Last updated: July 26, 2026
Reports & Opinions · Compliance Q&A

What are complementary user entity controls (CUECs)?

Complementary user entity controls, or CUECs, are controls the service organization assumes its customers will operate for the overall controls to work. They are listed in the SOC 2 report, and the auditor does not test them.

The full answer

Complementary user entity controls are the assumptions a service organization builds into its control design about what customers must do on their end. A SaaS provider might design strong access controls internally, but those only protect you if your team promptly removes departing employees, enforces its own passwords, and reviews the access reports the vendor exposes. Those customer-side duties are the CUECs.

They appear in a dedicated section of the SOC 2 report, usually near the system description or the auditor's test results. The auditor lists them but does not test them, because they sit outside the service organization's boundary. Responsibility for operating them falls entirely on the user entity, meaning your company when you are the customer reading the report.

This matters in two directions. When you read a vendor's SOC 2, the CUEC list is effectively a to-do list: the report's clean opinion only holds if you actually perform those controls. Because a Type 2 report covers an observation window that usually runs three to twelve months, the vendor is assuming you operated those controls across the whole period, not just once. When you publish your own SOC 2, well-written CUECs keep your scope defensible, because you are not claiming to control what your customers configure.

Practically, review the CUEC section as carefully as the opinion letter. Map each item to an owner on your side and confirm it is actually happening. When you scope a SOC 2 through the AuditNex network, the licensed firm helps you word CUECs so they reflect real shared responsibilities rather than quietly shifting your own obligations onto customers.

Go deeper

Short answer not enough? These pages cover the full picture:

SOC 2 Type 1 vs Type 2 ›  ·  Complete SOC 2 guide ›

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Sources: AICPA SOC 2 Trust Services Criteria (2017, rev. 2022); AICPA SSAE No. 18 attestation standards. Answer written and maintained by the AuditNex research team; last reviewed July 26, 2026. AuditNex is a marketplace — accredited firms price and scope engagements independently.