Fintech companies face a more complex compliance landscape than most other technology sectors. They are simultaneously subject to financial services regulation (OJK in Indonesia, SEC/FINRA in the US, FCA in the UK), payment card industry requirements (PCI DSS if they touch card data), and enterprise security requirements from financial institution clients (who typically have the most mature and demanding vendor security programs in any industry). SOC 2 sits at the intersection of these requirements — it is not a substitute for regulatory compliance, but it is the mechanism through which fintech companies demonstrate operational security maturity to enterprise clients.
SOC 2 vs. SOC 1 for Financial Services
A critical distinction for fintech companies: SOC 2 and SOC 1 are related but different frameworks. SOC 1 (formally SSAE 18) covers controls relevant to financial reporting — it is the framework used by payment processors, transfer agents, and other financial service providers whose operational controls affect the financial statements of their clients. SOC 2 covers controls relevant to the security, availability, and integrity of the system. Both may be required; they serve different audiences.
| Framework | Purpose | Who Requires It | Audit Standard |
|---|---|---|---|
| SOC 1 (SSAE 18) | Controls over financial reporting — assurance that service provider’s controls don’t create material financial statement errors for clients | Client’s auditors (for financial statement audit); institutional clients with outsourced financial processes | SSAE 18 / AT-C Section 320 |
| SOC 2 | Controls over security, availability, processing integrity, confidentiality, and privacy of the service system | Enterprise client security programs; procurement security reviews; regulatory requests for evidence of information security controls | AT-C Section 205 |
| PCI DSS | Security of cardholder data environments | Any entity that stores, processes, or transmits payment card data; card brands (Visa, Mastercard, Amex) | PA-DSS / PCI DSS SAQ or QSA assessment |
Fintech companies that process card payments and serve enterprise clients typically need all three: PCI DSS for card data handling, SOC 1 if their processing affects client financial statements, and SOC 2 for the enterprise security review process. The control overlap between these frameworks is significant, and a well-designed compliance program builds shared evidence that satisfies all three.
PCI DSS and SOC 2 Control Overlap
PCI DSS and SOC 2 Security criteria cover much of the same technical territory: access control, vulnerability management, change management, monitoring, and incident response. The key difference is that PCI DSS is prescriptive — it specifies exact technical requirements (MFA for all non-console administrative access, quarterly external vulnerability scans by an Approved Scanning Vendor, annual penetration test) — while SOC 2 is principles-based.
| KEY IDEA | Organizations running PCI DSS compliance programs will find that their PCI controls satisfy most SOC 2 CC6 and CC7 requirements. The incremental effort for SOC 2 after PCI DSS is primarily organizational (CC1 governance documentation), risk assessment (CC3), and the system description. Running PCI and SOC 2 simultaneously with shared evidence reduces total compliance cost by an estimated 25–35%. |
Financial Services Vendor Security Programs
Financial institution vendor security programs are typically the most rigorous in any industry. Banks and insurance companies that deploy hundreds of technology vendors have mature third-party risk management frameworks: vendor risk tiers based on data access and system criticality, annual due diligence requirements including SOC 2 report review, and ongoing monitoring that includes reviewing vendors’ publicly available SOC 2 exceptions for trends.
For fintech companies serving financial institution clients, a SOC 2 Type II report is not optional — it is the minimum expected evidence for vendor approval. The observation period length matters: many financial institution vendor programs require a 12-month observation period. Financial services clients often send their own vendor questionnaire in addition to requesting the SOC 2 report, and they will use the SOC 2 report to validate questionnaire responses.
| BITLION INSIGHT | Indonesian fintech companies targeting US and European financial institution clients should expect the most rigorous security review they will encounter. These clients have dedicated third-party risk management teams, defined vendor risk frameworks, and documented minimum control requirements that are mapped to the SOC 2 criteria. Building a SOC 2 program that meets financial institution standards from the outset — 12-month observation period, Security + Availability + Confidentiality criteria, no material exceptions — positions the company for approval without a second review cycle. |
Indonesian Fintech Regulatory Context
Indonesian fintech companies face a dual compliance obligation: Indonesian financial services regulation (OJK, Bank Indonesia) and the requirements of international enterprise clients. OJK Regulation No. 13/POJK.02/2018 on Digital Financial Innovation and subsequent regulations on information technology risk management for financial services institutions reference ISO 27001 as the primary framework for demonstrating information security control. PBI No. 23/6/PBI/2021 on Payment Systems similarly references ISO 27001.
This means Indonesian fintech companies serving both domestic regulated clients and US/European enterprise clients need both ISO 27001 (for Indonesian regulatory compliance) and SOC 2 (for US enterprise client requirements). The most efficient path is to implement ISO 27001 first (satisfying Indonesian regulatory requirements immediately), then layer SOC 2 on the established control environment, sharing evidence between the two frameworks.