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

TL;DR: Manual identity governance creates bottlenecks in approvals, entitlement updates, and access visibility, leaving organisations exposed when leaders cannot answer who has access and why, according to RSA Security. The governance problem is not just inefficiency, it is the inability to make timely, auditable access decisions before gaps become breaches.


At a glance

What this is: RSA Security argues that manual identity governance slows approvals, obscures access visibility, and increases the risk of exposure.

Why it matters: For IAM, NHI, and human identity programmes, the issue matters because delayed governance decisions weaken auditability, increase entitlement drift, and leave security teams reacting after access problems have already spread.

👉 Read RSA Security's discussion of why manual identity governance raises breach risk


Context

Manual identity governance means access decisions, entitlement updates, and review follow-up depend on people moving work through inboxes and spreadsheets rather than through governed workflows. In that model, visibility breaks down first, then accountability, then response speed, which is why the same pattern creates risk across human IAM, NHI governance, and broader lifecycle control.

The core problem is not simply scale. It is that compliance pressure, hybrid environments, and distributed workforces expose how much of identity governance still relies on slow, fragmented handling of access data. Once leaders cannot answer who has access, why they have it, and whether that access is still justified, the programme is already operating behind the risk.


Key questions

Q: How should security teams reduce risk in manual identity governance processes?

A: Security teams should remove repeatable approval work from email and spreadsheet handling, then tie each access decision to identity context, entitlement state, and ownership. The goal is not just speed. It is to make every access change auditable, reviewable, and easier to defend when compliance or incident response asks why the access existed.

Q: Why does fragmented access visibility create governance risk?

A: Fragmented visibility creates risk because no one can reliably explain who has access, why it exists, or whether it is still justified. When identity data sits in separate systems, reviews become incomplete and audits become reconstruction exercises. That increases the chance that stale or excessive access survives longer than it should.

Q: What do teams get wrong about automating identity governance?

A: Teams often automate the routing of work without fixing the underlying evidence problem. If approvals still rely on incomplete identity data, the workflow is faster but not necessarily safer. Effective automation needs context, ownership, and entitlement state in the same control flow, otherwise the programme only accelerates bad decisions.

Q: How can organisations tell if identity governance is actually working?

A: Governance is working when teams can answer access questions quickly, recertification produces clear outcomes, and entitlement updates do not stall in queues. A stronger sign is when auditors and business owners can trace a decision back to evidence without manual detective work. If that is not possible, the control is still too dependent on people.


Technical breakdown

Why manual approvals create governance bottlenecks

Manual identity governance depends on humans to route, review, and approve entitlement changes one request at a time. That creates queueing effects, especially when approvals sit in inboxes, when reviewers lack context, or when ownership is unclear. The technical issue is not just delay. It is that the control plane becomes inconsistent, because policy decisions are being reconstructed after the fact instead of being enforced through repeatable workflow logic and identity context.

Practical implication: replace inbox-based approval chains with governed workflow automation tied to identity context and entitlement state.

Why fragmented visibility breaks access decision-making

Visibility fails when identity data, access entitlements, and contextual signals live in separate systems that do not form a complete decision record. In practice, this means teams can see fragments of an identity but cannot confidently explain why an entitlement exists, who approved it, or whether the access is still appropriate. Without that joined-up view, recertification becomes performative and audit response becomes manual reconstruction rather than evidence-led governance.

Practical implication: centralise identity and access evidence so each access decision can be explained, reviewed, and audited from one record.

How low-code governance changes the operating model

Low-code and no-code governance tools matter because they reduce dependence on custom scripts and fragile point-to-point logic. That does not remove governance work, but it changes how policy is expressed and maintained. The architectural gain is that workflows, connectors, and visual policy layers can expose access state to auditors and business owners more consistently, which shortens the time between a question and a defensible answer.

Practical implication: standardise governance workflows so access reviews and entitlement changes are repeatable instead of script-dependent.


NHI Mgmt Group analysis

Manual identity governance is a control delay problem, not just an efficiency problem. When approvals and entitlement updates depend on inbox handling, the programme loses the ability to act at the pace of access change. The result is governance lag, where risk accumulates faster than the control process can close it. Practitioners should treat delay itself as a control weakness, not a back-office inconvenience.

Access visibility is the prerequisite for any credible identity decision. If leaders cannot answer who has access and why, then certification, investigation, and audit all become reconstructive exercises. That weakens both human IAM and NHI governance because the same evidence gap affects users, service accounts, and delegated access paths. Practitioners should expect every downstream governance activity to fail if the evidence layer is incomplete.

