Compliance / Assurance Standard

AICPA TSC 2017 (with 2022 revised POF)

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In this article
At a Glance
AICPA TSC 2017 – POF 2022
  • Classification
    Category
    Compliance / Assurance Standard
    Domain
    Cybersecurity
    Framework Family
    SOC Frameworks
  • Regulatory Context
    Type
    Standard
    Legal Instrument
    Standard
    Sector
    Cross-Sector
    Industry
    Cross-Industry
  • Region / Publisher
    Region
    North America
    Region Detail
    United States
    Publisher
    American Institute of Certified Public Accountants (AICPA)
  • Versioning
    Version
    2017 (with 2022 revised Points of Focus)
    Effective Date
    December 15, 2018
    Issue Date
    2017 (revised Points of Focus 2022)
  • Adoption
    Adoption Model
    Industry Requirement
    Implementation Complexity
    High
  • Official Reference
License Information

License included / downloadable: No

The AICPA publishes the 2017 Trust Services Criteria with revised Points of Focus (2022) as a free download that requires a free AICPA & CIMA account. The text is not included with the platform.

Framework text is licensed by its publisher and is included only where stated above.

Official Resources
AICPA Trust Services Criteria
Describes the framework for evaluating and reporting on system controls.
Guide to SOC 2 Reporting on Controls
Provides guidance on SOC 2 reporting according to the Trust Services Criteria.
AICPA Privacy Management Framework
Outlines principles and criteria for managing privacy risks within the Trust Services Criteria.
Key takeaways
  • The AICPA Trust Services Criteria are the control criteria a CPA applies in SOC 2 and SOC 3 examinations.
  • They cover five categories: security, availability, processing integrity, confidentiality, and privacy, with the common criteria applying to every engagement.
  • The 2017 criteria with Points of Focus revised in 2022 are aligned to the 17 COSO 2013 principles.
  • Nothing is certified: an independent CPA examines the organization and issues a Type 1 or Type 2 report.
  • SmartSuite Compliance Management links each control to the criterion it supports, with testing and evidence in the same record.

Overview

The AICPA 2017 Trust Services Criteria (TSP Section 100), with Points of Focus revised in 2022, are the control criteria a CPA applies when examining a service organization's controls over security, availability, processing integrity, confidentiality, and privacy. They are the evaluation criteria for SOC 2 and SOC 3 reports and are also used in SOC for Cybersecurity and SOC for Supply Chain examinations.

The AICPA's Assurance Services Executive Committee (ASEC) issued the criteria for use in attestation or consulting engagements. They are not a law, and nothing is certified: an independent CPA examines the organization and issues a report. A Type 2 report includes an opinion on operating effectiveness over a specified period and describes the tests performed; a Type 1 report carries no such opinion. The common criteria apply to every engagement, and availability, processing integrity, confidentiality and privacy are added when they are in scope.

Teams implement the criteria by defining the system and the categories in scope, mapping each control to the criterion it supports, and keeping evidence the auditor can test. The Points of Focus guide that work, but the criteria do not require an assessment of whether each point of focus is addressed.

Why does it matter?

A SOC 2 report gives customers independent assurance about the controls behind a service, and the Trust Services Criteria define what the auditor tests.

Key benefits include:

  • One criteria set, five categories

Scope the report to the categories customers need, from security alone to all five; each added category brings only its own criteria on top of the common criteria.

  • Aligned to COSO 2013

The criteria are aligned to the 17 principles of the COSO 2013 Internal Control framework, so control environment, risk assessment and monitoring follow a structure auditors already use.

  • Guidance for design and testing

Points of Focus show the characteristics of each criterion, which helps management design controls and helps the practitioner judge them.

  • Reuse across SOC engagements

The same criteria serve SOC 2, SOC 3, SOC for Cybersecurity and SOC for Supply Chain examinations, so a program built for one can be extended to the others.

  • Defined privacy coverage

The P series sets privacy criteria from notice to monitoring and enforcement for organizations that handle personal information.

How does it work?

The criteria are organized as the common criteria (CC1 to CC9) plus category-specific series: A1 for availability, PI1 for processing integrity, C1 for confidentiality, and P1 to P8 for privacy. CC1 to CC5 follow the COSO principles for control environment, communication and information, risk assessment, monitoring, and control activities. CC6 to CC9 are supplemental criteria for logical and physical access, system operations, change management, and risk mitigation.

An engagement is read against the service organization's commitments and system requirements, and only for the categories in scope. The practitioner may report on any category alone or in combination. In limited cases a criterion that does not apply can be left out; P3.1, for example, does not apply to an organization that does not collect personal information directly from data subjects.

In SmartSuite, Compliance Management links each control to the criterion it supports, with testing and evidence in the same record, and Enterprise Reporting shows status by category and criterion.

Key Elements

  • Common criteria (CC1 to CC9)

Nine series apply to every engagement: control environment, communication and information, risk assessment, monitoring, control activities, logical and physical access, system operations, change management, and risk mitigation. CC1 to CC5 carry the 17 COSO principles, and CC9.2 covers risks from vendors and business partners.

  • Availability (A1.1 to A1.3)

A1.1 covers monitoring and managing processing capacity, A1.2 covers environmental protections, data backup processes and recovery infrastructure, and A1.3 requires testing of recovery plan procedures. The criteria do not set a minimum performance level.

  • Processing integrity (PI1.1 to PI1.5)

Five criteria cover quality information about processing objectives, system inputs, processing, outputs, and stored items, aimed at processing that is complete, valid, accurate, timely, and authorized.

  • Confidentiality (C1.1 and C1.2)

C1.1 requires the entity to identify and maintain confidential information and C1.2 to dispose of it. Confidentiality covers any information designated confidential, while privacy covers only personal information.

