They should treat those applications as permanent exceptions, not temporary gaps. Build a manual-execution register, assign owners, define approval and validation steps, and apply compensating controls such as tighter review cadence and stronger logging. The goal is to preserve governance even when the application cannot join normal IAM automation.
Why This Matters for Security Teams
Applications that cannot support SCIM or federation do not become safer by being ignored; they simply fall outside normal identity governance. That creates a blind spot for provisioning, deprovisioning, and access review, which is especially dangerous for secrets-bearing workflows and service accounts. NHI Management Group notes that only 5.7% of organisations have full visibility into their service accounts, and that visibility gap is where unmanaged access tends to accumulate, as discussed in the Ultimate Guide to NHIs — Lifecycle Processes for Managing NHIs.
The practical risk is not just operational drift. Unintegrated applications often rely on static credentials, shared accounts, or manual approvals that never get reviewed with the same rigor as automated IAM flows. That clashes with the intent of the NIST Cybersecurity Framework 2.0, which expects governance, access control, and monitoring to remain consistent even when implementation differs by system. In practice, many security teams encounter uncontrolled access only after a stale account, orphaned API key, or audit finding has already exposed the gap.
How It Works in Practice
The right model is to classify each unsupported application as a permanent exception with explicit ownership, documented approval paths, and compensating controls. That means the application is still governed, but through a manual execution register rather than SCIM or federation. The register should record the identity used, the business justification, the approver, the review date, and the expiry or revalidation date. Where credentials are involved, the record should also show where the secret is stored, who can retrieve it, and how revocation happens.
This approach aligns with the broader lifecycle discipline described in NHI Lifecycle Management Guide and with the governance themes in NIST CSF 2.0. It also gives auditors a clear control narrative: if automation is impossible, control evidence must become more explicit. A workable control set usually includes:
- Named business and technical owners for each application
- Pre-approved request templates for each allowed access pattern
- Time-bound approvals with forced revalidation at set intervals
- Stronger logging for use, failed access, and administrative actions
- Compensating controls such as PAM, tighter segmentation, and secret rotation
- Offboarding steps that are tested, not just documented
For high-risk environments, this manual register should be tied to the same review cadence used for privileged access, so exceptions do not linger beyond their business need. The Top 10 NHI Issues research is clear that unmanaged service accounts and static secrets are recurring failure points, not edge cases. These controls tend to break down in legacy, outsourced, or air-gapped environments because ownership becomes ambiguous and revocation is harder to prove.
Common Variations and Edge Cases
Tighter exception control often increases operational overhead, requiring organisations to balance governance strength against application fragility and support capacity. Some teams can retrofit a gateway, proxy, or PAM layer around the application, while others must accept a fully manual pattern because the system cannot tolerate protocol changes. Current guidance suggests treating those paths differently based on risk, but there is no universal standard for this yet.
One common edge case is a vendor-hosted application where the customer cannot change authentication behavior but still owns the data and access decisions. In that case, the exception register should include vendor contact points, incident notification routes, and evidence of revocation testing. Another is a machine-to-machine integration that uses long-lived API keys because the application cannot support short-lived tokens. Here, best practice is evolving toward stronger containment, including secret vaulting, narrow network allowlists, and frequent review, rather than pretending the key can be governed like a federated user login.
For audit and risk teams, the key question is not whether the application is modern enough for federation, but whether the exception is visible, approved, and reversible. NHI Management Group’s Ultimate Guide to NHIs — Regulatory and Audit Perspectives is useful here because it frames unsupported systems as a lifecycle problem, not a tooling defect. In practice, organisations that fail here usually discover the gap during an audit, after a breach, or when a decommissioning request cannot be completed cleanly.
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 | Unsupported apps often depend on unmanaged NHI credentials and access paths. |
| NIST CSF 2.0 | PR.AC-4 | Access governance still applies when automation is unavailable. |
| NIST AI RMF | GOVERN | Manual exceptions need accountable oversight and risk ownership. |
Apply least-privilege review and revalidation to all manual-access application exceptions.
Related resources from NHI Mgmt Group
- What should organisations do when their current auth stack cannot support SCIM and self-service admin?
- How do organisations operationalise NHI ownership at scale?
- How can organizations manage the risk of credential leaks in MCP frameworks?
- When should organisations treat an NHI as a high-priority risk?