We failed our audit. What happens now?
Failing a SOC 2 audit results in a qualified or adverse opinion, while a CMMC assessment yields a "Did Not Meet" finding. Both outcomes necessitate immediate remediation through a Corrective Action Plan (CAP) and subsequent re-assessment. This can severely impact an organisation's ability to secure new contracts, retain existing business, and maintain stakeholder trust, requiring transparent communication and diligent corrective action to restore compliance.
For SOC 2, a failed audit means the auditor cannot issue an unqualified opinion, instead providing a qualified or adverse opinion, indicating significant control deficiencies or a pervasive failure to meet Trust Services Criteria. The organisation must address these findings, typically through a remediation period, before undergoing a re-audit to achieve an unqualified report. In CMMC, a "Did Not Meet" finding means the organisation has not achieved the required maturity level, preventing it from bidding on or holding contracts requiring that level. While a Plan of Action and Milestones (POA&M) may be permitted for a limited number of minor deficiencies under specific conditions for certain CMMC levels, a "Did Not Meet" outcome generally necessitates full remediation of all identified gaps and a subsequent re-assessment to achieve certification.
The practical consequences extend beyond the audit report itself. A qualified or adverse SOC 2 report can deter potential clients and partners, as it signals elevated risk and a lack of assurance regarding the organisation's control environment. Similarly, a "Did Not Meet" CMMC status directly disqualifies an organisation from Department of Defense (DoD) contracts requiring CMMC certification, leading to loss of revenue and market access. Both scenarios demand a robust, documented Corrective Action Plan (CAP) with clear timelines and accountability. Failure to promptly and effectively remediate can result in sustained reputational damage, contractual penalties, and a significant competitive disadvantage in relevant markets.
Sources
- AICPA, Trust Services Criteria for Security, Availability, Processing Integrity, Confidentiality, and Privacy (TSC)
- Cybersecurity Maturity Model Certification (CMMC) Model, Version 2.0
- CMMC Assessment Process (CAP) Guide