TL;DR: User access reviews are a useful compliance starting point, but Zluri argues they cannot deliver continuous governance because access changes between review cycles, coverage often stays limited to a few apps, and manual review alone cannot sustain least privilege across modern environments. The real control problem is lifecycle and monitoring, not periodic certification.
At a glance
What this is: This is an editorial analysis of why user access reviews help with compliance but do not complete identity governance.
Why it matters: It matters because IAM, IGA, and PAM teams need continuous lifecycle controls, not just periodic reviews, to keep human access aligned with business change.
👉 Read Zluri's analysis of why user access reviews are only the start of IGA
Context
User access reviews are a point-in-time control. They can confirm who had access on the day of review, but they do not prevent entitlement drift between review cycles, especially where hiring, promotions, transfers, and terminations happen faster than quarterly governance processes.
For IAM and IGA teams, the real question is not whether review workflows exist, but whether the programme can keep pace with access change across all in-scope systems. That makes lifecycle automation, event-driven triggers, and broader coverage more important than a narrow certification exercise.
Key questions
Q: How should security teams use access reviews without overrelying on them?
A: Treat access reviews as a validation step, not the core governance mechanism. They are useful for audit evidence and exception handling, but they cannot keep pace with continuous role changes, terminations, and application sprawl. Teams should combine them with automated provisioning, deprovisioning, and event-driven monitoring so entitlement changes are governed when they occur, not only when someone later certifies them.
Q: Why do access reviews fail to guarantee least privilege?
A: They fail because least privilege is a moving target, while reviews are typically periodic. A user can be correctly certified at one point and still accumulate excess access before the next cycle. If the review scope is limited to a few applications, the gaps are even larger. Least privilege depends on continuous coverage across the full application estate.
Q: What do security teams get wrong about user access reviews?
A: The most common mistake is treating successful completion as proof of effective governance. In reality, a clean review only shows that a snapshot was assessed. It does not show whether access stayed appropriate between cycles, whether all systems were covered, or whether lifecycle events automatically corrected drift. Mature programmes use UAR to support governance, not replace it.
Q: How do organisations reduce access drift after a review cycle?
A: Link access governance to joiner, mover, and leaver workflows so entitlement changes happen when business status changes. Add continuous monitoring for sensitive applications, and route only high-risk or privileged access into manual certification. That creates a smaller manual workload and closes the gap between formal review and actual access state.
Technical breakdown
Why point-in-time access reviews miss entitlement drift
User access reviews validate access after the fact, usually on a fixed cadence such as quarterly or annually. That model works for audit evidence, but it cannot continuously correct access that becomes outdated between review rounds. In practice, the control only sees a frozen snapshot while the environment keeps changing. When role changes, terminations, and application sprawl outpace the review calendar, stale or excessive access can persist even if each individual review was completed correctly.
Practical implication: use access reviews as evidence, not as the only enforcement mechanism for entitlement accuracy.
Why limited application coverage weakens least privilege
Many organisations start user access reviews with a narrow set of systems that matter most for compliance, such as SOX or HIPAA scope. That creates an uneven governance model in which some applications are controlled while SaaS tools, cloud services, and secondary business systems remain outside regular scrutiny. Least privilege is not achieved by reviewing a subset of entitlements. It depends on broad coverage, consistent policy enforcement, and visibility across the full application estate.
Practical implication: expand review scope beyond audit-driven core apps to the systems where access risk accumulates.
How lifecycle automation closes the gap left by reviews
Automated provisioning and deprovisioning turn access governance from a periodic correction activity into a continuous control process. When joiner, mover, and leaver events feed the identity platform directly, access can be granted, changed, or removed at the moment business status changes. That reduces the chance that managers will either overapprove stale access or underapprove needed access out of caution. It also creates a more reliable audit trail than manual follow-up alone.
Practical implication: connect identity lifecycle events to automated access changes so reviews become one control in a broader governance loop.
NHI Mgmt Group analysis
Access review programmes fail when they are treated as governance rather than evidence. A user access review proves that someone looked at entitlements on a schedule, not that access stayed correct throughout the period. The article is right to separate compliance reassurance from actual control effectiveness. Practitioners should treat UAR as documentation of oversight, not as the engine of least privilege.
Point-in-time certification: this governance model was designed for slow-changing access environments. That assumption fails when organisational change happens continuously and entitlements drift between review cycles. The implication is not simply to add more review tasks, but to rethink whether periodic certification can remain the primary control in a fast-moving IGA programme.
Coverage is the hidden weakness in many access review programmes. Teams often begin with a narrow set of in-scope applications and call that governance. In reality, that leaves shadow risk in SaaS, cloud services, and lower-profile business systems that never enter the review queue. Practitioner conclusion: least privilege is a coverage problem as much as a review problem.
