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10 SOC Type I vs Type II

SOC reports commonly appear in two forms:

Type I
Type II

The difference is fundamental because they answer different assurance questions.

A Type I report asks:

Are the controls suitably designed and implemented at a specified point in time?

A Type II report asks:

Were the controls suitably designed and did they operate effectively throughout a defined period?

A simple comparison is:

Type I
→ Point in Time
Type II
→ Period of Time

For GRC professionals, understanding this distinction is essential when:

  • Evaluating third-party providers.

  • Preparing for SOC examinations.

  • Reviewing audit evidence.

  • Supporting external auditors.

  • Assessing report freshness.

  • Deciding whether additional assurance is required.

  • Managing bridge periods.

  • Evaluating control exceptions.

By the end of this lesson, you will be able to:

  • Explain SOC Type I reports.

  • Explain SOC Type II reports.

  • Distinguish point-in-time from period-of-time assurance.

  • Understand control design.

  • Understand control implementation.

  • Understand operating effectiveness.

  • Understand report periods.

  • Understand control operating periods.

  • Understand population and sampling.

  • Understand evidence coverage.

  • Analyze Type II exceptions.

  • Understand bridge periods.

  • Understand bridge letters.

  • Evaluate report freshness.

  • Determine which report type fits an assurance need.

  • Understand how user auditors rely on reports.

  • Build practical Type I vs Type II assessment artifacts.

Consider a service provider that claims:

Quarterly privileged-access reviews are performed.

A Type I report might establish that:

Review Process Exists
Owner Assigned
Procedure Documented

at one particular date.

A Type II report may establish whether:

Q1 Review Completed
Q2 Review Completed
Q3 Review Completed
Q4 Review Completed

during the examination period.

That is a significantly different level of assurance.

A Type I report evaluates controls at a specified date.

Example:

As of:
31 December 2026

The focus is generally on:

System Description
Control Design
Control Implementation

at that date.

Think of Type I as a snapshot:

Organization
31 December
Controls Evaluated

It answers:

What does the control environment look like on this date?

Control:

All production administrators are required to use MFA.

At the specified date, the auditor may determine:

Policy Exists
MFA Configuration Exists
Administrators Covered

This can support a Type I conclusion.

Type I does not provide the same period-of-time evidence that the control operated consistently for prior months.

For example:

MFA Enabled
on
31 December

does not automatically prove:

MFA Was Enabled
Throughout January–December

The primary question is:

Is the control suitably designed and implemented at the specified date?

A Type II report covers a defined period of time.

Example:

01 January 2026
through
31 December 2026

It evaluates:

Control Design
Implementation
Operating Effectiveness

Think of Type II as a movie rather than a photograph.

January
February
March
...
December

The question becomes:

Did the controls operate effectively throughout the defined period?

Control:

Privileged access is reviewed quarterly.

Expected:

Q1
Q2
Q3
Q4

Auditor may test several or all review cycles depending on the audit approach.

Area Type I Type II
Specific Date Yes No
Defined Period No Yes
Control Design Yes Yes
Implementation Yes Yes
Operating Effectiveness No Yes
Testing Across Period No Yes

Design effectiveness asks:

If the control operates exactly as designed, will it reasonably achieve its objective?

Example risk:

Unauthorized Administrator Access

Weak control:

Administrator passwords must contain eight characters.

Even if implemented perfectly, this may not sufficiently address the risk.

A stronger control might be:

Privileged access requires approved role assignment, MFA, least privilege, logging, and quarterly review.

The control is more likely to address the intended risk.

Implementation asks:

Has the designed control actually been put into operation?

Example:

Policy Says:
MFA Required

but:

MFA Technology
Not Configured

Then the control is designed but not implemented.

Design
→ What should happen?
Implementation
→ Is it actually in place?

Operating effectiveness asks:

Did the control actually operate as designed throughout the period?

Example:

Quarterly Access Review

Expected:

4 Reviews

Actual:

Q1 ✓
Q2 ✓
Q3 ✗
Q4 ✓

Conclusion:

Operating Effectiveness Issue

A well-designed control that does not operate is not reliable.

Example:

Security Policy:
Excellent

but:

Access Reviews:
Never Performed

This creates control failure.

Organizations pursuing their first SOC report may begin with Type I because it can help demonstrate that the control environment has been established.

