Performance Reviews for SOC 2: A Startup Guide

You’re preparing for your startup’s first SOC 2 audit. You’ve locked down your infrastructure, implemented access controls, and documented your security policies. Then your auditor asks: “How do you evaluate employee competence and performance?”

Wait—employee evaluation is part of SOC 2?

Yes. SOC 2’s Common Criteria 1.4 requires evidence that you develop and evaluate employees—and for many startups without dedicated HR teams, this catches them off guard. While there are several ways to satisfy this requirement, performance reviews are the most common and defensible approach. The good news: you don’t need enterprise HR software or months of preparation. Here’s how to implement SOC 2 compliant performance reviews without slowing down your business.

Why performance reviews matter for SOC 2

SOC 2 isn’t just about firewalls and encryption. It’s a comprehensive framework that examines how your entire organization manages risk—including your people.

Common Criteria 1.4 (CC1.4) maps to COSO Principle 4: “The organization demonstrates a commitment to attract, develop, and retain competent individuals in alignment with objectives.” In plain English, auditors want to see that you:

Define clear job responsibilities
Evaluate whether employees meet those responsibilities
Address performance gaps through training or other interventions
Document all of the above

While CC1.4 doesn’t explicitly mandate performance reviews, they’re the most straightforward way to satisfy the second and third points. Other acceptable evidence can include documented manager check-ins, promotion or compensation review records, training plans, or formal improvement processes—but performance reviews provide the clearest, most comprehensive documentation.

What auditors actually look for

When auditors assess your CC1.4 controls, they’re not looking for elaborate 360-degree feedback systems. They want to see that performance management actually happens. According to Secureframe, auditors typically verify this through sampling—they’ll select a few employee names and ask for evidence of competence evaluation.

Here’s what typically satisfies the requirement:

Frequency: Most auditors expect reviews at least annually, and annual cadence is the safest default. Some accept rolling reviews or continuous documented check-ins, but inconsistent timing without a defined process will raise questions.

Coverage: Every employee should have documented evaluation evidence. Gaps raise red flags.

Content: Reviews should connect to role expectations (whether in job descriptions, leveling frameworks, or OKRs) and address whether employees meet them. They don’t need to be lengthy—but they need to exist and be substantive.

Documentation: Evidence must be stored and retrievable. If you can’t produce it during an audit, it didn’t happen.

Consistency: Your process should be repeatable and applied uniformly across the organization.

The challenge for startups without HR

Here’s the reality: most startups pursuing SOC 2 don’t have dedicated HR teams. As Humadroid notes, achieving SOC 2 compliance without full-time security or HR staff “isn’t just possible—it’s increasingly common.”

But that doesn’t make it easy. Without HR infrastructure, performance reviews typically fall to:

Founders who are already stretched thin
Chiefs of Staff managing compliance alongside everything else
Engineering leads who’d rather be shipping product

The traditional approach—chasing employees for self-reviews, manually compiling feedback, writing reviews from scratch—consumes hours that early-stage companies can’t spare. Industry estimates suggest managers can spend upwards of 200 hours per year on performance management activities.

For a 20-person startup where every manager reviews 4-5 people, that’s potentially weeks of productivity lost to a compliance exercise.

A practical framework for SOC 2 compliant reviews

You don’t need to replicate what Fortune 500 companies do. You need a process that’s defensible to auditors, sustainable for your team, and actually useful for employee development.

Step 1: Establish clear role expectations

Before you can evaluate performance, you need to define what good performance looks like. Auditors often expect role expectations to be documented somewhere—whether in job descriptions, leveling frameworks, or role scorecards.

Create simple role definitions that include:

Core responsibilities (5-7 bullet points)
Key competencies required
Success metrics where applicable

These don’t need to be elaborate. A one-page document per role is sufficient. Keeping them updated is a best practice that strengthens your CC1.4 story.

Step 2: Set a realistic review cadence

Annual reviews are the most common cadence for satisfying SOC 2’s CC1.4 requirement. For startups, this is often the right choice—it’s frequent enough to satisfy most auditors without creating constant process overhead.

