
Industries Served and Compliance Standards We Support
Learn how PCI-DSS, SOC 2, and HIPAA shape penetration testing requirements across sectors. A practical guide to scoping compliance-led pentests.
PCI-DSS, HIPAA, and SOC 2 are the compliance frameworks most frequently supported by penetration testing engagements, each requiring evidence that security controls are effective against real-world attack techniques. These three standards cover different sectors and different data types, but they share one demand: proof that a system has been tested by someone trying to break it, not just scanned by a tool looking for known flaws.
The frameworks are not interchangeable and they are not mutually exclusive. A healthcare SaaS platform that processes card payments for patient billing may need to satisfy all three at once, and the pentesting engagement has to be scoped to meet the strictest overlapping requirement rather than running three separate, duplicated tests.
| Standard | What it regulates | Who it applies to | Pentest requirement | Typical cadence |
|---|---|---|---|---|
| PCI-DSS | Cardholder data environment (CDE) | Any organisation storing, processing, or transmitting card data | Explicit (Requirement 11.4) | Annual pentest, quarterly vulnerability scans |
| SOC 2 | Trust Services Criteria across the whole in-scope system | SaaS, technology, and service organisations reporting to customers/partners | Implied (CC7.2, CC7.3) | Typically annual, or after significant system change |
| HIPAA | ePHI and systems handling protected health information | US healthcare providers, health plans, and their business associates (and vendors serving them) | Implied (Security Rule technical evaluation) | Periodic, based on documented risk analysis |
PCI-DSS is the most prescriptive of the three: it names penetration testing directly and sets a fixed annual cycle, scoped tightly to the CDE. SOC 2 never uses the word "pentest" in its criteria, but auditors expect it as the practical way to evidence that monitoring and detection controls (CC7.2, CC7.3) actually work. HIPAA's Security Rule asks for periodic technical evaluation without naming a method, which is why penetration testing has become the accepted way to demonstrate that technical safeguards hold up under attack rather than just on paper.
Industries We Serve and the Standards That Apply to Them
The standard that applies to an organisation is determined by the data it handles, not its size or sector label. A retailer taking card payments online falls under PCI-DSS regardless of turnover, while a two-person health tech startup handling patient records can face the same HIPAA scrutiny as a large hospital trust.
| Industry | Standards typically applicable | Data types driving compliance | Pentesting focus areas |
|---|---|---|---|
| Financial services | PCI-DSS, FCA expectations, SOC 2 (for fintech vendors) | Cardholder data, transaction records, account credentials | API security, payment flows, segmentation controls |
| Healthcare and health tech | HIPAA (US patients), NHS DSPT context (UK providers), SOC 2 (SaaS platforms) | PHI/ePHI, patient identifiers, clinical records | EHR system integrations, third-party data exchanges, access controls |
| SaaS and technology | SOC 2, ISO 27001 adjacency | Customer personal data, tenant configuration, credentials | Multi-tenancy isolation, authentication, cloud configuration |
| Retail and e-commerce | PCI-DSS | Cardholder data, order and customer records | Checkout flows, payment gateway integrations, web application layer |
| Legal | SRA expectations, client confidentiality obligations | Privileged client data, case files | Document management systems, email security, access segregation |
| Public sector | NCSC guidance, sector-specific frameworks | Citizen data, operational systems | External perimeter, internal segmentation, legacy system exposure |
These pairings overlap in practice more often than they diverge. A fintech payment processor commonly needs PCI-DSS alongside SOC 2 because its enterprise customers demand a Trust Services report on top of card network requirements. A health tech SaaS vendor often needs HIPAA for its US clients and SOC 2 for everyone else. UK organisations should also weigh ICO expectations under UK GDPR, FCA rules where financial services apply, and NCSC guidance for public sector and critical national infrastructure work, alongside whichever of the three core standards applies.
The same standard tests differently depending on the industry it sits in. A pentest supporting PCI-DSS for a payment processor has to prioritise API security and transaction flow integrity, because that is where card data actually moves. A pentest supporting HIPAA for a hospital system has to account for EHR complexity and the web of third-party integrations that typically surround clinical software, because that is where PHI is most often exposed. Applying the same generic scope to both would satisfy neither auditor.
What Each Compliance Standard Requires from Your Pentest
Each standard sets a different bar for what counts as sufficient evidence, and knowing that bar is what separates a useful proposal from a generic one.
PCI-DSS
PCI-DSS Requirement 11.4 requires an annual penetration test of the cardholder data environment, covering both network-layer and application-layer testing, alongside separate quarterly vulnerability scans.
Requirement 11.4.1 specifically calls for testing at both layers, and organisations using network segmentation to reduce PCI scope must also test that the segmentation controls actually hold, since a failed segmentation test can pull previously out-of-scope systems back into the CDE.
Both internal and external testing are expected, since the CDE typically has exposure from both directions.
