A brief announcement on Thursday said the army Criminal Investigation Division had "identified 28 soldiers with possible culpability in these two cases, meaning that they may have committed one or more offences punishable under the uniform code of military justice".
The soldiers could face charges ranging from manslaughter to conspiracy.
The announcement followed charges filed earlier against a US military police sergeant in the alleged abuse deaths of the two prisoners at Kabul's Bagram Air Base.
It did not name the soldiers but said a detailed report had been passed to commanders listing potential offences including involuntary manslaughter, assault consummated by battery, maiming, maltreatment, dereliction of duty and conspiracy.
"Many of the 28 soldiers may have lesser culpability," the army said, adding that "commanders, with the advice of their lawyers, will consider the full range of appropriate administrative and disciplinary measures from taking no action to recommending trial by court martial".
US soldiers also abused prisoners
in Baghdad's Abu Ghraib prison
The two prisoners died in December, after blunt force injuries, according to the army.
Military medical examiners classified their deaths as homicides.
Autopsies said a 30-year-old prisoner died of a blood clot in the lung triggered by blunt-force injuries to the legs, and a 22-year-old prisoner died because of blunt-force injuries to his lower extremities that exacerbated existing coronary artery disease.
Sergeant James Boland, an army reservist, was earlier charged with assault, maltreatment and dereliction of duty in the deaths.
US soldiers face accusations of abusing prisoners both in Afghanistan and Iraq.
Iraqi inmates at Baghdad's Abu Ghraib prison were subjected to physical abuse and sexual humiliation by US prison guards.