Without usage evidence, access reviews become certifications of paperwork instead of certifications of real access. Teams may keep dormant subscriptions, unneeded integrations, and stale entitlements because they cannot prove whether the access is still active or valuable. That creates both unnecessary cost and lingering exposure across the SaaS stack.
Why This Matters for Security Teams
Access reviews are supposed to answer a simple question: does this SaaS access still serve a real business purpose, and is it still being used? Without usage evidence, the review becomes a paperwork exercise that can certify dormant seats, abandoned integrations, and stale tokens as if they were active controls. That matters because SaaS sprawl often hides non-human access paths that are easy to miss in entitlement reports but visible in login, API, and audit logs. NHI Mgmt Group notes that only 5.7% of organisations have full visibility into their service accounts in the Ultimate Guide to NHIs, which helps explain why review packages so often lack proof of real use. The issue is not just cost. Unused access widens the attack surface, preserves privilege longer than necessary, and makes offboarding decisions less defensible. OWASP’s OWASP Non-Human Identity Top 10 treats visibility and lifecycle control as core problems because entitlement data alone does not show actual operational risk. In practice, many security teams discover stale SaaS access only after an audit finding, a breach review, or a cost reduction initiative, rather than through intentional access governance.Usage evidence changes the review from “who was granted access” to “who actually depended on it, and how recently.”
How It Works in Practice
Effective reviews combine entitlement data with activity evidence from the same review period. For human users, that usually means login history, file access, workflow actions, and approval events. For non-human identities, it should include API calls, OAuth token use, SCIM activity, service-to-service transactions, and admin console events. The point is not to demand perfect telemetry, but to make a removal decision based on observable use instead of assumptions.A practical workflow looks like this:
- Pull the entitlement inventory from the SaaS app, IdP, and PAM where applicable.
- Attach usage evidence for the last review window, such as last login, API activity, or task execution logs.
- Flag accounts with no evidence of use, then require a business owner to justify retention.
- Separate interactive user access from service accounts and integrations, because the evidence model differs.
- Revoke or downgrade access when no operational dependency can be demonstrated.
That approach aligns with the NHI Lifecycle Management Guide, especially where SaaS access is really an identity lifecycle problem in disguise. It also matches the direction of least-privilege guidance in the OWASP Non-Human Identity Top 10, which emphasizes evidence, rotation, and offboarding rather than static entitlement lists. Current guidance suggests that review evidence should be time-bounded and specific to the service’s actual functions, not a generic screenshot of “last active” status. These controls tend to break down in SaaS environments with poor audit logging, shared admin accounts, or apps that do not expose usable API activity data because reviewers cannot distinguish legitimate idle access from dead entitlement.
Common Variations and Edge Cases
Tighter evidence requirements often increase review effort, requiring organisations to balance stronger assurance against heavier data collection and analyst time.The hard cases are usually not ordinary end users. Shared mailboxes, automation bots, delegated admins, and contractor-furnished integrations may show little human-style interaction even when they are essential. In those cases, best practice is evolving toward service-specific evidence, such as successful job runs, token refreshes, webhook deliveries, or upstream system dependencies, rather than forcing every account into the same review template. There is no universal standard for this yet, so the review owner needs clear decision rules.
Two additional edge cases matter. First, low-use does not always mean low-value, especially for emergency admin accounts that exist for exception handling. Second, heavy use does not always mean approved use if the activity falls outside policy or the original business justification. The strongest reviews combine usage evidence with scope, ownership, and recertification of purpose. NHI Mgmt Group’s 52 NHI Breaches Analysis shows how quickly weak identity governance becomes an incident pattern when access is left in place after the operational need has changed. The practical takeaway is simple: evidence should support the retention decision, not merely decorate it.
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-03 | Usage evidence supports timely review and removal of stale non-human access. |
| NIST CSF 2.0 | PR.AA-01 | Identity evidence is needed to verify whether access remains appropriate. |
| NIST CSF 2.0 | PR.AC-4 | Least-privilege reviews fail when access is certified without proof of need. |
Require activity evidence before recertifying SaaS access and revoke entitlements with no operational use.
Related resources from NHI Mgmt Group
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Reviewed and updated by the NHIMG editorial team on June 10, 2026.
NHI Mgmt Group — the #1 independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org
