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Control Institute
Category: Trust Services Criteria

Illustrative Controls

Also known as: Illustrative Control Objectives, Illustrative Controls Examples, Example Controls
Simply put

Illustrative controls are example controls or control objectives provided in guidance materials to show what a control might look like in practice. They are meant to help management and auditors understand and design their own controls, but they are samples rather than a required checklist. Each organization still needs to select and tailor controls to fit its own systems, risks, and audit scope.

Formal definition

Illustrative controls are non-authoritative sample control statements or control objectives published in professional guidance (for example, AICPA guides for SOC engagements or COSO's Illustrative Tools accompanying the Internal Control, Integrated Framework) to demonstrate how controls or control objectives may be articulated for a given process area, such as IT general controls, change management, or transaction processing. They serve as reference examples to assist management in designing and documenting controls and to assist practitioners in evaluating suitability of design; they are not a mandated set of controls. In a SOC context, the controls actually presented in a report are determined by management's control environment and the engagement scope rather than by any illustrative list, and inclusion of an illustrative example does not imply it is required or that its presence guarantees effective operation. Practitioners should treat illustrative controls as starting points to be tailored to the specific system, applicable criteria, and risk assessment rather than adopted verbatim.

Why it matters

Illustrative controls matter because they lower the barrier to designing a credible control environment, particularly for organizations that are new to SOC or ISMS-related work. Rather than starting from a blank page, management can consult example control statements and control objectives published in professional guidance, such as the AICPA guides for SOC engagements or COSO's Illustrative Tools accompanying the Internal Control, Integrated Framework, to understand how a control might be articulated for a process area like IT general controls, change management, or transaction processing. This helps management and practitioners align on language, structure, and intent before controls are formally documented and tested.

The critical caveat is that illustrative controls are non-authoritative samples, not a required checklist. In a SOC context, the controls actually presented in a report are determined by management's control environment and the engagement scope, not by any illustrative list. Treating an illustrative example as mandatory, or assuming that including it guarantees effective operation, is a common misunderstanding that can lead to controls that look reasonable on paper but do not fit the organization's actual systems, risks, or applicable criteria. Their presence in guidance does not imply they are required, and their adoption does not by itself demonstrate operating effectiveness.

Because of this, illustrative controls are best understood as starting points to be tailored rather than adopted verbatim. Organizations that copy example controls without mapping them to their own risk assessment and system boundaries may find gaps during design evaluation or testing. Used well, however, illustrative controls accelerate the design process and provide a shared reference vocabulary between management and the practitioners evaluating suitability of design.

Who it's relevant to

Compliance and GRC Managers
Compliance managers use illustrative controls as a design starting point, drawing on published examples to structure and articulate controls before formal documentation. They are responsible for tailoring these examples to the organization's actual systems, risks, and audit scope rather than adopting them verbatim, and for recognizing that no illustrative example is inherently mandatory.
Auditors and SOC Practitioners
Practitioners performing SOC engagements may reference illustrative control objectives, such as those for IT general controls, when evaluating the suitability of a control's design. They should treat these as reference examples rather than a required checklist, and should assess the controls management actually presents based on the engagement scope and applicable criteria, not on whether illustrative examples were included.
Security Engineers and Control Owners
Engineers who implement and operate controls can use illustrative examples to understand what a control might look like in practice for areas like change management or transaction processing. They still need to design controls that fit the organization's real systems, since the presence of an illustrative example does not guarantee effective operation.
Management Establishing an Internal Control Environment
Management applying frameworks such as COSO's Internal Control, Integrated Framework can use accompanying Illustrative Tools to support the design and documentation of controls. These tools assist rather than dictate, so management retains responsibility for selecting and tailoring controls to its own environment and risk assessment.

Inside Illustrative Controls

Example Control Statements
Sample descriptions of controls that an organization might implement to address specific criteria, offered as illustrations rather than prescriptive requirements. In SOC 2 engagements they map to the applicable Trust Services Criteria; in ISO 27001 contexts they may relate to Annex A reference controls or the ISMS requirements in clauses 4 through 10.
Mapping to Criteria or Requirements
An indication of which criterion, clause, or reference control each illustrative control is intended to help satisfy. For SOC 2 this ties to the Common Criteria and any optional categories in scope; for ISO 27001 this typically connects to controls selected via the Statement of Applicability.
Design and Operating Considerations
Guidance on how a control might be designed and, where relevant, operated over time. This distinction matters for SOC 2 Type I (suitability of design at a point in time) versus Type II (design and operating effectiveness over a defined period whose length depends on scoping).
Scope Dependency Notes
Reminders that the applicability and wording of any illustrative control depend on the organization's scope, risk assessment, applicable criteria, and the judgment of the auditor or certification body, rather than representing a fixed or mandatory set.

Common questions

Answers to the questions practitioners most commonly ask about Illustrative Controls.