Conceptually:

Design Controls
Implement Controls
Type I
Operate Controls
Type II

This can be useful, but a Type I is not always required before Type II.

Before a Type II examination, controls need time to operate.

Example:

Control Environment Established:
January

Type II period:

March–August

The organization needs sufficient evidence throughout the period.

Create a register showing when each control became operational.

Example:

Control Effective Date
MFA 01 Jan
Vendor Review 01 Jan
New DLP Control 15 Apr

Suppose Type II period is:

01 January – 30 June

But DLP control started:

15 April

The control did not operate for the entire period.

This requires consideration during the examination.

Evidence should correspond to the control period.

Example:

Control:
Monthly Vulnerability Review

Type II period:

6 Months

Expected evidence may include:

January Review
February Review
March Review
April Review
May Review
June Review

If March evidence is unavailable:

Control May Have Operated

but:

Unable to Demonstrate

This can become an audit exception.

Create:

01 Evidence Coverage Register

Use:

Control Frequency Expected Evidence Available Gap

Controls may operate:

Continuous
Daily
Weekly
Monthly
Quarterly
Annually
Event Driven

Frequency affects testing.

Example:

MFA Enforcement

may operate continuously.

Evidence may include:

Configuration
Population
Exceptions
Monitoring

Example:

Backup Job Monitoring

A Type II auditor may test samples across the period.

Example:

Vulnerability Review

Expected population across a twelve-month period:

12 Reviews

Example:

Privileged Access Review

Population:

4 Reviews Per Year

Example:

Security Risk Assessment

There may be only one execution during the report period.

This makes timing especially important.

Examples:

New Hire Access Approval
Production Change
Incident Response
Vendor Onboarding

The population depends on events occurring during the period.

A control population is the complete set of instances that should be subject to the control.

Example:

Production Changes:
3,200

This is the population for a production change-control test.

If the audit population excludes:

Emergency Changes

then the auditor may be testing an incomplete population.

Population completeness is fundamental.

Good sources may include:

Ticketing Systems
Identity Platforms
Cloud APIs
HR Systems
CI/CD Platforms
Security Tools

Auditors often cannot inspect every manual control instance.

They may sample from the population.

Example:

Population:
1,000 Access Requests
Sample:
40

For each selected item, auditor may verify:

Request
Approval
Role
Date
Provisioning

36. Sampling Does Not Mean Random Guessing

Section titled “36. Sampling Does Not Mean Random Guessing”

Audit sampling should follow an appropriate audit methodology.

From a GRC readiness perspective, your responsibility is to ensure:

Population Complete
Evidence Available
Control Operation Consistent

Some controls can support full-population testing.

Examples:

MFA Coverage
Encryption
Public Exposure
Security Agent Coverage

This may reduce reliance on manual sampling.

Type I evidence often focuses on:

Current Configuration
Current Policy
Current Control Owner
Current Implementation

Type II evidence may include:

Historical Configurations
Recurring Reports
Control Execution Records
Tickets
Approvals
Monitoring Results

across the report period.

Auditor asks:

Does a quarterly access-review control exist as of the report date?

Evidence:

Procedure
Owner
Current Access Review

Auditor asks:

Did the quarterly access-review control operate effectively during the report period?

Evidence:

Q1
Q2
Q3
Q4
Vendor Risk Process Exists
New Vendors During Period
Were Assessments Completed?
Change Process Defined

Auditor samples:

Production Changes

and verifies:

Approval
Testing
Deployment
Incident Response Process Exists

Auditor may select incidents during the period and inspect:

Classification
Investigation
Escalation
Closure

An exception occurs when tested evidence does not conform to the control description or expected operation.

Example:

Control:

Production changes require approval before deployment.

Test:

40 Changes

Exceptions:

3 Approved After Deployment

45. Exception Does Not Automatically Mean Qualified Opinion

Section titled “45. Exception Does Not Automatically Mean Qualified Opinion”

Important:

Control Exception
Automatically Modified Opinion

The service auditor evaluates significance across the engagement.

GRC should examine:

Control
Sample Size
Number of Exceptions
Risk
Root Cause
Period
Management Response

Example:

1 Exception
out of
60 Samples

caused by:

Missing Documentation

This may differ significantly from a systemic failure.

