Outsourcing a Process Does Not Outsource the Control
When a third-party provider holds a SOC 1 or SOC 2 report, many organisations treat that as sufficient evidence that the associated risks are under control. The assumption is understandable. But almost every SOC report also lists Complementary User Entity Controls that the client must implement for the vendor's assurance to hold — and most organisations never read that section. In 2026, three regulatory developments are making this gap impossible to ignore.