Visual workflow governance changes the governance model by reducing policy drift. Script-heavy or bespoke identity processes often survive only as long as the people who built them. Low-code and no-code workflow models make policy easier to maintain, review, and explain, which matters when auditors and business owners need fast answers. The practitioner lesson is that maintainability is part of governance strength.

Identity security posture management becomes more valuable when governance is manual. The reason is simple: the less consistent the workflow, the more important continuous evidence collection and prioritisation become. A manual programme cannot reliably prove that access remains appropriate at the moment it matters, so posture management should expose the biggest visibility and entitlement gaps first. Practitioners should use it to find where governance is already behind reality.

From our research:

  • 72% of organisations have experienced or suspect they have experienced a breach of non-human identities, with 46% confirmed and 26% suspected, according to The 2024 ESG Report: Managing Non-Human Identities.
  • Enterprises that have experienced a compromised NHI averaged 2.7 separate incidents in the past 12 months, which shows how quickly one access weakness can become repeated governance failure.
  • For the broader identity control model behind that pattern, see Ultimate Guide to NHIs , Lifecycle Processes for Managing NHIs for the lifecycle controls manual governance tends to obscure.

What this signals

Manual governance becomes more dangerous as identity sprawl grows. When access reviews and entitlement changes are still handled by people rather than workflow, the bottleneck shifts into the security programme itself. Teams should expect more stale access, slower certification cycles, and weaker audit evidence unless the operating model changes.

The practical signal is that governance maturity will increasingly be judged by evidence quality, not just review completion rates. Programmes that can surface access context quickly will respond better to audit, incident, and recertification pressure, especially where machine identities and delegated access are expanding.

Identity security posture management should be used as a prioritisation lens, not a reporting layer. The point is to find where manual governance is already creating risk debt, then focus remediation where privilege, review friction, and visibility gaps intersect.


For practitioners

  • Map every manual approval path to a governance risk Identify where access changes, entitlement updates, and recertifications still depend on email, chat, or ad hoc routing. Prioritise the paths that combine high privilege with slow review because those create the longest exposure windows.
  • Build a single evidence record for each identity Consolidate approval history, entitlement state, owner information, and last review outcome so each access decision can be explained without chasing multiple systems. This is the difference between defensible governance and manual reconstruction.
  • Replace script dependence with governed workflows Use repeatable workflow design for access reviews, approval routing, and entitlement changes so governance does not depend on fragile custom code. That makes policy easier to maintain when the environment changes.
  • Prioritise the identities with the most review friction Start with accounts and access paths that routinely stall in review or require repeated follow-up. Those are usually the places where entitlement drift is most likely and where remediation will reduce the largest amount of governance debt.

Key takeaways

  • Manual identity governance creates risk when access decisions move slower than the environments they are meant to control.
  • Visibility gaps turn reviews and audits into reconstruction exercises, which is why weak evidence is itself a security issue.
  • The immediate priority is to replace ad hoc identity handling with governed workflows and a complete evidence record for each access decision.

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.AA-01Identity evidence and access visibility are central to this article's governance problem.
NIST Zero Trust (SP 800-207)IDZero Trust depends on current identity context, which manual governance often obscures.
OWASP Non-Human Identity Top 10NHI-06Manual handling increases lifecycle and review gaps for non-human identities.

Use identity context as an input to access decisions instead of relying on stale approvals.


Key terms

  • Identity Governance: Identity governance is the set of processes that decide who or what should have access, who approved it, and when it must be reviewed or removed. In practice, it is the control layer that turns access policy into evidence, accountability, and lifecycle management across human and non-human identities.
  • Entitlement Drift: Entitlement drift is the gradual gap between approved access and actual access over time. It happens when changes are not reviewed, ownership is unclear, or access persists after the original business need has passed. Drift is one of the clearest signs that governance is operating too slowly.
  • Access Visibility: Access visibility is the ability to explain who has access, what they can reach, and why that access exists. Good visibility depends on joined-up identity data, entitlement state, and approval context. Without it, reviews become guesswork and auditors cannot verify that governance is working.

Deepen your knowledge

NHI governance, agentic AI identity, and machine identity security are core topics in our NHI Foundation Level course, the industry's only accredited NHI security programme. If you are responsible for identity security strategy or NHI governance in your organisation, it is worth exploring.

This post draws on content published by RSA Security: From Bottlenecks to Breaches, Why Manual Identity Governance Puts Organizations at Risk. 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