Do SOC 2 auditors require an annual policy review?

The criteria expect management to oversee the controls (CC1.2) and to keep policies in place and current (CC5.3). Most CPA firms read that as a review at least once a year, and most policy sets, including the Policyseed policies, commit to one in their review section. In a Type 2 examination the auditor can ask for the record of a review that fell inside the period.

What counts as evidence of the review?

A dated record that shows which policies were reviewed, by whom, what was found and that management approved the result: this checklist with its sign-offs and the signed re-approval, plus the updated revision history of each policy and the policy register. A calendar invite on its own shows that a meeting was planned, not what was reviewed.

What if nothing needs to change?

Record that. Mark each policy No under Changes needed, sign the record, and add a line to each policy's revision history with the review date. A review that changes nothing is still a review, and the date shows the policy is current.

We chose a quarterly cadence. Does this still apply?

Yes. The checklist reads the cadence from your generator answers, so the title, the review dates and the resolution follow it: a quarterly cadence gives a quarterly review record. Keep at least one full review of every policy each year.

How do we see what changed when we regenerate the policies?

Rebuild the Audit Kit in the same browser. The new kit lists the template changes since your previous kit, and for every policy whose text changed it adds a Word file with tracked changes against the previous version, so management re-approves only the changes. Policies with no change get no file.

Annual policy review checklist

Updated 23 October 2026

Policies are approved once and then reviewed on a schedule. This checklist walks the owner of each of the 22 Policyseed policies through what to check, records whether changes are needed, and produces a Word record with a summary of changes, a re-approval resolution and signatures. It uses your generator answers or the sample company and runs in your browser. No signup, nothing uploaded.

Annual Policy Review: Northwind Cloud Inc

Work through each policy, mark whether it needs changes, and download the record as Word. Your answers stay in this page’s address (after the #), so you can bookmark it or send the link to a colleague. Nothing is uploaded.

No generator answers found in this browser, so the checklist uses the sample company, Northwind Cloud Inc. Answer the 23 generator questions to get your own owners, cadence and review triggers.

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Why auditors ask for it

A policy approved two years ago and never looked at again may no longer describe the company. The SOC 2 criteria expect management oversight (CC1.2) and policies that stay in place and current (CC5.3), and nearly every policy commits to a periodic review in its own text. Each Policyseed policy has a Review Cadence section that sets the cadence you chose and names the events that call for an earlier review, such as a significant incident or a new hosting platform.

When the auditor samples the review, they look for the date, who reviewed each policy, what changed and who approved the result. The record below gives each of those a place, and its owners and cadence match the policy approval minutes the policies were first adopted with.

What is in the record

Review details: company, cadence, the date the review is due, the period covered, reviewers and approver. Facts the generator cannot know are [Fill in: ...] placeholders.
Per-policy checklist: owner, last review, what to check, changes needed yes or no, notes, reviewer and date. The checks quote the policy’s own review section (the events that call for a review, documents reviewed with it, what happens after a change), followed by four checks every policy shares.
Summary of changes: each policy marked Yes, what changes, the new version and the owner.
Re-approval and signatures: a resolution that keeps the unchanged policies approved, approves the revised ones at their new version and sets the next review date.

The checks for one policy, as they download for the sample company

Sample checklist entry

P03 Access Control Policy

Owner: Dana Whitfield, CTO. Last review: 2026-09-02. Cadence: Annual.

Review the role-to-access matrix together with the policy, as section 8 requires.
Besides the annual review, section 8 calls for a review after any incident involving unauthorized access, and whenever a new system holding Restricted data is introduced or the identity architecture of Northwind Cloud Inc changes. Note which of these events happened since the last review and what each one changes in the policy.
Section 8 also says: Revisions are approved by Priya Natarajan, CEO and recorded in section 9.
People, roles and tools named in the policy are still current: owner Dana Whitfield, CTO, approver Priya Natarajan, CEO.
Section 4 (Policy Statements) and section 5 (Procedures) describe how the company works today. List any commitment that is not being followed as a change needed or an action.
Exceptions granted under section 6 (Exceptions) since the last review are still needed, approved and within their end date.
Section 9 (Revision History) records this review, with a new version number if anything changed.

How to run the review

Schedule it before the due date: the record shows the date from your effective date and cadence.
Check the changelog for template changes since your policies were generated, and regenerate if a change applies to you.
Each owner works through the checks for their policies and marks Changes needed Yes or No, with notes.
Make the agreed changes and give each revised policy a new version number.
Management approves the result: sign the re-approval, update the policy register and the revision history of each policy, and collect new acknowledgments for policies that changed materially.

The Audit Kit includes this record in its governance folder, filled from your answers. When you rebuild the kit in the same browser, it also adds a Word redline for each policy whose text changed since your previous kit, with every insertion and deletion as a tracked change, so management reviews and re-approves only what changed.

Frequently asked questions

Do SOC 2 auditors require an annual policy review?: The criteria expect management to oversee the controls (CC1.2) and to keep policies in place and current (CC5.3). Most CPA firms read that as a review at least once a year, and most policy sets, including the Policyseed policies, commit to one in their review section. In a Type 2 examination the auditor can ask for the record of a review that fell inside the period.
What counts as evidence of the review?: A dated record that shows which policies were reviewed, by whom, what was found and that management approved the result: this checklist with its sign-offs and the signed re-approval, plus the updated revision history of each policy and the policy register. A calendar invite on its own shows that a meeting was planned, not what was reviewed.
What if nothing needs to change?: Record that. Mark each policy No under Changes needed, sign the record, and add a line to each policy's revision history with the review date. A review that changes nothing is still a review, and the date shows the policy is current.
We chose a quarterly cadence. Does this still apply?: Yes. The checklist reads the cadence from your generator answers, so the title, the review dates and the resolution follow it: a quarterly cadence gives a quarterly review record. Keep at least one full review of every policy each year.
How do we see what changed when we regenerate the policies?: Rebuild the Audit Kit in the same browser. The new kit lists the template changes since your previous kit, and for every policy whose text changed it adds a Word file with tracked changes against the previous version, so management re-approves only the changes. Policies with no change get no file.

Policyseed provides governance policy templates and AI tailoring. It is not legal advice and not a compliance guarantee. Management adopts the policies; the CPA firm performs the SOC 2 examination.