By NHI Mgmt Group Editorial TeamPublished 2026-02-22Domain: Governance & RiskSource: CyberArk

TL;DR: Identity is now infrastructure for workloads, certificates, API-driven automation, and AI actions, and CyberArk argues that strategy can stay global while governance must adapt locally to regional scrutiny, evidence demands, and accountability expectations. That split matters because machine identities now carry the operational and regulatory burden that legacy IAM models were never built to defend.


At a glance

What this is: This is an editorial on why identity strategy should be centralized while identity governance must be adapted to local regulatory and operational scrutiny, especially for machine identities and AI-driven actions.

Why it matters: For IAM and NHI practitioners, it shows why global policy is not enough if teams cannot prove control, revoke access, and reconstruct machine actions where scrutiny actually happens.

By the numbers:

👉 Read CyberArk's analysis of global identity strategy and local governance


Context

Identity governance has become a control problem, not just an authentication problem. As machine identities, service accounts, certificates, API keys, and AI agents take on more delegated authority, the real challenge is proving who or what is allowed to act, under which rules, and with what evidence when something breaks.

That is why this topic maps directly to NHI governance. A global identity strategy can define common trust and automation principles, but local governance determines whether those controls survive audit, outage, and regulatory scrutiny. For background on the underlying risk patterns, see the Ultimate Guide to NHIs and the Top 10 NHI Issues.


Key questions

Q: How should organisations govern machine identities across multiple regions?

A: Use a global identity strategy for trust, lifecycle, and automation standards, then apply local governance for evidence, accountability, and revocation requirements. The practical test is whether each region can prove control during an outage, audit, or incident review. If a policy cannot produce local evidence, it is not operationally complete.

Q: Why do machine identities complicate identity governance more than human accounts?

A: Machine identities act continuously, at scale, and with delegated authority, so they cannot rely on manual review cycles or human pauses. They often outnumber human users and can trigger downstream systems automatically. That makes runtime enforcement, ownership, and revocation timing much more important than in traditional user IAM.

Q: What is the difference between global identity strategy and local governance?

A: Global strategy defines the organisation’s common trust model, automation principles, and lifecycle intent. Local governance defines what must be proven in a specific region or regulatory context, including who approves, who owns, and what evidence must exist. Strategy sets direction. Governance determines whether the control survives scrutiny.

Q: When should security teams treat identity as infrastructure?

A: Security teams should treat identity as infrastructure whenever workloads, certificates, API keys, or AI agents are required for business continuity. At that point, identity failures can stop operations, not just block logins. The right response is to engineer identity for reliability, observability, and recoverability from the start.


Technical breakdown

Global identity strategy vs local identity governance

A global identity strategy defines the organization’s trust model, lifecycle rules, and automation principles. Local governance is the part that makes those rules defensible under jurisdiction-specific scrutiny, including evidence requests, recovery obligations, and accountability requirements. The failure mode is not usually absence of policy. It is mismatch between the policy and the proof required to satisfy regulators, auditors, or incident reviewers. That is why identity programs often look coherent centrally but break at the point of examination. Practical implication: design for a common trust model, then add jurisdiction-specific control evidence and decision trails.

Practical implication: Design for a common trust model, then add jurisdiction-specific control evidence and decision trails.

Machine identities change the governance model

Machine identities behave differently from human users because they operate continuously, at scale, and often without a natural pause for approval. Service accounts, certificates, API keys, and AI agents can authenticate other systems, trigger workflows, and propagate access automatically. That means governance cannot depend on manual interpretation or after-the-fact exception handling. If the identity layer is weak, automation becomes a force multiplier for risk rather than a control surface. Practical implication: treat machine identity governance as runtime infrastructure, not a periodic compliance exercise.

Practical implication: Treat machine identity governance as runtime infrastructure, not a periodic compliance exercise.

Why local scrutiny exposes brittle identity controls

Regional regulators and internal control owners often care about different proof points even when the underlying access pattern is the same. One jurisdiction may focus on revocation timing during outages, another on traceability months later, and another on lawful access across failover paths. This creates a hard requirement for controls that can emit usable evidence on demand. A control that exists in policy but cannot demonstrate action, ownership, or recovery path will fail under scrutiny. Practical implication: map every high-risk NHI control to the evidence a local authority would actually ask for.

Practical implication: Map every high-risk NHI control to the evidence a local authority would actually ask for.


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


NHI Mgmt Group analysis

Local governance is now the real test of identity maturity. Strategy can be standardized, but control validation cannot be. When regulators, auditors, or incident responders ask for proof, the relevant question is not whether the policy exists, but whether the organization can demonstrate it in the right jurisdiction at the right time. That is the divide between design intent and operational reality, and it is where most identity programs fail. Practitioners should treat local evidence as part of the control, not as an afterthought.

Machine identities expose the gap between access design and control enforcement. Human-centric IAM assumes discretion, prompts, and review cycles. NHIs and agents do not wait for review, and that changes the meaning of governance. Once workloads and AI agents can initiate actions autonomously, identity controls must be enforceable at runtime, not just attestable in policy. Practitioners need governance models that are built for continuous execution.