Pick a consistent time each year. Many companies align with fiscal year-end or avoid Q4 entirely (when everyone’s busy closing deals and shipping releases). The key is consistency: if your policy says reviews happen in Q2, they need to happen in Q2.

Step 3: Gather context before writing

The biggest time sink in performance reviews is managers staring at blank documents trying to remember six months of work. Flip the script: gather context first, then write.

Self-reviews: Ask employees to document their own accomplishments and development areas. Keep it to 3-5 questions. This surfaces contributions managers might have missed.

Peer feedback (optional but valuable): Even one or two peer perspectives add dimension. Ask simple questions: What does this person do well? Where could they improve?

Work artifacts: Pull data from your existing tools. What did this person ship? What projects did they lead? What does their GitHub activity, Jira history, or Salesforce dashboard show?

Step 4: Write substantive but concise reviews

Auditors don’t grade on length. A well-structured one-page review is better than a rambling five-page document.

Every review should cover:

Key accomplishments with specific examples
Areas for development with actionable suggestions
Assessment against role expectations (from job descriptions, leveling frameworks, or OKRs)
Goals for the next period

Connecting reviews to documented role expectations is a strong best practice. This creates the throughline auditors want to see: defined expectations → evaluation against expectations → development plan.

Step 5: Document and store everything

If it’s not documented, it didn’t happen. Ensure every review is:

Saved in a centralized, searchable location
Associated with the correct employee and time period
Accessible when auditors request samples

Compliance platforms like Vanta or Drata can help organize this evidence, but even a well-structured Google Drive folder works for smaller teams.

How Nirvana ran SOC 2 ready reviews without an HR team

Nirvana, a healthcare technology company, faced exactly this challenge. As Emily Baccaglini, their Chief of Staff, put it: “Without an HR team, performance reviews typically mean long hours, scattered spreadsheets, and immense administrative burden.”

For Emily, running the company’s first formal performance review cycle—during their busiest season—seemed daunting. She needed a process that wouldn’t “disrupt or distract the team from their day-to-day work.”

Using Windmill, Nirvana achieved:

100% completion rate for self and upward reviews
5-minute median peer review time
50-minute median self-review time
80% employee preference for Windmill among those with prior review experience

The key was meeting employees where they already worked. Instead of introducing new software, Windmill’s AI assistant Windy conducted reviews through Slack conversations. “Because Slack is part of our everyday workflow, the rest of the team was immediately very comfortable engaging with Windy there—which made the whole process extremely low-lift.”

For SOC 2 purposes, every review was documented, timestamped, and stored—ready for auditor sampling whenever needed.

Automating compliance without enterprise overhead

The traditional choice for startups has been: spend weeks on manual reviews, or invest in expensive enterprise HR platforms designed for companies ten times your size.

Windmill offers a third path. Built for companies that need mature performance management outputs without dedicated HR teams, Windmill automates the most time-consuming parts of the review process:

Self-reviews via Slack: Employees chat naturally with Windy instead of filling out forms. Completion rates jump from typical 50-60% to 90%+.
Automatic context gathering: Windmill integrates with GitHub, Jira, Linear, Salesforce, and 30+ other tools to surface what employees actually accomplished.
AI-drafted reviews: Managers select key wins and development areas, then Windy generates a draft. Average time per review: 6 minutes instead of 6 hours.
Built-in documentation: Every review is automatically stored with full audit trails—no manual filing required.

For SOC 2 specifically, this means your CC1.4 evidence is generated as a byproduct of running reviews, not as extra compliance work.

