By NHI Mgmt Group Editorial TeamBased on Twine Security: “The Last Manual Audit: Agentic AI and the Future of Compliance” (October 2, 2025)

TL;DR: Agentic AI could change compliance audits from periodic reconstruction to continuous evidence gathering, with one IBM audit described as consuming 2,300 hours of human labor over three weeks, according to Twine Security. The real shift for IAM teams is not speed alone but whether machine-driven evidence can preserve context, lineage, and access accountability without weakening trust.


At a glance

What this is: This is a Twine Security analysis of how agentic AI could change compliance audits by turning evidence collection into a continuous, context-rich process rather than a manual reconstruction exercise.

Why it matters: It matters to IAM and audit teams because agentic evidence handling changes how access lineage, entitlement history, and control effectiveness are proven across human, NHI, and autonomous workflows.

By the numbers:

  • That IBM identity and access management audit consumed 2,300 hours of human labor over three weeks, according to Twine Security.

Context

Compliance audits still depend on humans gathering static evidence after the fact, which means context is often lost before the audit team can explain it. In identity and access management, that is especially painful because access history, approvals, entitlements, and revocations are spread across systems that age out of sync.

Agentic AI changes the audit model by acting as a persistent evidence collector that can investigate, cross-reference, and adapt in real time. For identity programmes, the question is no longer whether evidence exists, but whether it can be assembled with trustworthy lineage, decision history, and traceability.

The article frames this shift through an IBM audit and the author’s experience of manual reconstruction. That starting point is typical of many enterprise audits, which rely on delayed evidence retrieval rather than continuously available control proof.


Key questions

Q: How should security teams use agentic AI in compliance audits?

A: Security teams should use agentic AI to gather evidence, correlate records, and flag anomalies, but keep human owners in charge of final audit decisions. The control model should define provenance, review points, and exception handling so automation improves assurance without becoming an unreviewed source of truth.

Q: What breaks when audit evidence is still collected as screenshots and exports?

A: Screenshots and exports decay the moment they are taken, so they quickly diverge from the live identity state. That makes it hard to prove why access existed, whether it was used, and whether the control worked throughout the review period. Manual reconstruction also increases the chance that important lineage details are missed or disputed.

Q: When should organisations prioritise continuous evidence over periodic audit preparation?

A: Prioritise continuous evidence when identity changes are frequent, approvals span multiple systems, or audit questions depend on lineage rather than a single control snapshot. If the environment changes faster than the audit cadence, periodic preparation will always lag behind the facts. Continuous evidence reduces that gap and shortens the path to defensible assurance.

Q: How do auditors evaluate AI-generated evidence narratives?

A: Auditors should test whether the narrative is traceable to authoritative source records, whether it preserves approval and usage context, and whether it can be reproduced on demand. A useful narrative explains the sequence of identity decisions, not just the final access state. If the chain cannot be inspected, the narrative is only a summary, not proof.


Technical breakdown

Why static audit evidence breaks down

Traditional audit evidence is static: screenshots, exports, timestamps, and attestations captured at a moment in time. The problem is that the evidence ages immediately, while the underlying system keeps changing. In identity governance, that creates a gap between what the control looked like when captured and what it actually looked like during the period under review. A human audit team must reconstruct access lineage from partial records, which is slow and error-prone. Agentic AI changes the mechanism by continuously correlating records, but only if the data sources are authoritative and the evidence chain remains intact.

Practical implication: Treat audit evidence as a governed data product, not a one-off export.

How agentic AI can investigate audit questions in real time

Agentic AI is being used here as a runtime investigator, not just a reporting layer. It can pull logs, compare entitlement changes, follow request histories, and adapt its next query based on what it finds. That is materially different from scripted automation because the system can decide what to inspect next as the audit narrative develops. In identity terms, this matters for joiner-mover-leaver history, privilege approvals, and dormant access paths. The value is not speed alone, but the ability to build a defensible chain of evidence while the underlying state is still observable.

Practical implication: Use runtime investigation to surface access lineage while the control state is still live.

Why context and lineage are the real audit requirement

Auditors rarely want a raw log line by itself. They want to know why a permission existed, who approved it, whether it was ever used, and whether it aligned with policy. That means the real control problem is lineage, not simply collection. In identity programmes, lineage connects a person or workload to the entitlement, the business reason, the approval path, and the current risk posture. Agentic AI can help assemble that narrative, but only if the organisation has already designed for traceability across systems and time.

Practical implication: Build evidence models that preserve approval context, entitlement lineage, and usage history.


Threat narrative

Attacker objective: The objective is not attacker-driven compromise but audit failure by overwhelming manual evidence gathering and obscuring access lineage.

  1. Entry occurs through fragmented audit data, where logs, tickets, and approval records are scattered across systems that do not preserve a complete identity trail.
  2. Escalation happens when the audit team must manually reconcile old permissions, delayed updates, and incomplete histories under a fixed deadline.
  3. Impact is delayed assurance, because the organisation can only prove control operation after extensive reconstruction rather than through continuous evidence.
  • Sisense breach 2024: A credential in Sisense's GitLab reportedly opened S3 buckets of customer tokens, passwords and certificates; CISA urged a full reset.

Read our 52 NHI Breaches Analysis report for a comprehensive view of breaches impacting Non-Human Identities including AI Agents.