Identity blast radius is the right concept for this problem. A global policy can define who should trust what, but local governance determines how far a compromised identity can move before someone can stop it. That blast radius grows when service accounts, API keys, and certificates are shared across regions or systems without clear ownership. The practical answer is to reduce standing authority, bind every identity to a named owner, and limit cross-boundary reuse.

Regulatory fragmentation is pushing identity teams toward evidence-first operations. The article correctly shows that the same control can be judged differently across markets. For practitioners, that means governance design must include logging, revocation proof, and reconstructability from the start. The direction of travel is clear: identity programs that cannot produce jurisdiction-specific evidence will be treated as incomplete, even if the underlying architecture looks modern.

Machine identity governance will increasingly be judged by resilience, not just access policy. Outages, failovers, and recovery events are where weak identity control becomes visible. The field is moving toward programs that can revoke, reconstruct, and reauthorize without breaking operations. Teams that build for resilience now will be better positioned as NHI oversight becomes more operational and less theoretical.

From our research:

  • 97% of NHIs carry excessive privileges, increasing unauthorised access and broadening the attack surface, according to the Ultimate Guide to NHIs.
  • Only 20% have formal processes for offboarding and revoking API keys, and even fewer have procedures for rotating them, which is why governance breaks down when machine identities are left to accumulate.
  • For a broader view of why machine identity controls fail in practice, compare this with 52 NHI Breaches Analysis and use it to pressure-test your revocation and ownership model.

What this signals

The practical signal for identity teams is that jurisdiction-specific evidence is becoming part of the control surface. Global policy still matters, but regulators and auditors will increasingly ask for proof that revocation, attribution, and recovery work where the system actually operates, not just in headquarters documentation.

Identity blast radius: the next governance conversation should focus less on account counts and more on how far a compromised machine identity can travel before it is contained. With 69% of organisations now having more machine identities than human ones, according to The Critical Gaps in Machine Identity Management report, scale has already outpaced manual governance in most environments.

That is why practitioners should align NHI controls with external frameworks such as the NIST Cybersecurity Framework 2.0 and internal resilience requirements. The programme implication is clear: if you cannot reconstruct a machine identity’s actions or prove local enforcement during disruption, the control is not ready for operational scrutiny.


For practitioners

  • Define a global trust model with local evidence requirements Document one enterprise trust model, then attach jurisdiction-specific proof artifacts for revocation, attribution, and recovery. Make local evidence requirements part of control design, not a separate audit task.
  • Map all high-risk NHIs to named owners and jurisdictions Assign every service account, certificate, API key, and AI agent to a clear owner, system, and operating region. This reduces ambiguity when regulators ask who approved access and where it was exercised.
  • Instrument revocation and reconstruction for machine identities Ensure you can revoke access during disruption and later reconstruct which machine identity acted, on which system, and under what entitlement. That capability is essential for auditability and post-incident review.
  • Reduce cross-border reuse of privileged machine credentials Avoid reusing the same credential sets across regions or business units unless you can prove local enforcement and separate rollback paths. Cross-border reuse expands blast radius and complicates scrutiny.
  • Build control evidence into automation pipelines Require logs, approvals, and lifecycle events from automation flows so evidence is produced as operations run. This makes access governance usable during outages and compliance checks.

Key takeaways

  • Global identity strategy can stay consistent, but governance has to be proven locally where regulators and auditors actually review it.
  • Machine identities force IAM teams to move from periodic review to runtime enforcement, because automated actions do not wait for human approval.
  • The key design goal is shrinking identity blast radius through ownership, revocation, and reconstructable evidence across every operating region.

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 controls must be enforceable and evidenced in each region.
NIST Zero Trust (SP 800-207)Zero trust depends on continuous verification of non-human access.
OWASP Non-Human Identity Top 10NHI-03Lifecycle control and revocation are central to local governance.

Apply continuous verification to machine identities and remove trust based on network location.


Key terms

  • Machine Identity: A machine identity is a non-human credential or trust object used by software, workloads, or agents to authenticate and act. It includes service accounts, certificates, API keys, tokens, and other secrets that let automation operate with authority.
  • Identity Governance: Identity governance is the set of rules, evidence, and approvals that prove access is appropriate and controllable. In NHI environments it must cover creation, rotation, revocation, ownership, and auditability without assuming a human is present to intervene.
  • Identity Blast Radius: Identity blast radius is the amount of damage a compromised identity can cause before containment. In practice it is shaped by privilege, reuse, ownership clarity, and how quickly access can be revoked or reconstructed across systems and regions.
  • Local Governance: Local governance is jurisdiction-specific control enforcement and evidence generation for identity actions. It ensures the global policy can be demonstrated under the rules of a particular regulator, market, or operational environment, especially during outages or incident review.

Deepen your knowledge

Identity as infrastructure and local governance are core topics in our NHI Foundation Level course, the industry's only accredited NHI security programme. If you are building a governance programme for machine identities across regions, it is worth exploring.

This post draws on content published by CyberArk: Why a global identity strategy requires local governance. Read the original.

NHIMG Editorial Note
Published by the NHIMG editorial team on 2026-02-22.
NHI Mgmt Group — the independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org