Start with discovery, not certification. Build a master inventory from the IDP, finance data, and department input, then scope only the highest-risk apps first. If you cannot see the full app and entitlement population, any access review will be incomplete by design and weak for both security and audit purposes.
Why This Matters for Security Teams
access review fail when teams try to certify what they cannot see. The real issue is not the review form, but the underlying entitlement population: service accounts, API keys, automation tokens, and shadow applications often sit outside the identity source of truth. NHI Management Group research shows only 5.7% of organisations have full visibility into their service accounts, and that gap makes any attestation programme incomplete by design. For a broader view of why this matters, see the Ultimate Guide to NHIs and the OWASP Non-Human Identity Top 10.
Security teams often assume that an access review programme begins with certifications and exception handling. In practice, discovery is the control boundary. Without a master inventory from the IDP, finance records, department input, and application owners, reviewers are forced to approve a partial dataset and auditors inherit that blind spot. That creates false confidence, especially where NHI sprawl is higher than human identity sprawl and where old integrations still hold standing access.
In practice, many security teams encounter the risk only after an audit exception, a breach, or a failed deprovisioning event has already exposed the gaps.
How It Works in Practice
The most effective way to start is to treat access review as a phased discovery programme. First, assemble a master inventory that combines identity provider exports, finance and procurement records, application catalogues, and input from business owners. Then normalize the data so each system has a named owner, a business purpose, and a risk tier. This is where NHI Lifecycle Management Guide becomes useful: lifecycle clarity is what turns a messy list into a reviewable population.
From there, scope the first review cycle to the highest-risk applications and the identities most likely to create audit or breach impact. A practical sequence is:
- Identify systems with privileged access, production data, or external connectivity.
- Separate human access from NHI access, since service accounts and tokens often require different evidence.
- Define review criteria before sending certifications, including owner, entitlement, last use, and business justification.
- Use remediation workflows for removal, not just attestation, so the programme produces real change.
Where visibility is weak, current guidance suggests using risk-based sampling rather than pretending the entire population is reviewable. That is consistent with the NHI problem space described in the Ultimate Guide to NHIs — Key Challenges and Risks, where missing inventory and excessive privileges are common failure modes. A good access review programme therefore measures completeness as a control in its own right, not just the number of approvals returned. These controls tend to break down in federated environments with unmanaged SaaS sprawl because ownership, entitlement data, and revocation paths are fragmented across systems.
Common Variations and Edge Cases
Tighter review scope often increases operational overhead, requiring organisations to balance coverage against speed and reviewer fatigue. That tradeoff is real, especially when the business wants enterprise-wide certification but the data is only reliable for a subset of applications. Best practice is evolving here: there is no universal standard for forcing a single review method across every app class, and trying to do so can dilute the programme.
One common variation is to run separate tracks for human access and NHI access. Another is to start with production, financial, and customer-data systems before expanding into lower-risk internal tools. Some teams also use management attestation for applications with poor telemetry, but that should be treated as a temporary control, not a permanent substitute for visibility. The Top 10 NHI Issues is a useful reminder that excessive privilege and poor lifecycle discipline often coexist, so reviews must look for both ownership and necessity.
Where the environment includes legacy infrastructure, shared accounts, or third-party integrations, the first programme cycle should prioritise inventory cleanup over certification volume. Otherwise the organisation ends up reviewing stale records instead of reducing actual access risk.
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 CSF 2.0 set the governance and control requirements practitioners need to meet.
| Framework | Control / Reference | Relevance |
|---|---|---|
| OWASP Non-Human Identity Top 10 | NHI-01 | Inventory and visibility are foundational to reviewing non-human access safely. |
| NIST CSF 2.0 | PR.AC-1 | Access permissions must be known before they can be reviewed or reduced. |
| NIST CSF 2.0 | GV.RM-1 | Risk-based scoping is needed when full visibility is not yet available. |
Build and maintain a complete NHI inventory before starting entitlement certification.
Related resources from NHI Mgmt Group
- Who should own access review remediation when multiple teams are involved?
- How should security teams run access reviews for non-human identities?
- How should security teams govern non-human identities that have persistent access?
- How should security teams govern API keys used for generative AI access?
Deepen Your Knowledge
Reviewed and updated by the NHIMG editorial team on July 6, 2026.
NHI Mgmt Group — the #1 independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org