Lifecycle automation is the control family that makes access reviews usable at scale. Reviews cannot keep pace with joiner, mover, and leaver events if the identity layer does not automatically respond to role changes. The editorial lesson is that IGA maturity is measured by how much access change is governed at the point of change, not by how many attestations were completed later. Practitioner conclusion: move from periodic correction to continuous entitlement governance.
From our research:
- 91.6% of secrets remain valid five days after the targeted organisation is notified, showing a critical gap in remediation procedures, according to Ultimate Guide to NHIs.
- Only 5.7% of organisations have full visibility into their service accounts, which helps explain why point-in-time governance so often misses real access drift.
- For lifecycle control guidance, see NHI Lifecycle Management Guide for provisioning, rotation, and offboarding patterns that keep governance continuous.
What this signals
Point-in-time governance is structurally behind the operating model. When access changes continuously, review cadences cannot be the primary defence. The programme signal is clear: identity teams need event-driven lifecycle controls, not just attestations, and they need them across both human access and non-human identity estates.
Access review coverage is becoming a measurement problem, not a process problem. Teams should track how much of the application estate sits outside certification workflows, because partial coverage creates a false sense of control. The broader the business use of SaaS and cloud services, the more the review programme must look like a coverage map rather than a compliance task list.
Lifecycle automation is the difference between governance on paper and governance in production. As access state changes, the identity platform must be able to react without waiting for the next recertification cycle. That is the practical test of IGA maturity, and it aligns directly with the continuous governance model described in the Ultimate Guide to NHIs , Lifecycle Processes for Managing NHIs.
For practitioners
- Reclassify access reviews as a control checkpoint Use UAR to validate high-risk entitlements, but do not treat completion rates as proof of continuous governance. Tie the review outcome to downstream remediation so exceptions are removed, not merely recorded.
- Expand review coverage beyond compliance scope Map every SaaS, cloud, and business application that can create material access risk, then phase them into the review programme. A narrow SOX or HIPAA list leaves the largest entitlement gaps untouched.
- Connect JML events to automated access changes Integrate joiner, mover, and leaver triggers with provisioning and deprovisioning workflows so entitlement state changes when employment status changes. This reduces the time access can remain misaligned with business need.
- Use risk-based reviews for privileged access Reserve manual certification for elevated or sensitive entitlements where human judgement adds value. Routine access should be governed through policy and automation, not repeated by blanket review cycles.
Key takeaways
- User access reviews are necessary for oversight, but they do not by themselves maintain least privilege over time.
- The biggest governance failures in UAR programmes usually come from drift and incomplete coverage, not from the review workflow itself.
- Continuous lifecycle automation is what turns access certification into a meaningful part of IGA rather than a standalone control.
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 CSF 2.0 and NIST Zero Trust (SP 800-207) set the governance and control requirements practitioners need to meet.
| Framework | Control / Reference | Relevance |
|---|---|---|
| NIST CSF 2.0 | PR.AC-1 | Access reviews support identity proofing and entitlement governance across the programme. |
| NIST CSF 2.0 | PR.AC-4 | Least privilege requires timely adjustment of user access as roles change. |
| NIST Zero Trust (SP 800-207) | Continuous verification depends on current entitlement state, not stale review snapshots. |
Treat access reviews as supporting evidence and enforce continuous entitlement checks for critical systems.
Key terms
- User access review: A user access review is a periodic certification process in which managers or application owners validate whether a person still needs assigned entitlements. It produces audit evidence, but by itself it does not enforce continuous least privilege or correct access drift between review cycles.
- Entitlement drift: Entitlement drift is the gradual mismatch between granted access and current business need. It happens when users change roles, move teams, or leave the organisation while permissions remain in place longer than intended, creating excess access and governance blind spots.
- Joiner, mover, leaver process: Joiner, mover, leaver is the identity lifecycle model that governs access when people enter, change, or exit an organisation. In mature programmes, it triggers provisioning, access changes, and deprovisioning automatically so access stays aligned with role and employment status.
- Risk-based recertification: Risk-based recertification is a targeted review approach that focuses human attention on privileged, sensitive, or unusual access instead of certifying every entitlement equally. It is more effective than blanket reviews when paired with automation and accurate lifecycle signals.
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 governance in your organisation, it is worth exploring.
This post draws on content published by Zluri: Access Management You Just Implemented Your Access Reviews. What's Next? Read the original.
Published by the NHIMG editorial team on 2025-09-10.
NHI Mgmt Group — the independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org