Yes. A resilient identity strategy should include non-digital alternatives for people who cannot or do not want to use a digital credential. That avoids exclusion, supports choice, and makes the overall identity process more accessible while digital methods mature and gain trust.
Why Non-Digital Identity Still Belongs Beside Digital IDs
digital identity can improve convenience, verification speed, and portability, but it does not cover every person or every use case equally. A well-designed identity system keeps an alternative path for people who lack compatible devices, have accessibility barriers, face low trust in the digital channel, or simply need a different way to prove who they are without being locked out.
That is not a rollback of digital identity. It is a resilience and inclusion choice: the more important the identity function becomes, the more important it is to avoid making one channel the only route to access.
Where Non-Digital Options Fit in an Identity Strategy
Non-digital identity options usually sit alongside digital IDs as a fallback, an assisted channel, or a parallel assurance route. They may include in-person proofing, paper-based references, legacy credentials, call-centre support, or other controlled methods that let an organisation complete the identity process when the digital route is unavailable or unsuitable.
The key design question is not whether digital identity is preferable in principle, but whether the organisation can still authenticate, verify, or recover identity when the preferred method fails. Identity proofing and KYC controls remain relevant when organisations need a non-digital path that still resists fraud, impersonation, and weak assurance.
That same design logic applies to government and cross-border identity programmes. eIDAS 2.0 is pushing digital identity wallet adoption across the EU, but large-scale digital identity programmes still need a transition model that does not assume every user can move at the same pace or through the same device. eIDAS 2.0, the EU Digital Identity Framework is a useful reference point because it shows how digital identity is being standardised without erasing the need for operational flexibility.
Why Organisations Benefit from Keeping the Alternative Open
Non-digital options reduce exclusion. Some users have no suitable phone, lose access to a device, cannot complete a biometric flow, or are unable to use a digital credential because of disability, language, age, connectivity, or policy constraints. A secondary path also gives organisations operational continuity if a digital provider, wallet, or verification service is down.
There is also a trust dimension. Identity systems are adopted more readily when users are not forced into a single control path that they do not understand or cannot complete. In practice, the strongest programmes let the digital route become the default while preserving a bounded non-digital path for exception handling, recovery, and accessibility.
For practitioners comparing human and machine identity governance, it helps to keep the human access path understandable and supportable. Human vs Non-Human Identity is a useful reminder that good governance depends on choosing the right control path for the right population, not forcing every population into the same pattern.
Risk and Threat Considerations
Removing non-digital alternatives can create a concentration risk: one technical channel becomes the only route to identity, and any outage, device loss, accessibility failure, or user rejection can become a hard denial of service. A weak fallback, however, creates the opposite problem, because attackers often target the exception path when the primary digital route is better controlled.
Failure mechanism: organisations either over-constrain access by making digital identity mandatory for everyone, or they under-control the fallback and let it become the easiest way around stronger digital checks.
Impact: the first case produces exclusion and operational disruption; the second creates fraud, impersonation, and assurance downgrade risk, especially where identity proofing is not as strict as the digital path.
Standards & Framework Alignment
This section maps relevant standards and security frameworks to the operational risks and controls described in this guidance.
NIST SP 800-63 and NIST CSF 2.0 set the technical controls, while ISO/IEC 27001:2022 defines the regulatory obligations.
| Framework | Control / Reference | Relevance |
|---|---|---|
| NIST SP 800-63 | IA-12 — Identity Proofing | Non-digital fallback paths still need proofing assurance for people who cannot use digital IDs. |
| IA-8 — Identification and Authentication (Non-Organizational Users) | The question concerns people using identity services, including alternative authentication paths. | |
| Recommendation — Align fallback enrollment with identity proofing assurance before granting access. Provide equivalent authentication options for non-organizational users. | ||
| ISO/IEC 27001:2022 | A.5.15 — Access control | Identity channels must be governed so alternative paths do not weaken access decisions. |
| Recommendation — Define and enforce access rules for both digital and non-digital identity routes. | ||
| NIST CSF 2.0 | PR.AA-05 — Authentication policies are managed, and only authorized users, software, and services are allowed access. | Alternative identity options still need controlled authentication policy and access authorization. |
| GV.RR-01 — Roles, responsibilities, and authorities are established and communicated. | Non-digital identity options need clear ownership and exception handling. | |
| Recommendation — Manage authentication policy across primary and fallback identity methods. Assign ownership for fallback identity processes and exception decisions. | ||
Practitioner Guidance
What to prioritise: Treat the non-digital path as a designed control, not as an embarrassment or an afterthought. It should have clear eligibility, clear approval criteria, and a documented assurance level so staff know when it is appropriate and when it is not.
What to verify: Test whether a user can complete the identity journey without a smartphone, without biometric success, and without stable connectivity. If the answer is no, the digital programme is not yet operationally inclusive, even if it is technically modern.
Decision rule: If the non-digital route materially lowers assurance, reserve it for recovery, exception handling, or assisted access rather than normal high-risk transactions. If it preserves equivalent assurance through strong proofing and verification, it can be a valid parallel channel.
Practitioner takeaway: The goal is not to keep paper or in-person identity forever, it is to prevent digital identity from becoming a single point of exclusion or failure while the organisation is still proving the maturity of the digital channel.
Related resources from NHI Mgmt Group
- How should security teams govern non-human identities alongside human accounts?
- How should teams govern non-human identities alongside CAASM and EASM?
- How should organisations think about managing non-employee identities alongside core identity security controls?
- Why do organisations struggle to keep secrets management and non-human identity governance under control as environments expand?
