They often treat manual review as a simple compliance task rather than a control test. In reality, manual review is vulnerable to missed identities, inconsistent judgement, and slow remediation. That combination can create a false sense of assurance, especially when the access surface is large or changes frequently.
Why This Matters for Security Teams
Manual access reviews are often mistaken for a routine attestation exercise, but for non-human identities they are really a control validation problem. When service accounts, API keys, and workload tokens outnumber human identities, a spreadsheet review cannot reliably prove who has access, why it exists, or whether it is still needed. NHI Mgmt Group notes that Ultimate Guide to NHIs highlights how NHIs can outnumber human identities by 25x to 50x in modern enterprises, which makes manual review scale poorly.
The deeper issue is that reviewers are asked to make binary decisions about identities whose risk depends on workload, privilege, rotation status, and downstream dependencies. That is why guidance from the OWASP Non-Human Identity Top 10 emphasizes visibility, lifecycle control, and privilege reduction, not just periodic approval. In practice, teams often confuse “review completed” with “access is safe,” only to discover stale entitlements after an incident, an audit finding, or a failed offboarding effort.
How It Works in Practice
A manual review should be treated as a focused test against current entitlement data, not as the control itself. The reviewer needs a complete inventory of non-human identities, the owning application or service, last used date, privilege scope, secret age, and whether the identity is tied to a production dependency. Without that context, the review becomes guesswork.
Operationally, better programs combine manual review with automated evidence from identity systems, vaults, CI/CD, and cloud control planes. That usually means:
- defining ownership for every service account and API key before the review cycle begins
- tagging each NHI by business service, environment, and risk tier
- flagging dormant, overprivileged, or unrotated secrets for immediate action
- separating “approve,” “remediate,” and “decommission” decisions so reviewers do not default to rubber-stamping
This is where lifecycle guidance matters. The NHI Lifecycle Management Guide frames review as one checkpoint in a broader process that includes issuance, rotation, offboarding, and revocation. When that lifecycle is weak, manual review has to compensate for missing governance, which it cannot do well. The result is often a false pass on identities that should already have been retired or rotated. NHI Mgmt Group research also shows that only 20% of organisations have formal processes for offboarding and revoking API keys, which explains why stale access keeps surviving review cycles.
Controls tend to break down when the access surface changes faster than the review cadence, especially in cloud-native and CI/CD-heavy environments where secrets and workloads are created and destroyed continuously.
Common Variations and Edge Cases
Tighter review criteria often increase operational overhead, requiring organisations to balance assurance against engineering disruption. That tradeoff becomes especially visible when a service account is shared across multiple applications, when ownership has changed teams, or when a production dependency cannot be interrupted for immediate revocation.
Best practice is evolving, but there is no universal standard for deciding how much manual judgement is acceptable when an identity is technically “active” but functionally obsolete. Some organisations require evidence of recent use, while others require a compensating control such as rotation, vault binding, or JIT issuance before approval can stand. The important point is that review outcomes should trigger action, not just sign-off.
Manual review also struggles when entitlement data is incomplete. If one system shows an API key as active while another shows it as disabled, the reviewer cannot reliably adjudicate risk without resolving the source of truth. That is why manual review works best as part of a broader hygiene program that includes Ultimate Guide to NHIs — Key Challenges and Risks and continuous monitoring, rather than as a standalone compliance ritual.
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 and OWASP Non-Human Identity Top 10 address the attack and risk surface, while 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 | Manual reviews fail when NHI inventory and ownership are incomplete. |
| OWASP Non-Human Identity Top 10 | NHI-03 | Stale credentials and poor rotation are common findings in manual reviews. |
| NIST CSF 2.0 | PR.AC-4 | Access reviews are a governance check on privilege and entitlements. |
Validate complete NHI inventory and ownership before approving any access review.
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Deepen Your Knowledge
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
