Manual reviews fail when reviewers lack context and are asked to make too many decisions too quickly. They see spreadsheets, not access history, business purpose, or entitlement source, so approval becomes the path of least resistance. The process creates paperwork and evidence, but not necessarily security improvement.
Why This Matters for Security Teams
Manual access reviews are meant to catch stale or excessive access, but they often miss the highest-risk entitlements because the reviewer is working without context. When access is spread across service accounts, API keys, CI/CD tokens, and delegated admin paths, a spreadsheet review can confirm ownership without confirming necessity. That is why NHI Management Group treats review quality as a visibility problem, not just a governance one. The Ultimate Guide to NHIs notes that only 5.7% of organisations have full visibility into their service accounts.
The operational risk is simple: reviewers approve what they can see, not what is actually still needed. That gap matters because identity sprawl is already large, and privilege tends to accumulate faster than teams can audit it. The OWASP Non-Human Identity Top 10 highlights the control failures that arise when secrets and machine identities are not governed with the same rigour as human access. In practice, many security teams discover risky access only after a secret leak, privilege escalation, or service outage has already made the review process look cosmetic rather than preventive.
How It Works in Practice
Manual reviews usually rely on managers, system owners, or application leads to validate whether access should remain. That can work for a small number of human accounts with stable job functions, but it breaks down when the subject is a non-human identity with a changing purpose, rotating dependencies, and hidden inheritance. A reviewer looking at an entitlement list cannot easily tell whether a token is tied to one deployment job, a dormant integration, or a critical production workflow.
Better practice is to pair reviews with evidence that describes actual use, not just assigned permission. That means access history, last use timestamps, entitlement source, and business owner all need to be visible in one place. It also means separating standing access from access that should be issued only when needed. The NHI Lifecycle Management Guide and the NIST Cybersecurity Framework 2.0 both support stronger asset, identity, and governance discipline around ongoing access validation.
- Use recertification to confirm business need, not just named ownership.
- Pull in secret age, last rotation date, and last successful use before reviewers vote.
- Flag high-risk entitlements such as production write access, admin tokens, and shared credentials.
- Tie reviews to remediation so approvals, revocations, and rotations happen in the same workflow.
Where possible, organisations should supplement periodic reviews with continuous signals from vaults, PAM, CI/CD, and workload identity systems. Current guidance suggests this is especially important for machine credentials because a yes-or-no review once a quarter cannot reflect fast-changing build pipelines, ephemeral workloads, or delegated automation. These controls tend to break down in environments with shared service accounts and undocumented integrations because no single reviewer can reconstruct actual dependency chains from a static entitlement export.
Common Variations and Edge Cases
Tighter review processes often increase administrative overhead, requiring organisations to balance coverage against reviewer fatigue and operational downtime. That tradeoff becomes most visible in environments with thousands of NHIs, rapid deployment cycles, or outsourced application ownership, where every additional approval step can slow delivery.
There is no universal standard for this yet, but current guidance suggests moving away from one-size-fits-all recertification. High-risk privileges should be reviewed more frequently than low-risk read-only access, and short-lived credentials may need exception handling rather than traditional quarterly attestation. The Top 10 NHI Issues is useful here because it shows how excessive privilege, weak visibility, and poor rotation reinforce one another. NHI Management Group also recommends comparing review results against broader breach patterns in the 52 NHI Breaches Analysis, because post-incident access often reflects controls that looked fine on paper.
Manual reviews are most likely to fail when ownership is ambiguous, when access is inherited through groups or templates, or when revocation depends on another team to act after the review closes. In those cases, the issue is not reviewer intent but the fact that the review process is disconnected from the systems that actually issue, use, and remove access.
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-01 | Addresses poor visibility and review gaps in non-human identity access. |
| NIST CSF 2.0 | PR.AC-4 | Covers least privilege and access governance for identities and entitlements. |
| NIST AI RMF | GOVERN | Supports accountability and oversight for automated decision workflows. |
Continuously validate access and revoke stale entitlements instead of relying on periodic spreadsheet attestations.
Related resources from NHI Mgmt Group
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Reviewed and updated by the NHIMG editorial team on June 10, 2026.
NHI Mgmt Group — the #1 independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org
