: SaaS with Stripe Integration

Situation: You use Stripe Elements to collect payments. No card data touches your servers.

PCI DSS need: SAQ A (minimal scope, ~27 questions in v4.0)
SOC 2 need: Depends on customer requirements
Recommendation: Complete SAQ A first (quick), then pursue SOC 2 if customers require it

Scenario 2: Payment Gateway / Processor

Situation: You're building payment infrastructure that handles card data directly.

PCI DSS need: SAQ D (Service Provider) or Level 1 QSA assessment
SOC 2 need: Almost certainly required by your customers
Recommendation: Pursue both simultaneously, leveraging control overlap

Scenario 3: Fintech App with Stored Cards

Situation: You store encrypted card tokens (not full PANs) for recurring billing.

PCI DSS need: SAQ D (Merchant) or potentially SAQ A-EP depending on implementation
SOC 2 need: High probability if selling to enterprises
Recommendation: Clarify PCI scope first, then add SOC 2 using shared controls

Strategic Approach: Getting Both

If you need both frameworks, here's the efficient path:

Option 1: Start with PCI DSS

When to choose this path:

• You're already processing payments or launching soon
• PCI DSS is blocking your payment processing
• SOC 2 requests are less urgent

Approach:

1. Complete PCI DSS implementation and assessment
2. Document controls with SOC 2 in mind
3. Layer SOC 2 on top (60-70% controls already done)
4. Complete SOC 2 Type 2 observation period

Option 2: Start with SOC 2

When to choose this path:

• Payment processing is already PCI compliant (via Stripe SAQ A)
• Enterprise customers are requesting SOC 2 urgently
• You can complete SAQ A quickly

Approach:

1. Complete SAQ A for basic PCI DSS coverage
2. Implement SOC 2 program
3. If you later need more PCI DSS coverage, expand controls

Option 3: Parallel Implementation

When to choose this path:

• You need both frameworks urgently
• You have resources for parallel workstreams
• You want the most efficient approach

Approach:

1. Identify overlapping controls
2. Implement shared controls once
3. Run PCI and SOC 2 assessments in parallel or sequence
4. Maintain unified compliance program

Unified Compliance Program

Once you have both frameworks, maintain them together:

Activity	PCI DSS	SOC 2	Combined Approach
Access reviews	Required	Expected	Single review covers both
Vulnerability scans	Quarterly (ASV required)	Recommended	Run internal + external quarterly
Penetration testing	Annual	Recommended	Single annual test covers both
Security training	Annual	Expected	One training program
Policy review	Annual	Annual	Unified policy set
Risk assessment	Annual	Expected	Single risk assessment
Evidence collection	Ongoing	Ongoing	Single evidence repository

Common Questions

Can SOC 2 replace PCI DSS?

No. SOC 2 doesn't satisfy PCI DSS requirements, and card brands don't accept SOC 2 as a substitute. If you handle card data, you need PCI DSS compliance regardless of SOC 2 status.

Can PCI DSS replace SOC 2?

Not really. While PCI DSS demonstrates strong security controls, most customers requesting SOC 2 want to see the SOC 2 report specifically. PCI DSS AOC may satisfy some security questionnaires but won't replace SOC 2 for customers who require it.

Which framework has stricter requirements?

PCI DSS is more prescriptive and specific about technical controls. SOC 2 is more flexible but expects you to meet the Trust Services Criteria in whatever way makes sense for your organization.

Do I need a penetration test for both?

PCI DSS requires annual penetration testing. SOC 2 doesn't require it, but most organizations include it. A single comprehensive pen test can serve both purposes.

If I'm already PCI compliant, how long does SOC 2 take?

With PCI DSS controls in place, SOC 2 implementation typically focuses on documentation, policies, and any gaps. The main timeline driver is still the SOC 2 Type 2 observation period (minimum 3 months).

Frequently Asked Questions

What if a customer asks for PCI DSS and I only have SOC 2?

You'll need to pursue PCI DSS compliance if you handle card data. Share your SOC 2 report in the interim to demonstrate security maturity, and provide a timeline for PCI DSS completion.

How do auditors view companies with both frameworks?

Having both frameworks demonstrates comprehensive security maturity. Auditors and customers see it as a positive indicator of a well-run security program.

---

Need help implementing PCI DSS, SOC 2, or both? Talk to our team

---

Sources

• PCI Security Standards Council - PCI DSS documentation
• AICPA SOC Suite of Services - SOC 2 framework
• AICPA Trust Services Criteria - SOC 2 criteria documentation