Because the review boundary is usually too narrow. A managed identity can be harmless on paper but dangerous once it is linked to a secret, certificate, or downstream API permission. Cloud access reviews need to account for where those credentials can travel after initial authorization, not just where they were granted.
Why This Matters for Security Teams
Managed identities and secrets complicate cloud access reviews because the real risk is not just the entitlement shown in a console, but the credential material that can be reused, copied, or embedded elsewhere. A review that checks only who was granted access will miss where tokens, certificates, and API keys can still operate after the original assignment looks clean. That gap is exactly where cloud incidents begin.
This is a recurring pattern in NHI governance, especially when organisations inherit broad service permissions, long-lived credentials, and weak offboarding discipline. NHIMG research on the Guide to the Secret Sprawl Challenge shows how quickly secrets spread across systems, tickets, and code paths, making a point-in-time review insufficient. The OWASP Non-Human Identity Top 10 also reflects this problem by treating credential lifecycle and exposure as primary risk factors, not just access assignment.
In practice, many security teams discover the issue only after a secret has already been copied into a pipeline, shared in a ticket, or left active after the original workload changed.
How It Works in Practice
Cloud access reviews for managed identities need to follow the identity beyond the first permission grant. A managed identity may look acceptable in IAM, but if it can mint tokens, assume roles, call downstream APIs, or retrieve secrets from a vault, the effective access surface is much larger than the review record suggests. That is why current guidance suggests reviewing both direct entitlements and the pathways those identities can use at runtime.
Security teams usually need to verify four things together: what the managed identity can reach, which secrets it can retrieve, how those secrets are stored or replicated, and whether the resulting tokens are short-lived or persistent. The most defensible model is to combine cloud IAM review with secret inventory, vault policy review, and workload-to-workload dependency mapping. The 2025 State of NHIs and Secrets in Cybersecurity report from Entro Security highlights the scale of the problem: 62% of secrets are duplicated across multiple locations, which makes a single access review incomplete by design.
- Review the managed identity and the downstream services it can impersonate or call.
- Trace secret retrieval paths from vault to workload to pipeline to API.
- Prefer short-lived credentials and limit static secrets to exceptional cases.
- Revalidate after deployment changes, not only during quarterly reviews.
Where possible, align cloud access review evidence with runtime policy and workload identity signals from standards such as the NIST Cybersecurity Framework 2.0 and the NHI Lifecycle Management Guide. These controls tend to break down when identities are reused across multiple apps because the review no longer reflects a single owner, a single purpose, or a single blast radius.
Common Variations and Edge Cases
Tighter review scope often increases operational overhead, requiring organisations to balance stronger assurance against the cost of tracing every downstream dependency. That tradeoff matters most in hybrid estates, CI/CD-heavy environments, and shared platform accounts where a managed identity is both infrastructure glue and a privileged access path.
There is no universal standard for how deep a cloud access review must go, but best practice is evolving toward evidence of usage, not just evidence of assignment. For example, a managed identity with no direct human owner may still be high risk if it can unlock a vault, exchange tokens, or sign requests on behalf of multiple workloads. In those cases, the access review should include secret rotation status, token TTL, last-used telemetry, and the workload boundary it serves.
Edge cases also appear when secrets are embedded in build systems, shared libraries, or service meshes. A review can look clean while the actual access path persists through automation. NHIMG’s 52 NHI Breaches Analysis and Top 10 NHI Issues both underscore the same operational lesson: the identity record is only one piece of the control surface.
These reviews tend to break down in fast-moving multi-cloud pipelines because the identity can change faster than the approval record.
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 CSA MAESTRO address the attack and risk surface, while NIST CSF 2.0, NIST SP 800-53 Rev 5 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 | Secret lifecycle and exposure issues directly affect cloud access review accuracy. |
| NIST CSF 2.0 | PR.AC-4 | Least-privilege reviews must include downstream access enabled by managed identities. |
| NIST SP 800-53 Rev 5 | AC-6 | Least privilege controls are central when secrets extend identity reach. |
| NIST AI RMF | Governance is needed for autonomous access paths and hidden runtime behaviour. | |
| CSA MAESTRO | M2 | Agent and workload access governance depends on tracing identity-to-resource relationships. |
Validate that each managed identity has only the access needed for its current workload.
Related resources from NHI Mgmt Group
- How should security teams run access reviews for non-human identities?
- How should security teams govern non-human identities that have persistent access?
- How should security teams govern non-human identities in cloud environments?
- When do NHI access reviews create more value than a one-time cleanup?
Deepen Your Knowledge
Reviewed and updated by the NHIMG editorial team on August 11, 2026.
NHI Mgmt Group — the #1 independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org
