Yes, when both are used for phishing-resistant access and both require issuance, recovery, and removal controls. The important distinction is not the form factor but the lifecycle risk: each credential type needs consistent ownership, reset policy, and decommissioning discipline.
Why passkeys and smart cards fit the same governance model
Passkeys and smart cards are different authenticators, but governance should be anchored in the same lifecycle controls: who can issue them, how they are recovered, when they are revoked, and how exceptions are approved. If the organisation treats them as separate policy islands, it usually creates uneven assurance, inconsistent recovery, and blind spots during offboarding or replacement.
That is why a shared governance model works well when the control objective is phishing-resistant access rather than the device type itself. The policy should define common ownership, issuance criteria, recovery approvals, and decommissioning triggers, while still allowing implementation details to differ by platform, user population, and risk tier.
For organisations building that model, Workforce Identity Security Guide is a useful anchor for the broader access lifecycle, and Passwordless and Passkeys Guide is the more specific reference for phishing-resistant sign-in and recovery design.
What should stay common, and what should stay different?
The common layer is governance: policy ownership, approval flow, audit evidence, reset authority, and revocation standards. If a passkey or smart card can open the same enterprise resources, both should be subject to the same minimum controls for enrollment, recovery, and removal, because the risk is not the token form, it is the access it enables.
The different layer is operational handling. Smart cards may depend on physical issuance, card stock, and PIN management, while passkeys may involve device binding, sync behavior, and recovery through account systems. Those differences affect procedures, but they should not produce separate governance logic unless the assurance level or recovery path is materially different.
A practical way to model this is to separate policy from mechanism: one policy for authoritative lifecycle decisions, multiple procedures for how each authenticator meets that policy. That keeps the security standard consistent while avoiding a forced one-size-fits-all operational design.
How to prevent inconsistent recovery and deprovisioning
The biggest failure mode is not enrolment, it is recovery. Recovery paths often become the weakest part of the control set because they are treated as convenience processes rather than security decisions. If a help desk can reissue a passkey or smart card without strong verification, the organisation has effectively shifted trust from the authenticator to the recovery workflow.
Decommissioning deserves the same discipline. When a user changes role, leaves the organisation, or replaces hardware, the old credential must be removed from authoritative records and from any backup or synchronized state that could still authenticate. Shared governance makes that easier because the organisation can apply the same offboarding standard to both authenticator types.
For threat context, MFA Guide and Twilio 0ktapus breach 2022 both reinforce the same lesson: the attacker often targets the weakest recovery or verification step, not the strong authenticator itself. A shared governance model should therefore treat recovery approval as a high-risk control, not an administrative convenience.
Risk and Threat Considerations
When passkeys and smart cards are governed inconsistently, the result is usually uneven assurance and avoidable attack surface. The most common risk is control drift: one authenticator gets strong issuance and revocation rules, while the other is left with weaker help desk recovery, stale credentials, or unclear ownership.
Failure mechanism: An attacker or insider does not need to defeat the stronger authenticator directly if they can exploit a weaker recovery, replacement, or offboarding process, or if old credentials remain trusted after role change or separation.
Impact: The organisation can lose the benefit of phishing-resistant access, create preventable account takeover paths, and fail audits because lifecycle controls are inconsistent across credential types that protect the same resources.
Standards & Framework Alignment
This section maps relevant standards and security frameworks to the operational risks and controls described in this guidance.
NIST SP 800-53 Rev 5, CIS Controls v8 and NIST CSF 2.0 set the technical controls, while ISO/IEC 27001:2022 defines the regulatory obligations.
| Framework | Control / Reference | Relevance |
|---|---|---|
| NIST SP 800-53 Rev 5 | IA-5 — Authenticator Management | Both passkeys and smart cards depend on lifecycle control of authenticators. |
| IA-2 — Identification and Authentication (Organizational Users) | The question concerns workforce access and phishing-resistant sign-in governance. | |
| IA-5(1) — Password-based Authentication | Recovery and fallback paths often reintroduce weaker authentication assumptions. | |
| Recommendation — Apply IA-5 to govern issuance, rotation, replacement, and revocation for both authenticator types. Use IA-2 to require consistent authenticated access rules across user authenticators. Limit fallback authentication and prevent weaker recovery paths from bypassing stronger authenticators. | ||
| ISO/IEC 27001:2022 | A.5.15 — Access control | Shared governance for authenticator lifecycle is an access-control policy issue. |
| A.8.5 — Secure authentication | Passkeys and smart cards are secure authentication mechanisms requiring consistent handling. | |
| Recommendation — Define one access-control policy for issuing, reviewing, and revoking both credential types. Standardise secure-authentication requirements for enrollment, recovery, and decommissioning. | ||
| CIS Controls v8 | CIS-5 — Account Management | Authenticator governance depends on joiner-mover-leaver and account lifecycle discipline. |
| Recommendation — Tie authenticator issuance and removal to account-management events and verified ownership. | ||
| NIST CSF 2.0 | PR.AA-05 — Authenticator Management | The CSF addresses how authenticators are issued, maintained, and revoked. |
| GV.RM-01 — Risk Management Strategy | Shared governance should align to a risk-based assurance strategy for phishing-resistant access. | |
| Recommendation — Manage authenticators through a single lifecycle process with clear issuance and revocation rules. Set one risk-based governance strategy for all phishing-resistant authenticators. | ||
Practitioner Guidance
What to prioritise: Put issuance, recovery, and decommissioning under one governance owner or control board, then define authenticator-specific procedures underneath that model. If the assurance target is the same, the approval standard should also be the same.
What to verify: Check whether help desk recovery can re-establish access faster than you can revoke the old authenticator. That is where governance usually breaks, especially when smart cards and passkeys are managed by different teams or different ticket workflows.
What good looks like: Every authenticator type has a recorded owner, a defined recovery path, a revocation trigger, and an auditable removal step. The user sees different hardware or software, but the control plane behaves consistently.
Practitioner takeaway: Treat passkeys and smart cards as different implementations of the same access control problem, and govern them together whenever they protect the same identities and systems.
Related resources from NHI Mgmt Group
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