By NHI Mgmt Group Editorial TeamBased on Cerbos: “10 critical challenges CISOs face in 2026 and how to solve them” (January 5, 2026)

TL;DR: CISOs in 2026 are dealing with intensifying compliance pressure, Zero Trust execution gaps, tool sprawl, and AI-era access risk, with one survey showing 70% feel at risk of a material cyber attack in the next 12 months, according to Cerbos. The core issue is that security programmes still treat authorization as an app detail instead of a central control plane, which leaves access decisions inconsistent and hard to audit.


At a glance

What this is: Cerbos argues that 2026 CISO pressure is being amplified by authorization control gaps, where access logic remains scattered across applications instead of being centrally visible and auditable.

Why it matters: This matters because IAM, IGA, and PAM teams cannot prove least privilege or support Zero Trust at scale when authorization decisions are embedded in code and hidden from governance.

By the numbers:

  • 70% of CISOs feel at risk of a material cyber attack in the next 12 months, according to Cerbos.

Context

Authorization is the decision layer that determines who can do what, on which data, and under what conditions. In 2026, the problem is not that organisations lack identity systems, but that many still distribute access logic across application code, making governance, audit, and policy change far harder than they need to be.

For IAM programmes, that creates a structural gap between authentication and enforcement. Zero Trust, compliance evidence, and AI-era access governance all depend on authorization being visible, testable, and consistent across services rather than hidden in bespoke implementation code.

Cerbos frames this as a CISO-wide operating problem rather than a narrow application issue. The article's starting position is typical for modern enterprise environments, where cloud distribution and software decentralisation have made centralized access governance harder to achieve.


Key questions

Q: How should security teams find authorization logic hidden in application code?

A: Start with static discovery across repositories and look for role checks, ownership predicates, ORM filters, middleware guards, and feature gates. Then classify those decision points by business criticality so you can prioritise the ones that affect sensitive data, privileged actions, and cross-tenant access. A searchable inventory is the first step toward policy consolidation.

Q: Why does distributed authorization create Zero Trust risk?

A: Because Zero Trust depends on evaluating every request against policy, not only authenticating the identity once. When each application makes its own authorization decision, the organisation loses consistency, traceability, and the ability to answer who can access what. That creates gaps even when sign-in is strong.

Q: What are the signs that authorization governance is failing?

A: Common signs include conflicting permissions across applications, frequent code changes for access rules, difficulty answering audit questions, and teams relying on custom logic to grant or block access. Those symptoms show the policy plane is fragmented, which usually means governance is lagging behind application development.

Q: How should teams centralize authorization without slowing application delivery?

A: Teams should separate decision logic from application code, place it in one governed policy layer, and validate latency under production load. That approach reduces duplicated rules, keeps changes consistent, and prevents developers from rebuilding custom checks in each service when business requirements change.


Technical breakdown

Why embedded authorization logic breaks governance

When authorization rules are hard-coded in each application, policy drift becomes inevitable. Different teams implement role checks, attribute checks, and edge cases differently, so the organisation loses a single source of truth for access. That breaks auditability because reviewers cannot easily trace why a decision was made or whether the same rule is enforced everywhere. It also slows change, since every policy update requires code changes and release cycles. For identity teams, the issue is not just scale, but consistency: the same identity can receive different outcomes depending on the service making the decision. That undermines least privilege, compliance evidence, and incident investigation.

Practical implication: externalize authorization so policy changes are controlled centrally rather than buried in application code.

How central policy decision points support Zero Trust

Zero Trust is not only about authenticating every request. It requires each request to be evaluated against context, roles, attributes, and data sensitivity at the point of use. A centralized policy decision point makes that feasible by separating decision logic from the application and allowing one policy set to govern many services. This matters because identity verification alone does not answer the question of what the identity may actually do. When authorization is distributed, organisations can still have authenticated users moving laterally inside trusted applications. A policy service gives security teams one place to express and inspect those rules.

Practical implication: use centralized authorization to make Zero Trust enforceable after login, not just at sign-in.

Why compliance needs audit-ready authorization decisions

Compliance pressure increases sharply when organisations must prove who accessed what, when, and why. That evidence is difficult to assemble if authorization is scattered across applications and custom code paths. Central policy management creates a durable record of policy changes and access decisions, which supports audits, incident review, and control validation. It also helps map business access rules to regulatory expectations without reverse-engineering each application. In practice, this turns authorization from an application concern into a governance control with traceability. For security leaders, the value is not simply operational efficiency, but the ability to produce evidence on demand.

Practical implication: design access governance so every decision leaves an audit trail that can survive regulatory review.


NHI Mgmt Group analysis

Authorization visibility gap: The core governance failure is not the absence of authentication, but the absence of a central, testable view of who can do what. Hard-coded authorization logic turns access into local implementation detail, which means governance teams inherit inconsistency instead of control. The practical conclusion is that authorization must be treated as a shared identity governance layer, not an application footnote.

