C5
BSI C5:2020 attestation program build and ongoing support for B2B SaaS and consulting firms in the German enterprise market.

Comprehensive BSI C5 Attestation Consulting & End-to-End ISAE 3000 Program Build
C5:2020 is the cloud assurance criteria catalogue published by Germany's Federal Office for Information Security (BSI). It is the principal procurement signal for cloud services entering the German federal government and the largest German enterprise buyers, including the DAX 40 supply chain. C5 is an attestation, not a certification: an independent auditor (typically a German Wirtschaftsprüfer firm) examines the cloud service provider's controls under ISAE 3000 or the equivalent IDW PS 860 and issues an AT-1 Type 1 (point in time) or AT-2 Type 2 (operating effectiveness across a 6 to 12 month observation period) attestation report. The C5 control set is organized into 17 subject areas with Basic Criteria and optional Additional Criteria for higher-assurance workloads.
Security Consultants prepares CSPs for C5 attestation. We are not an attestation auditor. We scope the cloud service against C5:2020, author the System Description (SoyD), align documentation to all 17 subject areas, uplift cryptography to BSI Technical Guideline TR-02102, build the government investigative authority handling procedure (INQ), document portability and interoperability (PI), and manage the subservice organization register with C5 reliance evidence from AWS, Microsoft Azure, Google Cloud, or Oracle. Once the attestation report is issued, our vCISO subscription operates continuous evidence collection through the observation period, annual penetration testing, BCP and DR testing, and cryptography reviews against TR-02102 updates. The same evidence base supports parallel ISO 27001 and SOC 2 programs.
System Description (SoyD) Built for the German Auditor
The SoyD is what the Wirtschaftsprüfer examines first. We author it with the depth on processing locations, subservice organization reliance from your underlying IaaS provider's C5 attestation, Complementary User Entity Controls, and Complementary Subservice Organization Controls that German auditors expect. No thin or boilerplate System Descriptions.
BSI TR-02102 Cryptography Alignment
German auditors test algorithm selection against BSI Technical Guideline TR-02102 across general use, TLS, IPsec, and SSH. We audit your cryptographic inventory, deprecate non-compliant cipher suites, document the key management lifecycle, and build HSM use into the architecture where Additional Criteria require customer-controlled keys.
INQ and PI: The C5-Distinct Controls
Government investigative authority handling (INQ) and Portability and Interoperability (PI) are C5-specific subject areas without equivalents in SOC 2 or ISO 27001. We build the INQ procedure for receipt, validation, escalation, and lawful customer disclosure, plus the documented data export tooling that PI examiners test.
Readiness Consulting, Not Attestation Audit
We prepare you for the auditor. We are not the auditor and never will be. That separation lets us build a defensible System Description, run the pre-audit readiness review, and advocate through the fieldwork without the conflict that comes from selling readiness and attestation under one roof.
A proven, methodical
approach
Project Kick-Off & Setup
We start with a project kick-off where the manager sets up your engagement in our project management platform. We confirm your target report (AT-1 Type 1 or AT-2 Type 2), define the scope, select your auditor or coordinate with your existing Wirtschaftsprüfer firm, agree the observation period, and name a program lead.
Scope Definition & Subservice Organization Mapping
We confirm the cloud service in scope, the data sensitivity and customer-base profile, the Basic Criteria baseline, and which Additional Criteria apply. The subservice organization register maps every underlying IaaS provider (AWS, Azure, GCP, Oracle, IBM) to its existing C5 attestation and documents the carve-out or inclusive method.
Gap Analysis Against C5:2020
We assess implementation control-by-control across all 17 C5 subject areas: OIS, HR, AM, PS, RB, OPS, IDM, CRY, COS, PI, DEV, SSO, SIM, BCM, COM, INQ, and PSS where applicable. Remediation is prioritized by auditor risk and observation-period start date.
System Description Authoring & Documentation Stack
We author the SoyD with the depth a German auditor expects, build the cryptography policy aligned with BSI TR-02102, document the INQ government request handling procedure, prepare the PI portability and interoperability documentation, and align the BCP, DR, and IR procedures to the 17 subject areas.
Technical Remediation & Auditor Coordination
We close the technical gaps: TR-02102-aligned cryptography across general, TLS, IPsec, and SSH; phishing-resistant MFA on privileged access; centralized logging with retention sufficient for the observation period; annual penetration testing for Additional Criteria coverage. We coordinate the AT-1 or AT-2 fieldwork with the Wirtschaftsprüfer and represent the program through finding response.
Post-Attestation Operations, vCISO & Ongoing Assurance
After the attestation report is issued, our vCISO subscription operates continuous evidence collection through the next observation period, quarterly access reviews, annual BCP and DR testing, annual penetration testing, TR-02102 reviews on BSI updates, and subservice organization C5 documentation refresh. The evidence base is shared with parallel ISO 27001 and SOC 2 programs.