Authoritative SOC 2 Control Narratives: Active vs Passive Voice for Type II Assurance

1) Active vs Passive Voice in the SOC 2 Type II Context

In a SOC 2 Type II report, the auditor’s job is to evaluate whether your controls were suitably designed and operated effectively over a defined period. To make that possible, your control narratives must clearly show responsibility, timing, and method. This is where the choice between active and passive voice becomes decisive.

In active voice, the sentence names the actor before the action. The structure puts the responsible role in the subject position, followed by a clear verb and a direct object. For example, when your narrative states that a specific role “approves,” “reviews,” or “reconciles,” you make ownership explicit. Active voice removes ambiguity because it answers “who does what, when, and how” without delay. It fits the auditor’s need to link control performance to the right actor and evidence.

In passive voice, the action is described without naming the actor directly, or the actor appears as an optional add-on. This structure often hides responsibility or makes it feel optional. Passive voice tends to be softer and more general. In a Type II context, habitual passive voice weakens assurance, because it forces the auditor to ask follow-up questions about who is actually performing the control, how often, and what evidence proves it happened throughout the period. Over time, this increases audit friction and introduces risk of misinterpretation.

To be clear, passive voice has legitimate, limited uses. Sometimes you may wish to de-emphasize the actor when summarizing an outcome (“Exceptions were documented and remediated”) or when the actor is truly variable and not central to the control’s reliability. However, these cases are rare in core control statements. Most of the time, your control statement needs a visible, accountable actor that the auditor can map to artifacts and samples. In SOC 2 Type II, where the test period matters, passive voice typically blocks the auditor’s line of sight to accountability and timing, reducing confidence in operating effectiveness.

The key principle is this: in control narratives, use active voice for statements that define policy ownership, procedural execution, and recurring performance. Reserve passive voice for brief summaries of outcomes or when the actor is intentionally not the focus, and only when that choice does not impair traceability to evidence.

2) How Active Voice Improves Auditability: Ownership, Timing, Evidence

Active voice improves auditability because it forces you to identify the control owner and the action in a way that aligns with how auditors test operating effectiveness over time. Auditors need to confirm that controls ran consistently and as designed. If your narrative names the role, states the action, provides a frequency, and describes the evidence, the auditor can quickly select samples and verify that those samples include the required signatures, timestamps, and artifacts.

Consider the anatomy of an auditor-ready control statement. A consistent sentence pattern delivers clarity and reduces back-and-forth:

• Actor + Verb + Object + Frequency + Evidence

This pattern provides a compact backbone for any control. The Actor is the accountable role (not a generic “team”). The Verb is a specific action word that signals control performance (approve, review, reconcile, grant, revoke, compare, monitor). The Object clarifies what is being acted upon (access requests, firewall rules, change tickets). The Frequency anchors the control over time (upon request, prior to deployment, daily, monthly, quarterly). The Evidence describes the durable artifacts that prove the control ran (ticket IDs, logs, signed reports, automated alerts, screenshots with timestamps).

This structure does more than organize information. It directly matches how auditors design tests: they pick samples by date or frequency, identify the responsible party, and review the artifacts that show the action occurred as described. When your narrative follows this pattern, sampling becomes straightforward. The auditor can map each sample to a named role, a dated action, and a concrete piece of evidence that is easy to retrieve. The result is fewer clarification emails and fewer meetings to explain what “usually” happens.

Active voice also strengthens timing assurance. In Type II, timing is essential because auditors look for evidence across the entire period. A control that states “reviews are performed monthly” without naming a role and artifact will trigger questions about who performed the review, when exactly, and how the review was documented. In contrast, an active statement that names the role and the artifact gives the auditor clear points of verification: a dated, signed report or a system log that shows the monthly cadence.

Moreover, active voice aligns with the concept of acceptance criteria. If the actor, method, frequency, and evidence are explicit, the auditor can define what a “pass” looks like for each sample. This shared clarity reduces disputes later. The acceptance criteria might include the presence of approvals, timestamps, reconciliations, or exception handling steps—all traceable to a role and a document or system record.

3) Applying Active Voice to CC-Series (e.g., CC3.2) with Auditor-Ready Controls

Within the Trust Services Criteria, control narratives that follow the active structure become easier to assess, especially across risk assessment and control activities like CC3.2 (addresses the selection and development of control activities). CC3.2 expects that the organization selects and develops activities that mitigate risks to acceptable levels. If your narrative is vague or passive, the link between the risk and the control activity becomes harder to substantiate. An active, structured narrative makes the chain of logic visible: a named role performs a defined action on a stated frequency, with evidence that can be inspected.

In the context of CC3.2, auditors look for control activities that are responsive to risk assessments and are embedded in day-to-day operations. The narrative should show design sufficiency and operational consistency. When you express the control activity in active voice, you remove interpretive gaps. The auditor no longer has to infer who evaluates risk changes, who approves mitigation steps, or how exceptions are tracked. Instead, the narrative foregrounds these elements and links them to durable artifacts.