Zero Trust collapses without centralized authorization: Identity verification without request-time authorization only secures the front door. Once applications make their own access decisions, the architecture stops being zero trust in practice because policy cannot be enforced uniformly across cloud, SaaS, and internal services. Practitioners should read that as a control-design failure, not a tooling preference.

Compliance evidence is now an access architecture problem: Continuous compliance depends on being able to show access intent, policy history, and decision traceability on demand. If decisions live in code across dozens of services, auditability becomes reverse engineering. The implication for IAM and IGA teams is that evidence generation must be designed into authorization, not bolted on after control deployment.

AI-era access makes the gap more expensive: As organisations extend systems to automated workflows and AI-driven actions, authorization inconsistencies become harder to detect and easier to exploit. The same control gap that frustrates auditors can also let machine-initiated access exceed its intended scope. That means governance models need a unified decision layer before AI increases the volume of access decisions beyond human review capacity.

Policy-as-code is only useful if the policy plane is singular: The article's underlying message is not that code is bad, but that fragmented code-based authorization is ungovernable at enterprise scale. A named concept here is the authorization visibility gap, where policy exists but cannot be seen, tested, or audited consistently. Practitioners should close that gap by collapsing authorization into one governable plane.

What this signals

Authorization control planes are becoming a governance necessity: Organisations that still treat access decisions as local code will keep paying an audit and change-management tax. The practical shift is to design one policy layer that can be evaluated, versioned, and defended across the estate.

Authorization visibility gap: When the policy exists but cannot be seen centrally, teams lose the ability to prove least privilege or spot drift before it becomes an incident. That is why the control plane, not the individual app, is now the unit of governance.

Identity programmes will be judged on decision traceability, not just login success: Boards and auditors will increasingly ask how access was allowed, not whether the user authenticated successfully. Programmes that cannot answer that question will struggle to demonstrate mature IAM and Zero Trust execution.


For practitioners

  • Externalize application authorization Move access decision logic out of individual services into a centralized policy layer so changes are governed once and enforced everywhere.
  • Map access decisions to audit evidence Record policy changes, access outcomes, and the reason each decision was made so auditors can trace control operation without code review.
  • Inventory hard-coded authorization paths Identify every service that still embeds role checks or permission logic and prioritise those systems where sensitive data or regulated workflows are involved.
  • Align Zero Trust to request-time decisions Use contextual authorization at the point of use so identity checks continue after sign-in and do not rely on network location or application trust.

Key takeaways

  • The central risk is not weak authentication but fragmented authorization, which makes access decisions inconsistent across applications.
  • The article ties 2026 CISO pressure to compliance, Zero Trust execution, cloud complexity, and AI-era access risk.
  • Centralized, auditable authorization is the control that most directly improves visibility, consistency, and evidence generation.

Standards & Framework Alignment

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

NIST CSF 2.0, NIST Zero Trust (SP 800-207), CIS Controls v8 and NIST SP 800-53 Rev 5 set the governance and control requirements practitioners need to meet.

FrameworkControl / ReferenceRelevance
NIST CSF 2.0PR.AA-05 — Access Permissions, Entitlements and AuthorizationsThe article centers on centralized, auditable authorization decisions across applications.
Recommendation — Apply PR.AA-05 to centralize and document access permissions and entitlement decisions.
NIST Zero Trust (SP 800-207)Policy Decision PointZero Trust execution in the article depends on request-time authorization and centralized policy decisions.
Recommendation — Use centralized policy decisions to enforce Zero Trust at the point of use.
CIS Controls v8CIS-5 — Account ManagementThe article highlights access governance, least privilege, and control over who can do what.
Recommendation — Tighten account management so access rules are governed, reviewed, and consistently enforced.
NIST SP 800-53 Rev 5AC-6 — Least PrivilegeThe article repeatedly points to least-privilege enforcement as a core control objective.
Recommendation — Apply least privilege to minimize access and reduce inconsistent application-level permissions.

Key terms

  • Access visibility gap: The difference between knowing an identity exists and being able to prove what it accessed, when, and under which privileges. In AI agent programmes, this gap widens because action happens continuously and may bypass the log sources traditional IAM tools expect.
  • Policy decision point: A policy decision point evaluates contextual rules and returns an access decision that enforcement points can act on. It separates authorization logic from application code, which helps teams manage tenant rules, resource ownership, and risk signals consistently.
  • Policy as Code: Policy as code stores authorization logic in version control and evaluates it through testable, reviewable rules. For agent governance, it makes runtime decisions reproducible and measurable, which is critical when actions can be triggered by untrusted content and executed at machine speed.
  • Zero Trust Authentication: Zero Trust Authentication is an approach that never assumes a user, device, or workload is trustworthy just because it is inside a network. It requires each sign-in or access request to be verified with strong identity signals, context, and policy checks, then continuously re-evaluated as risk changes.

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NHIMG Editorial Note
Published by the NHIMG editorial team on June 10, 2026.
Updated on October 6, 2026.
NHI Mgmt Group, the independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org