If your company handles health data, you’ve probably felt pulled in two directions at once. A hospital’s procurement team wants your SOC 2 report before they’ll sign. Your legal counsel keeps pointing at HIPAA. And somewhere in a sales thread, a prospect asked whether your SOC 2 attestation “covers” HIPAA, as if one document could stand in for the other.
It can’t. SOC 2 and HIPAA are separate frameworks with separate goals, and treating either as a substitute for the other tends to end in a failed vendor review or, worse, lost opportunities. They aren’t strangers, though. The two overlap heavily on one point: proving that someone actually tried to break your systems and wrote down what they found.
That point is penetration testing. Federal regulators have signaled that hands-on security testing is moving from good practice toward expectation, while SOC 2 auditors already treat a pentest as standard evidence. In this guide we walk you through where the two frameworks diverge and where they meet, and then show you why a single well-scoped manual pentest can carry weight under both.
SOC 2 and HIPAA aren’t the same thing
People blur these two frameworks because both deal with protecting sensitive information, and both produce paperwork that buyers ask for. In reality, they answer different questions and come from different places. We briefly explain both below.
SOC 2
SOC 2 is a voluntary attestation created by the American Institute of CPAs. An independent auditor examines your controls against the Trust Services Criteria, which cover security along with optional categories like availability and confidentiality. A Type 1 report captures a single moment in time, while a Type 2 report watches your controls operate across a window of several months. No law requires SOC 2, but customers do. For a fuller breakdown of the criteria and report types, our explainer on what SOC 2 attestation covers goes deeper.
HIPAA
HIPAA is federal law. Its Privacy Rule governs how protected health information gets used and shared, and its Security Rule sets safeguards for the electronic version of that data, known as ePHI. The law applies to covered entities like providers and health plans, and it reaches business associates too, meaning any vendor that touches ePHI on a covered entity’s behalf. No official “HIPAA certified” stamp exists. You either meet the obligations or you don’t, and the government can penalize you when you don’t.
Where the overlap ends
Because both frameworks revolve around data protection, teams assume a report for one satisfies the other. A SOC 2 report is not a HIPAA attestation, and meeting HIPAA does not hand you a SOC 2 report. An auditor’s SOC 2 opinion says nothing about whether you’ve signed business associate agreements or honored patient access rights. HIPAA compliance, in turn, says nothing about the availability or confidentiality commitments a SOC 2 buyer cares about. The two reinforce each other, yet neither fills in for the other.
So you’re looking at two obligations with different origins and different proof. The next question is why so many companies find themselves owing both at once.
Why health-tech companies end up needing both
For a growing set of companies, HIPAA and SOC 2 aren’t a choice between frameworks. They act as two gates on the same road, and you have to clear both to sell into healthcare while staying on the right side of the law.
HIPAA is the legal floor
If your product stores or transmits ePHI, HIPAA already applies to you. That holds whether you’re the provider generating the records or the analytics vendor crunching them downstream. Business associate agreements push the obligations down the supply chain, so a SaaS company three steps removed from the patient can still carry direct liability. You don’t get to opt out of the floor.
SOC 2 is the commercial key
HIPAA keeps you legal. SOC 2 helps you close. Healthcare buyers run rigorous vendor security reviews, and a clean Type 2 report short-circuits weeks of questionnaires. Many procurement teams won’t even schedule a call until they’ve seen one. For software vendors selling into regulated markets, the report works as a trust shortcut, which is why so many prioritize it early. Our guide to SOC 2 for software vendors covers that motion in detail.
The business-associate squeeze
Put those forces together and health-tech vendors feel pressure from both sides. Regulators expect HIPAA safeguards because you handle ePHI. Customers expect SOC 2 because that’s how they vet vendors. Skip HIPAA and you risk enforcement; stall on SOC 2 and you stall in procurement. Companies that plan for both early tend to spend far less than those scrambling to bolt on one after the other.
Owing both frameworks sounds like double the work. On the security-testing side, it mostly isn’t, because the two lean on the same underlying evidence.
Where the two frameworks overlap on security testing
Compliance work spans policies, training, access reviews, and plenty more. Security testing is the slice where SOC 2 and HIPAA converge most tightly, so it’s worth understanding what each one expects before you scope any work.
What HIPAA expects today
The current Security Rule never uses the word pentest. Instead it requires a risk analysis under 45 CFR 164.308(a)(1)(ii)(A) and a periodic evaluation of your safeguards under 164.308(a)(8). In practice, you can’t credibly analyze risk to ePHI or evaluate your defenses without testing them, and a penetration test is the most direct way to do that. Whether the law strictly demands one comes up constantly, and our piece on whether HIPAA mandates a pentest unpacks the nuance.
What the proposed Security Rule would change
In December 2024, the Office for Civil Rights issued a Notice of Proposed Rulemaking to modernize the Security Rule, published in the Federal Register in early January 2025. Among other changes, it proposes a new vulnerability-management standard that would call for automated vulnerability scans at least every six months and a penetration test at least once every twelve. Keep in mind that this rule remains proposed rather than final, and its requirements and timing could still change before anything takes effect. Even so, the direction reads clearly: regulators want hands-on testing on a fixed cadence.
