United States · Fintech companies
ISO/IEC 27001 for US Fintech Companies: Banks, Regulators, Buyers
How ISO/IEC 27001 helps US fintechs answer banks, the FTC Safeguards Rule, NYDFS Part 500 and SEC-driven vendor reviews, prepared by Sterling.
Did you know ISO 27001 can cost less than US$10,000, all-inclusive? If you've been quoted more, talk to us before you sign.
100% success, on time: the Sterling Promise
We stay with you until your agreed outcome is achieved, through consulting, audit preparation and the resolution of audit findings. The engagement defines the standard, scope, outcome and responsibilities; your organization puts the agreed controls into use; an accredited certification body issues the certificate, and that decision stays independent.
Done for you, end to end
We write the policies, set up the controls and evidence, run the internal audit and coordinate the independent audit. You deal with one team from first call to final report.
Simple and quick
A free gap assessment, then one plan with dates from day one. Effivity, our GRC automation platform, is included to keep the evidence moving.
8,100+ client engagements
In 60+ countries over 20+ years, with experts who bring 30+ years of experience.
Under US$10,000, all-inclusive
For most start-ups and SMEs: SOC 2, ISO 27001, ISO 42001, HIPAA or ISO 9001, including the independent audit. A fixed quote follows a free gap assessment.
Included in every engagement
Every Sterling consulting engagement comes with the following, so you are not buying extras to get to the finish line:
- Effivity, Sterling's GRC automation platform, with a full-year subscription, to run your controls, evidence, tasks and audits in one place.
- Sterling Academy: preferential course access, with complimentary awareness training for your people.
- Internal auditor training for your audit team, as applicable to your standard.
- For information-security engagements, a vulnerability assessment.
These are part of the engagement, not a separate purchase. The details depend on the standard you are working toward, which we confirm during the free gap assessment.
Consulting and auditing are always separated: the people who consult never audit you. That keeps your internal audit objective and protects the independence of the CPA firm, Qualified Security Assessor or certification body that performs the final step.
Behind this are 8,100+ client engagements in 60+ countries over 20+ years, led by experts with 30+ years of experience.
All-inclusive pricing for start-ups and SMEs
Did you know SOC 2 or ISO 27001 can cost less than US$10,000, all-inclusive? If you've been quoted more, talk to us before you sign.
Sterling's all-inclusive fee for SOC 2, ISO 27001, ISO 42001, HIPAA or ISO 9001 is under US$10,000 for most start-ups and SMEs. It covers our done-for-you consulting and the independent audit: the SOC 2 report from a US-licensed CPA firm, as AICPA standards require, or the certification audit by an accredited certification body. For HIPAA, it covers HIPAA compliance consulting and an independent HIPAA assessment. Effivity, training and a vulnerability assessment are included. That's less than a month's cost of an in-house security hire: the US Bureau of Labor Statistics puts the national median annual wage for information security analysts at $129,180 (May 2025), about $10,765 a month in pay alone[1].
A fixed quote follows a free gap assessment.
What the fee covers, and what it doesn't:
- It is the fee for your first SOC 2 report or your first certification only.
- Annual work is always additional and billed the following year: later SOC 2 report periods, and ISO surveillance and recertification audits.
- It assumes a typical start-up or SME scope: one product or service and one main location.
- Larger or multi-site scopes get a fixed quote after the gap assessment.
- PCI DSS is quoted separately: a fixed quote follows a free gap assessment.
[1] Occupational Employment and Wage Statistics, May 2025: 15-1212 Information Security Analysts, national annual median wage. US Bureau of Labor Statistics. accessed October 23, 2026.
Why US fintechs are asked for ISO/IEC 27001
The outcome: a certified information security management system that bank, insurer and enterprise reviewers recognize in the US and abroad, prepared for you and audited by an accredited certification body. Sterling prepares you; Sterling does not certify.
ISO/IEC 27001 is the international standard for information security management systems[1]. No US financial regulation requires it. In Sterling's experience, US fintechs meet it in four situations:
- Foreign banks and insurers. Procurement teams in Europe, the Gulf or Asia name it in their vendor requirements.
- US institutions with global operations. One supplier standard recognized in every region.
- Multi-country products. Engineering in one country, customers in another, one system covering both.
- US boards and investors. A security program with owners, objectives and annual review, not a run of one-off projects.
