Why does DORA increase the importance of privileged access reviews?

Why This Matters for Security Teams

DORA changes privileged access reviews from a routine hygiene task into evidence of operational resilience. When a firm cannot show who can reach production systems, who can approve emergency access, and which elevated entitlements are still justified, it also cannot show that critical services are protected during stress. That is why review quality matters as much as review frequency. The regulatory expectation sits alongside long-standing identity guidance in EU Digital Operational Resilience Act (DORA) and the broader control expectations in NIST SP 800-53 Rev 5 Security and Privacy Controls.

For NHI-heavy environments, the same issue becomes sharper because privileged service accounts, API keys, and automation tokens often outlive the humans who approved them. NHIMG’s Ultimate Guide to NHIs notes that 97% of NHIs carry excessive privileges, which is exactly the kind of condition DORA expects firms to detect and remediate before it affects resilience. In practice, many security teams encounter overprivileged access only after an outage, incident review, or audit finding has already exposed the gap rather than through intentional governance.

How It Works in Practice

Privileged access reviews under DORA should focus on whether elevated access is still necessary, who owns it, how it is used, and how quickly it can be revoked. The practical test is not simply whether an account exists, but whether its permissions are traceable to a current business need and an accountable approver. That means reviewing admin roles, support break-glass access, vendor access, and machine identities that can reach sensitive systems, then documenting the rationale for retention or removal.

Security teams usually get better results when they connect access review evidence to operational processes:

• Map each privileged entitlement to a named owner and a live service or control objective.
• Use short review cycles for production, recovery, and third-party support access.
• Separate standing admin rights from NHI lifecycle management so stale keys and forgotten service accounts are not treated as minor exceptions.
• Record approvals, exceptions, and revocations in a way that supports audit and incident reconstruction.

For non-human identities, the review must also check credential age, rotation status, and whether the identity still needs privileged scope at all. NHIMG’s Ultimate Guide to NHIs — Key Challenges and Risks highlights how excessive privilege and poor visibility combine into systemic exposure. That aligns with OWASP Non-Human Identity Top 10 guidance, which treats overprivileged NHI access as a core failure mode, not a corner case. These controls tend to break down in fast-moving cloud environments where access is granted through CI/CD, federated trust, and temporary support workflows because ownership and scope become hard to verify in real time.

Common Variations and Edge Cases

Tighter privileged access review often increases operational overhead, so organisations need to balance resilience evidence against the cost of manual review and exception handling. That tradeoff is real, especially in firms with many subsidiaries, outsourced support teams, or high-volume automation. Current guidance suggests risk-based review frequencies rather than a one-size-fits-all calendar, but there is no universal standard for this yet.

The edge cases are usually where the risk is highest. Emergency access, shared vendor accounts, and machine-to-machine credentials can all appear temporary while effectively becoming standing privilege. For those identities, best practice is evolving toward time-bounded access, explicit owner attestations, and removal of broad entitlements once the task ends. The challenge is even greater when service accounts support recovery or settlement workflows, because revocation may disrupt essential operations if dependencies have not been mapped first. NHIMG’s Ultimate Guide to NHIs and the incident patterns in 52 NHI Breaches Analysis both show that excessive privilege is rarely isolated. It usually sits inside a wider visibility and lifecycle problem that DORA now makes harder to ignore.

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?
• Why do AI-assisted attacks increase the importance of privileged access governance?
• Why do service-account and privileged-access records matter in defence compliance?