By NHI Mgmt Group Editorial TeamBased on C1.ai: “Beyond Checking the Box: How to Use UARs for Real Security” (June 20, 2025)

TL;DR: C1.ai argues that user access reviews should do more than satisfy SOX and PCI audit cycles, because monthly campaigns can help remove unused access, clean up orphaned accounts, and reduce standing privilege across service accounts, contractors, and policy exceptions. Security-led UARs turn a compliance process into a practical identity control.


At a glance

What this is: This is a blog post arguing that user access reviews can be used as an active security control, not just a compliance exercise.

Why it matters: For IAM, IGA, PAM, and NHI teams, the practical lesson is that review cadence, ownership, and scoping decisions can shrink standing access before it becomes an incident path.

👉 Read C1.ai's guidance on using user access reviews for real security


Context

User access reviews are often treated as a quarterly audit task, but that model leaves too much access in place between review cycles. The governance gap is not the review itself, but the assumption that compliance cadence is an adequate security cadence for changing access risk.

In identity programmes, UARs become materially more useful when they are driven by actual access behaviour, ownership, and policy exceptions. That makes them relevant across human users, service accounts, and contractor access where entitlement drift and stale access are the real problem.


Key questions

Q: What breaks when access reviews are treated as a compliance exercise only?

A: You get sign-off without assurance. Reviews that check boxes but do not verify entitlement accuracy, ownership, and business purpose will miss stale permissions, orphaned accounts, and third-party access that no longer has a valid justification. The result is auditable paperwork with weak real-world control.

Q: Why do unused accounts and service accounts create ongoing identity risk?

A: Unused and ownerless accounts often persist outside normal joiner-mover-leaver processes, so no one is clearly accountable for them. That makes them easy to overlook during quarterly reviews and harder to remove when the business no longer needs them. The risk is persistence without ownership, which turns access into a standing exception.

Q: How can security teams tell whether UARs are reducing risk?

A: Look for evidence that reviews are removing access faster than new exceptions are created. Useful indicators include fewer unused entitlements, fewer direct grants that violate policy, clearer ownership on service accounts, and shorter exposure windows for contractor access. If reviews end with completed attestations but no revocation activity, the control is mostly administrative.

Q: How should teams balance quarterly compliance reviews with ongoing access governance?

A: Use quarterly reviews for audit proof, but reserve recurring targeted campaigns for the access paths that change most often. That usually means production access, contractor entitlements, service accounts, and accounts with no recent use. The right model is layered: broad governance for assurance, narrower campaigns for actual risk reduction.


Technical breakdown

Why quarterly user access reviews miss active risk

A quarterly review cycle is designed to prove oversight, not to continuously reduce exposure. If access changes, user behaviour shifts, or ownership becomes unclear between cycles, the review can only react after the fact. That is why unused access, orphaned accounts, and contractor entitlements persist even in organisations that pass audits. The mechanism is simple: the more time that passes between review points, the more stale access accumulates and the less the review reflects current business need.

Practical implication: shorten review cadence for the most change-prone access paths instead of relying on the default audit rhythm.

How filters turn UARs into control enforcement

The technical value of UARs increases when campaigns are scoped with filters that isolate a specific risk pattern. Examples include users with no login activity, accounts with no known owner, service accounts with unclear assignment, and direct access grants that violate policy. This shifts the review from a broad attestation exercise to a targeted control enforcement mechanism. It also improves reviewer accuracy because they are asked to judge a narrower, higher-signal set of entitlements rather than an entire access population.

Practical implication: design review campaigns around one control question at a time, such as unused access or policy-breaking direct grants.

Why ownership is the control that makes recertification work

Access reviews fail when no one can answer who should approve or revoke the entitlement. That is especially true for service accounts and orphaned accounts, which often sit outside normal joiner-mover-leaver workflows. Ownership turns a review from a visibility exercise into an accountable decision process. Once an account has a named owner, the organisation can certify, remove, or time-box access based on actual responsibility rather than leaving it to a generic audit queue.

Practical implication: assign accountable owners to service and orphaned accounts before expecting reviews to produce real remediation.


NHI Mgmt Group analysis

UARs become a security control only when they are used to remove exposure between formal review cycles. A compliance-only programme proves that access was looked at, but it does not meaningfully change the amount of standing privilege that persists in the environment. The security value comes from using reviews to reduce stale entitlements faster than the business can accumulate them. Practitioners should treat cadence as a risk lever, not an audit calendar.

Orphaned and ownerless accounts are a governance failure, not just an inventory problem. When no business owner can validate an entitlement, the organisation has already lost the accountability chain needed for safe recertification. That is why orphaned access becomes especially dangerous in contractor-heavy and application-account-heavy environments. The control issue is not discovery alone; it is whether ownership is sufficiently explicit to support removal.

Standing privilege is the real target of modern UAR design. The article shows that access reviews can be used to find unused access, direct grants that violate policy, and service accounts that persist without clear need. That makes UARs a practical complement to PAM and lifecycle governance, because the review process can expose where privilege remains persistent even when business use has stopped. The practitioner takeaway is to aim reviews at persistence, not paperwork.