What the FTC, NYDFS and the SEC expect from US fintechs
The outcome: one system whose records serve your own regulatory duties and your customers' vendor reviews. ISO/IEC 27001 supports that work; it does not replace it.
- FTC Safeguards Rule. For financial institutions within its scope, 16 CFR 314.4 requires a written risk assessment, a designated Qualified Individual, access controls, encryption of customer information, multi-factor authentication, a written incident response plan and oversight of service providers[2]. Absent effective continuous monitoring, it requires annual penetration testing and vulnerability assessments at least every six months[2]. The Qualified Individual must report in writing to the board at least annually[2].
- New York. DFS promulgated 23 NYCRR Part 500 on March 1, 2017. It covers anyone operating under, or required to operate under, a license, registration, charter or similar authorization under New York's Banking, Insurance or Financial Services Law[3].
- Public-company customers. SEC Regulation S-K Item 106 requires registrants to describe whether they oversee cybersecurity risks from third-party service providers[4].
An ISMS has the same skeleton: risk assessment, owners, controls, monitoring, response and supplier oversight. We map each duty to it during scoping.
Scoping the ISMS around what US customers rely on
The outcome: a scope statement that answers your largest customer's question by itself.
- Product and platform. Every environment where customer financial data lives.
- Teams. Whoever builds, runs and supports it, wherever they sit.
- Offices and remote work. Stated clearly.
- Key providers. Cloud, identity verification, payments processing, treated as managed interfaces.
- Justified exclusions. For example an unrelated legacy product.
Two calls recur. An ISMS that stops at the corporate network will not satisfy a bank, so include production. If a licensed entity and an unlicensed one share management, decide whether one scope or two reflects reality. We settle the statement during the gap assessment and test it against your largest customer's due-diligence questions before it is fixed.
The controls US bank and insurer reviewers test first
The outcome: the areas where a fintech audit is won or lost are covered first. This is Sterling's plain-English summary, not the standard's text.
- A risk register in use. Owners and a treatment decision for each material risk, revisited when products change.
- Access to production. Role-based, strongly authenticated, reviewed, with leavers removed promptly.
- Secure development. Review, testing, separate environments and controlled releases.
- Cryptography and test data. Encryption, key custody and no live customer data in development.
- Providers. Who reaches which data, with reviews matched to risk.
- Vulnerabilities and logging. Problems found and fixed within a stated time.
- Incidents and continuity. A tested plan and backups that have been restored.
- The management loop. Objectives, internal audit, management review and corrective action, where fast-shipping teams most often fall short.
Where US fintech ISMS projects slip
The outcome: we take these off the critical path.
- A borrowed policy pack. It describes another company and fails at interview.
- No management review. A founder who has never seen the risk register is an easy finding.
- The product scoped out. Fine until it excludes what customers use.
- Unmanaged payment and identity providers. Show how you choose and monitor them.
- Paper without operating history. Auditors want records that controls ran.
- Stopping at the certificate. Surveillance audits follow, and the system must keep running.
How Sterling takes a US fintech to ISO/IEC 27001
The outcome: a successful certification audit, with the work done for you. Sterling's record is 100% success and on-time completion across 8,100+ client engagements in 60+ countries over 20+ years, and our experts bring 30+ years of experience. The people who consult never audit you.
1. Free gap assessment. Current practice measured against the standard and your FTC or NYDFS duties, with a proposed scope. 2. System design. Risk method, policies, procedures and the statement of applicability, built around your engineering and operations. 3. Operation. Your team runs the system; Effivity holds the register, tasks and records. 4. Internal audit and management review. We test first and help leadership complete its review. 5. Certification audit. We coordinate with the accredited body you select and support you through any findings.
Bank reviews waiting on you? Get started and a Sterling expert will reply.
How Sterling delivers ISO certification
ISO management system standards such as ISO/IEC 27001, ISO/IEC 42001 and ISO 9001 are certified by an accredited certification body, not by a consultant[1]. Sterling never certifies. The certificate carries the name of the body that issued it, and that independence is what makes it credible to your buyers.
What Sterling does is prepare your company so that the certification body's audit goes smoothly. We coordinate:
- a gap assessment against the standard;
- the management system itself: scope, risk assessment, policies, procedures and records, sized for your company;
- training for your people and an internal audit before the certification audit;
- management review and corrective actions;
- the certification audit process, from choosing an accredited body to closing any findings.
Consulting and auditing are always separated. The people who consult never audit you, so the internal audit is a genuine test and the certification body's audit is independent.