Example:

22 Exceptions
out of
40 Samples

This may indicate the control is not operating consistently.

Create:

02 Exception Impact Matrix

Use:

Control Samples Exceptions Risk Systemic? Action

The service organization may explain:

Root Cause
Correction
Corrective Action

Example:

The organization implemented automated workflow enforcement after identifying the approval issue.

51. Management Response Is Not Auditor Testing

Section titled “51. Management Response Is Not Auditor Testing”

The response is useful but should not be confused with independent testing.

A corrective action implemented late in the report period may require future validation.

Type II reports state a defined examination period.

Example:

01 July 2025
through
30 June 2026

Always record this period.

Your organization’s assessment period may differ.

Example:

Provider SOC:
Jul 2025 – Jun 2026
Your Audit:
Jan – Dec 2026

Uncovered period:

Jul – Dec 2026

The period between:

SOC Report End Date

and:

Customer Assessment Date

is sometimes referred to operationally as the bridge period.

A provider may provide a letter addressing significant changes after the SOC report period.

It may state that management is not aware of material changes to the control environment.

Remember:

Bridge Letter
Independent Type II Testing

It should be evaluated as supplemental assurance.

SOC report ends:

31 March

Current review:

31 August

Gap:

5 Months

Request:

Bridge Letter
Major Change Disclosure
Incident Information

A GRC team should define acceptable assurance freshness.

Example:

Critical Providers
→ Current SOC Type II

If report is too old:

Additional Assurance Required

A low-risk provider and a critical identity provider may have different assurance expectations.

Consider:

Criticality
Data Sensitivity
Control Dependency
Contract Requirements

A Type I report may still be valuable.

For example:

New SaaS Company
Recently Established Controls
Type I Available

GRC may use it with additional assurance.

If your requirement is:

Demonstrate operating effectiveness over time.

Then:

Type I Alone

may be insufficient.

Type II generally provides stronger historical evidence for recurring controls.

Useful areas include:

Access Reviews
Change Management
Incident Response
Vendor Assessments
Backup Monitoring

63. Type II Does Not Mean Perfect Security

Section titled “63. Type II Does Not Mean Perfect Security”

A Type II report may still contain:

Exceptions
Carve-Outs
CUECs
Scope Limitations

It should still be reviewed carefully.

A provider may be:

Early in SOC Program

while still having strong controls.

Risk assessment should consider context.

Ask:

What assurance question are we trying to answer?

If:

Are controls established today?

Type I may be useful.

If:

Did controls operate consistently during the last year?

Type II is more appropriate.

Need Operating Effectiveness?
├── Yes → Type II Preferred
└── No
Need Point-in-Time Design Assurance?
├── Yes → Type I May Be Suitable
└── Evaluate Other Assurance

For SOC 1:

Type I
→ ICFR-Relevant Control Design at Date
Type II
→ ICFR-Relevant Control Operation Across Period

Financial auditors often place greater reliance on Type II when period coverage is needed.

For SOC 2:

Type I
→ TSC Control Design at Date
Type II
→ TSC Operating Effectiveness Across Period

User auditors consider whether the SOC report provides evidence relevant to their audit objective.

They may assess:

Report Type
Period
Scope
Controls
Exceptions
CUECs

Example:

User audit:

01 Jan – 31 Dec

SOC 1 Type II:

01 Apr – 31 Mar

The periods overlap but do not fully align.

Additional procedures may be required.

Regardless of Type I or Type II:

Provider Controls
+
Customer Controls

may be required.

A Type II report does not eliminate the customer’s CUECs.

Type II report may use:

Inclusive Method

or:

Carve-Out Method

Review dependencies.

SaaS provider Type II report:

Application Controls
→ Covered

Cloud-hosting provider:

Carved Out

The Type II status does not automatically provide assurance over the carved-out cloud controls.

74. Report Scope Matters More Than Report Label

Section titled “74. Report Scope Matters More Than Report Label”

A Type II report that does not cover your product may be less useful than a Type I that directly covers it.

Always prioritize:

Relevant Scope

Create:

03 SOC Report Period Register

Use:

Provider Report Start End Review Date Gap

Create:

04 Control Operating Period Matrix

Use:

Control Effective Date Report Start Full Period? Status
Control Effective Date Type II Start Full Period?
MFA 01 Jan 01 Jan Yes
DLP 01 Apr 01 Jan No

Create:

05 Evidence Coverage Matrix

Use:

Control Jan Feb Mar Apr May Jun

Use:

✓ Evidence Available
✗ Missing
N/A Not Required

This makes it easy to identify gaps before the auditor arrives.

