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Compliance · Feb 12, 2026 · 1 min read

SOC 2 + AI: governance for clinical agent systems

SOC 2's controls were written before LLMs existed, but they map cleanly onto agent architectures if you know how to translate. Here's the mapping — and the documents you should have on file before the auditor walks in.

SOC 2's Trust Services Criteria predate LLMs by more than a decade. The controls were written for a different shape of system — but they apply, with careful translation, to AI workflows. The work is mostly translation, not invention.

This post is a sketch. The full mapping (CC1–CC9, plus the relevant Privacy and Confidentiality criteria) is the kind of artifact I help clients build during a Build engagement. The short version:

  • CC6 (Logical access) — your AI orchestration layer is access-controlled like every other production system. Federated where possible. RBAC mapped to clinical/admin roles. Logged.
  • CC7 (System operations) — you have monitoring, drift detection, incident response, and change management on prompts and skill files specifically — not just on code.
  • CC8 (Change management) — prompt changes go through PR review with a clinical or domain reviewer named on changes that affect output behavior.
  • A1 / Confidentiality — the BAA chain. PHI minimization at the prompt level. Encryption at rest and in transit, including for the inference path.

If your team is in the lead-up to a SOC 2 audit and the AI surface is making you nervous, book a call. The translation is doable. The right time to start is before the auditor's first meeting, not after.

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