This approach also respects the separation between the control statement and the testing procedures. The control statement explains what your organization does, not how the auditor will test it. Keeping these separate prevents confusion and discourages language that reads like an audit program rather than a description of internal operations. The role of the control statement is to define accountable performance and available evidence. The role of the testing procedures, which the auditor designs, is to validate those assertions. Active voice naturally supports this separation because it focuses on your actions and artifacts, avoiding the metadiscourse that audits sometimes introduce.

In addition, the active structure supports mapping to acceptance criteria—what the auditor needs to see in a sample to consider the control operating effectively. Because the narrative names the actor, specifies the action, and describes the evidence, the acceptance criteria follow directly. For example, if a control activity includes prior approval, the acceptance criteria can reference the presence of the approver’s identity, the date before the action, and a record of what was approved. This alignment reduces misinterpretation of what “complete” or “approved” means in practice.

Finally, clarity in voice and structure lowers the risk of false comfort. Passive voice can sound official while still leaving gaps (“reviews are conducted,” “exceptions are addressed”). These phrases seem strong but do not anchor responsibility or evidence. In a Type II audit, this often leads to findings where the design sounds adequate, but samples fail because the underlying artifacts are not consistent. Active voice addresses this by requiring you to say who acts, what they do, when they do it, and what proof exists.

4) Practice and Quick Checks: Reinforcing Voice Choice and Control–Test Separation

To maintain high-quality control narratives across your environment, develop habits that reinforce active voice selection and a clear line between control statements and testing procedures. The following practice principles can guide daily writing and review:

• Begin each control statement by naming the accountable role. If you cannot name a role, question whether the control is truly owned.
• Use strong operational verbs that imply observable behavior. Replace vague verbs like “ensure” and “validate” with action verbs that produce evidence, such as “approve,” “review,” “compare,” “reconcile,” “grant,” “revoke,” “investigate,” “escalate,” “document,” or “retain.”
• Define the frequency precisely. Avoid general terms like “periodically.” Use specific cadences such as “daily,” “weekly,” “monthly by the 10th business day,” or “prior to production deployment.”
• Describe evidence in concrete terms. State what artifact exists, where it is stored, and what metadata it contains (timestamps, approver identity, ticket numbers).
• Keep testing language out of the control statement. Do not write about sampling or what the auditor will look at. The control statement is about your operations; the evidence you cite will naturally inform the auditor’s testing procedures.
• Use limited passive voice only when the actor is nonessential to the point being made or when summarizing results. Even then, consider whether clarity would benefit from naming the actor.
• Review narratives for consistency across the CC-series. Aim for the same sentence pattern and level of specificity so that the map from control to acceptance criteria is predictable.

For quick self-checks, apply simple questions that reveal weaknesses:

• Who is the actor? If you cannot answer immediately, the statement is likely passive or vague.
• What is the verb, and is it observable? If the action does not produce an artifact or is not time-stamped, the auditor’s test may fail.
• What is the object? Ensure that the narrative specifies what is being approved, reviewed, or monitored.
• What is the frequency? Verify that it matches operational reality and is feasible to evidence across the entire Type II period.
• What is the evidence? Confirm that the artifact exists today, is retained for the period, and can be retrieved promptly.

These checks help you detect and correct weak phrasing before an audit begins. They also promote internal discipline: by requiring roles, actions, timing, and evidence, your organization designs controls that are more likely to operate effectively, not just read well on paper.

Why This Approach Works for Type II Assurance

Auditors evaluating operating effectiveness over time need more than aspirational statements. They need assurance that controls were performed consistently and that documentation exists for each occurrence or sample. Active voice directly supports this need by making the actor and the action central. The consistent sentence pattern aligns with how auditors plan and execute their procedures, which reduces misinterpretation and the need for iterative clarifications.

Moreover, active voice supports scalability. As your environment grows, you can extend the same narrative structure across new systems, processes, and teams. Because each statement encodes ownership, timing, and artifacts, new joiners and cross-functional teams can quickly understand what is expected and how to demonstrate compliance. In contrast, passive or vague narratives create knowledge silos and fragile practices that rely on tribal knowledge during audits.

Finally, this method helps create a durable link between risk assessment and control performance. CC-series criteria, including CC3.2, rely on controls that are not only designed to mitigate risks but are also executed in a repeatable, evidenced way. Active voice and the Actor + Verb + Object + Frequency + Evidence pattern turn that expectation into an actionable writing standard. When your narratives are that clear, you facilitate efficient sampling, minimize findings tied to ambiguity, and strengthen the credibility of your Type II report.

In summary, authoritative SOC 2 control narratives depend on active voice to communicate ownership, timing, and method. By adopting a consistent sentence structure and maintaining a strict separation between control statements and testing procedures, you support the auditor’s objectives and reduce follow-ups. The outcome is practical: faster audits, stronger evidence trails, and higher confidence that your controls are both suitably designed and operating effectively across the entire period.