Timeline: From zero to audit-ready

If you’re starting from scratch, here’s a realistic timeline to implement SOC 2 compliant performance reviews:

Week 1: Foundation

Document job descriptions for all roles
Choose your review tool (manual, spreadsheet, or automated)
Communicate the process to employees

Weeks 2-3: First review cycle

Collect self-reviews (5-7 days)
Gather peer feedback if included (5-7 days, can overlap)
Managers write reviews (7-10 days)

Week 4: Finalization

Brief calibration discussion to ensure consistency
Deliver reviews in 1:1 meetings
Store all documentation

With Windmill, this timeline compresses significantly. Rho completed their entire cycle—from self-reviews through manager reviews—in 8 days.

Common mistakes that create audit risk

Inconsistent coverage: If 90% of employees have reviews but 10% don’t, auditors will notice. Ensure every employee is included.

Missing documentation: Verbal feedback doesn’t count. If reviews aren’t written down and stored, they’re invisible to auditors.

Disconnected from role expectations: Reviews are strongest when they reference documented expectations (job descriptions, leveling frameworks, or OKRs). Generic feedback that could apply to anyone raises questions.

Irregular timing: If your policy says annual reviews but you skip a year, that’s a control failure. Pick a cadence you can sustain.

Last-minute scrambles: Rushing reviews the week before an audit produces low-quality documentation. Build reviews into your regular operating rhythm.

Beyond compliance: Reviews that actually help

The best outcome isn’t just passing your SOC 2 audit—it’s building a performance culture that helps your company grow. When reviews happen consistently:

Employees get clarity on expectations and growth paths
Managers identify development needs before they become performance problems
The company builds documentation that supports promotion and compensation decisions

SOC 2 compliance becomes a forcing function for practices you’d want anyway. The audit requirement just ensures you actually do them.

Key takeaways

SOC 2 CC1.4 requires evidence of employee evaluation—performance reviews are the most common and defensible way to satisfy this.
Auditors sample evaluation evidence during audits—gaps in coverage or documentation create compliance risk.
You don’t need an HR team to run compliant reviews. You need a clear process, consistent execution, and proper documentation.
Automation dramatically reduces burden. Tools like Windmill cut review time by 90% while generating audit-ready documentation automatically.
Start simple. A well-executed basic process beats an elaborate system you can’t sustain.

SOC 2 compliance opens doors to enterprise customers who require it. Don’t let employee evaluation be the unexpected blocker. Build a sustainable process now, and you’ll satisfy auditors while actually developing your team.

Frequently Asked Questions

Are performance reviews required for SOC 2 compliance?

Not explicitly, but they're the most common and defensible way to satisfy the requirement. SOC 2 Common Criteria 1.4 (CC1.4) requires organizations to demonstrate commitment to developing and evaluating employees. Auditors verify this by requesting evidence of competence evaluation—which can include performance reviews, documented manager check-ins, training records, or promotion review documentation. Performance reviews are the most straightforward evidence to produce and explain.

How often do performance reviews need to happen for SOC 2?

Most auditors expect at least annual reviews, and annual cadence is the safest default. Some accept rolling reviews or continuous documented check-ins if there's a defined process. The key is consistency—if your policy states a specific cadence, you must follow it. Sporadic or undocumented evaluation is what creates compliance risk.

Can a startup pass SOC 2 without an HR department?

Absolutely. Many startups achieve SOC 2 compliance without dedicated HR or security teams. The key is implementing clear processes and using automation tools to handle documentation. Chiefs of Staff, founders, or operations leads often manage HR-related compliance requirements at early-stage companies.

What should a SOC 2 compliant performance review include?

A strong review should document: key accomplishments with specific examples, areas for development, assessment against role expectations (from job descriptions, leveling frameworks, or OKRs), and goals for the next period. Connecting reviews to documented role expectations is a best practice that strengthens your CC1.4 story. Reviews should be stored in a retrievable format. Length matters less than substance and consistency.

How do I document performance reviews for SOC 2 auditors?

Store all reviews in a centralized, searchable location with clear timestamps and employee associations. Auditors will request samples during the audit, so reviews must be quickly retrievable. Compliance platforms, dedicated HR tools like Windmill, or even well-organized cloud storage can satisfy this requirement—the key is consistency and accessibility.