NHI Mgmt Group analysis

Agentic AI turns audit work from reconstruction into continuous evidence operations: The core shift is not faster reporting but a different control model for proving identity governance. When evidence is assembled continuously, audit readiness becomes a standing operational state instead of a period-end scramble. Practitioners should treat this as a redesign of audit evidence architecture, not a productivity tweak.

Static evidence is the real bottleneck in identity audits: Screenshots, exports, and attestations age immediately, while entitlements and approvals keep moving. That is why access reviews and audit narratives so often trail the actual state of the environment. The implication is that identity teams need evidence pipelines that preserve traceability at the moment of change.

Digital archaeology is an inadequate governance model for modern identity estates: Reconstructing who had access, why they had it, and whether it was used is too slow when identity changes are frequent and distributed. The problem is not just volume, but the loss of causal context across systems. Practitioners need to assume that if provenance is not captured near the event, it may never be recoverable.

Living evidence will become a governance expectation, not a convenience: As agentic systems mature, auditors will expect machine-generated narratives that can explain both the what and the why. That pressure reaches beyond human IAM into NHI and autonomous workflows, because the same lineage question applies whenever access is created, used, or inherited. Teams should prepare for evidence models that can survive scrutiny across actor types.

Named concept: living evidence for identity audits: This article points to a model where evidence is continuously maintained, context-rich, and queryable rather than static and retrospective. For identity teams, that means the audit artefact is no longer a file set but an always-current accountability record. Practitioners should design for continuous proof, not periodic reconstruction.

From our research library:

What this signals

Living evidence will become the practical standard for audit-ready identity programmes: Continuous proof changes the audit question from “Can you find the record?” to “Can you trust the lineage?” That shift matters across human access, NHI credentials, and autonomous workflows because each relies on the same basic accountability chain. Teams that still optimise for screenshots will keep losing time to reconstruction.

Agentic AI will not remove audit judgement, but it will move judgement closer to evidence creation. That makes identity workflows more important, not less, because every approval, entitlement change, and revocation has to be structured so a machine can explain it later.


For practitioners

  • Define evidence lineage requirements Map which identity events must be preserved with approval, usage, and ownership context so audit questions can be answered without manual reconstruction.
  • Replace snapshot evidence with live records Prioritise systems that maintain continuously updated access histories, entitlement changes, and ticket links instead of one-time exports and screenshots.
  • Instrument identity changes at the point of change Capture business reason, approver, and entitlement delta as part of the access workflow so the audit trail is created when the decision is made.
  • Validate that AI-generated audit narratives remain traceable Require the system to show which source records, logs, and approvals support each conclusion before auditors rely on the output.

Key takeaways

  • Agentic AI points to a new audit model where evidence is assembled continuously rather than reconstructed after the fact.
  • The main governance issue is not speed alone, but whether identity evidence keeps its context, lineage, and accountability intact.
  • IAM teams should design evidence flows that preserve the decision trail at the point of change, because that is what makes audits defensible.

Standards & Framework Alignment

This section maps relevant standards and security frameworks to the operational risks and controls described in this guidance.

OWASP Agentic AI Top 10 and OWASP Non-Human Identity Top 10 address the attack and risk surface, while NIST AI RMF, NIST CSF 2.0 and NIST SP 800-53 Rev 5 set the governance and control requirements practitioners need to meet.

FrameworkControl / ReferenceRelevance
OWASP Agentic AI Top 10ASI03 — Identity & Privilege AbuseAgentic AI audit workflows depend on who can act and with what authority in runtime evidence gathering.
Recommendation — Constrain agent authority so audit evidence collection cannot exceed its delegated access.
NIST AI RMFGOVERN — AI Governance and AccountabilityThe article is fundamentally about governing an AI system that participates in compliance evidence production.
Recommendation — Define ownership, oversight, and accountability for AI-generated audit evidence.
NIST CSF 2.0PR.AA-05 — Access Permissions, Entitlements and AuthorizationsAudit readiness depends on proving entitlement history and authorization decisions across identity systems.
Recommendation — Preserve entitlement and authorization evidence so access decisions remain traceable.
NIST SP 800-53 Rev 5AU-6 — Audit Record Review, Analysis, and ReportingThe article centres on how audit records are reviewed, correlated, and turned into evidence.
Recommendation — Automate audit record correlation while retaining the source records needed for review.
OWASP Non-Human Identity Top 10NHI-01 — Improper OffboardingThe article's access-lineage examples include terminated employees and lingering contractor access.
Recommendation — Verify offboarding leaves no unresolved access path or stale entitlement in the audit trail.

Key terms

  • Living Evidence: Evidence that is continuously updated and traceable as the environment changes, rather than captured once in a static export. It is valuable in audits because it preserves context and change history, but only if source integrity and chain of custody are maintained.
  • Audit Lineage: The record that connects an identity to a session and then to the action it performed. In AI and NHI security, lineage is what makes attribution possible when multiple actors, tokens, and automations can use the same interfaces.
  • Agentic Evidence Collection: Agentic evidence collection uses an AI system to investigate, correlate, and adaptively gather audit material at runtime. For identity teams, the value is not automation for its own sake, but the ability to assemble explainable proof while the underlying state is still visible.
  • Control Reconstruction: Control reconstruction is the manual process of rebuilding audit proof from logs, tickets, and screenshots after the fact. It is slow, fragile, and highly dependent on human memory, which makes it a poor fit for fast-moving identity environments with frequent access changes.

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NHIMG Editorial Note
Published by the NHIMG editorial team on May 28, 2026.
Updated on October 6, 2026.
NHI Mgmt Group, the independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org