Organisations should document the gap, assign a named owner, and define a compensating control that covers provisioning, deprovisioning, and review evidence. If the app cannot support automation, it still needs a repeatable governance process rather than ad hoc manual handling.
Why This Matters for Security Teams
When an application cannot support identity automation, the risk is not just extra admin work. It is the loss of consistent control over provisioning, deprovisioning, and periodic review, which is where service accounts, API keys, and other secrets most often become durable attack paths. NHI Mgmt Group’s Ultimate Guide to NHIs shows why this matters: only 20% of organisations have formal processes for offboarding and revoking API keys, and 71% of NHIs are not rotated on time. That gap becomes more dangerous when the app cannot plug into IAM tooling, ticketing, or vault automation. Current guidance from NIST Cybersecurity Framework 2.0 still points teams toward governance, review, and accountable access control even where the technology stack is uneven. The practical issue is that manual handling often survives as an informal exception long after the original business need has changed. In practice, many security teams encounter stale access only after an audit finding, a leaked secret, or a service outage has already exposed the gap.How It Works in Practice
The right response is to replace automation with a documented compensating control, not with one-off approval habits. That control should name the application owner, define who can request access, specify how credentials are issued, and set the exact evidence needed for review and removal. For NHI governance, this usually means a repeatable workflow that covers:- named business and technical ownership for the app and its secrets
- manual provisioning steps with ticket references and approver identity
- deprovisioning triggers tied to role changes, project closure, or inactivity
- recurring attestations that verify the app still needs each identity or secret
- vaulting or escrow of secrets where direct automation is impossible
Common Variations and Edge Cases
Tighter governance often increases operational overhead, so organisations have to balance risk reduction against business continuity and support burden. Some teams can use partial automation, such as ticket-driven approval plus vault-managed secret rotation, while others must rely on scheduled reviews because the application exposes no usable API or lifecycle hooks. Best practice is evolving, and there is no universal standard for this yet, but the direction is consistent: every exception should be time-bounded, owned, and reviewable. If the application is critical, one common variation is to reduce the blast radius rather than force full automation, for example by isolating the app, narrowing the scope of the secret, or placing the account behind PAM and strict RBAC. NHI Mgmt Group’s JetBrains GitHub plugin token exposure is a good reminder that even well-known tooling can leak secrets when lifecycle controls are weak. For organisations aligning to broader risk programs, the governance expectation also fits the spirit of NIST Cybersecurity Framework 2.0: identify the exception, protect it with compensating controls, and verify it on a recurring basis.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 | Covers lifecycle controls when automation is missing. |
| NIST CSF 2.0 | PR.AC-4 | Least-privilege access still applies to manual app exceptions. |
| NIST AI RMF | Governance and accountability map well to compensating controls. |
Assign clear ownership, track exceptions, and keep decision records for every manual identity process.
Related resources from NHI Mgmt Group
- How do organisations know if patient access identity controls are working?
- How should organisations decide whether their multi-cloud identity model is working?
- How should security teams govern app identity modernization across multi-cloud environments?
- How can organisations govern sensitive agent actions without blocking automation?
Deepen Your Knowledge
Reviewed and updated by the NHIMG editorial team on June 6, 2026.
NHI Mgmt Group — the #1 independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org