CC3.4 Identifying and assessing significant changes (COSO principle 9)
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.
Source: SOC 2 (2017 Trust Services Criteria), CC3.4. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open SOC 2 (2017 Trust Services Criteria) in the compliance library.
These are criteria, not controls: you design controls that meet them, and which criteria are in scope follows the categories your report covers (Security always; Availability, Confidentiality, Processing Integrity and Privacy only if chosen). A Type 2 report tests that the controls operated across the period, so the evidence asked for is samples across that period, not one copy.
These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Risk assessment updates triggered by acquisitions, new products or major system changes · Policy repository / GRC workspace
- Regulatory change log and impact assessments · Regulator portal / correspondence
- Management review minutes discussing leadership or strategic changes · Policy repository / GRC workspace
- Vendor onboarding or exit triggering a risk review · HR system / LMS
governing documentDocuments that govern the control
- Threat intelligence or vulnerability trend reviews feeding risk register updates · Policy repository / GRC workspace
First move
Common gaps auditors find
- 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
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheetCC3.3 Considering fraud risk (COSO principle 8) · CC4.1 Ongoing and separate evaluations of control (COSO principle 16)