Are illustrative controls a mandatory checklist I must implement to pass a SOC 2 examination?
No. Illustrative controls are examples that demonstrate how an entity might satisfy a given Trust Services Criterion; they are not a required checklist. The AICPA framework specifies criteria, not prescribed controls. In most engagements, the service organization designs its own controls to meet the applicable criteria based on its environment and scope, and the auditor evaluates whether those chosen controls are suitably designed and, for a Type II, operating effectively. Two organizations meeting the same criterion may use quite different controls.
Does using published illustrative controls mean my controls will automatically be accepted by the auditor?
Not automatically. Illustrative controls are starting points, not guaranteed approvals. The CPA firm performing the SSAE 18 examination still evaluates whether each control, as actually implemented in your environment, addresses the relevant Trust Services Criterion. Copying an illustrative control verbatim without tailoring it to your systems and processes can result in a control that does not fit your operations, which may lead to exceptions. The outcome depends on the auditor, the scope, and the applicable criteria.
How should I use illustrative controls when first building my control set?
Typically they serve as a reference to help you interpret what a criterion is asking for and to spark ideas about control activities that might address it. A common approach is to review the applicable Trust Services Criteria in scope, consider the illustrative examples associated with each, and then adapt them to reflect your actual systems, teams, and processes rather than adopting the wording as-is. The goal is a control that genuinely operates in your environment and that you can evidence.
Can I map illustrative controls across SOC 2 and ISO 27001 to avoid duplicate work?
Partial mapping is possible, but caution is warranted. SOC 2 illustrative controls relate to the Trust Services Criteria, while ISO 27001 uses ISMS requirements in clauses 4 through 10 plus Annex A reference controls selected via a Statement of Applicability. Some controls may satisfy elements of both frameworks, but satisfying one does not automatically satisfy the other. Any crosswalk should be validated against each framework's requirements rather than assumed, since the structures and evaluation methods differ.
What determines which illustrative controls are relevant to my examination?
Scope is the key factor. Security (the Common Criteria) is the only required Trust Services category, so its associated illustrative controls are generally relevant. The Availability, Processing Integrity, Confidentiality, and Privacy categories are optional and only apply if you include them in scope, so their illustrative controls become relevant only when those categories are selected. Your risk profile, system boundaries, and the criteria you commit to shape which examples are worth considering.
Do the illustrative controls I select cover everything a SOC 2 report attests to?
A SOC 2 report attests only to the controls and the period or point in time covered by the examination, regardless of how those controls were derived from illustrative examples. The report reflects whether the described controls were suitably designed (Type I) and, where applicable, operated effectively over the defined review period (Type II). It does not guarantee freedom from breaches, and controls outside the described scope are not covered. Illustrative controls help you build the control set but do not expand what the resulting report addresses.

Common misconceptions

Illustrative controls are a mandatory checklist that must be implemented as written to pass a SOC 2 examination or achieve ISO 27001 certification.
Illustrative controls are examples, not requirements. In most engagements, actual controls are determined by the organization's scope, risk assessment, and the applicable Trust Services Criteria or, for ISO 27001, the controls selected through the Statement of Applicability. The specific controls needed depend on the auditor, certification body, and scope.
A single set of illustrative controls can satisfy both SOC 2 and ISO 27001 at once.
The two frameworks are distinct: SOC 2 is an attestation examination performed by a CPA firm resulting in a report, while ISO 27001 is a certification against an ISMS standard issued by an accredited certification body. Mapping between them is possible but partial, and satisfying illustrative controls for one does not automatically satisfy the other.
Implementing the illustrative controls guarantees security and freedom from breaches.
Illustrative controls only illustrate approaches to meeting criteria or requirements within a defined scope. A SOC 2 report attests only to the controls and period covered and does not guarantee freedom from breaches, and an ISO 27001 certificate covers only the defined scope of the ISMS.

Best practices

Treat illustrative controls as a starting reference, then tailor each control to your actual scope, risk assessment, and the specific criteria or requirements you are addressing.
For SOC 2, confirm which Trust Services Criteria are in scope (Security is required; Availability, Processing Integrity, Confidentiality, and Privacy are optional) before adopting any illustrative control, and distinguish design-focused controls for Type I from those needing operating evidence for Type II.
For ISO 27001, map illustrative controls to your Statement of Applicability and the underlying risk assessment, and specify which version of Annex A you are working from when referencing reference controls, since counts and structure differ between the 2013 and 2022 revisions.
Document evidence expectations for each control so that operating effectiveness can be demonstrated over the applicable review period where required.
Validate any adopted illustrative controls with your auditor or certification body early, since applicability and adequacy ultimately depend on their judgment and your scope.
Where you intend to use controls across both frameworks, document the partial mapping explicitly and avoid assuming that one framework's coverage fully satisfies the other.