Accountability should sit with the identity governance function, the cloud platform owners, and the business owner for the access request. If any one of those groups treats reviews as a checkbox exercise, drift persists. Frameworks such as NIST Cybersecurity Framework 2.0 and zero trust architecture both depend on evidence that access is continuously validated.
Why This Matters for Security Teams
When multi-cloud access reviews miss excessive permissions, the failure is rarely just a missing signature. It usually means identity governance, cloud platform operations, and application owners have split accountability in a way that lets privilege drift accumulate across AWS, Azure, GCP, and internal platforms. That creates a governance gap that reviews cannot reliably close after the fact. The issue is especially visible for non-human identities, where access is often inherited, reused, or forgotten.
NHIMG’s Ultimate Guide to NHIs treats lifecycle control as the baseline for reducing this drift, and the OWASP Non-Human Identity Top 10 makes clear that weak ownership and stale entitlements are recurring causes of exposure. In NHIMG’s 2024 Non-Human Identity Security Report, 35.6% of organisations said consistent access across hybrid and multi-cloud environments is their top NHI security challenge, which explains why review programs often lag the environments they are supposed to govern. In practice, many security teams discover excessive access only after an audit exception, incident, or cloud misconfiguration has already made the drift visible.
How It Works in Practice
Accountability should follow the control point, not just the ticket queue. Identity governance owns the review process and evidence, cloud platform owners own the actual entitlements and technical guardrails, and the business owner owns the need for access and the business justification. If any one of those parties treats the review as ceremonial, the excess permission often survives the review cycle. Current guidance from OWASP NHI and NIST zero trust practice is moving toward continuous validation rather than periodic rubber-stamping.
In multi-cloud environments, effective review programs usually combine three controls:
- Authoritative ownership records for each identity, role, and cloud subscription or account.
- Entitlement inventories that show effective permissions, not just intended roles.
- Recertification workflows that require the business owner to confirm necessity and the platform owner to remove stale access.
That model becomes stronger when organizations map review evidence to a broader NHI lifecycle, as described in NHIMG’s NHI Lifecycle Management Guide, because access review findings can then feed provisioning, rotation, and deprovisioning decisions instead of living in an isolated spreadsheet. The operational point is simple: if no one is accountable for removing access, the review is only documentation, not control. These controls tend to break down when cloud teams manage permissions locally in each account or subscription because central reviewers cannot see inherited and cross-account privileges in real time.
Common Variations and Edge Cases
Tighter access review governance often increases coordination overhead, so organisations must balance stronger assurance against slower change management. That tradeoff becomes more acute in shared platform teams, M&A integrations, and fast-moving engineering groups where permission sets change faster than review cycles.
There is no universal standard for this yet, but best practice is evolving in a consistent direction: use risk-based review frequency for high-impact workloads, require platform owners to attest to technical removals, and escalate unresolved exceptions to a named business owner. For highly dynamic cloud estates, the strongest signal may come from monitoring and detection rather than human recertification alone. NHIMG’s 52 NHI Breaches Analysis shows how quickly ignored identity sprawl becomes an incident pattern, especially when teams assume the last review was sufficient. Organisations with federated cloud operations also need a clear decision on whether the security function can veto excess access or only recommend remediation, because unclear authority often leaves remediation incomplete.
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 Zero Trust (SP 800-207) set the governance and control requirements practitioners need to meet.
| Framework | Control / Reference | Relevance |
|---|---|---|
| NIST CSF 2.0 | PR.AA-01 | Assigns accountability for identity and access decisions across the enterprise. |
| NIST Zero Trust (SP 800-207) | AC-6 | Least privilege requires continuous access validation, not periodic checkbox reviews. |
| OWASP Non-Human Identity Top 10 | NHI-02 | Targets ownership and lifecycle gaps that let non-human access drift persist. |
Name owners for review evidence, entitlement cleanup, and exception approval across each cloud domain.
Related resources from NHI Mgmt Group
- How should security teams run access reviews for non-human identities?
- When do NHI access reviews create more value than a one-time cleanup?
- How should security teams implement cloud user access reviews across SaaS and multi-cloud environments?
- Why do role-based access reviews miss the most dangerous permissions?
Deepen Your Knowledge
Reviewed and updated by the NHIMG editorial team on June 20, 2026.
NHI Mgmt Group — the #1 independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org
