They should treat IAM, PAM, and NHI controls as part of the regulated ICT risk framework, not as separate technical tools. That means documenting access ownership, tightening supplier credential lifecycles, and ensuring incident reporting can trace identity-related failures across internal and external systems. DORA expects governance evidence, not just security intent.
Why This Matters for Security Teams
DORA changes IAM from an internal control problem into an operational resilience requirement. For financial institutions, the hard part is not proving that access exists, but proving who owns it, why it exists, how long it lasts, and how failures are detected across suppliers and internal systems. That is especially important for NHI, PAM, and service-account access, where weak lifecycle control often sits outside traditional joiner-mover-leaver workflows.
Regulators care about evidence trails, not just policy statements. The identity layer has to support incident response, supplier oversight, and auditability across interconnected ICT services. Guidance from DORA — Digital Operational Resilience Act and NHIMG’s Ultimate Guide to NHIs — Regulatory and Audit Perspectives both point to the same practical issue: unmanaged machine access becomes a governance failure when it cannot be traced, justified, or revoked.
In practice, many security teams encounter identity-related third-party incidents only after a supplier token has already been abused, rather than through intentional resilience testing.
How It Works in Practice
Financial institutions should map IAM and third-party access to the same control framework used for ICT risk, supplier management, and incident reporting. That means every privileged user, service account, API key, certificate, and outsourced admin path needs an accountable owner, defined purpose, expiry, and review cadence. DORA does not require a single product choice; it requires governance evidence that access can be controlled, traced, and recovered under stress.
The operational model usually combines four moves. First, centralise identity inventory so internal and external access paths are visible, including cloud, CI/CD, and managed service relationships. Second, reduce standing privilege with PAM and just-in-time access where feasible, especially for supplier support accounts. Third, tighten NHI lifecycle controls so secrets are issued for a defined task, rotated, and revoked automatically when the task ends. Fourth, connect identity telemetry to incident response so access failures, credential abuse, and supplier misuse can be correlated quickly.
Current best practice is to use policy-as-code and continuous control monitoring rather than rely on annual attestations. NIST’s NIST SP 800-63 Digital Identity Guidelines remains useful for assurance concepts, while OWASP’s OWASP Non-Human Identity Top 10 highlights common failure modes such as exposed secrets, over-privilege, and weak rotation. NHIMG’s 52 NHI Breaches Analysis is a useful reminder that identity compromise is often the first step in broader operational disruption.
These controls tend to break down when supplier access is delivered through shared accounts, unmanaged break-glass credentials, or locally administered exceptions that never re-enter the official review process.
Common Variations and Edge Cases
Tighter access control often increases operational overhead, requiring institutions to balance resilience and auditability against business continuity, supplier responsiveness, and regulatory deadlines. That tradeoff is real, especially where core banking, payment processing, or outsourced infrastructure depends on 24/7 support access.
There is no universal standard for this yet, but current guidance suggests treating exceptions as temporary, documented, and tested. For example, emergency supplier access should use time-bound approval, session recording where appropriate, and post-event review. Long-lived shared credentials should be phased out, but legacy platforms may need compensating controls if immediate replacement is not feasible.
Financial institutions should also separate two questions that are often conflated: whether a supplier is trusted, and whether a specific credential or workload is still valid. DORA-aligned governance works better when identity risk is assessed at the credential level, not just the vendor level. NHIMG’s Ultimate Guide to NHIs — Key Challenges and Risks notes that non-human identities frequently outnumber human identities by a wide margin, which makes manual review alone unrealistic.
In environments with fragmented IAM ownership across business units and outsourcing chains, the model degrades quickly because no single team can prove end-to-end accountability for access and revocation.
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 surface, NIST CSF 2.0 set the technical controls, and DORA define the regulatory obligations.
| Framework | Control / Reference | Relevance |
|---|---|---|
| DORA | DORA requires traceable ICT risk governance for internal and supplier access. | |
| OWASP Non-Human Identity Top 10 | NHI-03 | Credential lifecycle weaknesses are central to third-party and service-account risk. |
| NIST CSF 2.0 | PR.AC-4 | Least-privilege access for third parties aligns with identity and access control. |
Tie IAM, PAM, and NHI controls to ICT risk evidence, incident traceability, and supplier oversight.
