Security teams should use user-based access reviews when the question starts with a person or a defined population, not an application. They work best for offboarding, role changes, project wrap-ups, and security alerts because they surface everything a person can touch in one certification. The key is to tie the review to a real trigger and keep recurring app-level reviews in place for baseline coverage.
Why This Matters for Security Teams
User-based access reviews are most valuable when the trigger is a person leaving, moving roles, or closing out a project, because the objective is to answer a simple question: what did this person accumulate that now needs removal or revalidation? That makes them a strong fit for offboarding and project wrap-up, where hidden access often outlives the work itself. NIST SP 800-53 Rev. 5 treats access review and removal as core governance practices, and the same logic applies here: certification is only useful if it is tied to a real lifecycle event.
NHIMG research shows why this matters operationally. In The 2025 State of NHIs and Secrets in Cybersecurity, Entro Security reports that 91% of former employee tokens remain active after offboarding, a reminder that access removal often fails after HR has already closed the record. For broader lifecycle discipline, the NHI Lifecycle Management Guide and Top 10 NHI Issues show that unmanaged credentials and unclear ownership are recurring causes of exposure. In practice, many security teams discover stale access only after a project has ended and the systems tied to it have already drifted out of ownership.
How It Works in Practice
The practical model is straightforward: start with a trigger, build the review from the person outward, and make remediation part of the same workflow. For offboarding, that means using the review to enumerate all accounts, entitlements, groups, secrets, and delegated permissions tied to the departing user. For project closures, it means certifying access against the project roster and removing anything that has no remaining business justification. This is not a replacement for ongoing app-level reviews. It is a focused, event-driven control layered on top of baseline governance.
Security teams usually get better results when the review packet includes:
- Identity, group membership, and privileged roles
- SaaS accounts, cloud permissions, and VPN or remote access
- API keys, tokens, certificates, and other secrets tied to the person
- Shared mailbox, ticketing, and collaboration tool access
- Approved exceptions with an explicit expiry date
Use the review to drive two outcomes: revoke access that is no longer needed and retain only what has a named owner and expiry date. Map that process to least privilege guidance in the OWASP Non-Human Identity Top 10 for any machine credentials the user may have created or administered, because project teams often leave behind service tokens that survive the human owner. The strongest operating pattern is to combine HR, IT, and application owners in one certification so removal is not delayed by handoffs. These controls tend to break down when access is distributed across many unmanaged SaaS tools because no single system has full visibility into what the person can still touch.
Common Variations and Edge Cases
Tighter access review scopes often increase administrative overhead, so organisations have to balance speed against completeness. That tradeoff is especially visible in project closures, where temporary access, shared accounts, and delegated admin rights can make the certification noisy. Current guidance suggests that the answer is not to widen the review indefinitely, but to define the population clearly and make exceptions explicit. If a person supported multiple projects, the review should separate access by business purpose so reviewers are not forced to certify unrelated entitlements.
There are two common edge cases. First, contractors and consultants may never appear in the normal employee offboarding workflow, so they need the same user-based review trigger but with a different source of truth. Second, users who created or managed secrets on behalf of a team often leave behind credentials that are invisible in standard IAM reports. That is where the lifecycle focus from Ultimate Guide to NHIs becomes relevant, because the question is not only who had an account, but what identities, tokens, and service connections were created during the work. Best practice is evolving, but the current consensus is clear: user-based reviews work best when they are trigger-based, time-bound, and followed immediately by revocation and verification rather than deferred cleanup.
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, NIST SP 800-63, NIST AI RMF and NIST Zero Trust (SP 800-207) set the governance and control requirements practitioners need to meet.
| Framework | Control / Reference | Relevance |
|---|---|---|
| OWASP Non-Human Identity Top 10 | NHI-03 | Covers lifecycle hygiene and timely removal of stale NHI access. |
| NIST CSF 2.0 | PR.AC-4 | Least-privilege access reviews support removal of unnecessary entitlements. |
| NIST SP 800-63 | Identity proofing and authenticator lifecycle inform secure account deprovisioning. | |
| NIST AI RMF | GOVERN | Governance requires clear ownership and accountability for access decisions. |
| NIST Zero Trust (SP 800-207) | AAM | Zero trust emphasizes continuous, context-based authorization and revocation. |
Verify and revoke user-created secrets during offboarding and project closure, then confirm removal.
Related resources from NHI Mgmt Group
- How should security teams use AI agents for user access reviews?
- How should security teams automate user access reviews without losing control quality?
- How should security teams implement cloud user access reviews across SaaS and multi-cloud environments?
- How should security teams combine segregation of duties and user access reviews?
Deepen Your Knowledge
Reviewed and updated by the NHIMG editorial team on August 24, 2026.
NHI Mgmt Group — the #1 independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org
