By NHI Mgmt Group Editorial TeamPublished 2025-09-30Domain: Governance & RiskSource: SecurEnds

TL;DR: Manual user access reviews are failing at enterprise scale because spreadsheets, emails, and fragmented approvals cannot keep pace with rapid permission changes across cloud and SaaS environments, according to SecurEnds. The real shift is that review cadence, auditability, and privilege cleanup now need automation, or access governance will continue to lag behind identity risk.


At a glance

What this is: This is an analysis of why automated user access reviews have become a baseline control, with the central finding that manual spreadsheet-led reviews are no longer practical for modern identity sprawl.

Why it matters: It matters because IAM, NHI, and human access programmes all rely on the same recertification logic, and manual reviews leave excess privilege, audit gaps, and delayed revocation unresolved.

By the numbers:

👉 Read SecurEnds' analysis of automated user access review tools in 2026


Context

User access review automation is the move from periodic, manual permission checks to continuous, system-led certification of who has access and whether that access is still justified. The primary problem is not the review itself, but the scale mismatch between modern identity sprawl and spreadsheet-based governance, especially when access changes across SaaS, cloud, and internal systems faster than humans can reconcile them.

For IAM teams, the issue is broader than compliance. Access reviews are a lifecycle control that affects human users, privileged administrators, and non-human identities where access entitlements drift, persist, or outlive the business need that created them. When reviews are slow or incomplete, privilege creep becomes a standing condition rather than an exception.


Key questions

Q: How should security teams automate user access reviews without losing control?

A: Start by automating the highest-change environments, such as SaaS, cloud, and privileged systems. Keep human approval for exceptions, but let the platform handle entitlement discovery, campaign routing, evidence capture, and revocation tracking. That gives reviewers current data instead of spreadsheets, while preserving accountability where policy judgment is required.

Q: Why do manual access reviews fail in modern IAM programmes?

A: Manual reviews fail because access changes faster than people can reconcile approvals, exports, and audit evidence. In large environments, that creates stale attestations, missed entitlements, and delayed revocation. The problem is structural, not procedural, so automation becomes necessary when the review volume exceeds human coordination capacity.

Q: What do security teams get wrong about privileged access reviews?

A: They often treat privileged reviews as a separate audit task instead of a higher-risk version of the same entitlement problem. Privileged accounts need tighter evidence, faster revocation, and more frequent certification because the blast radius is larger. Without that distinction, elevated access tends to persist unnoticed.

Q: Who is accountable when access review failures lead to audit findings?

A: Accountability usually sits with the identity, compliance, and system owners jointly, because review failure is both a governance and a control-implementation problem. Regulators expect proof that access was monitored, certified, and removed when no longer needed. The organisation must be able to show who approved what, when, and why.


Technical breakdown

Why manual access review workflows break at scale

Manual access review workflows depend on people exporting entitlements, chasing approvals, and reconciling evidence across disconnected systems. That process may work in a small environment, but it collapses when access is changing continuously across SaaS apps, cloud platforms, and internal systems. The main failure is not intent, it is latency and inconsistency. By the time a spreadsheet is approved, the access graph has already changed. That is why audit evidence, review completeness, and revocation timing all deteriorate together.

Practical implication: automate recertification for high-change applications before manual reviews become a bottleneck.

How role based access control and segregation of duties support reviews

Role based access control reduces the number of individual entitlements a reviewer has to assess by grouping permissions into job functions. Segregation of duties adds another layer by flagging combinations that should never sit with one identity, such as request and approve or create and pay. Together, they make access review more than a checkbox by turning it into a policy validation exercise. Without these structures, reviewers are left judging raw permissions one at a time, which is slow and error-prone.

Practical implication: align review campaigns to roles and SoD rules so reviewers validate policy exceptions, not every entitlement from scratch.

Why privileged access reviews need tighter evidence trails

Privileged access reviews are different because elevated permissions create higher blast radius if they are left unchecked. The technical requirement is not just visibility, but an evidence trail that shows when access was granted, who approved it, when it was reviewed, and when it was removed. Automated platforms reduce the burden by making the review event itself observable and repeatable. That matters in audits, where the absence of clean evidence often becomes the control failure, even when the underlying access issue was known.

Practical implication: require audit-ready logging for privileged review decisions, not just for access grants.


  • Sisense breach — unauthorized GitLab access led to exfiltration of access tokens, API keys and certificates.
  • Cisco DevHub NHI breach — IntelBroker exploited exposed Cisco credentials, API tokens and keys in DevHub.

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


NHI Mgmt Group analysis

Manual access review is a governance lag problem, not just an operational inconvenience. When permissions change faster than reviewers can certify them, the control stops describing reality and starts documenting stale state. That creates a false sense of oversight because the organisation can produce a review record without proving current entitlement accuracy. The practitioner conclusion is simple: recertification must track live access conditions, not past spreadsheet state.

