By NHI Mgmt Group Editorial TeamBased on Zluri: “5 Identity Challenges in M&A To Address in 2026” (February 28, 2026)

TL;DR: Mergers and acquisitions create identity visibility, access management, privilege, and compliance problems that can delay integrations and expose sensitive systems, according to Zluri. The core issue is that identity programmes assume one operating model, while M&A forces two or more to coexist long enough for gaps to become exploitable.


At a glance

What this is: This article argues that M&A turns identity fragmentation, access governance, and compliance alignment into the main integration risks, not side tasks.

Why it matters: IAM, IGA, PAM, and security teams need a merger-ready access model because duplicated accounts, mismatched policies, and delayed revocation can quickly become operational and security failures.


Context

Mergers and acquisitions often create an identity governance gap because two organisations bring different directories, role models, access processes, and compliance obligations into one operating environment. When identity data is fragmented, teams lose visibility into who has access, which privileges are valid, and which accounts should be removed.

In this article, M&A is treated as an access governance problem because the hard part is not the deal itself but the identity overlap it creates. The practical challenge is to unify identity data, align access workflows, and keep critical systems available while the merged environment is still unstable.


Key questions

Q: What breaks when identity governance is not unified in an M&A deal?

A: Duplicate accounts, conflicting roles, and inconsistent entitlement rules make it hard to know who should have access after the merger. The result is slow onboarding, failed access changes, and certification records that no longer match the real environment.

Q: Why do M&A integrations create so much access risk for IAM teams?

A: Because two organisations often bring different access models, revocation cadences, and approval paths into one estate. If those differences are not reconciled quickly, standing access can persist, privileged accounts can multiply, and users can lose access to critical systems.

Q: What are the main signs that M&A identity cleanup is failing?

A: Look for duplicate identities, delayed access requests, orphaned accounts, repeated manual overrides, and unresolved role conflicts between the two organisations. Those signals usually mean the merged access model is not yet stable enough for reliable governance.

Q: What should teams do when access decisions differ between two merging organisations?

A: Use one governing access model for the combined estate, then map exceptions explicitly until the old policies are retired. If teams leave both models in place, they create ambiguity over who can approve, provision, and revoke access.


Technical breakdown

Why identity visibility breaks during M&A

M&A creates an identity inventory problem before it creates a tooling problem. Each company may manage users through different directories, naming conventions, role structures, and entitlement models, so the combined estate is not immediately legible. Without a consolidated view, teams cannot reliably answer basic questions such as who exists, what they can access, and which identities are duplicated or stale. That lack of visibility drives access delays, role mismatches, and certification errors. In practice, federated identity and dynamic grouping reduce manual reconciliation, but the deeper issue is that the merged identity model has to be normalised before governance can be trusted.

Practical implication: Establish a consolidated identity source of truth before attempting large-scale access cleanup.

How application migration creates access drift

Application migration during M&A is an identity dependency problem disguised as an infrastructure project. Applications are often tied to specific identity providers, directory attributes, license terms, or access policies, so moving them without a plan can break authentication or leave permissions behind. A staging layer can reduce disruption by repointing identity providers and data sources gradually, but the key technical constraint is preserving entitlement continuity while the backend changes. If migration sequencing is wrong, users experience denied access, duplicate accounts, or orphaned permissions that survive the move. The governance risk is that the access model changes more slowly than the application estate.

Practical implication: Map identity dependencies for every application before deciding whether to migrate, stage, or retire it.

Why least privilege becomes harder in a combined estate

M&A often widens privilege faster than it narrows it. One organisation may use tightly scoped admin roles while the other relies on broader access or manual grants, and those differences collide when the environments are integrated. That creates over-permissioned users, lingering admin rights, and delayed deprovisioning windows, especially where onboarding and offboarding remain manual. Centralised access management, MFA for sensitive systems, and role-based access control reduce the risk, but the technical issue is that merged privilege models rarely align cleanly at day one. Until entitlements are rationalised, the combined estate carries elevated exposure by default.

Practical implication: Review high-risk admin and privileged roles first, then remove standing access that no longer matches the merged organisation.


NHI Mgmt Group analysis

M&A is really an identity normalisation problem. The article is correct to frame mergers as an access governance issue rather than a pure integration exercise. Until identity stores, role models, and entitlement rules are reconciled, every downstream project inherits ambiguity about who should have access and why. The practitioner takeaway is that identity normalisation has to precede broad integration work.

Duplicate identities and mismatched roles are the first operational warning signs. These are not just data quality issues. They create access errors, certification noise, and delays in granting or revoking permissions across the merged estate. A merger programme that cannot reconcile identity overlap early will struggle to produce trustworthy access decisions later.

