Security teams should treat enhanced due diligence as a risk-based control path, not a universal process. Apply deeper verification, richer evidence collection, and more frequent monitoring only when the customer, transaction, or relationship crosses defined risk thresholds. The key is to make the trigger, review, and escalation steps auditable and consistent.
Why Enhanced Due Diligence Matters for High-Risk Identities
enhanced due diligence is what keeps risk-based identity governance from becoming a checkbox exercise. High-risk identities, whether human or non-human, are not all equally trustworthy, and the control path should reflect that difference. NIST’s Cybersecurity Framework 2.0 treats identity, monitoring, and governance as continuous functions, not one-time approvals. NHI Management Group research shows why that matters: in The State of Non-Human Identity Security, only 1.5 out of 10 organisations reported high confidence in securing NHIs.
That confidence gap is often driven by weak visibility, poor rotation discipline, and inconsistent escalation when risk changes. Enhanced due diligence is the mechanism that forces deeper verification when an identity touches sensitive data, privileged systems, external vendors, regulated workflows, or unusual transaction patterns. The goal is not to scrutinise every identity equally, but to make higher-risk relationships harder to create, easier to review, and faster to revoke when the risk profile changes. In practice, many teams discover the need for enhanced due diligence only after a privileged account or service token has already been overexposed, rather than through intentional risk triage.
How It Works in Practice
Enhanced due diligence works best as a tiered control path with clear triggers, evidence requirements, and review intervals. Security teams should define what qualifies as “high-risk” before onboarding begins. Common triggers include access to production secrets, payment or customer data, admin privileges, third-party integrations, cross-tenant access, and identities that can act autonomously or chain actions across systems. For those cases, the review should be deeper than standard onboarding and should require stronger proof of ownership, business justification, and technical safeguards.
Practically, teams should combine policy, identity proofing, and operational monitoring. The evidence pack might include:
- business owner approval and accountable system owner
- scope of access, privilege level, and expiry date
- credential type, rotation policy, and revocation path
- logging, alerting, and exception handling requirements
- periodic revalidation tied to risk rather than calendar convenience
For human identities, this often maps to stronger identity proofing, step-up verification, and tighter privileged access management. For non-human identities, the equivalent is stronger workload identity, short-lived credentials, and continuous attestation. Guidance from OWASP NHI Top 10 and the Top 10 NHI Issues reinforces that high-risk identities fail when long-lived credentials, missing rotation, and weak monitoring are treated as acceptable defaults. Current best practice is to make the enhanced review auditable, time-bound, and tied to explicit risk thresholds. These controls tend to break down in fast-moving DevOps environments where identity creation is automated faster than governance review can keep up.
Common Variations and Edge Cases
Tighter due diligence often increases onboarding time and operational friction, so organisations must balance assurance against delivery speed. That tradeoff is especially visible when high-risk identities are created dynamically, such as CI/CD service accounts, API integrations, or delegated vendor access. In those cases, best practice is evolving toward automated risk scoring and just-in-time approval rather than manual review for every request.
There is no universal standard for this yet, but current guidance suggests using enhanced due diligence only where the blast radius justifies it: production-admin rights, regulated data paths, privileged machine identities, or relationships that cross organisational boundaries. A useful exception is low-risk, low-scope identities with short-lived credentials and strong telemetry. Those should still be monitored, but they do not always need the same review depth as a high-value vendor connector or privileged automation account. The main failure mode is inconsistency: when teams apply enhanced checks informally, they create blind spots, delayed approvals, and inconsistent escalation. That is why the trigger criteria, approval chain, and revalidation cadence should be documented and enforced the same way every time.
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 address the attack and risk surface, while NIST CSF 2.0 and NIST AI RMF set the governance and control requirements practitioners need to meet.
| Framework | Control / Reference | Relevance |
|---|---|---|
| OWASP Non-Human Identity Top 10 | NHI-03 | High-risk identities often fail through weak rotation and review discipline. |
| NIST CSF 2.0 | PR.AC-4 | Enhanced due diligence depends on controlled access and least privilege. |
| NIST AI RMF | Risk-based identity review aligns with governance and accountability expectations. |
Use AI RMF GOVERN practices to define ownership, thresholds, and auditable escalation for high-risk identities.
Related resources from NHI Mgmt Group
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Reviewed and updated by the NHIMG editorial team on June 23, 2026.
NHI Mgmt Group — the #1 independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org
