Why do access reviews so often become rubber stamping?

Why This Matters for Security Teams

Rubber stamping is rarely a review problem alone. It is a signal that access governance has drifted away from operational reality, where reviewers are asked to validate entitlements without enough context, evidence, or confidence that exceptions can be handled safely. In NHI-heavy environments, that becomes more dangerous because service accounts, API keys, and workload identities often accumulate privileges faster than humans can inspect them. The result is that “approve” feels safer than “remove,” even when the entitlement is no longer defensible.

NHIMG research shows the scale of the issue: 97% of NHIs carry excessive privileges, increasing unauthorised access and broadening the attack surface, according to Ultimate Guide to NHIs. That is why access review quality depends on upstream identity hygiene, not just reviewer discipline. OWASP also treats poor entitlement governance as a core non-human identity risk in the OWASP Non-Human Identity Top 10.

In practice, many security teams discover the problem only after an incident, when an “approved” entitlement is shown to have been unnecessary for months.

How It Works in Practice

The mechanics are straightforward. When a review queue is large and the reviewer cannot quickly answer three questions, rubber stamping starts: what does this identity actually do, what evidence proves it still needs access, and what happens if it is removed. If those answers are hidden in tickets, spreadsheets, or tribal knowledge, the review becomes a compliance gesture rather than a control.

For NHIs, better practice is to make each review item defensible by design. That means surfacing ownership, last use, scope, dependencies, privilege level, and rotation state in the same view. It also means separating “should this still exist?” from “does this still need these privileges?” so reviewers are not forced to make a binary decision on incomplete data. The 52 NHI Breaches Analysis and the NHI Lifecycle Management Guide both reinforce the same operational lesson: identities that are not lifecycle-managed tend to become over-entitled and poorly reviewed.

• Prioritise high-risk items first: privileged, dormant, externally exposed, or unowned NHIs.
• Attach evidence that is current, such as last-seen usage, approved service mapping, and dependency metadata.
• Use JIT where possible so reviewers are assessing short-lived access rather than permanent standing privilege.
• Route exceptions to the business owner, not only the technical reviewer, so accountability is explicit.

Current guidance suggests that access reviews work best when they are fed by continuous inventory and policy signals, not when they are treated as a periodic human memory test. These controls tend to break down when identities span multiple cloud accounts and CI/CD systems because the reviewer cannot reliably see live usage and ownership in one place.

Common Variations and Edge Cases

Tighter review controls often increase operational overhead, requiring organisations to balance assurance against reviewer fatigue and change velocity. That tradeoff is especially visible where access is intentionally dynamic, such as ephemeral build agents, release pipelines, and AI-driven workloads that request tools on demand.

For those environments, the standard role-based access review model is often a poor fit. Autonomous systems do not always have stable, human-like job functions, so static RBAC can hide the real question: is the agent authorised for this intent, at this moment, with this context? Emerging practice is moving toward intent-based authorisation, workload identity, and short-lived secrets, but there is no universal standard for this yet. The practical goal is to shrink standing privilege and make each access decision more traceable at runtime. The OWASP Non-Human Identity Top 10 remains useful here because it frames credential sprawl, over-privilege, and weak lifecycle control as structural issues rather than reviewer mistakes.

That also means edge cases need explicit handling. Shared service accounts may require compensating controls if ownership is unclear. Third-party NHIs may need different evidence thresholds because operational dependence can mask unnecessary access. Secrets embedded in pipelines can make “removal” disruptive unless teams first redesign the deployment path. The safest path is to reduce the number of decisions a human reviewer has to infer, and increase the number of facts the platform can prove. In practice, rubber stamping persists longest where access is both mission-critical and poorly instrumented, because reviewers hesitate to break a process they cannot observe in real time.

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 govern non-human identities that have persistent access?
• When does a machine identity become a compliance problem?