Sterling has completed 8,100+ client engagements in 60+ countries over 20+ years, and our experts bring 30+ years of experience.
[1] About the IAF MLA (multilateral recognition arrangement). International Accreditation Forum (functions transferred to Global Accreditation Cooperation Inc., 1 Jan 2026). accessed October 23, 2026.
Sources
1. ISO/IEC 27001, Information security management systems (standard listing). ISO. accessed October 23, 2026.
2. 16 CFR 314.4 Elements (FTC Safeguards Rule), paragraphs (a)-(d), (f), (h) and (i). Electronic Code of Federal Regulations. accessed October 26, 2026.
3. Cybersecurity Resource Center (23 NYCRR Part 500: promulgated March 1, 2017; who must comply). New York State Department of Financial Services. accessed October 26, 2026.
4. 17 CFR 229.106 (Item 106 of Regulation S-K) Cybersecurity, paragraph (b)(1)(iii). Electronic Code of Federal Regulations (SEC). accessed October 26, 2026.
Information only
The information on this page is provided for general informational purposes only. It is not legal advice, and it is not a substitute for advice from a qualified attorney about your own situation.
Requirements depend on your scope, your customers' contracts, your industry and the regulations that apply to you. Two companies asking for the same standard can have very different obligations. We confirm yours during a gap assessment, and we update our content as standards change, but you should check the current text of any standard or rule that matters to you.
Sterling consults and prepares. It does not decide whether you meet a standard. That decision belongs to the independent party that performs the final step: the US-licensed CPA firm for a SOC 2 report, the Qualified Security Assessor or acquirer for PCI DSS, and the accredited certification body for ISO certificates. Timelines and outcomes depend on your readiness and on those parties.
Standards and marks named on this site belong to their respective owners.
FAQs
Frequently asked questions
Does ISO 27001 replace a SOC 2 report for a US fintech?
Usually not. They serve different readers. A SOC 2 report is what most US bank and enterprise reviewers expect, while ISO/IEC 27001 is the certificate recognized internationally. Many fintechs end up holding both, and one risk assessment and control set can serve each. We help you choose which comes first from the contracts and reviews in front of you.
Is ISO 27001 required by the FTC Safeguards Rule or NYDFS?
No. The Safeguards Rule sets its own required elements for covered financial institutions[2], and Part 500 is New York's cybersecurity regulation for entities operating under authorizations from its banking, insurance or financial services laws[3]. Neither requires ISO/IEC 27001. A working ISMS covers the same ground, so its records support both duties without a second program.
Who issues the ISO 27001 certificate?
An accredited certification body audits your management system and decides whether to issue a certificate. Sterling prepares you, runs the internal audit and coordinates the process, but Sterling does not certify. Consulting and auditing are always separated, so the people who consult never audit you, and you deal with Sterling from scoping to the decision.
Our vulnerability testing already follows the Safeguards Rule. Does that count?
It helps. Where effective continuous monitoring is absent, the rule requires annual penetration testing and vulnerability assessments at least every six months[2]. Those results are useful evidence for an ISMS, which also needs a method for acting on findings within a stated time. Your Sterling engagement includes a vulnerability assessment as well, because ISO/IEC 27001 is an information-security engagement.
How long does it take?
It depends on scope, the documentation you already have and how quickly your team builds operating records. The system has to run for a period before the certification audit so there is evidence to examine. We set a dated plan after the gap assessment, tied to your commercial deadlines, rather than quoting a duration before we have seen your environment.
What happens after we are certified?
The certification body returns for surveillance audits in later years and for recertification at the end of the cycle. Your system keeps operating in between, which is why we set up Effivity and train your own internal auditors. Those later audits are annual work billed the following year, and we explain them before you sign.
Can the same work support PCI DSS later?
Partly. Access control, change management, logging, provider oversight and incident evidence carry across. PCI DSS has its own scoping and validation rules, so it runs as a separate track and is quoted separately: a fixed quote follows a free gap assessment. We plan both together so nothing is built twice.
What is included in the engagement?
Effivity, Sterling's GRC automation platform, with a full-year subscription; Sterling Academy preferential course access, with complimentary awareness training for your people; internal auditor training for your audit team, as applicable to your standard; and a vulnerability assessment. The certification body's audit sits inside the all-inclusive fee for a typical scope.
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Compliance for Fintech companies in the US
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