SOC 2
SOC 2 maps pentesting evidence to specific Trust Services Criteria, most directly CC7.2 (monitoring system components for anomalies) and CC7.3 (responding to detected anomalies), with CC8.1 relevant where change management and malicious code protection are in scope.
The pentest report itself becomes supporting evidence within the SOC 2 report's control testing narrative, which means the report has to speak the language of the criteria it is supporting rather than reading as a standalone technical document.
HIPAA
The HIPAA Security Rule's technical safeguards set the scope:
- Access control (45 CFR 164.312(a))
- Audit controls (164.312(b))
- Integrity controls (164.312(c))
- Transmission security (164.312(e))
Periodic evaluation is not defined by a fixed number of months; it is risk-based, meaning the frequency should be justified and documented within the organisation's own risk analysis rather than left to guesswork.
What the Report Must Include
Across all three standards, the report itself needs to include:
- An executive summary for non-technical stakeholders
- A clear methodology section
- Findings with severity ratings
- Evidence that vulnerabilities were actually exploited, not just flagged
- Remediation guidance
- A compliance mapping section tying findings back to the specific requirement they affect
What auditors increasingly want to see is not just that a test happened, but that findings were remediated and then verified through a retest. A findings list without a documented retest cycle is the difference between passing an audit and struggling to defend one when challenged.
Vulnerability Scans vs. Penetration Tests: What Each Standard Expects
A vulnerability scan is an automated process that checks systems against a database of known weaknesses and produces a list of potential issues; a penetration test combines automated tooling with manual technique to determine whether those issues are actually exploitable and what the resulting business impact would be.
Confusing the two is the single most common compliance mistake organisations make, and it is the fastest way to fail an audit that expected the latter.
| Factor | Vulnerability scan | Penetration test |
|---|---|---|
| Method | Fully automated | Automated tooling plus manual, human-led exploitation |
| False positive rate | Higher, unverified findings | Lower, findings confirmed through exploitation |
| Evidence depth | List of potential issues | Proof of exploitability and business impact |
| Auditor perception | Baseline hygiene evidence | Strong control-effectiveness evidence |
| Compliance value | Meets quarterly scan requirements (PCI) | Meets annual/periodic test requirements across all three standards |
PCI-DSS is explicit that both are required and neither substitutes for the other: quarterly scans under Requirement 11.4.2 and an annual pentest under 11.4.1.
SOC 2 and HIPAA do not name scans versus tests directly, but a scan alone will not satisfy an auditor looking for evidence of control effectiveness, because a scan cannot show what an attacker could actually achieve.
If the current testing programme consists only of scans, that is the gap in the compliance posture, not a supplementary activity to build on later.
How Our Compliance-Led Pentesting Engagements Work
A compliance-grade engagement is structured around evidence production at every stage, not just a technical exercise that gets written up afterwards. The stages below map each milestone to the compliance output it generates.
- Scoping. The compliance boundary is defined first: which systems hold cardholder data, ePHI, or in-scope SOC 2 infrastructure, backed by asset inventories and network diagrams. Output: a documented scope agreement that an auditor can cross-reference against the compliance boundary.
- Pre-engagement documentation gathering. Previous scan reports, prior pentest findings, and system architecture are reviewed before testing starts. Output: a test plan that avoids duplicating work already covered by existing scans.
- Testing. External, internal, and application-layer testing is carried out as required by the applicable standard, whether that is a PCI network test focused on the CDE or a HIPAA-relevant web application test covering ePHI-handling systems. Output: interim findings as issues are identified.
- Reporting. Findings are written up with severity ratings, exploitation evidence, and business impact, then cross-referenced against the specific requirement or criterion they affect. Output: the final report with compliance mapping.
- Remediation support. Guidance is provided on fixing each finding, prioritised by severity and exploitability rather than a flat list. Output: a remediation roadmap the internal team can action.
- Retesting and verification. Fixed issues are retested to confirm the vulnerability no longer exists. Output: a retest certificate or verification statement auditors can rely on as closure evidence.
Timelines vary with scope and complexity, but a standard single-application or single-network engagement typically runs two to four weeks from scoping to final report, with more complex, multi-system environments taking longer.
Organisations needing PCI-DSS coverage for their cardholder data environment are typically pointed toward a dedicated PCI network testing engagement, while those with HIPAA obligations around patient-facing applications are usually better served by a HIPAA penetration testing engagement scoped specifically to ePHI-handling systems, and SaaS providers pursuing a Trust Services report are typically routed to a dedicated SOC 2 penetration testing engagement covering the full in-scope system.
The report structure itself is built to serve two readers at once: the security team needs the technical findings, and the auditor needs the compliance mapping, without either side having to translate or reformat the other's version.
