Control A.9.2.5

Expanded Definition

Control A.9.2.5 is an access governance requirement, not just an audit activity. It expects user access rights to be reviewed at intervals that match risk, the business process, and the sensitivity of the systems involved. In practice, that means the organisation must define a cadence, prove that all in-scope access is covered, and show that exceptions or removals are handled through a documented workflow. This aligns closely with the review-and-remediation discipline described in the NIST Cybersecurity Framework 2.0, especially where access governance supports ongoing protection outcomes. In NHI environments, the same idea extends to service accounts, API keys, tokens, and automation identities because their access often persists far longer than intended. The control is most meaningful when it is tied to actual privilege risk, not a calendar task performed for evidence only. NHI Management Group’s Ultimate Guide to NHIs — Standards frames this as a governance control that must be observable, repeatable, and actionable. The most common misapplication is treating the review as a checkbox exercise, which occurs when teams sample a few accounts instead of verifying complete entitlement coverage and remediation.

Examples and Use Cases

Implementing Control A.9.2.5 rigorously often introduces administrative overhead, requiring organisations to weigh review depth against operational speed.

• A quarterly access review for finance applications verifies that role assignments still match current job responsibilities and that removed staff no longer retain access.
• A monthly review for production service accounts checks whether long-lived automation identities still need write access, using the governance patterns described in the Ultimate Guide to NHIs — Standards.
• A post-migration review confirms that temporary contractor access was revoked after a cloud cutover and that any exceptions were approved through the access workflow.
• An annual review for lower-risk internal tools is justified only when the organisation can evidence why the cadence is proportionate, consistent with NIST Cybersecurity Framework 2.0 governance expectations.
• A CI/CD permissions review inspects whether pipeline credentials still align with deployment scope, especially where token use is tied to ephemeral releases rather than static access.

For NHI-heavy estates, these reviews should include system owners, privileged access logs, and lifecycle evidence so that removals are traceable rather than informal.

Why It Matters in NHI Security

Access review controls become critical in NHI security because machine identities tend to accumulate excess privileges, remain undocumented, and outlive the systems or people that created them. That creates a direct path from stale access to lateral movement, data exposure, and unauthorized automation. NHI Management Group notes that Ultimate Guide to NHIs — Standards reports 97% of NHIs carry excessive privileges, which makes periodic review a core containment mechanism rather than a compliance formality. The risk is amplified when secrets and credentials are distributed across code, vaults, and CI/CD systems, because reviewers must validate both who has access and whether the access path itself is still justified. Control A.9.2.5 also supports broader governance by forcing ownership clarity, remediation deadlines, and escalation when access cannot be explained. Practitioners should interpret this control as a way to expose hidden privilege drift before it becomes an incident. Organisations typically encounter the consequences only after a breach investigation or failed audit reveals dormant accounts and over-privileged service identities, at which point the control becomes operationally unavoidable to address.

Related resources from NHI Mgmt Group

• Control Monitoring
• What is the difference between patching and blast radius control?
• What is the difference between source control leakage and SharePoint secret exposure?
• How should security teams control overprivileged NHIs?