Before Type I, validate:

Controls Designed
Policies Approved
Owners Assigned
Systems Configured
Evidence Available

Before Type II, also validate:

Controls Operating Consistently
Historical Evidence Retained
Exceptions Managed
Populations Available

Control:

Quarterly Vendor Review

If Type I date is:

31 December

the organization should demonstrate the control has been designed and implemented as of that date.

For Type II:

01 Jan – 31 Dec

the organization must support evidence showing operation across the period.

Perform a monthly readiness review:

Control
Evidence Due?
Available?
├── Yes → Store
└── No → Escalate

85. Evidence Should Be Collected During the Period

Section titled “85. Evidence Should Be Collected During the Period”

Weak approach:

Audit Starts
Recreate 12 Months of Evidence

Strong approach:

Control Operates
Evidence Captured
Stored Continuously

Evidence should preserve:

Date
Source
Population
Approver
Control Execution

Avoid creating evidence after the fact to make it appear that controls operated earlier.

The appropriate action is to document the gap and remediate.

Example:

MFA Configuration Failed
for
2 Days

Do not hide it.

Document:

Duration
Impact
Root Cause
Correction
Monitoring

Suppose the issue is corrected halfway through the report period.

The auditor may still report the historical exception.

Remediation does not erase prior failure.

Controls can change.

Example:

Manual Access Review
Automated Access Review

Document:

Old Control
Transition Date
New Control
Evidence

Poorly documented transitions can create:

Evidence Gap
Population Gap
Ownership Gap

A new subsidiary or system may enter scope during the report period.

Determine:

When Added?
Controls Implemented?
Evidence Available?
Included in Scope?

Similarly:

New Product Launch
Scope Assessment
Control Coverage

Material changes should be communicated to the auditor where relevant.

Examples:

Cloud Migration
Acquisition
Major Architecture Change
Identity Provider Change

Create:

06 SOC Report Selection Checklist

Ask:

  • What assurance is required?

  • Is point-in-time assurance sufficient?

  • Is operating effectiveness required?

  • Is the service correctly scoped?

  • Is the period relevant?

  • Are required TSC categories included?

  • Are CUECs understood?

  • Are subservices included or carved out?

  • Are exceptions acceptable?

  • Is bridge assurance needed?

Provider:

New SaaS Startup

Available:

SOC 2 Type I

Service:

Moderate Risk

Decision may be:

Acceptable With:
Additional Questionnaire
Contractual Security Requirements
Future Type II Requirement

97. Vendor Review Example — Critical Identity Provider

Section titled “97. Vendor Review Example — Critical Identity Provider”

Provider:

Identity Platform

Available:

SOC 2 Type I Only

Because of criticality, GRC may require:

Additional Assurance
Security Review
Future Type II
Risk Owner Approval

98. Vendor Review Example — Current Type II

Section titled “98. Vendor Review Example — Current Type II”

Provider:

Critical SaaS

SOC:

Type II

Period:

Recent

Opinion:

Unmodified

No material exceptions.

Result:

Strong Assurance Input

subject to scope, CUECs, and other risk considerations.

Provider has:

SOC 2 Type II

but period ended:

20 Months Ago

Do not assume:

Type II
=
Current Assurance

Request updated evidence.

Provider A:

Type I
Current
Correct Scope

Provider B:

Type II
Two Years Old
Wrong Product

Provider A’s report may be more relevant for some assurance questions.

Report type alone should never determine the decision.

Type II generally requires more operational discipline because:

Controls Must Operate
Evidence Must Persist
Failures Must Be Managed
Control Owner
Control Execution
Evidence
GRC Review
Gap Escalation
Remediation

Track:

Controls Due
Evidence Received
Evidence Missing
Exceptions
Open Findings

Review:

Control Coverage
New Systems
New Vendors
Significant Changes
Risk Changes

Example:

Metric Target Current
Controls With Current Evidence 100% 97%
Missing Evidence Items 0 5
Open High Control Gaps 0 2
Control Owner Completion 100% 96%

Create:

07 Type I vs Type II Comparison Matrix

Use:

Attribute Type I Type II
Assurance Date Specific Date Period
Design Yes Yes
Implementation Yes Yes
Operating Effectiveness No Yes
Population Testing Limited Yes
Historical Evidence Limited Required
Exceptions Across Period No Yes

Ask:

Is the control actually implemented?
Is the system in scope?
Is the report current?
Does the design address our risk?
What operating history exists outside the report?

