Why do manual access approvals create ongoing risk in identity programmes?

Manual approvals are slow, inconsistent, and often missing the usage context needed to judge whether access is still justified. They also encourage role drift, because people keep access longer than their work requires. In practice, the risk is not only delay. It is persistent over-entitlement that accumulates across users, apps, and lifecycle events.

Why This Matters for Security Teams

Manual access approvals look like a governance control, but they often become a control gap when they are disconnected from actual usage. Approvers usually see a request form, not the workload, data sensitivity, or lifecycle trigger that makes access necessary. That makes approval decisions stale almost as soon as they are granted, especially when access is reused across systems and never revalidated.

This is a familiar pattern in NHI governance too. NHI Management Group has documented that 97% of NHIs carry excessive privileges and that only 20% of organisations have formal processes for offboarding and revoking API keys in the Ultimate Guide to NHIs. For broader identity programmes, the same weakness appears when approvals are treated as one-time events instead of continuous decisions. Current guidance from the NIST Cybersecurity Framework 2.0 reinforces that access governance should support ongoing risk management, not just intake processing.

In practice, many security teams discover that manual approval workflows do not prevent over-entitlement; they simply document it after the fact.

How It Works in Practice

Manual approvals create risk because they rely on human judgment at a single point in time. Once granted, access often persists through project changes, job moves, service ownership changes, and emergency exceptions. The control may look strong on paper, yet the real environment changes faster than the approval record. That is why practitioners increasingly pair approvals with OWASP Non-Human Identity Top 10 guidance and lifecycle controls that continuously reassess whether access still matches purpose.

For identity programmes, the practical alternative is not removing approvals entirely. It is moving from static approval to context-aware authorisation and short-lived access. That means:

• Using approvals only as a gate for higher-risk access, not as the full decision model.
• Binding access to business purpose, data classification, device posture, or ticket context at request time.
• Applying just-in-time access so privileges expire automatically after the task completes.
• Reviewing standing access on a recurring basis, with automatic revocation when ownership, role, or system state changes.

For non-human workloads, this logic becomes even more important because tokens, keys, and service accounts do not self-report drift. The 52 NHI Breaches Analysis shows how quickly weak lifecycle control turns into operational exposure, and the same pattern appears in enterprise IAM when approvals are detached from revocation. The operational goal is to make access ephemeral, reviewable, and tied to real usage rather than organizational memory. These controls tend to break down in large federated environments because ownership, entitlement source, and revocation responsibility are split across teams and systems.

Common Variations and Edge Cases

Tighter approval workflows often increase operational overhead, requiring organisations to balance governance quality against delivery speed and user friction. That tradeoff is real, especially in environments that need rapid access for engineering, incident response, or third-party support.

Best practice is evolving, but current guidance suggests not all access needs the same approval depth. High-risk data, privileged admin functions, and production changes usually justify stronger sign-off, while low-risk, repetitive access may be better handled through policy-based automation. The key is to avoid making every request equally manual, because that drives shadow processes and exception sprawl.

Manual approval also becomes less effective when access is delegated across contractors, machine identities, and service workflows. In those cases, reviewers may approve the requester but miss the actual consuming identity. NHI Management Group’s Top 10 NHI Issues highlights how excessive privilege and weak offboarding compound over time, which is why identity teams should treat approval as one signal in a broader control set. The practical lesson is simple: if access can outlive the reason it was granted, the approval process is not controlling risk, only recording it.

Related resources from NHI Mgmt Group

• When does JIT access create more risk than it reduces?
• Why do web server vulnerabilities create identity and access risk for NHI programmes?
• Why do remote workers create more risk for identity and access management programmes?
• Why does birthright access create ongoing identity risk?