Financial institutions should treat non-human identities as a core part of ICT risk management, not a side control. That means inventorying service accounts, API keys, tokens, and machine identities, enforcing least privilege, monitoring usage, rotating credentials, and decommissioning stale access. DORA readiness depends on visibility, governance, detection, and lifecycle discipline across cloud, SaaS, on-premises, and third-party environments.
Why This Matters for Security Teams
DORA changes the question from whether non-human identities are convenient to whether they are governable under ICT risk management. Financial institutions rely on service accounts, API keys, certificates, and automation tokens to move data, trigger payments, reconcile ledgers, and integrate third parties. If those identities are overprivileged, untracked, or long-lived, they become a resilience problem, not just an access control problem.
Current guidance suggests treating NHI governance as part of operational resilience, aligned to the EU Digital Operational Resilience Act (DORA) and the NIST Cybersecurity Framework 2.0. NHIs are often the hidden path through cloud workloads, SaaS connectors, and CI/CD pipelines, so inventory and ownership matter as much as encryption or logging. NHI Management Group research shows only 5.7% of organisations have full visibility into their service accounts, which is a serious gap for auditability and incident response. The practical lesson is that institutions usually discover NHI weakness during an outage, vendor compromise, or suspicious token use, not during a planned access review.
How It Works in Practice
To support DORA compliance, institutions need a lifecycle model for each non-human identity: create, approve, scope, monitor, rotate, and retire. That starts with a complete inventory of service accounts, secrets, certificates, workload identities, and third-party tokens, then assigning an owner, a business purpose, a system dependency, and a review date. The Ultimate Guide to NHIs — Lifecycle Processes for Managing NHIs is useful here because DORA expects traceability across the full lifecycle, not just initial provisioning.
Security teams should pair that inventory with technical controls that make abuse harder and detection faster:
- Use least privilege and separate identities by application, environment, and function.
- Prefer short-lived credentials and workload identity over static secrets where possible.
- Rotate API keys, certificates, and tokens on a defined schedule and after suspected exposure.
- Log authentication, privilege changes, and anomalous machine-to-machine access.
- Disable or revoke stale identities during application decommissioning, vendor offboarding, and staff changes.
For assurance, map these controls to the control expectations in NIST SP 800-53 Rev 5 Security and Privacy Controls and the identity assurance guidance in NIST SP 800-63 Digital Identity Guidelines. When the environment includes cloud-native automation, the operational pattern should be to issue narrowly scoped credentials at runtime and revoke them automatically after the task completes. These controls tend to break down when legacy batch jobs, shared service accounts, and undocumented integrations still depend on permanent credentials.
Common Variations and Edge Cases
Tighter NHI control often increases operational overhead, requiring institutions to balance resilience gains against release velocity, third-party complexity, and legacy compatibility. That tradeoff is real in banking environments where core platforms, managed services, and outsourced operations may not support modern workload identity. Best practice is evolving, so there is no universal standard for every NHI pattern yet.
Edge cases deserve explicit policy exceptions rather than silent drift. For example, long-lived certificates may still be necessary for some industrial or mainframe integrations, but they should have compensating controls such as constrained network paths, stronger monitoring, and documented renewal ownership. Third-party and SaaS identities also need particular scrutiny because they expand the trust boundary beyond internal systems; NHI Management Group research shows many organisations expose NHIs to third parties, which makes vendor offboarding and secret revocation a DORA issue, not just procurement hygiene. The Top 10 NHI Issues and the Ultimate Guide to NHIs — Regulatory and Audit Perspectives both reinforce the same point: audit teams will ask who owns the identity, why it exists, and how quickly it can be revoked. Institutions that cannot answer those questions consistently usually end up treating NHI remediation as an incident response exercise rather than a control design choice.
Related resources from NHI Mgmt Group
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Reviewed and updated by the NHIMG editorial team on August 27, 2026.
NHI Mgmt Group — the #1 independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org
