A shadow process in which business teams continue to approve or review access through email, spreadsheets, tickets, or local records outside the central IAM workflow. It weakens control consistency because the organisation ends up with multiple versions of the truth.
Expanded Definition
Parallel access governance describes a split-control pattern where approval, review, or exception handling for access is performed outside the central IAM workflow, often in email threads, spreadsheets, or ticket notes. In NHI and agentic AI environments, this creates a second authority path that can override or delay policy enforcement.
Definitions vary across vendors, but the core issue is the same: governance decisions exist in parallel with, rather than inside, the system of record. That makes entitlement evidence harder to reconcile, weakens auditability, and can cause privileged access to remain active after the business context has changed. The control problem is not the spreadsheet itself, but the fact that it becomes an unofficial decision engine. This is closely related to the access governance themes in the Ultimate Guide to NHIs — Regulatory and Audit Perspectives and the lifecycle discipline described in the Ultimate Guide to NHIs — Lifecycle Processes for Managing NHIs. The most common misapplication is treating an offline approval trail as equivalent to enforced policy, which occurs when local reviewers are trusted to authorize access without synchronising changes back into IAM.
For control language, the closest standards concepts are least privilege and authoritative access records in the NIST Cybersecurity Framework 2.0 and the access enforcement expectations in the OWASP Non-Human Identity Top 10.
Examples and Use Cases
Implementing access governance rigorously often introduces process friction, requiring organisations to weigh speed of local decision-making against the consistency and traceability of a single control plane.
- A finance team approves a service account exception by email during a system cutover, but the IAM record is updated two days later, leaving a temporary overprivilege window.
- A product group uses a shared spreadsheet to track API token approvals for vendors, while IAM shows only the original request, creating conflicting evidence during audit.
- An SRE team revokes a bot’s access in a ticketing system, but the change is never reconciled into the central workflow, so the NHI remains active in production.
- A security reviewer signs off on a high-risk integration in a local record, yet the approval criteria are not aligned with policy, which weakens separation of duties.
These patterns are visible across breach and governance research discussed in the state of non-human identity security and the broader findings in The 2024 ESG Report: Managing Non-Human Identities. They are also where access evidence should be aligned with the control model described in NIST SP 800-53 Rev 5 Security and Privacy Controls.
Why It Matters in NHI Security
Parallel Access Governance is especially dangerous for NHIs because machine identities often outlive the projects, owners, and teams that approved them. If approvals are fragmented, organisations lose confidence in who authorized a secret, token, or certificate, and they can no longer prove whether privilege was granted for the right duration or purpose. NHIMG research shows that only 1.5 out of 10 organisations are highly confident in their ability to secure NHIs, which reflects how governance gaps translate into operational risk.
This matters because NHIs tend to accumulate access silently across environments, vendors, and automation workflows. Parallel approvals make that accumulation harder to see and even harder to reverse. The problem also surfaces during incident response, when security teams discover that the most important access decision is buried in an inbox or spreadsheet instead of the authoritative IAM record. The control implications connect directly to the Top 10 NHI Issues and the breach patterns analysed in the 52 NHI Breaches Analysis. Organisations typically encounter the impact only after an access review, incident, or audit failure exposes conflicting entitlement records, at which point parallel governance becomes operationally unavoidable to address.
Standards & Framework Alignment
This section maps relevant standards and security frameworks to the operational risks and controls described in this guidance.
OWASP Non-Human Identity Top 10 address the attack and risk surface, while NIST CSF 2.0, NIST SP 800-63, NIST Zero Trust (SP 800-207) and NIST SP 800-53 Rev 5 set the governance and control requirements practitioners need to meet.
| Framework | Control / Reference | Relevance |
|---|---|---|
| OWASP Non-Human Identity Top 10 | NHI-04 | Addresses inconsistent access governance and review paths for non-human identities. |
| NIST CSF 2.0 | PR.AC-1 | Access permissions and approvals must be managed through governed, auditable processes. |
| NIST SP 800-63 | Identity proofing and assurance depend on reliable authoritative records, not parallel shadow logs. | |
| NIST Zero Trust (SP 800-207) | Zero Trust depends on continuously verifiable access decisions, not offline exceptions. | |
| NIST SP 800-53 Rev 5 | AC-2 | Account management requires controlled provisioning, review, and revocation records. |
Centralize account lifecycle actions and reconcile any out-of-band approvals immediately.