What SOC 2 auditors expect
While the Trust Services Criteria don’t script a specific test, auditors routinely look for a penetration test as evidence that you monitor for and detect vulnerabilities. A recent, well-documented pentest report has become one of the most reliable ways to satisfy that expectation. Our how pentests support SOC 2 guide shows exactly where the report fits inside an audit.
Both frameworks point at the same activity from slightly different angles. The catch is that not every pentest counts, and the difference comes down to whether a human did the work.
The one control you can’t automate
Scanners are fast and cheap, and they’re genuinely useful. They also miss the flaws that put patient records at real risk, which is why leaning on automation alone leaves gaps that both auditors and regulators have learned to look for.
Automated scans versus manual testing
A vulnerability scanner compares your systems against a database of known issues and flags what matches. That helps you catch missing patches and obvious misconfigurations. But a scanner follows a script. It won’t chain small weaknesses into a real attack path or reason about how an intruder would actually move through your environment. Manual testing does. That distinction shows up constantly in audit evidence, and we break it down in scans against hands-on testing.
Why bundled “pentests” fall short
Plenty of compliance-oriented tools now advertise a pentest as part of the package. Read the fine print and many turn out to be automated scans wearing a nicer label. Auditors have caught on, and the scrutiny regulators bring to a breach investigation is even less forgiving. When cross-tenant isolation or patient-record access control is on the line, a script-driven scan won’t probe the way a skilled tester will. We dig into where automated coverage breaks down and why that gap matters.
The ePHI risks a scanner won’t find
Health applications carry a specific class of danger. Picture a patient portal where changing a single ID in a URL surfaces someone else’s records, or a multi-tenant platform where one clinic can quietly reach another’s data. Those are access-control and business-logic failures, and automated tooling rarely catches them because they aren’t known vulnerabilities. They’re logic that works exactly as coded while exposing data it shouldn’t. Manual testing built for healthcare targets these directly, as our testing that targets patient data guide describes.
Once you accept that the testing has to be hands-on, the efficiency argument comes into focus. One serious pentest can feed both compliance efforts at the same time.
One pentest, evidence for both frameworks
Because SOC 2 and HIPAA both value the same kind of hands-on testing, a single engagement, scoped thoughtfully, can produce evidence that serves both. You plan and test once, then report in a way that speaks to auditors and business-associate obligations alike.
Scoping to cover both at once
Start with where ePHI actually lives and moves: the web app, the APIs behind it, the cloud infrastructure hosting it, and the identity layer controlling access. A pentest scoped around those systems checks the boxes SOC 2 auditors care about while probing the exact assets HIPAA’s risk analysis exists to protect. Define the scope with both frameworks in mind and you avoid paying for two separate engagements.
What the report has to contain
The deliverable is what auditors and partners actually read, so it has to do more than list findings. It needs clear methodology, severity ratings, evidence of what got tested, and a remediation trail showing you fixed what mattered. A report built for compliance review reads very differently from a raw tool dump, and our walkthrough of a report auditors accept lays out the anatomy.
Getting the cadence right
Point-in-time testing satisfies the letter of an annual requirement, but healthcare systems change constantly, and a test from ten months ago says little about the feature you shipped last week. SOC 2 Type 2 rewards continuous monitoring, and the proposed HIPAA cadence leans annual with more frequent testing when risk warrants. Pairing a yearly deep engagement with ongoing coverage keeps you defensible between audits, an approach we cover in keeping coverage between audits.
Handled well, compliance testing stops feeling like a tax and starts doubling as genuine security work. That outcome is what CYBRI is built to deliver.
How CYBRI tests for SOC 2 and HIPAA
Plenty of providers can run a scan and hand you a PDF. Fewer approach healthcare testing as a manual, human-led discipline, which is the standard both frameworks increasingly demand.
CYBRI leads with manual testing performed by senior pentesters who hold certifications like OSCP, OSWE, GIAC, and CISSP. The team scopes each engagement around the ePHI systems that matter for HIPAA and the controls SOC 2 auditors examine, then delivers a report structured for compliance review rather than a wall of scanner output.
Testing doesn’t have to stop when the report ships. Through our Blue Box platform, you track findings, retests, and remediation in one place, while Cybri’s proprietary scanner provides native continuous coverage across your external attack surface, cloud configuration, and CI/CD pipeline between deeper manual engagements. If you’re weighing options, our guide compares SOC 2 testing providers.
Bringing SOC 2 and HIPAA together
SOC 2 and HIPAA will keep showing up together for any company building in healthcare. One is the law you have to meet; the other is the report your customers demand. They don’t replace each other, but they do share a spine, and penetration testing is it. Regulators keep moving toward requiring it outright, and auditors already expect it, so investing in serious manual testing now pays down both obligations at once and leaves your systems genuinely harder to breach. When you’re ready to scope an engagement that satisfies both, reach out to the CYBRI team to talk it through.