  • Privacy (P1 to P8)

Eight groups cover notice, choice and consent, collection, use, retention and disposal, access, disclosure and notification, quality, and monitoring and enforcement. P6.6 addresses notification of breaches and incidents to affected data subjects, regulators, and others.

  • Points of Focus

Each criterion carries Points of Focus, which COSO describes as important characteristics of the criteria. They are guidance and may be customized. The 2022 revision updated the Points of Focus; the criteria remain the 2017 criteria.

What does it cover?

The criteria can be applied across an entire entity, at a subsidiary, division or operating unit, within a function, or to a particular type of information. In a SOC 2 engagement they are applied to a service organization's system and its commitments, and only for the categories included in the scope of the engagement.

What are its objectives?

The criteria exist so that controls can be designed, evaluated, and reported on against a common set of statements.

Evaluate the suitability of design and the operating effectiveness of controls over security, availability, processing integrity, confidentiality, or privacy.

Give management a defined set of criteria, aligned to COSO 2013, to design controls against.

Give users of SOC 2 and SOC 3 reports a common basis for judging a service organization.

Let the scope follow the service, from one category to all five.

Support readiness work as well as attestation, because the criteria may also be used in consulting engagements.

Framework in Context

TSP Section 100 sits beside the AICPA's SOC 2 guide, issued in 2018, which contains performance and reporting guidance for SOC 2 examinations. Organizations commonly map the criteria to ISO/IEC 27001, ISO/IEC 27002, the NIST Cybersecurity Framework, and NIST SP 800-53 to reuse control work across audits.

Common Framework Mappings

SOC 2 control work is often reused across other frameworks; the frameworks below overlap with the Trust Services Criteria.

Mapped frameworks include:

CIS Controls v8.1

ISO 27001:2022

ISO 27002:2022

ISO 27018

ISO 27701

MITRE ATT&CK

NIST CSF 2.0

NIST 800-53 Rev.5

SMARTSUITE

How SmartSuite Supports AICPA TSC 2017 (with 2022 revised POF)

SmartSuite provides the system for managing controls, evidence, mappings, assessments, and reporting.

Use Compliance Management to hold each control against the criterion it supports, with testing and evidence in the same place.

Criteria-to-control library

Record controls against CC1 to CC9 and the A, PI, C and P series for the categories in scope.

Ownership and review cadence

Assign each control an owner and a review schedule so evidence stays current across the examination period.

Evidence and audit trail

Attach evidence to the control it supports, with timestamps, reviewers and a history the auditor can follow.

Control testing

Plan tests, record results and track exceptions, which supports the operating-effectiveness opinion in a Type 2 report.

Vendor and risk alignment

Link risks and third parties to the criteria they affect, including vendor risk under CC9.2, using Third Party Risk Management.

Reporting for auditors and leadership

Use Enterprise Reporting to show status by category and criterion, with open exceptions.

Related frameworks

CIS Controls v8.1

CIS Controls v8.1 is a prioritized set of 18 Controls and 153 Safeguards, in three Implementation Groups, with a new Govern function.

ISO 27001:2022

ISO/IEC 27001:2022 specifies requirements for an information security management system: Clauses 4 to 10, risk treatment, the Statement of Applicability and 93 Annex A controls.

ISO 27002:2022

ISO/IEC 27002:2022 is the reference set of 93 information security controls in four themes, with attributes and implementation guidance, that supports an ISO/IEC 27001 ISMS.

ISO 27018

ISO/IEC 27018:2025 gives guidelines for protecting PII in public clouds acting as PII processors, built on ISO/IEC 27002:2022 with an extended control set.

ISO 27701

ISO/IEC 27701:2025 specifies requirements for a stand-alone privacy information management system (PIMS) for PII controllers and processors, replacing the 2019 edition.

MITRE ATT&CK

MITRE ATT&CK is a free knowledge base of adversary tactics, techniques and sub-techniques from The MITRE Corporation, updated twice a year; the current release is v20.0.

NIST CSF 2.0

NIST CSF 2.0 (CSWP 29, February 26, 2024) is the voluntary cybersecurity framework with six Functions including Govern, 22 Categories, 106 Subcategories, Profiles and Tiers.

NIST 800-53 Rev.5

NIST SP 800-53 Rev. 5 is the NIST catalog of security and privacy controls in 20 families, mandatory for federal systems under OMB A-130 and FISMA; Release 5.2.0 issued August 27, 2025.

FAQ

Frequently Asked Questions For AICPA TSC 2017 (Trust Services Criteria)

The Trust Services Criteria are the control criteria, issued by the AICPA's Assurance Services Executive Committee. A SOC 2 report is the result of a CPA's examination of a service organization's controls against those criteria.

No. The common criteria (the CC series) apply to every engagement and cover security. Availability, processing integrity, confidentiality and privacy are added when they are in scope, each with its own criteria series. The practitioner may report on any category alone or in combination.

A Type 2 report includes an opinion on the operating effectiveness of controls throughout a specified period and describes the tests performed and their results. A Type 1 report addresses the same subject matter but contains no opinion on operating effectiveness and no detailed description of tests.

No. The criteria state that their use does not require an assessment of whether each point of focus is addressed, and management may customize a point of focus. The 2022 revision updated the Points of Focus; the criteria are the 2017 criteria.

No. A SOC 2 report is an attestation: an independent CPA issues an opinion on the controls. Write SOC 2 Type II report or SOC 2 attestation, not SOC 2 certified.

Put this framework to work in SmartSuite

Manage controls, risks, evidence, and audits in one platform designed for modern governance, risk, and compliance.