Access review belongs in the same control family as NHI governance. Service accounts, API keys, and human users all accumulate excess privilege when entitlement review is weak, even if the approval path looks different for each actor type. The governance challenge is the same: verify that access still maps to a current business purpose. Practitioners should treat review automation as a cross-identity control, not a human-only compliance task.

Privilege creep is the named failure mode this article exposes. Users, admins, and application accounts slowly accumulate permissions that nobody remembers to remove, especially when access changes are frequent and review processes are fragmented. That is not a policy edge case, it is the predictable outcome of manual certification at scale. The practitioner conclusion is to measure drift as a recurring condition, not an occasional exception.

Automated access review has become part of the zero trust control stack. Zero trust assumes continuous verification, but access reviews are often still periodic and disconnected from runtime conditions. That mismatch weakens the governance layer behind the architecture. The practitioner conclusion is that certification cadence, entitlement scope, and revocation workflow all need to be treated as one operating model, not separate programmes.

From our research:

  • Only 5.7% of organisations have full visibility into their service accounts, according to Ultimate Guide to NHIs.
  • That same research shows 97% of NHIs carry excessive privileges, which explains why review automation has to address entitlement scope as well as certification cadence.
  • For the broader lifecycle picture, see 52 NHI Breaches Analysis, which shows how weak review and revocation controls turn into real incidents.

What this signals

Privilege creep is becoming a cross-domain governance signal, not a narrow IAM hygiene issue. Once access reviews move from manual to automated, organisations can finally see where entitlement drift is accumulating across humans, service accounts, and administrative roles. That makes review data useful for board reporting, audit readiness, and NHI lifecycle governance rather than just compliance evidence.

The next programme maturity step is not simply faster certification. It is connecting review outcomes to offboarding, revocation, and role change handling so that access review stops being a retrospective task and becomes a living control signal. Teams that do this well will expose stale access earlier and reduce the number of identities that outlive their business purpose.

Review automation will increasingly converge with zero trust enforcement. As identity programmes adopt continuous verification, the boundary between access review, policy enforcement, and runtime detection will narrow. That is especially important in environments where service accounts and privileged users generate more risk than ordinary accounts, and where NIST Cybersecurity Framework 2.0 controls need to be demonstrably operational, not just documented.


For practitioners

  • Automate high-change review cycles first Start with SaaS, cloud, and privileged systems where access changes most often. Use automation to surface stale entitlements, route approvals, and generate audit evidence without relying on spreadsheets.
  • Tie reviews to roles and SoD rules Map review campaigns to role based access control and segregation of duties policies so reviewers validate meaningful exceptions instead of scanning every raw entitlement.
  • Separate privileged reviews from standard access Give admin, finance, and other elevated accounts stricter review cadence, stronger approval thresholds, and a dedicated evidence trail for every decision.
  • Measure revocation speed after access is no longer needed Track how quickly access is removed after role changes, project completion, or account inactivity so you can see whether review outcomes are actually reducing exposure.

Key takeaways

  • Manual access reviews no longer scale cleanly in environments where permissions change continuously across cloud and SaaS systems.
  • The main failure mode is privilege creep, where access persists beyond business need because review and revocation are too slow or fragmented.
  • Automated certification, stronger evidence trails, and role-based review logic are now core governance controls, not optional efficiency upgrades.

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 Zero Trust (SP 800-207) set the governance and control requirements practitioners need to meet.

FrameworkControl / ReferenceRelevance
NIST CSF 2.0PR.AC-4Access permissions and review cadence map directly to identity governance.
NIST Zero Trust (SP 800-207)Continuous verification is the architectural context for automated access reviews.
OWASP Non-Human Identity Top 10NHI-03Review failure often leaves non-human and privileged identities over-privileged.

Treat access review as part of zero trust enforcement and not a separate compliance task.


Key terms

  • Access Review: An access review is a formal check that confirms whether an identity still needs the permissions it has. In practice, it is a governance control that compares current access against current business need and records whether entitlement should remain, change, or be removed.
  • Privilege Creep: Privilege creep is the gradual accumulation of permissions beyond what an identity actually needs. It happens when access is granted for temporary tasks, role changes, or exceptions and is never fully removed, creating hidden exposure across human and non-human identities.
  • Segregation Of Duties: Segregation of duties is a control that prevents one identity from holding conflicting permissions that could enable fraud, error, or unchecked change. In access review programmes, it is used to detect combinations of rights that should be split, challenged, or revoked.
  • Recertification: Recertification is the periodic reapproval of existing access to confirm it still matches the user’s job, system role, or business purpose. For modern IAM and NHI programmes, it is less about paperwork and more about proving entitlement accuracy over time.

Deepen your knowledge

User access review automation, privilege creep detection, and access certification design are core topics in our NHI Foundation Level course, the industry's only accredited NHI security programme. If you are building a governance programme that spans humans and non-human identities, it is worth exploring.

This post draws on content published by SecurEnds: user access review tools and automated access reviews in 2026. Read the original.

NHIMG Editorial Note
Published by the NHIMG editorial team on 2025-09-30.
NHI Mgmt Group — the independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org