Service accounts need lifecycle governance, not one-off attestation. Monthly self-certification works only if the account has a named owner, a defined purpose, and a repeatable decision path for removal or continuation. Without that structure, the account becomes a permanent exception that no quarterly process can clean up effectively. The implication for identity teams is to fold service accounts into ongoing governance rather than treating them as special cases outside normal control design.

Access review drift: the gap between what a review certifies and what the environment actually needs grows when campaigns are broad, infrequent, or detached from policy intent. This is why review design matters as much as review execution. Teams that scope campaigns around unused access, contractors, and direct grants create a stronger control signal than teams that only chase completion rates. Practitioners should optimise for control precision, not review volume.

What this signals

Access review cadence should be driven by entitlement volatility, not by audit convenience. When contractors, service accounts, and production access all change on different time horizons, one quarterly rhythm is too blunt to manage them well. The practical programme shift is to reserve recurring campaigns for the access paths most likely to drift.

Ownership is the hidden dependency in any effective review process. If an account cannot be tied to a responsible person or team, the review outcome will be ambiguous even when the workflow completes successfully. Identity teams should treat accountable ownership as a prerequisite for revocation, not an administrative afterthought.


For practitioners

  • Target unused access with monthly campaigns Filter for users who have not logged in recently, especially in AWS and production environments, and revoke entitlements that no longer have an active business purpose.
  • Map orphaned accounts to named owners Identify application accounts that do not map to a directory identity, then assign a responsible owner or remove the account before it becomes ungoverned access.
  • Recertify service accounts on a recurring schedule Use recurring campaigns to have service account owners confirm purpose, configuration, and continued need, then remove or scope down access that is no longer justified.
  • Time-box contractor production access Set shorter review windows for contractors with access to production data, and consider limiting that access to narrow approval periods rather than open-ended entitlements.
  • Review direct grants that bypass policy Filter for entitlements assigned directly instead of through teams or groups, then revoke the access paths that violate your access model.

Key takeaways

  • User access reviews can do more than satisfy auditors, but only if they are designed to remove stale entitlements instead of merely documenting them.
  • The article’s core examples are unused access, orphaned accounts, service accounts, and contractor production access, all of which are common sources of standing privilege.
  • The strongest control move is to combine targeted review filters with explicit ownership so that revocation decisions are both faster and more accountable.

Standards & Framework Alignment

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

NIST SP 800-53 Rev 5, NIST CSF 2.0 and CIS Controls v8 set the technical controls, while ISO/IEC 27001:2022 defines the regulatory obligations.

FrameworkControl / ReferenceRelevance
NIST SP 800-53 Rev 5AC-6 — Least PrivilegeThe post focuses on reducing standing privilege through access review action.
Recommendation — Use AC-6 to remove unnecessary entitlements and constrain standing access during reviews.
NIST CSF 2.0PR.AA-05 — Access Permissions, Entitlements and AuthorizationsUARs are directly about reviewing and correcting access permissions and entitlements.
Recommendation — Apply PR.AA-05 to govern entitlements with recurring review and revocation workflows.
CIS Controls v8CIS-5 — Account ManagementThe article covers account ownership, recertification, and removal of stale access.
Recommendation — Use CIS-5 to maintain account ownership and remove dormant or unneeded accounts.
ISO/IEC 27001:2022A.5.15 — Access controlThe governance discussion maps cleanly to access control policy and review.
Recommendation — Implement access control reviews that validate necessity and revoke excess rights.

Key terms

  • User Access Review: A user access review is a periodic check that confirms each account still needs the access it has. In identity programs, the control is used to reduce excess privilege, support compliance, and catch access that has outlived its business need.
  • Standing Privilege: Standing privilege is access that remains active even when no immediate task requires it. For NHI programmes, it is a common failure mode because long-lived credentials and persistent roles create unnecessary exposure. Reducing standing privilege usually means tighter expiry, on-demand access, and clearer review of who or what still needs access.
  • Orphaned Account: An orphaned account is an identity that remains active without a clear owner or business purpose. These accounts are dangerous because they often escape review, retain unnecessary access, and provide attackers with low-friction entry points into otherwise governed environments.
  • Recertification campaign: A recertification campaign is a structured review cycle where managers, application owners, or approvers validate that existing access is still justified. In practice, campaign quality depends on current ownership data, clear entitlement meaning, and a scope small enough for reviewers to make accurate decisions.

What's in the full article

C1.ai's full blog post covers the operational detail this post intentionally leaves for the source:

  • How to configure targeted UAR campaigns for unused access, orphaned accounts, service accounts, and contractor entitlements
  • Examples of filtering logic for direct versus inherited access grants in policy enforcement
  • Operational guidance for recurring review cadences and ownership assignment across service accounts
  • How CEL can be used to automate approvals and revocations based on request metadata

👉 The full C1.ai post covers targeted review filters, recurring service account campaigns, and policy-based automation details.

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 8, 2026.
Updated on October 7, 2026.
NHI Mgmt Group, the independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org