Least privilege becomes fragile the moment two privilege models are merged. One company’s assumptions about admin scope, approval flow, and revocation cadence rarely map cleanly to the other’s. That is why M&A exposes over-permissioning so quickly. The practical conclusion is that privilege rationalisation must be treated as a merger workstream, not a post-merger clean-up task.

Merger identity sprawl: the governing problem is not access volume, it is access provenance. In a combined environment, the core question is whether each entitlement can still be traced to a valid business need across both organisations. Where provenance is unclear, access reviews, compliance reporting, and offboarding lose reliability. Practitioners should treat provenance as the control boundary for the merged identity estate.

Access governance in M&A is now a business continuity issue. The article’s examples show that delayed access, blocked users, and stale permissions can disrupt payroll, operations, and customer-facing work just as much as they can increase risk. That means IAM and IGA teams need to be involved at deal speed, not after the integration plan is already fixed.

What this signals

Identity governance has to move ahead of application consolidation. When mergers begin, the most valuable control is not the final target architecture but the ability to explain every user, role, and entitlement across both estates. If that explanation is missing, the integration programme will keep rediscovering the same access conflicts in different places.

Privilege rationalisation is the real control boundary in M&A. The merged organisation inherits the riskiest parts of both access models, so high-risk admin rights and manual exceptions deserve early attention. Teams that postpone that work usually carry excess access far longer than they expect.


For practitioners

  • Consolidate identity data before integration Build a unified inventory of users, roles, groups, and linked applications across both organisations before merging access policies.
  • Map application identity dependencies Document which apps depend on which identity providers, directory attributes, licences, and entitlement rules before any migration begins.
  • Rationalise privileged access early Review admin accounts, broad grants, and manual exceptions first, then remove standing privileges that no longer match business need.
  • Automate onboarding and offboarding workflows Replace manual grants and revocations with workflow-based access changes so users from both companies get the right access from day one.
  • Run access reviews on merged entitlements Use certification cycles to validate whether duplicated or inherited permissions still have a valid business owner after the merger.

Key takeaways

  • M&A exposes identity fragmentation because two operating models are forced to coexist before access can be rationalised.
  • The practical risks are access delays, duplicate accounts, over-permissioning, and compliance gaps across merged systems.
  • Merger programmes need identity normalisation, privileged access cleanup, and access reviews early enough to support the integration timeline.

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 SP 800-53 Rev 5 and CIS Controls v8 set the technical controls, while ISO/IEC 27001:2022 defines the regulatory obligations.

FrameworkControl / ReferenceRelevance
NIST CSF 2.0PR.AA-05 — Access Permissions, Entitlements and AuthorizationsThe article centres on reconciling merged entitlements and access governance.
Recommendation — Apply PR.AA-05 to normalise entitlements across both organisations before broad integration.
NIST SP 800-53 Rev 5AC-6 — Least PrivilegeM&A often expands privileges and leaves standing access in place.
Recommendation — Enforce AC-6 to remove excess access and re-baseline privilege after the merger.
CIS Controls v8CIS-5 — Account ManagementThe article focuses on duplicate accounts, onboarding, and offboarding during integration.
Recommendation — Use CIS-5 to inventory, reconcile, and disable accounts that no longer belong in the merged estate.
ISO/IEC 27001:2022A.8.2 — Privileged Access RightsMerged estates often expose privileged access mismatches and admin sprawl.
Recommendation — Review A.8.2 to revalidate privileged access after systems and teams are combined.

Key terms

  • Identity Normalisation: The process of reconciling two or more identity estates so users, roles, groups, and entitlements can be governed consistently. In M&A, it means making access data comparable across organisations before certification, provisioning, or compliance reporting can be trusted.
  • Privilege Normalisation: Privilege normalisation is the process of translating different platform-specific access models into a common governance view. It helps security and audit teams compare authority across ERP, cloud, and ITSM systems so they can apply consistent policy and evidence requirements.
  • Access Provenance: Access provenance is the record of how an identity was created, approved, used, and withdrawn. In NHI governance, it is the evidence trail that lets teams prove an account is legitimate, explainable, and still within its intended access boundary.
  • Merged Estate: The combined identity and access environment that exists after two organisations begin operating under shared governance. It includes human accounts, machine identities, applications, and privileged pathways that must be controlled as one system even if the underlying infrastructure remains split.

Deepen your knowledge

NHI governance, agentic AI identity, and machine identity lifecycle are core topics in our NHI Foundation Level course, the industry's only accredited NHI security programme. If you are building or maturing an IAM programme, it is worth exploring.
NHIMG Editorial Note
Published by the NHIMG editorial team on June 9, 2026.
Updated on October 8, 2026.
NHI Mgmt Group, the independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org