[ COMPLIANCE_DOSSIER / SOC_2 ]

What does SOC 2 require for AI agents?

SOC 2 auditors increasingly ask for evidence that AI agents with data access are governed the same way human employees are. Centurian generates SOC 2-ready evidence (access logs, attestation, audit trail) per agent, automatically.

Agents are already inside SOC 2’s scope

SOC 2's Trust Services Criteria cover access control, change management, and monitoring for anything that touches customer data. That scope was written for human employees and service accounts, but the criteria don't actually say "human", they say "any principal with access." An AI agent holding a database connection or an API key is the exact access-control surface a SOC 2 audit already covers. Auditors asking about agents specifically is the framework catching up to reality, not a new requirement being invented.

In practice, that means an auditor will ask the same three questions about an agent that they ask about a new hire: who authorized this access, what can it actually do, and can you show me what it did. Most companies can answer the first two. Almost none can answer the third for an AI agent today. See the audit trail page for how that evidence gets built.

Why the evidence should come from outside

57% of organizations prefer third-party-built compliance and governance tooling over internally built (KPMG), an independence preference that predates AI agents but applies directly to them. The team that configured an agent's access is not the ideal sole source of the evidence that the access was appropriate; a SOC 2 auditor will trust an independent record more than a self-reported one.

Centurian generates three evidence primitives automatically: per-agent access logs (what data and systems each agent touched), attestation records (who owns the agent and what it's authorized to do), and the bitemporal, signed audit trail (every action, timestamped). Deloitte Zora AI, PwC Agent OS, and KPMG Workbench build comparable layers internally at large enterprises as part of consulting engagements; Centurian ships the same primitives as a self-serve product for teams that don't have a consulting budget for it. See proving AI agent compliance for how this rolls into a full compliance package.

FAQ

What does SOC 2 require for AI agents?

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SOC 2 auditors increasingly ask for evidence that AI agents with data access are governed the same way human employees are. Centurian generates SOC 2-ready evidence (access logs, attestation, audit trail) per agent, automatically.

Why would a SOC 2 auditor even ask about AI agents?

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SOC 2's Trust Services Criteria cover access control, change management, and monitoring for anything that touches customer data, historically applied to human employees and service accounts. An AI agent with a database connection or an API key is functionally the same access-control surface a SOC 2 audit already scopes; auditors are catching up to the fact that agents are a new class of principal, not a new category the framework has to invent.

Should evidence come from the company being audited or a third party?

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57% of organizations prefer third-party-built compliance and governance tooling over internally built (KPMG), largely on independence grounds, the same team that configured an agent's access shouldn't be the sole source of the evidence that access was appropriate. Centurian sits outside the agent's own vendor and the org's internal tooling, producing evidence neither built.

What specific evidence does Centurian generate for a SOC 2 audit?

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Per-agent access logs (what data and systems each agent touched), attestation records (who owns the agent and what it's authorized to do), and the bitemporal audit trail (every action, signed, timestamped), the same evidence primitives an auditor already expects for human employees, applied to agents automatically instead of assembled by hand at audit time.

How does this compare to what Big 4 firms offer?

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Deloitte Zora AI, PwC Agent OS, and KPMG Workbench build internal AI governance layers as part of consulting engagements at large enterprises. Centurian ships the same evidence primitives, registration, attestation, audit trail, as a self-serve product a mid-market team can wire up directly, without a consulting engagement, and grow from there.
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