Ask:

Does the report cover the required period?
How were controls tested?
What exceptions occurred?
Were controls changed?
Are populations complete?
Are CUECs operating?

Mistake 1 — Treating Type I as Operating Effectiveness

Section titled “Mistake 1 — Treating Type I as Operating Effectiveness”

It is not.

Mistake 2 — Assuming Point-in-Time Control Means Historical Control

Section titled “Mistake 2 — Assuming Point-in-Time Control Means Historical Control”

The past period is not demonstrated.

Correct report type, wrong service.

Exceptions can exist.

The assurance may be stale.

Historical operation cannot simply be manufactured.

Mistake 4 — Control Changes Not Documented

Section titled “Mistake 4 — Control Changes Not Documented”

Evidence becomes inconsistent.

Mistake 5 — Population Completeness Ignored

Section titled “Mistake 5 — Population Completeness Ignored”

Auditor tests only part of the real population.

Type II?
Yes
Approved
Report Type
Scope
Period
Control Design
Operating Effectiveness
Evidence
Exceptions
CUECs
Subservices
Customer Risk

113. Practical Activity — Build Type I vs Type II Comparison

Section titled “113. Practical Activity — Build Type I vs Type II Comparison”

Create:

01 Type I vs Type II Comparison Matrix

Include:

Purpose
Timing
Design
Implementation
Operating Effectiveness
Evidence
Testing
Typical Use

114. Practical Activity — Build SOC Report Period Register

Section titled “114. Practical Activity — Build SOC Report Period Register”

Create:

02 SOC Report Period Register

Add at least ten fictional providers.

Track:

Report Type
Start Date
End Date
Current Review Date
Bridge Needed

115. Practical Activity — Build Control Operating Period Matrix

Section titled “115. Practical Activity — Build Control Operating Period Matrix”

Create:

03 Control Operating Period Matrix

Add at least 20 controls.

Identify:

Control Effective Date
Type II Start Date
Full Period Coverage

116. Practical Activity — Build Evidence Coverage Register

Section titled “116. Practical Activity — Build Evidence Coverage Register”

Create:

04 Evidence Coverage Register

Include controls such as:

Access Reviews
Vulnerability Reviews
Backups
Vendor Reviews
Risk Assessments

117. Practical Activity — Build Exception Impact Matrix

Section titled “117. Practical Activity — Build Exception Impact Matrix”

Create:

05 Exception Impact Matrix

Add fictional examples for:

Access
Change Management
Backup
Vendor Risk
Incident Response

118. Practical Activity — Build Bridge Period Register

Section titled “118. Practical Activity — Build Bridge Period Register”

Create:

06 Bridge Period Register

Use:

Provider Report End Current Date Gap Bridge Evidence Status

119. Practical Activity — Build SOC Report Selection Checklist

Section titled “119. Practical Activity — Build SOC Report Selection Checklist”

Create:

07 SOC Report Selection Checklist

Use three fictional scenarios:

New Low-Risk SaaS
Critical Identity Provider
Financial Processing Provider

Determine whether:

Type I
Type II
Additional Assurance

is appropriate.

  • Scope defined.

  • System description current.

  • Applicable criteria identified.

  • Controls documented.

  • Control owners assigned.

  • Policies approved.

  • Controls implemented.

  • Current evidence available.

  • Design gaps remediated.

  • Significant systems included.

  • All Type I readiness items complete.

  • Operating period defined.

  • Control effective dates recorded.

  • Evidence requirements defined.

  • Evidence collected throughout period.

  • Control populations available.

  • Recurring controls completed.

  • Exceptions tracked.

  • Remediation documented.

  • Control changes tracked.

  • Significant system changes assessed.

  • CUECs reviewed.

  • Subservice dependencies reviewed.

  • Readiness reviews performed.

