Start by building a complete identity inventory that includes employees, contractors, service accounts, API keys, and other non-human identities. Then apply access policy, authentication monitoring, and risk assessment consistently across both human and machine identities. NIST CSF 2.0 expects identity controls to support continuous governance, not one-time checks, so coverage, visibility, and least privilege matter more than siloed control ownership.
How to Apply NIST CSF 2.0 to Both Human and Non-Human Identities
NIST CSF 2.0 works best here when identity is treated as a single control plane, not two separate programmes. The practical goal is to inventory every actor that can authenticate or exercise access, then apply the same governance logic to human users, service accounts, API keys, certificates, and other machine-facing identities. That keeps access decisions, monitoring, and lifecycle controls aligned across the environment.
Within CSF 2.0, this means the identity story should cut across Govern, Identify, Protect, Detect, Respond, and Recover rather than sit inside one team’s workflow. If one population is governed differently, gaps appear quickly in ownership, review cadence, revocation, and evidence collection. Organisations that want consistent coverage should anchor their programme in a single inventory and a common policy model, then map control execution to the most appropriate system owners.
A useful starting point is the same visibility problem NHI programmes struggle with at scale, because hidden accounts and secrets are where identity control usually breaks down. NHIMG’s Ultimate Guide to NHIs — Key Challenges and Risks is a strong reference for the inventory, sprawl, and over-privilege patterns that CSF programmes need to account for. The underlying control lesson is simple: you cannot govern what you cannot consistently see.
Where Identity Controls Need to Behave the Same Way
The important design choice is not whether an identity is human or non-human, but whether the control outcome is the same. Access policy should define what is allowed, authentication should prove the right entity is acting, monitoring should detect unusual use, and risk review should examine privilege, scope, and lifespan. If one class gets lighter review or weaker evidence requirements, the control model becomes inconsistent and brittle.
In practice, organisations should avoid separate exception paths for people and machines unless the implementation detail truly differs. For example, a service account may use certificates or tokens instead of MFA, but the control intent is still authentication assurance, least privilege, and traceable ownership. Likewise, recertification should not disappear just because an identity is automated; the review question changes, but the governance obligation remains.
When teams need a concrete policy baseline for both populations, the best external fit is NIST Cybersecurity Framework 2.0, because its functions support shared governance, protection, detection, response, and recovery objectives. For the underlying control mechanics, NIST SP 800-53 Rev. 5 Security and Privacy Controls provides the access control, identification and authentication, audit, and configuration families that make the CSF guidance operational.
Practitioner Guidance for Building One Identity Control Model
What to prioritise: Start with inventory, ownership, and lifecycle status before trying to harmonise every downstream control. If an identity lacks a named owner, expiry rule, or revocation path, the rest of the control stack will not be reliable.
What to measure: Track coverage across both populations using the same metrics, including inventory completeness, privileged access review completion, stale credential age, and time to revoke access after change or termination. The goal is not identical mechanics, but identical assurance outcomes.
Common mistake: Teams often build strong human IAM while leaving machine identities to platform teams, developers, or cloud engineers without equivalent governance. That split creates unmanaged exceptions, especially around service accounts, API keys, and secrets that outlive their intended use.
Practitioner takeaway: Treat human and non-human identities as one governed estate with different authenticators, not different control standards. The most defensible CSF 2.0 implementation is the one that preserves consistent ownership, review, monitoring, and least privilege regardless of who or what is using the access.
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, CIS Controls v8, NIST SP 800-63 and NIST Zero Trust (SP 800-207) set the governance and control requirements practitioners need to meet.
| Framework | Control / Reference | Relevance |
|---|---|---|
| NIST CSF 2.0 | GV — Govern | CSF 2.0 requires shared identity governance across people and machine accounts. |
| ID — Identify | Identity inventory and visibility are central to consistent control coverage. | |
| PR.AA — Identity Management, Authentication and Access Control | This control family directly covers authentication and access enforcement for human and machine identities. | |
| Recommendation — Establish one identity governance model with clear ownership, policy, and review cadences for both populations. Inventory all identities, secrets, and access paths in one authoritative register. Apply consistent authentication and least-privilege rules to every identity type. | ||
| CIS Controls v8 | 5 — Account Management | Account management applies directly to human and non-human identities and their lifecycle. |
| 6 — Access Control Management | Access control management is the core mechanism for enforcing consistent permissions and least privilege. | |
| 8 — Audit Log Management | Identity events must be logged to validate access and investigate misuse. | |
| Recommendation — Standardise account lifecycle ownership, provisioning, review, and removal across all identity classes. Enforce role- or policy-based access decisions consistently for users, services, and automation. Log identity lifecycle and access events for both humans and non-humans in a central pipeline. | ||
| NIST SP 800-63 | IAL — Identity Assurance Level | Assurance concepts help align proofing strength and trust decisions for identity populations. |
| Recommendation — Match assurance requirements to the risk of the access being granted, then apply them consistently. | ||
| NIST Zero Trust (SP 800-207) | SC — Continuous Verification and Least Privilege | Zero Trust reinforces consistent verification and minimisation of privilege across identities. |
| Recommendation — Verify every access request and minimise standing privilege regardless of whether the caller is human or machine. | ||
| OWASP Non-Human Identity Top 10 | NHI-01 — Secrets and Credential Management | Secrets governance is material because API keys, tokens, and certificates are part of the identity estate. |
| NHI-02 — Authentication and Authorization | Non-human identities need explicit authentication and access authorisation controls. | |
| Recommendation — Manage machine credentials with the same lifecycle discipline you apply to human authentication factors. Define how each non-human identity authenticates and what it is authorised to do. | ||
Related resources from NHI Mgmt Group
- How should organisations measure identity security maturity across human and non-human identities?
- How should security teams implement identity observability across human and non-human identities?
- How should security teams govern non-human identities at scale?
- How should security teams govern non-human identities for compliance?
