When do the revised AICPA criteria apply to your audit?
The AICPA writes the SOC standards. On 28 October 2026 it published an exposure draft of revised Trust Services Criteria. The AICPA news release says it would apply to engagements beginning on or after 31 December 2027. Early adoption is permitted. A public comment period runs through 15 January 2027, so nothing is final yet.
The draft adds focus areas on AI governance, model monitoring, prompt manipulation, data poisoning, and training-data management. Until it is final, the 2017 criteria with revised 2022 points of focus still apply. The start date of your engagement picks the rulebook. An engagement that begins in 2027 uses the current criteria. One that begins on or after December 31, 2027 would use the revised set, if the AICPA approves it.
How much does SOC 2 Type 1 vs Type 2 cost in total?
The Drata 2026 cost guide puts a small to midsize Type 1 audit at $7,500 to $15,000. A large organization pays up to $60,000 for a Type 1. The same guide prices a Type 2 at $12,000 to $20,000 for a small to midsize company. A large organization pays $30,000 to $100,000 or more.
The SOC 2 Type 1 vs Type 2 fee gap is the first number to sort out. The Truvo 2026 guide puts a Type 2 at 30 to 50 percent above a Type 1. The audit fee is only part of first-year spend. Truvo puts first-year totals from $25,000 for a small startup to over $200,000 for a large enterprise. Most startups spend $25,000 to $50,000 in year one. Illustrative Type 2 totals run about $28,000 for 25 people and $75,000 for 100 people. A 500-plus-person enterprise sees $180,000 or more.
Our guide to SOC 2 compliance cost 2026 covers the other line items in that budget. Tooling and platform bills sit on top of the audit fee. Read the Vanta pricing 2026 cost per employee and Secureframe pricing 2026 compliance cost numbers first.
| Cost line | Type 1 | Type 2 |
|---|
| Audit fee, small to midsize company | $7,500 to $15,000 | $12,000 to $20,000 |
| Audit fee, large organization | Up to $60,000 | $30,000 to $100,000 or more |
| Relative price | Baseline | 30 to 50 percent higher |
| Calendar time | 1 to 3 months of prep, then 5 weeks to 2 months of audit and report | 1 to 3 months of prep, a 3 to 12 month window, 2 to 5 weeks of audit, 2 to 6 weeks of report |
| Certificate issued | No, an attestation with an auditor opinion | No, an attestation with an auditor opinion |
Which SOC 2 report do enterprise buyers actually accept?
Most customers and prospects who know SOC 2 ask for a Type 2 report. Secureframe notes that many prospects now reject a Type 1 outright. A Type 1 can be finished in a matter of weeks. A Type 2 can take 12 months to complete. That gap is why a dated deal sometimes justifies a Type 1. It is also why a Type 1 rarely satisfies a procurement review.
The report itself has no formal expiry date. Enterprise buyers treat a Type 2 as current for 12 months. They count from the end of the observation window, not the report date. That date decides when a renewal has to start.
A bridge letter covers a short gap. It is a temporary self-attestation that you draft and sign. The CPA firm does not sign it. The stated industry standard is no more than three months. Most enterprise buyers accept one for three months. Past six months, a bridge letter is unlikely to be accepted. Start a renewal around the six-month mark.
What should you do next?
The customer's own wording settles most of the SOC 2 Type 1 vs Type 2 decision. If they named a Type 2, a Type 1 will not close the deal. If the deadline is weeks away, a Type 1 can hold the process. A Type 2 window runs alongside it.
Ask for two quotes before you sign. One covers a single Type 2 audit. The other covers a combined Type 1 and Type 2 scope. Compare both totals against the two-audit path. Check whether the customer accepts a different standard. Our ISO 27001 certification cost for small businesses in 2026 guide covers that path.
If you want the current criteria, start your engagement before 31 December 2027. If you already run AI features, you can adopt the revised set early once it is final.
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Fazlur Rahman
