They should judge usage, business purpose, data sensitivity, and ownership together. An app that is widely used but lacks a control owner, clear contract trail, or identity integration should be treated as a governance candidate, not automatically approved. Sanctioning should follow evidence, not convenience.
Why This Matters for Security Teams
Sanctioning a SaaS app is not just a procurement decision. It is an identity and data-control decision that determines whether the app can authenticate, what it can reach, and who owns its risk. Teams often approve apps because they are popular or already embedded in workflows, but popularity does not prove control. A sanctioned app without a clear owner, contract trail, or identity integration can become a shadow control plane for secrets, data, and privileged access.
That matters because SaaS apps frequently sit at the junction of human access, service accounts, OAuth grants, and third-party integrations. NHI Mgmt Group notes that 80% of identity breaches involved compromised non-human identities such as service accounts and API keys in the Ultimate Guide to NHIs, which is why app sanctioning must be tied to identity governance and not only user demand. The NIST Cybersecurity Framework 2.0 reinforces the need to manage assets, access, and third-party risk together rather than in separate review lanes. In practice, many security teams encounter app sprawl and exposed tokens only after a breach or audit finding has already exposed the gap.
How It Works in Practice
The decision should start with evidence, not convenience. A SaaS app is a better candidate for sanctioning when the business use is documented, the data categories are known, the owner is named, and the app can participate in identity controls. That means SSO integration, SCIM or lifecycle hooks where available, audit logging, and a documented process for revoking access and OAuth grants when the business need ends.
Current guidance suggests evaluating four questions together:
- Does the app have a defined business purpose and a sponsor who can accept risk?
- Does it handle regulated, sensitive, or production data that requires stronger controls?
- Can it enforce central authentication, MFA, and role separation?
- Is there a contract, security review, and offboarding path for tokens, keys, and admin access?
This is where SaaS governance intersects with NHI governance. A sanctioned app often becomes the parent system for machine credentials, API keys, bot accounts, and integration tokens. If those identities are not inventoried and rotated, the app can look approved while still acting as a blind spot. The Snowflake breach and the Salesloft OAuth token breach both illustrate how sanctioned services can still become exposure paths when token governance is weak. Best practice is evolving toward continuous review, where sanctioning is not a one-time approval but a recurring control state. These controls tend to break down in fast-moving SaaS environments where teams can self-enable integrations faster than security can review the resulting access paths.
Common Variations and Edge Cases
Tighter sanctioning often increases friction for business teams, requiring organisations to balance speed of adoption against control depth. That tradeoff becomes more visible with collaboration tools, AI-enabled SaaS, and department-owned apps that already have active user bases before security review begins.
There is no universal standard for this yet, but current guidance suggests treating some cases as conditional rather than fully approved. For example, an app may be allowed for low-risk collaboration while remaining prohibited for regulated data, or it may be permitted only through a brokered integration that removes direct secret handling. Vendor maturity also matters. If an app cannot support SSO, lifecycle automation, logging, or contract clarity, sanctioning should be limited or deferred until compensating controls are in place.
Edge cases also include merger environments, temporary projects, and business-critical legacy tools. In those cases, the decision should be time-boxed and linked to a remediation plan, not normalized as permanent approval. Sanctioned status should expire if ownership is lost, identity integration is removed, or data scope changes materially. NHI Mgmt Group research on the Ultimate Guide to NHIs shows how widespread non-human identity risk can become when visibility is incomplete, and the BeyondTrust API key breach shows why third-party access paths deserve the same scrutiny as the app itself. Each exception should be logged as a risk decision with an owner, review date, and clear revocation trigger.
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 |
|---|---|---|
| OWASP Non-Human Identity Top 10 | NHI-01 | Sanctioning depends on knowing which non-human identities the SaaS app introduces. |
| NIST CSF 2.0 | PR.AA-01 | SaaS sanctioning hinges on identity proofing, access control, and third-party trust. |
| NIST AI RMF | AI RMF governance helps assess risk, accountability, and acceptable use for SaaS tooling. |
Use governance and mapping functions to assign owners, define scope, and review risk continuously.
Related resources from NHI Mgmt Group
- How do organisations decide whether to replace an identity platform or keep extending it?
- How do teams decide whether browser-based app integration is good enough?
- How should organisations decide whether appsec, IAM, or platform teams own a control failure?
- How do organisations decide whether to prioritise secrets management or access governance first?