What You Receive: Building Your Compliance Evidence Package
The tangible output of a compliance-led engagement is an evidence package, not just a test result, and knowing what is in it before signing off is what lets internal stakeholders and external auditors both sign off with confidence.
- Penetration test report, including an executive summary for management and technical appendices for engineering teams
- Compliance mapping document, cross-referencing each finding to the specific PCI-DSS requirement, SOC 2 TSC criterion, or HIPAA Security Rule safeguard it affects
- Remediation roadmap, with fixes prioritised by severity and exploitability rather than listed alphabetically or by discovery order
- Retest verification report, confirming which findings were fixed and closed
- Letter of engagement and scope confirmation, documenting exactly what was and was not tested
The compliance mapping document is often the most time-saving deliverable in the package, because it does the translation work an internal compliance team would otherwise have to do manually, line by line, before an audit.
Sensitive material generated during the engagement, including network diagrams, credentials, and findings, is handled under NDA and stored securely throughout and after the test.
Audit support typically includes availability to answer auditor questions and clarify report content during the evidence review period, though no engagement can guarantee an audit outcome, since that ultimately depends on how thoroughly findings are remediated.
How to Evaluate a Compliance-Focused Pentest Proposal
A proposal is worth engaging with if it references your specific compliance standard by requirement number, not just the word "security." Generic proposals that talk about "security testing" without naming PCI 11.4.1, SOC 2 CC7.2, or the relevant HIPAA safeguard are a signal the provider is not scoping for compliance evidence at all.
Key Questions to Ask Any Provider
- How do you map findings to my specific compliance standard?
- Do you have direct experience in my industry and its typical data types?
- What does the report include: executive summary, compliance mapping, remediation guidance?
- Is a retest cycle included, or is it a separate cost?
- What is the testing methodology, and what is the manual-versus-automated mix?
- Do you provide support during the auditor's evidence review period?
- What certifications do the testers hold, such as CREST or OSCP?
Red Flags in a Proposal
Red flags include scopes that never mention the specific standard by name, no clear list of evidence deliverables, no remediation support built into the engagement, no retest offering, and testers without recognised industry certifications.
One practical check that most buyers overlook: ask the provider to share a redacted sample report before signing anything. A compliance-focused provider will produce one readily, and it will show immediately whether findings are mapped to standards and whether the structure is built for auditor consumption rather than just an internal read.
Frequently Asked Questions
Does SOC 2 require a penetration test?
SOC 2 does not name penetration testing explicitly, but the Trust Services Criteria, particularly CC7.2 and CC7.3, require evidence that security controls detect and respond to attacks. Pentesting is the accepted, practical way auditors expect that evidence to be produced. Most organisations pursuing a SOC 2 report include an annual pentest as standard practice.
What are the 12 PCI-DSS requirements and which ones involve penetration testing?
PCI-DSS has 12 requirements spanning network security, access control, data protection, monitoring, and policy management. Requirement 11.4 is the one that directly involves penetration testing, requiring an annual test of the cardholder data environment alongside quarterly vulnerability scans under 11.4.2. Segmentation testing also falls under this requirement where segmentation is used to reduce PCI scope.
How often do we need to conduct compliance penetration testing?
PCI-DSS requires an annual penetration test plus quarterly vulnerability scans, SOC 2 is typically tested annually or after significant system changes, and HIPAA requires periodic testing based on the organisation's own documented risk analysis.
Check your specific audit or renewal cycle to confirm timing, since testing too close to a deadline leaves no time for remediation and retesting.
Is PCI-DSS compliance legally required in the UK?
PCI-DSS is a contractual obligation imposed by card networks such as Visa and Mastercard rather than a UK statute. Non-compliance can still result in fines, increased transaction fees, or loss of card-processing privileges from your payment provider. In the event of a breach, non-compliance can also increase legal and regulatory exposure under UK GDPR.
What is the difference between a vulnerability scan and a penetration test?
A vulnerability scan is automated and produces a list of potential issues, while a penetration test uses manual technique to prove whether those issues are actually exploitable and what the business impact would be. PCI-DSS requires both at different cadences: quarterly scans and an annual test. SOC 2 and HIPAA do not name scans directly, but pentesting carries far more weight as audit evidence because it demonstrates impact rather than presence.
How should we scope a pentest for multiple compliance standards?
Scope to the strictest overlapping requirement rather than running separate tests for each standard: include the full cardholder data environment for PCI-DSS, the entire in-scope system for SOC 2, and every system touching ePHI for HIPAA.
A single well-scoped engagement covering all applicable boundaries avoids duplicated cost and produces one compliance mapping document referencing every relevant standard. Confirm with your provider before testing begins that the scope agreement explicitly lists which standards each in-scope asset is being tested against.
Need a pentest scoped to your compliance standard?
Talk to our London-based team about mapping your engagement to PCI-DSS, SOC 2, or HIPAA — with a report your auditor can accept without rework.