Why Periodic Access Reviews Can’t Keep Up With Risk

Periodic access reviews are one of the most common identity governance controls.

They are also one of the least aligned with how risk actually changes.

Most organizations review access on a fixed schedule — quarterly, biannual, or annual. These reviews are designed to satisfy audit requirements and demonstrate oversight. In practice, they leave long windows where access risk goes unreviewed.

The problem is not execution.

It’s that risk does not change on a schedule.

Periodic Reviews Assume a Static Organization

Periodic access reviews are built on a flawed assumption: that access remains stable between review cycles.

In practice, reviews are based on point-in-time snapshots.

Access data is pulled, normalized, and packaged into review campaigns — often days or weeks before a reviewer ever sees it.

From the moment a campaign is generated, the data begins to age.

Users can change roles, move departments, gain new access, or leave the organization entirely minutes or hours after a review is created. None of those changes are reflected until the next review cycle.

Meanwhile, organizations continue to change:

• People move into new roles
• Teams reorganize
• Responsibilities expand or contract
• Temporary access quietly becomes permanent

None of these changes wait for the next review window.

By the time a periodic review begins, access decisions may already be certifying conditions that no longer exist.

Risk Spikes When Business Events Occur

The moments of highest access risk are not evenly distributed across the year.

Risk increases sharply when:

• An employee moves into a new role
• A user transfers to a different department
• Reporting lines or managers change
• Temporary or emergency access is granted
• Projects start, end, or shift scope

Periodic reviews are blind to these events until the next cycle — creating long unmanaged exposure windows.

Delayed Reviews Create Compounding Risk

When access reviews occur only a few times a year:

• Excessive access accumulates
• Privileges layer on top of each other
• Ownership becomes unclear
• Exceptions persist across cycles

Each delay compounds risk rather than containing it.

From a security perspective, this means access risk is often highest between reviews, not during them.

Periodic Reviews Encourage Volume Over Judgment

Because periodic reviews bundle large amounts of access into a single event, reviewers are forced to:

• Evaluate long access lists
• Make decisions under time pressure
• Approve access they don’t fully understand

As volume increases, decision quality declines.

This leads to:

• Rubber-stamped approvals
• Minimal scrutiny of high-risk access
• A focus on completion rather than correctness

The process favors efficiency over risk reduction.

Static Schedules Don’t Match Audit Intent

Audit frameworks require organizations to demonstrate control over access.

They do not require access to be reviewed only on fixed schedules.

When periodic reviews are treated as the primary governance mechanism:

• Audits become the driver of review timing
• Evidence becomes more important than outcomes
• Controls lag behind real-world change

This creates the illusion of governance while risk continues to evolve unchecked.

Periodic Reviews Create Long Windows of Exposure

A quarterly review cadence can leave up to:

• 90 days of unmanaged risk

A biannual review can leave:

• 6 months of exposure

An annual review can leave:

• An entire year of inappropriate access

For high-risk systems, privileged roles, and sensitive data, these windows are unacceptable.

This Is Why “More Frequent” Isn’t the Answer

Many organizations respond by increasing review frequency.

But more frequent periodic reviews:

• Increase operational burden
• Increase reviewer fatigue
• Do not align reviews with meaningful change
• Still miss risk spikes between cycles

The issue is not how often reviews occur. It’s what triggers them.

Governance That Keeps Up With Risk Responds to Change

Access risk changes when the business changes.

Governance models that reduce risk:

• Reassess access when meaningful events occur
• Focus effort where risk actually increases
• Avoid reviewing unchanged, low-risk access repeatedly
• Produce evidence continuously, not periodically

This does not eliminate audits or reviews — it makes them more relevant and defensible.

Periodic Reviews Are a Symptom of Time-Based Governance

Periodic access reviews persist because they are easy to schedule and easy to explain.

But they reflect a governance model built around calendars, not risk.

When governance relies solely on periodic reviews:

• Risk accumulates silently
• Access drift goes unnoticed
• Security teams lose confidence in controls

This is not a failure of process — it is a failure of design.

Why This Matters for Identity Governance

Access reviews are one of the most visible expressions of identity governance.

When they are misaligned with how risk changes, governance fails in practice — even if it looks complete on paper.

 👉  See how periodic access reviews contribute to broader identity governance breakdown: Identity Governance That Works in Practice 

Reducing Risk Requires Rethinking Review Timing

Organizations do not reduce risk by reviewing access more often.

They reduce risk by reviewing access when it actually changes.

That requires a governance approach that:

• Responds to business events
• Prioritizes high-risk access
• Verifies outcomes, not just intent
• Produces audit-ready evidence naturally

Moving Beyond Periodic Access Reviews

Periodic reviews will continue to exist.

They are familiar, auditable, and widely adopted.

But on their own, they cannot keep up with modern access risk.

Talk to an Identity Governance expert to see how OpenIAM helps organizations evolve beyond time-based reviews toward governance models that reflect how risk actually changes.

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