Migrating from SOC 2 to HIPAA
If your organization is SOC 2 compliant and expanding into healthcare, you're already 65% of the way to HIPAA compliance. The key gaps are legal and procedural—Business Associate Agreements, PHI-specific controls, and breach notification requirements—rather than technical.
Critical Compliance Gaps
Business Associate Agreements (BAAs)
HIPAA requires formal Business Associate Agreements with every third party that accesses Protected Health Information (PHI). SOC 2 vendor management doesn't include this specific legal requirement.
PHI-Specific Access Controls
HIPAA mandates the Minimum Necessary Rule—restricting PHI access to only what's required for specific job functions. This is more prescriptive than SOC 2's general access controls.
Breach Notification Requirements
HIPAA requires notification to HHS within 60 days for breaches affecting 500+ individuals, plus individual notifications. SOC 2 has no specific breach timeline requirements.
Notice of Privacy Practices
HIPAA requires maintaining and distributing privacy practices documentation to patients/users, which is not covered by SOC 2.
Step-by-Step Migration Roadmap
Follow these 10 steps to achieve HIPAA compliance. Estimated timeline: 10 weeks.
Map SOC 2 controls to HIPAA Security Rule Administrative, Physical, and Technical Safeguards
Identify all systems and workflows that process PHI
Draft and execute Business Associate Agreements with all relevant vendors
Implement Minimum Necessary access controls for PHI
Create Notice of Privacy Practices documentation
Establish HIPAA-compliant breach notification procedures
Train workforce on HIPAA-specific requirements
Conduct HIPAA-focused risk assessment
Implement audit controls for PHI access logging
Perform gap remediation and document compliance
Unique HIPAA Requirements
Strategic Use Cases
Verification Sources
Last verified: January 12, 2026
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SOC 2 to HIPAA Migration FAQs
Is SOC 2 sufficient for healthcare customers$2
No. While SOC 2 demonstrates strong security controls, healthcare customers and regulations require HIPAA compliance specifically. However, SOC 2 provides an excellent foundation—about 65% of controls overlap.
Do I need HIPAA if I don't store PHI but my customers do$3
If you access, process, transmit, or maintain PHI on behalf of a Covered Entity, you're a Business Associate and must comply with HIPAA. This includes most healthcare SaaS platforms.
How long does HIPAA compliance take after SOC 2$4
Typically 8-12 weeks with focused effort. The main work is legal (BAAs), procedural (breach notification), and documentation (Privacy Practices), not rebuilding technical controls.
What's the penalty for HIPAA non-compliance$5
HIPAA violations can result in fines from $100 to $50,000 per violation, up to $1.5M per year for repeat violations. Criminal penalties can include imprisonment for willful violations.
About RiscLens
Our mission is to provide transparency and clarity to early-stage technology companies navigating the complexities of SOC 2 (System and Organization Controls 2) compliance.
Who we serve
Built specifically for early-stage and growing technology companies—SaaS, fintech, and healthcare tech—preparing for their first SOC 2 audit or responding to enterprise customer requirements.
What we provide
Clarity before commitment. We help teams understand realistic cost ranges, timeline expectations, and common gaps before they engage auditors or expensive compliance vendors.
Our Boundaries
We do not provide legal advice, audit services, or certifications. Our assessments support internal planning—they are not a substitute for professional compliance guidance.
SOC 2 (System and Organization Controls 2) is a voluntary compliance standard for service organizations, developed by the AICPA, which specifies how organizations should manage customer data based on the Trust Services Criteria: security, availability, processing integrity, confidentiality, and privacy.
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