What Are the SOC 2 Password Requirements? (And How to Comply)

Compromised passwords are still a leading cause of data breaches. And as you work towards SOC 2, you’ll need to have clear policies in place to demonstrate how your organization approaches secure password management.

But, if you are looking for the exact paragraph in the AICPA (American Institute of Certified Public Accountants) handbook that says "passwords must be 12 characters long," you are going to be disappointed. It doesn't exist.

Instead, it mandates that organizations have password management policies. To help you figure out what this means for your organization, we’ll be diving into SOC 2 password requirements and best practices for password management.

What Are the SOC 2 Password Requirements?

SOC 2 is based on the five Trust Services Criteria (TCS): Security, Availability, Processing Integrity, Confidentiality, and Privacy. Security (also known as the Common Criteria) is the only mandatory criteria that must be included in all audits.

The Security criteria covers SOC 2 password requirements under Common Criteria 6 (CC6) of the Trust Services Criteria. Specifically:

• CC6.1 (Logical access security): You must implement logical access security measures to protect information and assets to protect them from security events.
• CC6.2 (User registration and credentials): Before anyone gets access to your systems, they must be registered and authorized to have access and only after authorization are they allowed to enter your systems.
• CC6.3 (Access based on roles / least privilege): Access to data, software, and systems has to be authorized based on roles and responsibilities within your organization.

Unlike PCI-DSS, which specifies concrete values (for example, a defined minimum password length in its requirements), SOC 2 is less prescriptive and leaves it to your organization to design and implement controls that meet the Trust Services Criteria.

Why SOC 2 Password Requirements Matter

SOC 2 is all about showcasing your security posture proving to partners and prospects that you take data security seriously. Passwords are one of the biggest vulnerabilities any system can have and if you don’t have the right policies and procedures in place, your entire IT system could be at risk.

Here’s why password requirements are an important part of your cybersecurity processes:

• Avoid Unauthorized Access: The most obvious answer, but strong passwords protect your systems against unauthorized access helping you to mitigate the risk of external threats gaining access to key systems and data.
• Trust: Security is all about trust. If you have strong, secure password requirements in place it’ll help build trust with key partners and stakeholders.
• Incident Response: When you have strong password practices in place it becomes easier to identify where brute force attacks or other types of attacks may have been attempted. For example, if a user account is locked out for too many unsuccessful login attempts, you’ll be able to dig deeper to see if it was down to genuine user error or something that needs deeper exploration.

Key Considerations for SOC 2 Password Security

While SOC 2 doesn't mandate specific settings, here are some recommendations on how you can meet the needed criteria:

Minimum Password Length and Complexity

Your password length has a huge impact on its security and effectiveness. The shorter a password is, the easier it is to figure out via brute force attacks (automated scripts that try thousands of passwords a second). Generally, you should be looking for a minimum of 12 characters for passwords.

Ideally, passwords should be as random as possible (not using complete words). I’m sure you’ve seen those messages saying “Your password needs one lowercase letter, one uppercase, one special character.” The reason password complexity matters is that the more random your password, the tougher it is to figure out via brute force attacks.

Tip: Encourage (or mandate) the use of password managers to help your team create and manage unique, strong passwords across all accounts.

Multi-Factor Authentication (MFA)

MFA involves using additional layers of authentication on top of a password to allow access to a system. Think: time-sensitive codes sent to a registered/approved device or biometric verification. Each additional layer strengthens your access control, making your system less vulnerable.

Account Lockout

If a hacker is trying to access your systems, they won’t often give up after one failed attempt. But you can help to stop brute-force attacks by locking accounts after a set number of failed attempts to login (typically 3-5).

Password Cycling and Reuse

Most service organizations have rules in place to avoid password reuse and recycling as it can reduce your organization’s overall security. Some organizations enforce regular password updates through automatic triggers every 3-6 months so no-one on your team has the same password for too long. But this isn’t always recommended unless there's an indication of compromised credentials.

User Access Reviews

Ensure your policies include regular reviews of who can access systems, databases, and apps to ensure only people who require access for their day-to-day activities can get in. Every quarter (at least), look at a list of everyone who has access to your critical systems (AWS, GitHub, Production DB) and verify they still need it.

In general, it's best practice to take a principle of least privilege approach, meaning that every user on your system is given the minimum privilege and access necessary to do their jobs. So no-one should have access to data or systems that aren’t essential for their roles.

Offboarding and Termination

Make sure you have a clear process in place for any employees leaving the business. This should cover how you close down their accounts and ensure they no longer have access to your systems.

How Workstreet Can Help You Meet SOC 2 Password Requirements

Reading a list of requirements is easy. Configuring your entire infrastructure to meet them (without breaking your engineering workflow) is hard.

Working with Workstreet's SOC 2 implementation service, you can achieve SOC 2 compliance faster than ever. From helping implement security controls and evidence collection automation to prepping for your SOC 2 audit, we guide you through every step and have helped hundreds of high-growth startups achieve compliance. Book a call with our security experts to learn more about how we can help.

SOC 2 Password Requirement FAQs

What Are the SOC 2 Password Requirements?

SOC 2 itself doesn't mandate specific password lengths or complexity rules. Instead, it requires that organizations have logical access controls appropriate to each user risk profile in line with CC6.1, CC6.2, and CC6.3.

What Password Length Should We Use?

While SOC 2 doesn’t mandate specific password lengths, many organizations align with guidance such as NIST SP 800-63B, which requires a minimum of at least 8 characters and encourages longer passwords. Many companies will set minimums of 12-15 characters. Using a password manager tool can help you teams to keep on top of longer, more complex passwords.

Is Multi-Factor Authentication (MFA) Required?

Again, like password length, MFA isn't explicitly required fro SOC 2, but it is increasingly expected by auditors as a standard security practice. If you are accessing production systems, admin accounts, or sensitive data without MFA, you will likely face significant pushback or a qualified report.

How Often Should Passwords Be Rotated?

Guidance has changed. NIST now recommends against forcing periodic password changes unless there’s evidence of compromise. Many SOC 2 auditors accept this approach when it’s backed by strong MFA and good monitoring. However, some more auditors  may still expect rotation and/or mandated password expiration for privileged or shared accounts, so it’s worth clarifying expectations during your readiness assessment.

Do We Need Different Password Policies for Different User Types?

Yes, for SOC 2 you should implement stronger controls for privileged accounts (admins, developers with prod access). This might mean longer passwords, stricter MFA settings, and more restrictive session timeouts compared to a standard sales user. Documenting a tiered approach is common and recommended.

How Should We Handle Password Storage?

If you store passwords (e.g., for your app's users), auditors will ask how they are hashed. You should be using modern hashing algorithms like bcrypt, scrypt, or Argon2 and not storing passwords in plain text. Legacy methods like MD5 or SHA-1 are unacceptable. Salting is expected as standard practice.

Do We Need Account Lockout Policies?

Yes, most auditors expect controls against brute force attacks. This typically means locking accounts or introducing exponential delays after a certain number of failed attempts.

Do Contractors and Vendors Need to Follow the Same Policies?

Yes, anyone accessing systems in scope needs to comply with your access control policies. This should be documented in your vendor agreements and enforced consistently.

How Do We Prove Compliance During an Audit?

Common evidence includes policy documents, system configuration screenshots (from IdP, Cloud Provider, Version Control), access control matrices, user access reviews, and logs showing enforcement of lockout policies and password changes.