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Governance, Ownership & Risk

Who is accountable for securing credential vaults when passkey adoption is incomplete?

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By NHI Mgmt Group Editorial Team Updated August 27, 2026 Domain: Governance, Ownership & Risk

Accountability sits with the organisation that designs and operates the identity control, not with the end user alone. Security, IAM, and platform teams should decide when hardware-backed authentication is mandatory, how recovery is governed, and which environments are still allowed to use weaker fallback methods. Governance must align to the sensitivity of the vault.

Why This Matters for Security Teams

When passkeys are not yet universal, credential vaults become the control point that decides whether authentication is truly stronger or only partially modernised. That makes accountability an organisational issue, not a user preference issue. Security and IAM teams must define the acceptable fallback paths, while platform owners must ensure those paths are monitored, revocable, and scoped to the sensitivity of the vault. The risk is not theoretical: secrets sprawl remains common, and NHI Management Group’s coverage of the Guide to the Secret Sprawl Challenge shows how unmanaged credentials persist across environments even after modern controls are introduced.

Practical accountability matters because vaults often protect the very recovery methods that bypass passkeys, including backup codes, break-glass accounts, and administrative reset flows. If those paths are left ambiguous, the organisation inherits the weakest link in the chain. Current guidance from NIST SP 800-63 Digital Identity Guidelines and the OWASP Non-Human Identity Top 10 both points to governance, lifecycle control, and recovery design as security responsibilities, not end-user improvisation. In practice, many security teams discover this only after a fallback path is abused, rather than through intentional passkey rollout governance.

How It Works in Practice

The accountable organisation should treat vault security as a layered control problem. Passkeys may be the preferred primary factor, but incomplete adoption means the vault still needs explicit rules for enrollment, fallback, recovery, and emergency access. Security should define who can approve exceptions, IAM should enforce the policy, and platform teams should implement the technical guardrails. That includes hardware-backed authentication for privileged access, short-lived recovery tokens, and time-bound approvals for any temporary weaker method.

Operationally, this works best when the vault is tied to identity assurance and access policy rather than to a single authentication mechanism. A well-run program will:

  • Classify vaults by sensitivity and require stronger controls for high-impact environments.
  • Use step-up authentication for recovery actions and administrative resets.
  • Log every fallback event and review it as a security signal, not a convenience feature.
  • Retire weaker methods as adoption improves, with dates owned by the control owner.

This is where NIST SP 800-53 Rev 5 Security and Privacy Controls is useful because it frames access, auditability, and system ownership as enforceable responsibilities. NHI Management Group’s MongoBleed breach and 230M AWS environment compromise coverage also illustrates the same pattern: once a vault or secret path is exposed, attackers move quickly and recoveries become expensive. These controls tend to break down when multiple teams own different parts of the authentication stack because no single team has authority over the fallback path.

Common Variations and Edge Cases

Tighter vault governance often increases operational overhead, requiring organisations to balance stronger assurance against recovery speed and user support burden. That tradeoff is most visible in regulated environments, shared administrator vaults, and legacy applications that cannot yet support passkeys. In those cases, current guidance suggests maintaining a documented exception process rather than allowing ad hoc exceptions, because exceptions tend to become permanent.

There is no universal standard for this yet, but a practical rule is that the same team should own the risk decision, the control requirement, and the exception lifecycle. If an outsourced help desk can reset a vault without strong verification, the organisation still owns the risk even if the workflow is delegated. The same applies to recovery email accounts, SMS-based resets, and manually issued backup codes.

For teams comparing maturity levels, the question is not whether passkeys exist, but whether the fallback environment is safer than the primary one. The The 2024 State of Secrets Management Survey notes that only 44% of organisations use a dedicated secrets management system, which helps explain why recovery paths often remain fragmented. The policy goal should be simple: every weaker method must have a named owner, a sunset date, and a measurable removal plan.

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 SP 800-63, NIST CSF 2.0, NIST AI RMF and NIST Zero Trust (SP 800-207) set the governance and control requirements practitioners need to meet.

FrameworkControl / ReferenceRelevance
OWASP Non-Human Identity Top 10NHI-03Covers secret lifecycle and fallback credential risk in vault governance.
NIST SP 800-63IAL2Identity assurance governs recovery and step-up authentication decisions.
NIST CSF 2.0PR.AC-1Access control ownership is central when fallback methods remain in use.
NIST AI RMFGOVERNGovernance is needed to assign accountability across security and platform teams.
NIST Zero Trust (SP 800-207)SC.PO-1Zero trust requires policy-driven access even when passkey adoption is incomplete.

Use assurance levels to decide when passkeys, recovery, or stronger checks are required.

NHIMG Editorial Note
Reviewed and updated by the NHIMG editorial team on August 27, 2026.
NHI Mgmt Group — the #1 independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org