Before relying on any SOC report:

  • SOC 1 / SOC 2 confirmed.

  • Type I / Type II confirmed.

  • Report period reviewed.

  • Report date reviewed.

  • Service scope confirmed.

  • Legal entity confirmed.

  • Relevant TSC categories confirmed.

  • Auditor opinion reviewed.

  • Exceptions reviewed.

  • Management responses reviewed.

  • CUECs reviewed.

  • Subservices reviewed.

  • Bridge period evaluated.

  • Additional assurance identified.

  • Final risk decision documented.

A GRC professional supporting Type I and Type II assurance may:

  • Determine appropriate report type.

  • Review provider report periods.

  • Assess report freshness.

  • Track bridge periods.

  • Maintain control effective dates.

  • Monitor control evidence.

  • Maintain control populations.

  • Perform readiness reviews.

  • Identify evidence gaps.

  • Review control exceptions.

  • Coordinate remediation.

  • Assess vendor assurance sufficiency.

  • Map CUECs.

  • Review subservice dependencies.

  • Support internal and external auditors.

GRC connects:

Control Owners
Security
Engineering
Finance
Procurement
Vendors
Internal Audit
External Auditors

A practical journey may look like:

Control Design
Implementation
Point-in-Time Readiness
Type I
Sustained Operation
Continuous Evidence
Type II
Ongoing Assurance

For every SOC report ask:

What question are we trying to answer?
Do we need a snapshot or operating history?
What period is covered?
Does the report cover our service?
Were relevant controls in place for the whole period?
How frequently should the controls operate?
Is the population complete?
What evidence did the auditor test?
What exceptions occurred?
Were those exceptions isolated or systemic?
Do CUECs affect us?
Are important subservices carved out?
Is there a bridge period?
What additional assurance is required?

When these questions can be answered, Type I and Type II become useful assurance tools rather than simple report labels.

  • Type I provides point-in-time assurance.

  • Type II provides period-of-time assurance.

  • Type I evaluates control design and implementation at a specified date.

  • Type II also evaluates operating effectiveness throughout a defined period.

  • A well-designed control may still fail if it does not operate consistently.

  • Control effective dates are important for Type II readiness.

  • Evidence must align with control frequency and the report period.

  • Control populations should be complete and reliable.

  • Manual controls are often sampled during Type II testing.

  • Automated controls may support complete-population testing.

  • Type II exceptions do not automatically mean a modified auditor opinion.

  • Report period and freshness should always be assessed.

  • Bridge letters may provide supplemental assurance but are not substitutes for independent Type II testing.

  • CUECs and subservice organizations remain important regardless of report type.

  • Type II is generally stronger for demonstrating operating effectiveness, but relevance, scope, and freshness remain critical.

  • GRC plays a central role in maintaining evidence, reviewing report sufficiency, tracking gaps, and supporting audit reliance.

Before continuing, make sure you can answer:

  1. What is a SOC Type I report?

  2. What is a SOC Type II report?

  3. What is point-in-time assurance?

  4. What is period-of-time assurance?

  5. What is control design?

  6. What is control implementation?

  7. What is operating effectiveness?

  8. Why does control effective date matter?

  9. What is a control population?

  10. Why is population completeness important?

  11. Why is sampling used?

  12. How can automated controls support testing?

  13. What is a Type II exception?

  14. Does a control exception automatically result in a qualified opinion?

  15. What is a bridge period?

  16. What is a bridge letter?

  17. Why should SOC report freshness be assessed?

  18. When might Type I be appropriate?

  19. When is Type II generally preferable?

  20. What role does GRC play in Type I and Type II assurance?

➡️ Next: 11 — SOC Readiness Assessment

In the next lesson, you will bring the complete SOC control environment together and learn how to determine whether an organization is actually ready for a SOC examination.

You will work through:

Define SOC Scope
Select Report Type
Define System Boundaries
Map Trust Services Criteria
Inventory Controls
Assign Control Owners
Map Evidence
Assess Design
Test Operating Effectiveness
Identify Gaps
Remediate
Perform Readiness Review
Prepare for Auditor

You will also build practical artifacts including a SOC Readiness Assessment Plan, Control Inventory, TSC-to-Control Mapping, Evidence Request List, Control Testing Workbook, Gap Register, Remediation Tracker, and SOC Readiness Dashboard.