CC9.1 CC9 · Risk Mitigation · Security (Common Criteria)

CC9.1 — Business disruption risk mitigation

Risk mitigation activities are identified, selected, and developed for risks arising from potential business disruptions.

Also written as CC 9.1, TSC CC9.1, SOC2 CC9.1, SOC 2 Type 2 CC9.1.

What SOC 2 CC9.1 requires

Business disruption risk mitigation is one of 2 criteria in the Risk Mitigation (CC9) series of the Security (Common Criteria) category. Risk mitigation activities are identified, selected, and developed for risks arising from potential business disruptions. CC9 covers business disruption and vendor risk, so evidence spans BCDR test results and the third-party review files that show you assess the vendors handling your data.

Audit evidence assessors look for

When preparing for a SOC 2 audit against CC9.1, gather artefacts such as:

  • Business continuity and disaster recovery plans
  • BIA identifying critical processes and dependencies
  • DR test records with results and follow-ups
  • Insurance coverage documentation where used as mitigation

ISO 27001 mapping

CC9.1 corresponds to the following ISO 27001:2022 Annex A control(s): A.5.30. If you already run an ISO 27001 ISMS, map your existing evidence for these controls to CC9.1 rather than duplicating work.

Map CC9.1 to ISO 27001 & NIST CSF →
Crosswalk this criterion in the Control Mapper & Gap Assessment.
Document the risk →
Record treatment for gaps against CC9.1 in the Risk Register.

Other Risk Mitigation criteria

CC9.2 Vendor and business partner risk

All CC9 Risk Mitigation criteria →

Frequently asked questions

Is CC9.1 required for a SOC 2 report?

Yes. CC9.1 sits in the Common Criteria, which apply to every SOC 2 engagement regardless of which additional categories you scope in — there is no SOC 2 report that omits them.

How does an auditor test CC9.1?

In a Type 1 report the auditor assesses design only — does a control exist at a point in time that would meet CC9.1 if it operated. In a Type 2 report they also test operating effectiveness by sampling evidence from across the review period, typically 3 to 12 months. That difference is why Type 2 evidence has to be continuous rather than assembled the week before fieldwork.

What happens if CC9.1 fails testing?

A control that fails becomes an exception, which the auditor describes in the report along with management's response. Exceptions do not automatically make a report "failed" — a SOC 2 report is an opinion, not a pass/fail certificate — but a qualified opinion is what customers notice, so remediate and re-test before fieldwork closes where you can.

Does SOC 2 CC9.1 map to ISO 27001?

Yes — CC9.1 aligns with ISO 27001:2022 Annex A control(s) A.5.30. If you already run a certified ISMS, re-point that evidence rather than building a parallel set; the underlying control is the same and only the reporting format differs.