SOC 2 Renewal: Year-Two Cost, Timeline and Changes
As of November 2026, a SOC 2 Type 2 renewal audit arranged through Agency Cybersecurity starts at $2,500 for eligible companies with 1–10 employees and Security-only scope, per Agency's renewal offer. Year two repeats the audit, the penetration test and the evidence work; it does not repeat the first-year build of policies and controls.
Key Takeaways
- •A renewal audit through Agency starts at $2,500 for eligible companies with 1–10 employees and Security-only scope.
- •Year two repeats the audit, the penetration test and the evidence work. The first-year build is not repeated.
- •Start the next observation period the day after the last one ends, so there is no gap.
- •Schedule the penetration test mid-period, with time to fix findings and retest before fieldwork.
What does a SOC 2 renewal cost in year two?
Year two has fewer line items than year one, and the ones that remain recur every year. The table sets each line against year one and shows Agency's published price where one exists.
| Line item | Year one | Year two | Agency's published price | Source |
|---|---|---|---|---|
| Program build: policies, control setup, first evidence library | One-time work | Not repeated | Part of the first-year program | Express Comply pricing |
| Program operation: evidence, access reviews, vendor reviews | Starts partway through the year | Runs all year | Express Comply renews at the then-current flat rate for your headcount band | Express Comply pricing |
| Independent audit | First examination | New examination of the next period | Renewal audit from $2,500 for eligible companies | Renewal offer |
| Penetration test | One test | A new test and a new report | $5,000 fixed for one web app | Pen test pricing |
| GRC platform subscription (varies by vendor and headcount) | Annual subscription | Renews | Not required; Agency runs programs with or without one | No figure |
| Client hours | Highest during the build | 25% to 40% fewer than year one when Agency runs both the program and the audit (Agency's estimate) | Not priced | Agency data |
The $2,500 starting price is promotional and applies to eligible companies with 1–10 employees seeking a Security-only Type 2 renewal with a standard audit scope, per the renewal offer. Larger companies, additional Trust Services Criteria and penetration testing are quoted from your request.
One public record shows how a renewal fee behaves. Kentucky's state IT agency contracted a Type II audit for $49,800 (March 2024 contract list), renewed for two years at $99,600, the same annual fee (July 2024 list), then added $37,200 when it expanded the scope for year two (June 2026 amendment list). The fee held when the scope held and rose when the scope grew. That is a large public agency.
In Agency's opinion of the market, the same renewal scope costs about $8,750 elsewhere, against its own $2,500 offer (renewal offer). Ask your current auditor for the renewal fee in writing before the period ends, and compare it against a quote for the same scope.
When should you start the renewal?
Start before the current observation period ends. A Type 2 report covers a specific period, so the cleanest renewal begins the next observation period the day after the last one ends. The standard does not fix the period's length: the Journal of Accountancy notes "there is no generally accepted minimum useful period that a report needs to cover" (Journal of Accountancy). Buyers fix the rhythm instead.
A 2026 Tennessee state contract, for one, makes its vendor "subject to an annual engagement by a CPA firm" for a SOC 2 Type II examination (Tennessee contract). Three decisions have to be made before your period ends:
- Auditor. Stay or switch. Either way, sign the engagement letter before the new period starts so the auditor agrees to the period and the criteria.
- Scope. List what changed since the last report: new products, infrastructure, vendors and added criteria. Scope changes found during fieldwork are the expensive kind.
- Operating owner. Name who runs the evidence calendar this year. Controls that lapse in month two become exceptions in the report.
Across Agency's renewal audits, the median time from the end of the period to the delivered report is about the same as for a first report. Customers will ask for something in that interval, which is what a bridge letter is for.
What does the auditor re-test in year two?
Everything in scope, for the new period. AICPA & CIMA's SOC overview describes SOC reports as CPA assurance services on a service organization's controls, and each Type 2 examination stands on its own evidence. Expect four things:
- New samples. The auditor selects items from this period's populations: this year's new hires, terminations, changes, incidents and access reviews.
- Follow-up on last year's exceptions. An exception that repeats reads worse than a new one. Fix the cause, then keep proof that the fix held.
- Changes to the system. New infrastructure, a new subservice organization or a reorganized team means an updated system description and sometimes new controls.
- A new management assertion. Management signs for the new period, so the people signing need to know what changed.
What does not repeat is the build. Policies are reviewed and approved again, not rewritten. Controls are operated, not designed. That is why year two is mostly an operating problem; Agency's SOC 2 service covers that operating work for teams that do not want to staff it.
What does a month-by-month renewal calendar look like?
This is an example calendar for a twelve-month period. Move the months to fit your own period dates and adapt the cadence to your controls.
| Month of the period | What happens |
|---|---|
| Month 1 | New period starts the day after the last one ended. Engagement letter signed. Scope changes confirmed. |
| Month 2 | System description updated for new systems, vendors and people. |
| Month 3 | Quarterly access review. Vendor reviews for critical vendors. |
| Month 4 | Risk assessment refreshed. Policies reviewed and approved. |
| Month 5 | Security awareness training. Incident response tabletop exercise. |
| Month 6 | Quarterly access review. Internal check of evidence against last year's exceptions. |
| Month 7 | Annual penetration test ordered and scoped. Test credentials handed over. |
| Month 8 | Penetration test runs. Findings triaged and fixed. |
| Month 9 | Retest of fixed findings. Quarterly access review. Backup and recovery test. |
| Month 10 | Readiness check against the auditor's request list. |
| Month 11 | Remaining gaps closed. Fieldwork dates confirmed. |
| Month 12 | Period ends. The next period begins the following day. Quarterly access review. |
| After the period | Fieldwork, management assertion and report. Bridge letter for customers who ask in the meantime. |
The penetration test sits in months 7 to 9 for a reason. Test too early and the report describes a system that has since changed. Test too late and there is no time to fix findings and retest before fieldwork. A mid-period test, a fix window and a retest give the auditor a report with remediation already shown.
What should you ask for at renewal?
Ask for the audit, the test and the operating work as separate lines, then decide which you need. Agency's renewal offer is built that way: you can request the independent Type 2 audit alone, add a penetration test, or add help running the program, and keep your current GRC platform or none.
Before you sign, get three things in writing: the period and criteria the auditor will examine, the fee for that scope, and the date the report will be delivered. For how often the cycle repeats, see how often a SOC 2 audit is required.
If you are still pricing the first year, start with what SOC 2 costs. For the test itself, penetration testing cost lists the price by scope and a sample statement of work. If the report will lapse before the new one arrives, read how a bridge letter works.
Frequently Asked Questions
How much does a SOC 2 renewal cost?
Is the second year cheaper than the first?
When should we start the renewal?
Does the auditor test everything again?
Do we need a new penetration test for the renewal?
What if our report expires before the new one is issued?
Can we buy only the audit at renewal?

Tyler Carbone
Managing Director and Cofounder
Tyler Carbone is a Managing Director and Cofounder of Agency and one of the industry's leading voices on governance, risk, and compliance. He holds degrees from Harvard and a JD/MBA from the University of Virginia, and previously worked in cybersecurity at Deloitte. Tyler has helped hundreds of companies operate SOC 2, ISO 27001, HIPAA, and GDPR programs.
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