They should first verify discovery completeness across identity providers, SaaS apps, and any adjacent systems that influence entitlements. If the inventory is incomplete, the review process cannot produce reliable decisions. The right sequence is visibility, then certification, then remediation, because certification without full coverage creates confidence without control.
Why This Matters for Security Teams
Access reviews are only useful when they cover the full entitlement surface. If important systems are missing, the review may approve, recertify, or overlook access that never entered the workflow. That gap is especially dangerous for non-human identities, because machine accounts, API keys, service principals, and SaaS integrations often sit outside the systems that traditional IAM teams monitor. The result is a false sense of compliance rather than actual control.
Current guidance in the NIST Cybersecurity Framework 2.0 and the OWASP Non-Human Identity Top 10 both point toward better asset and identity visibility as a prerequisite for governance. That matters because review fatigue usually sets in when certification campaigns are built on incomplete inventories, then escalated as if they were authoritative. NHI Management Group’s Ultimate Guide to NHIs — Regulatory and Audit Perspectives frames this as an auditability problem, not just an operational one. In practice, many security teams encounter missed systems only after an auditor, incident, or business owner exposes them, rather than through intentional discovery.
How It Works in Practice
The practical fix is to treat access review as the last step in a broader discovery and entitlement mapping process. Security teams should start by reconciling identities and access paths across the primary identity provider, SaaS applications, cloud platforms, shared admin tools, and any adjacent systems that mint, store, or propagate permissions. The goal is not just to count accounts, but to identify where access can be granted, inherited, or silently extended.
For non-human identities, this usually means connecting multiple evidence sources: identity provider logs, cloud IAM records, secret stores, OAuth consent grants, CI/CD integrations, and application-local admin tables. The Top 10 NHI Issues and Ultimate Guide to NHIs — Lifecycle Processes for Managing NHIs both reinforce that lifecycle data matters as much as access data. A certification process should then compare observed entitlements to an authoritative owner, purpose, and renewal date. If an entitlement has no owner or no business justification, it should be flagged for remediation rather than quietly renewed.
A useful operational pattern is:
- build an inventory of systems that issue or store access;
- map each entitlement to an owning team and a business function;
- identify orphaned, duplicate, and inherited access;
- run certification only after coverage checks pass;
- feed unresolved gaps into remediation and discovery backlog management.
This approach works best when inventory quality is continuously measured, not only during annual reviews. These controls tend to break down when acquisition sprawl, shadow IT, or application-specific permission stores create access paths that the review tool cannot see.
Common Variations and Edge Cases
Tighter discovery often increases operational overhead, requiring organisations to balance stronger assurance against the cost of maintaining a current inventory. That tradeoff is real, especially in hybrid estates where one identity can touch dozens of applications through federation, service accounts, or delegated SaaS admin rights.
Best practice is evolving for how far review automation should extend beyond the identity provider. There is no universal standard for this yet, but current guidance suggests that any system influencing entitlement state should be considered in scope. That includes change-management platforms, password vaults, token brokers, and application-layer role stores. For especially noisy environments, some teams use risk-based reviews to prioritise privileged, externally exposed, or non-expiring access first.
Vendor research from The State of Non-Human Identity Security highlights how common this visibility gap is, with 85% of organisations lacking full visibility into third-party vendors connected via OAuth apps. That makes a strong case for expanding review scope beyond the central directory. In mature programs, the question is not whether every asset can be reviewed equally well, but whether the team can prove what was excluded and why.
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 and NIST AI RMF set the governance and control requirements practitioners need to meet.
| Framework | Control / Reference | Relevance |
|---|---|---|
| NIST CSF 2.0 | ID.AM-1 | Incomplete reviews often trace back to missing asset and identity inventories. |
| OWASP Non-Human Identity Top 10 | NHI-01 | Access reviews fail when NHI discovery misses service accounts and API credentials. |
| NIST AI RMF | Governance must include complete visibility into AI-enabled access paths and dependencies. |
Map every system and entitlement source, then verify the inventory before starting certification.
Related resources from NHI Mgmt Group
- How should security teams handle access reviews for financial reporting systems?
- How should security teams run access reviews for non-human identities?
- How should security teams prepare data access governance before enabling GenAI tools?
- How should security teams reduce open access risk in data governance programmes?
