What should organisations do when identity reviews do not match operational reality?

They should treat the mismatch as a control design problem, not a documentation problem. If access reviews, SoD checks, and audit evidence do not reflect how work is actually performed, the governance model is detached from the system of record. Rebuild the workflow so approval, enforcement, and evidence are generated together.

Why This Matters for Security Teams

When identity reviews do not match operational reality, the issue is usually not the review itself. It is that the approval model, enforcement point, and evidence trail are no longer the same system. That creates false confidence: access looks governed on paper, yet production behaviour follows a different path. NHI risk data shows why this matters, with the Ultimate Guide to NHIs reporting that 97% of NHIs carry excessive privileges. In practice, that gap means review outputs can be clean while service accounts, API keys, and automation paths remain over-scoped.

Practitioners often try to fix the symptom by adding more attestations, but that usually increases noise. The better question is whether identity governance is being generated from the actual control plane. If access can be granted in one tool, used in another, and only later reflected in a spreadsheet, the organisation has a records problem, not a compliance problem. Current guidance from NIST Cybersecurity Framework 2.0 pushes teams toward measurable, repeatable control ownership, which is the right starting point.

In practice, many security teams encounter this failure only after an audit exception, incident review, or breach investigation has already exposed the disconnect.

How It Works in Practice

The fix is to redesign the workflow so entitlement, approval, enforcement, and evidence are produced together. That means identity reviews should pull from the system that actually grants access, not from a manually curated register. It also means each exception, temporary elevation, and offboarding event must leave an auditable record at the moment it happens. The 52 NHI Breaches Analysis is useful here because many real incidents begin with access that was formally approved long before it became operationally unsafe.

A practical sequence looks like this:

• Map every NHI, service account, API key, and automation token to a single source of truth.
• Make access review inputs come from live entitlement data, not static inventory exports.
• Require owners to validate both business purpose and runtime usage patterns.
• Generate approval and enforcement from the same workflow so evidence is automatic.
• Replace generic recertification with exception handling for standing access, stale secrets, and unused privileges.

This is where intent matters. If an NHI is used for a narrow job, the control should reflect that job, not a broad role label copied from human IAM. In mature environments, current guidance suggests using JIT credentials, short-lived secrets, and tightly scoped escalation paths, supported by zero trust principles and runtime policy checks. That approach is consistent with the operational lessons in the Top 10 NHI Issues and with NIST’s emphasis on continuous verification rather than periodic paperwork.

These controls tend to break down in hybrid estates where legacy apps, ad hoc scripts, and shadow automation can still authenticate outside the modern control plane because the evidence trail fragments across tools.

Common Variations and Edge Cases

Tighter governance often increases operational overhead, so organisations have to balance control precision against delivery speed. That tradeoff is especially visible when teams manage emergency access, outsourced operations, or CI/CD systems that change faster than review cycles. Best practice is evolving here: there is no universal standard for how often every NHI should be recertified, but there is broad agreement that long-lived access with no runtime validation is a weak design.

One common edge case is shared automation. If multiple jobs reuse the same credential set, a review may show one approved owner while dozens of workflows depend on it. Another is delegated administration, where a platform team can grant access that the business owner never sees. In those cases, the review should shift from “who approved this?” to “what runtime conditions prove this access is still justified?” That is where strong NHI governance overlaps with the lessons captured in the JetBrains GitHub plugin token exposure case: secrets become dangerous when they outlive the task they were created for.

For organisations with agentic systems or autonomous tooling, the gap is even wider because access may be exercised in ways the original approval never anticipated. In those environments, intent-based authorisation and workload identity are more reliable than static role mapping. Teams should also treat human review as a backstop, not the control itself, and align the operating model to NIST Cybersecurity Framework 2.0 outcomes rather than documentation volume.

Related resources from NHI Mgmt Group

• How should organisations stop identity governance from stalling in practice?
• How should organisations phase an identity governance programme to reduce risk?
• When should organisations prioritise AI identity governance over new AI deployments?
• How do organisations know if identity governance is too fragmented?