Understanding Complementary User Entity Controls: Key Considerations for SOC Report Readers and Service Organizations 

Complementary user entity controls (CUECs) are control activities that a service organization’s management expects user entities to implement in order to complement the service organization’s own controls. CUECs appear in both SOC 1 and SOC 2 reports and directly affect whether control objectives are met. Report readers are responsible for reviewing, assessing, and documenting how their organization addresses each CUEC listed in the report. 

Key Takeaways 

• CUECs are control activities that service organizations expect user entities to implement to complement their own controls. 

• User responsibilities are clearly outlined in service agreements, while CUECs represent control expectations not always explicitly defined in contracts. 

• Service organizations collaborate with auditors to determine whether CUECs are necessary, reviewing agreements and user guides to identify any gaps. 

• Report readers must assess, document, and act on any CUECs defined in the SOC report. 

What Are Complementary User Entity Controls (CUECs)? 

CUECs are control activities that the management of a service organization expects user entities to implement in order to complement the service organization’s own control activities. CUECs are distinct from user responsibilities, which are specific requirements outlined in service agreements and contracts. 

Understanding the difference between user responsibilities and CUECs is essential for both service organizations and report readers. The following scenarios illustrate that distinction. 

User Responsibility: An Example 

A service organization provides a Software as a Service (SaaS) platform to user entities. Upon signing the agreement, the user entity must provide information for the individual(s) who will be set up as administrators for their organization’s instance. This is a user responsibility because providing that information is necessary to use the contracted service and allows the service organization to fulfill its service commitment. 

CUEC: An Example 

A service organization’s system may require the installation of an appliance or server in the server room of user entities. In this scenario, the service organization cannot control the physical security mechanisms of those server rooms. The service organization would specify a CUEC in its report, stating that user entities are responsible for implementing appropriate physical security controls to restrict access to the server room, and therefore to the appliance or server, to authorized personnel only. 

How Does a Service Organization Determine What CUECs to Include in a SOC Report? 

CUECs can appear in both SOC 1 and SOC 2 reports, but they are not mandatory. Management of a service organization works with its auditor to determine whether CUECs are necessary. 

The auditor typically begins by working with management to understand what controls, if any, they expect to be in place at user entities. The service auditor then reviews agreements between the service organization and user entities, as well as user guides, to identify clearly defined responsibilities. Any control expectations from management that are not explicitly outlined in those documents will typically indicate the need for CUECs. 

This process requires close coordination between service organization management and its SOC audit provider to verify all relevant control gaps are identified and addressed before the report is finalized. 

What Are the Responsibilities of Report Readers Regarding CUECs? 

Report readers (user entities) must review the SOC report to determine whether any CUECs are defined in the system description. For each CUEC listed, the reader should: 

• Assess applicability — Determine whether the CUEC applies to the organization’s specific use of the service. 

• Evaluate existing controls — Review current controls to confirm they address the CUEC requirements. 

• Document responses — Record how each applicable CUEC is being met as part of vendor management obligations. 

• Develop a remediation plan — If a relevant CUEC lacks a corresponding control, develop and implement a strategy to address the gap. 

Failing to address applicable CUECs leaves gaps in the overall control environment and can undermine the assurance that a SOC report is intended to provide. 

Why Do Complementary User Entity Controls Matter for Control Objectives? 

User entities play a direct role in supporting service organizations in achieving control objectives. A SOC report reflects the combined control environment of both the service organization and the user entity. If a user entity does not implement the required CUECs, the overall control framework may be incomplete — regardless of how strong the service organization’s own controls are. 

Report readers should not treat CUECs as a formality. Reviewing, assessing, and acting on CUECs is a material part of fulfilling vendor management obligations and maintaining a sound compliance posture. 

Frequently Asked Questions About CUECs 

Q: What is CUEC meaning in a SOC report? 
CUEC stands for complementary user entity controls. In a SOC report, CUECs are control activities that a service organization expects the user entity (the organization reading the report) to implement. These controls complement the service organization’s own controls and are necessary for the overall system to meet its control objectives. 

Q: What is the difference between a CUEC and a user responsibility? 
A user responsibility is a specific requirement defined in a service agreement that a user entity must fulfill to receive the contracted service. A CUEC is a control expectation set by the service organization that may not be explicitly stated in the contract but is necessary to support the service organization’s control objectives. Both affect the user entity, but they arise from different sources and carry different obligations. 

Q: Do all SOC reports include CUECs? 
No. CUECs are not mandatory and do not appear in every SOC 1 or SOC 2 report. Whether CUECs are included depends on the nature of the service, the degree to which user entity controls affect the service organization’s control objectives, and the outcome of the review process conducted by management and the auditor. 

Q: What should a user entity do if it cannot meet a CUEC listed in a SOC report? 
If a user entity identifies a relevant CUEC but does not have a corresponding control in place, it should develop and implement a remediation plan. Leaving a CUEC unaddressed creates a gap in the control environment that could affect compliance obligations and vendor management assessments. 

Wolf’s SOC Reporting team provides expert guidance on reporting, helping organizations navigate CUECs and align controls with requirements. For questions about CUECs or SOC reporting requirements, reach out to a member of the Wolf team today.