Accountability sits with both the access governance function and the business owners who accept the process risk. If a conflict is only reported as a technical issue, remediation stalls. When it is mapped to a business process and tied to an approval or exception path, ownership becomes much harder to defer.
Why This Matters for Security Teams
SAP Segregation of Duties findings are not just audit noise. When a conflict is left open, the organisation is effectively choosing between operational speed and control integrity, and that choice has to be owned by someone with decision rights. In practice, the tension shows up when a finding is logged in GRC, but the business process owner treats it as an IT cleanup item and the access governance team treats it as a business exception. That gap is where findings linger.
The risk is broader than a missed remediation ticket. Persistent SoD conflicts can enable payment approval, vendor master changes, or user provisioning abuse without a second check. This is why governance frameworks such as the NIST Cybersecurity Framework 2.0 emphasize accountability and control ownership, not just detection. NHIMG’s Ultimate Guide to NHIs — Key Research and Survey Results shows that 68% of organisations do not know how to fully address NHI risks, a reminder that unresolved ownership is a recurring governance failure, not an isolated SAP issue.
In practice, many security teams encounter SoD drift only after an exception has already been accepted, not through timely remediation.
How It Works in Practice
Accountability is usually shared, but the mechanism must be explicit. The access governance function owns the control process: detection, triage, evidence collection, escalation, and tracking to closure. The business owner owns the process risk: whether the conflicting access is acceptable, for how long, and under what compensating controls. If either side can defer responsibility, the remediation workflow fails.
A workable model starts with classifying each SoD finding by business process, not just by role conflict. For example, a conflict in procurement approval should be tied to the process owner for purchasing, not left in a generic SAP security queue. The governance team then routes the issue through an approval or exception path, with clear due dates, compensating controls, and a renewal cycle. That structure aligns with NIST CSF 2.0 accountability principles and the operational discipline used in control libraries such as Ultimate Guide to NHIs, where lifecycle ownership matters as much as initial provisioning.
- Assign a named business owner for every unresolved finding.
- Record whether the finding is remediated, accepted, or time-bound as an exception.
- Require compensating controls when remediation is deferred.
- Review exception expiry on a fixed schedule, not ad hoc.
- Escalate overdue items to the risk owner, not only the system administrator.
Where this guidance breaks down is in highly decentralised SAP landscapes with inconsistent process ownership, because the same access path may support multiple legal entities and business functions.
Common Variations and Edge Cases
Tighter SoD governance often increases exception-handling overhead, so organisations have to balance speed of operations against the cost of stronger approval discipline. Current guidance suggests that the answer is not always immediate removal of access, especially when legacy roles, emergency access, or shared service models are involved.
One common edge case is temporary acceptance of a conflict while a process redesign is underway. In that case, the accountability should move from the access team to the named risk acceptor, with a documented end date and review trigger. Another is when a finding is technically true but operationally low risk because a compensating control already exists, such as independent post-transaction review. Even then, the exception must be owned and revalidated, not left to drift. This is consistent with the control-ownership model in NHI Mgmt Group research and the governance orientation of the NIST Cybersecurity Framework 2.0.
In vendor-managed SAP environments, the practical issue is often that the implementation partner can document the conflict but cannot accept the business risk. That distinction matters. Best practice is evolving, but there is no universal standard for this yet beyond one principle: the party that can accept the process risk must be clearly identified, or remediation will stall.
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 CSF 2.0 set the governance and control requirements practitioners need to meet.
| Framework | Control / Reference | Relevance |
|---|---|---|
| NIST CSF 2.0 | GV.RM-01 | Risk ownership is central when SoD findings remain open. |
| NIST CSF 2.0 | GV.OC-02 | Governance outcomes depend on clear operational accountability. |
| OWASP Non-Human Identity Top 10 | NHI-03 | Persistent access conflicts resemble unmanaged privileged identity risk. |
Map each unresolved finding to a business process owner and document decision rights.
