They should use identity governance as the evidence layer for access approval, review, and removal. The practical goal is to show that every entitlement has an owner, a business reason, and a lifecycle path. That makes compliance traceable and reduces the chance that stale access becomes an audit finding or operational weakness.
Why Identity Governance Is the Compliance Evidence Layer
For financial institutions, DORA and NIS2 are not satisfied by saying access is “controlled.” Regulators expect demonstrable governance: who approved access, why it was granted, when it was reviewed, and how it was removed. identity governance turns that activity into evidence. It also helps institutions prove that privileged access is limited, justified, and traceable across business units, service accounts, and vendor connections.
This matters because identity sprawl becomes operational risk long before it becomes a policy violation. NHIMG’s Ultimate Guide to NHIs — Regulatory and Audit Perspectives shows why audit readiness depends on lifecycle control, not just inventory. In practice, the gap is usually not a missing policy, but missing proof that the policy was enforced consistently against real entitlements. That is where identity governance supports obligations under DORA and EU NIS2 Directive. In practice, many security teams encounter entitlement drift only after an audit request, not through deliberate governance.
How to Operationalise Review, Approval, and Removal Controls
Identity governance works best when it is tied to authoritative sources of record and enforced as a repeatable workflow. For DORA and NIS2, the goal is to show that each entitlement has an owner, a valid business reason, a review cadence, and a removal path when it is no longer needed. That applies to employee access, privileged administrator roles, API keys, and machine accounts used in payment, trading, or resilience tooling.
A practical implementation usually includes:
- Access requests linked to a named business owner and a specific purpose.
- Periodic recertification for high-risk entitlements, with evidence of approval or revocation.
- Automated removal of stale access when roles change, contracts end, or systems are retired.
- Segregation of duties checks before approval for sensitive financial workflows.
- Logging that preserves who approved, reviewed, rejected, or removed access.
The strongest programmes treat this as lifecycle control rather than a point-in-time review. NHIMG’s Ultimate Guide to NHIs and Lifecycle Processes for Managing NHIs are useful here because they emphasise visibility, rotation, and offboarding as operational controls, not documentation exercises. That aligns well with NIST Cybersecurity Framework 2.0 and the broader identity assurance approach in NIST SP 800-63 Digital Identity Guidelines. These controls tend to break down in highly federated banking environments where entitlements are granted across many subsidiaries and outsourcing chains because ownership becomes ambiguous.
Where the Guidance Gets Hard in Real Financial Environments
Tighter identity governance often increases operational overhead, requiring organisations to balance audit defensibility against release speed, resilience, and regulatory deadlines. That tradeoff is especially visible when institutions must govern both human and non-human access across legacy core banking platforms, cloud workloads, and third-party service providers.
Current guidance suggests that there is no universal standard for every access scenario yet, especially for ephemeral service identities and automated workflows. Some entitlements should be reviewed by business owners, while others are better governed through technical controls such as time-bound access, vault rotation, and policy-as-code. Institutions should avoid forcing every access path into the same approval model, because that creates process bottlenecks without materially improving assurance.
The most common edge case is outsourced or shared operational access, where the business owner is unclear and removal depends on another party’s ticketing discipline. Another is machine-to-machine access, where the “user” is a workload rather than a person. In those cases, identity governance should still produce evidence, but the evidence may come from workload registration, secret rotation, and automated expiry rather than manual recertification alone. NHIMG’s breach analysis in 52 NHI Breaches Analysis is a reminder that stale access and weak lifecycle control are recurring failure patterns, not rare exceptions.
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 AI RMF set the governance and control requirements practitioners need to meet.
| Framework | Control / Reference | Relevance |
|---|---|---|
| NIST CSF 2.0 | PR.AA-02 | Identity lifecycle evidence supports access approval, review, and removal. |
| NIST CSF 2.0 | PR.AA-04 | Least privilege is central to limiting entitlement sprawl in regulated environments. |
| NIST AI RMF | Governance and measurement help prove accountability for automated access decisions. |
Use the GOVERN function to assign ownership, review cadence, and evidence retention for access decisions.
Related resources from NHI Mgmt Group
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Reviewed and updated by the NHIMG editorial team on June 25, 2026.
NHI Mgmt Group — the #1 independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org
