How should organisations run periodic access reviews without relying on spreadsheets and manual follow-up?

Why This Matters for Security Teams

Periodic access reviews fail when they are treated as a spreadsheet exercise instead of an identity control. Reviewers need current ownership, role, and entitlement context from the source system, not stale exports that drift before sign-off. That matters because access certification is only useful if it can prove a decision, a remediation, and a follow-up check in one audit trail. NHI Mgmt Group notes that only 20% of organisations have formal offboarding and revocation processes for API keys, which is a warning sign for any review process that stops at approval instead of removal, as discussed in the Ultimate Guide to NHIs. In practice, many security teams discover review failures only after auditors, incident responders, or control owners ask where the evidence went, rather than through intentional control testing.

How It Works in Practice

A workable access review programme starts by pulling entitlements from the systems of record, then routing them through a workflow that preserves who approved what, when, and why. The review set should include the identity, the business role, the privilege level, the last-used date where available, and the system owner responsible for the decision. That is the practical difference between a certification campaign and a cleanup spreadsheet. The strongest pattern is to automate the full loop:

• Generate the review list from authoritative identity and application sources.
• Assign reviewers based on ownership, not email distribution lists.
• Use time-boxed review windows with escalation for non-response.
• Auto-create remediation tickets or revoke access directly when policy allows.
• Capture proof of removal, not just a rejection in the workflow.

This is consistent with OWASP Non-Human Identity Top 10 guidance on reducing unmanaged privilege, and it aligns with the control intent in NIST SP 800-53 Rev 5 Security and Privacy Controls around account management and continuous accountability. For broader identity lifecycle context, the NHI Lifecycle Management Guide is useful because reviews should be tied to joiner-mover-leaver changes, not run as isolated events. Reviews also work better when evidence is retained in the ticketing or governance platform itself, since auditors usually want a complete chain from access grant to removal confirmation. These controls tend to break down when entitlements are scattered across legacy apps, shared service accounts, and manually provisioned admin paths because the review system cannot reliably determine what actually exists.

Common Variations and Edge Cases

Tighter review automation often increases integration and governance overhead, so organisations need to balance speed against the cost of connecting unreliable source systems. There is no universal standard for this yet, especially for edge cases such as shared mailboxes, delegated admin roles, emergency access, and service accounts that do not map cleanly to a named reviewer. In those situations, current guidance suggests using compensating controls rather than forcing a human-style review model onto machine access. That can mean shorter entitlement lifetimes, mandatory owner attestations, exception registers, or separate certification paths for privileged and non-privileged access. For NHI-heavy environments, this is especially important because long-lived secrets and excessive privilege are common failure modes; NHI Mgmt Group’s research notes that 97% of NHIs carry excessive privileges and 91.6% of secrets remain valid five days after notification, both of which reinforce the need for fast, closed-loop remediation in the Ultimate Guide to NHIs — Key Challenges and Risks. Teams also need to avoid treating exceptions as permanent, because a temporary workaround often becomes the default control. For environments with high change rates, the best practice is evolving toward continuous access evaluation plus periodic attestation, rather than one large annual campaign. Where that is not yet possible, the minimum defensible standard is to prove the review reached the correct owner and that removal was verified end to end.

Related resources from NHI Mgmt Group

• How should security teams run access reviews for non-human identities?
• How should organisations run ISO 27001 user access reviews without creating audit noise?
• How should companies run SOX access reviews without drowning in manual work?
• When do NHI access reviews create more value than a one-time cleanup?