Teams should assign ownership, define review cadence, and include machine identities and AI agents in the same certification logic as human access, but with role-appropriate approvers. If a non-human identity can act on sensitive data, it needs a lifecycle owner and a removal path just like any other privileged account.
How do access reviews work best for machine identities and AI agents?
Access reviews work best when machine identities and AI agents are treated as first-class subjects in the certification process, not as exceptions hidden in a separate queue. That means each non-human identity should have a named owner, a review schedule, clear business purpose, and an explicit decision path for retain, reduce, or remove access when the entitlement no longer fits the current use case.
For teams already standardising access governance, IAM and IGA Basics is the right foundation for understanding why certification should cover people and machines under the same governance model.
For AI agents specifically, the review should not stop at whether the agent is still running. Teams need to confirm whether the agent still has a valid task, whether its delegated authority still matches its function, and whether any tool, data, or action permission has become broader than the current job requires.
What should reviewers verify before approving non-human access?
Reviewers should verify three things: who owns the identity, what it is allowed to do, and whether that permission is still needed. For machine identities, that often means checking the service, workload, or application that depends on the credential; for AI agents, it also means checking the workflow, tool set, and human or system sponsor responsible for the agent’s behaviour.
The most useful review evidence is operational, not just administrative. Teams should be able to show the current system, pipeline, or workflow that uses the identity, the last known activity, the data or APIs it can reach, and the removal route if the owner cannot justify continued access.
A practical reference point is Access Reviews and Certification Guide, which focuses on making certification campaigns actionable rather than ceremonial.
When the identity is tied to a workload or service, lifecycle and rotation matter as much as approval history. A reviewed account that remains active with stale secrets, stale roles, or no accountable owner is still a control failure even if the review record itself is complete.
How do teams make review decisions at scale without creating noise?
At scale, the review process needs segmentation. High-risk machine identities and AI agents should be reviewed more often than low-risk ones, and the approver should be someone who can judge business necessity, not just a generic manager who cannot assess technical access. That is especially important when the identity can modify data, trigger payments, call privileged APIs, or influence production systems.
Teams should also avoid asking reviewers to re-certify every entitlement equally. Review logic should prioritise privileged, externally reachable, long-lived, and cross-environment access first, because those are the entitlements most likely to create blast-radius issues if left untouched.
For the broader lifecycle context, NHI Lifecycle Management Guide helps anchor access review decisions to provisioning, rotation, and offboarding rather than treating certification as a one-time audit event.
For AI agents, the strongest governance pattern is to make the review question specific: is the agent still authorised to act, is its tool access still appropriate, and does it still need the same data scope to complete its task? If the answer is unclear, the safer decision is usually to narrow or suspend access until ownership is revalidated.
Risk and Threat Considerations
Machine identities and AI agents create a review blind spot when they inherit access that no human is actively watching. Stale permissions, shared credentials, and unowned agents can leave sensitive systems exposed long after the original use case has changed.
Failure mechanism: Access reviews become a paper exercise when non-human identities are not tied to a live owner, a current business purpose, and a removal path that actually disables the credential or agent action.
Impact: Excess privilege can persist across production systems, data stores, and automation workflows, increasing the chance of misuse, lateral movement, or unintended action at machine speed.
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 and OWASP Agentic AI Top 10 address the attack and risk surface, while NIST SP 800-53 Rev 5 and CIS Controls v8 set the governance and control requirements practitioners need to meet.
| Framework | Control / Reference | Relevance |
|---|---|---|
| OWASP Non-Human Identity Top 10 | NHI-01 — Improper Offboarding | Expired machine and agent access must be removed cleanly. |
| NHI-05 — Overprivileged NHI | Reviews must catch excessive permissions on machine identities and agents. | |
| NHI-07 — Long-Lived Secrets | Access reviews should surface machine credentials that outlive their use case. | |
| Recommendation — Remove or disable non-human access promptly when the business purpose ends. Reduce non-human permissions to the minimum needed for the current task. Rotate or replace long-lived secrets tied to reviewed non-human identities. | ||
| OWASP Agentic AI Top 10 | ASI03 — Identity & Privilege Abuse | Agent reviews must check whether delegated authority still fits the task. |
| Recommendation — Validate agent authority and narrow privileges when the task scope changes. | ||
| NIST SP 800-53 Rev 5 | IA-5 — Authenticator Management | Machine identities rely on credential lifecycle, rotation, and revocation. |
| AC-6 — Least Privilege | Access reviews should enforce minimum necessary access for machines and agents. | |
| Recommendation — Manage non-human authenticators through rotation, revocation, and expiry controls. Revoke any non-human access that is not essential to the current function. | ||
| CIS Controls v8 | CIS-5 — Account Management | Certification campaigns are part of keeping accounts and service identities governed. |
| Recommendation — Inventory, review, and disable non-human accounts that are no longer justified. | ||
Practitioner Guidance
What to prioritise: Start with privileged machine identities and AI agents that can reach production data, deploy code, call financial or administrative APIs, or act across environments. Those are the identities most likely to cause material harm if they are over-permissioned or forgotten.
What to verify: Each non-human identity should have a named owner, a current purpose, a review cadence, and a tested removal path. If any of those are missing, the review should not treat the access as safely governed.
Decision rule: If the identity can act on sensitive data or perform a sensitive function, require an approver who understands the workflow and the blast radius, not just an organisational manager. If nobody can explain why the access still exists, remove or suspend it pending validation.
Practitioner takeaway: The governance test is not whether the identity is human or machine, it is whether someone can still justify its authority, prove its use, and revoke it quickly when the justification disappears.
Related resources from NHI Mgmt Group
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Reviewed and updated by the NHIMG editorial team on October 30, 2026.
NHI Mgmt Group — the #1 independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org