Identity Governance

Access Certification Campaigns: Why Reviews Get Rubber-Stamped and How to Fix Them

Access certification — a glowing access-review panel with two user rows approved and two revoked, beside a blue shield with a checkmark connected to database, cloud, laptop and folder systems

Most organisations already run access reviews. Every quarter or every six months, managers receive a list of their team's access and are asked to confirm it. Yet auditors still find former employees with active accounts, staff holding access from roles they left years ago, and shared admin accounts that nobody owns.

The reason is rarely that reviews are not happening. It is that reviews are being rubber-stamped: reviewers approve everything because it is the fastest way to clear the list. This article explains why that happens and how to design access certification campaigns that actually remove access people no longer need.

What Is Access Certification?

Access certification, also called an access review or user access review, is a periodic check of who has access to what. A reviewer looks at each user's access and makes one of two decisions: approve, if the person still needs it, or revoke, if they do not.

A group of these reviews run together, for example "all access to the core banking application, reviewed by its owner this quarter", is called a certification campaign. Common reviewer models are:

  • Manager review: each manager reviews the access held by the people who report to them.
  • Application or role owner review: the owner of an application or role reviews everyone who holds it.
  • Designated reviewer: a named person, such as a compliance or security lead, reviews a specific scope.

Regulators expect this control. RBI, SEBI's Cybersecurity and Cyber Resilience Framework (CSCRF) and IRDAI all expect regulated entities to review user access periodically, and the DPDP Rules name access control and review among the minimum safeguards for personal data. We cover these requirements in more detail in our articles on RBI, SEBI and IRDAI audits and the DPDP Act implementation checklist.

Why Access Reviews Get Rubber-Stamped

Rubber-stamping is rarely carelessness. It is usually the result of how the review was set up. These are the five most common causes.

1. Too Much to Review at Once

A manager with a team of 25 people can easily receive a list of 2,000 or more access items, covering every application, group and permission each person holds. Nobody can make 2,000 careful decisions in an afternoon. When the list is that long, approving everything becomes the only practical way to finish on time.

2. No Context for the Reviewer

Access is often stored under technical names such as GRP_FIN_RW_07 or SAP_Z_FI_POST. A business manager cannot tell from that name what the access allows, whether it is sensitive, or whether the person has used it recently. Faced with something they do not understand, most reviewers choose the option that will not disrupt anyone's work: approve.

3. "Approve All" Is the Easy Way Out

Bulk actions are necessary at enterprise scale. Without them, large campaigns would never finish. But if an "Approve All" button is the most visible option and there is no follow-up on how it is used, it can turn the review into a single click. A campaign where 100% of items were approved in a few seconds is a warning sign in itself.

4. Revoked Access Is Not Actually Removed

In spreadsheet-based reviews, a "revoke" decision is a note in a cell. Someone then has to raise a ticket, and someone else has to remove the access in Active Directory or the application. If that chain breaks, the access stays. Reviewers notice when their revoke decisions have no effect, and they stop making them.

5. Accounts Without an Owner Are Never Reviewed

Certification campaigns are built from identities: each person's access is sent to their reviewer. Accounts that are not linked to any person, such as old service accounts, test accounts or accounts left behind by former employees, have no reviewer. They never appear in a campaign, which means some of the riskiest accounts are never reviewed at all.

How to Design Access Reviews That Actually Work

The fixes below do not require reviewers to work harder. They make the right decision easier than the lazy one.

How to design access reviews that work — a focused SAP Finance access review of 80 items with business-friendly names and last-used dates, two unused permissions revoked and marked removed, surrounded by six fixes: smaller focused campaigns, right reviewer, clear context and last used, bulk actions on filtered lists, revocations removed automatically, and every account has an owner

1. Narrow the Scope of Each Campaign

Instead of one review of "all access for all users", run smaller campaigns: one per critical application, one for privileged access, one for roles. A reviewer who receives 80 relevant items will make far better decisions than one who receives 2,000 mixed ones. Review high-risk systems more often, for example quarterly, and lower-risk systems less often.

2. Send Each Item to the Right Reviewer

Managers know what a person's job needs. Application owners know what a permission inside their application allows. Use manager reviews for broad access, and owner reviews for sensitive applications and entitlements. When the reviewer understands the item, they are more likely to question it.

3. Give Reviewers the Context to Decide

Replace technical names with business-friendly descriptions, so that SAP_Z_FI_POST becomes "Post journal entries in SAP Finance". Where possible, show when the access was granted and when it was last used. Access that has not been used in 90 days is a natural candidate for removal.

4. Use Bulk Actions With Care

Keep bulk approve and bulk revoke, because they are essential for large campaigns. Encourage reviewers to use them on a filtered list, for example "approve all standard access for this team" or "revoke all access for people who have left", rather than on everything at once. Report on how bulk actions are used, so that a campaign where everything was approved in one click gets a second look.

The same caution applies to what happens when a campaign reaches its end date. Automatically approving every item that is still pending is a bulk approval that nobody made. For sensitive applications, leave pending items for reviewers to decide, and make sure they are told that action is still required.

5. Close the Loop on Revocations

A revoke decision should trigger removal of the access automatically, through a connector to the application or a ticket for applications that cannot be connected directly. The result of each revocation, whether it succeeded, failed or is waiting on a ticket, should be visible, and failures should be retried and followed up. This is what turns a review into a control that auditors can rely on.

6. Clean Up Unlinked Accounts Before the Campaign

Before a campaign starts, find accounts in each application that are not linked to any person. Link each one to its rightful owner, assign an owner to genuine service accounts, and disable the rest. Once accounts are linked, they appear in reviews like any other access.

Rubber-Stamped vs Effective Review

AreaRubber-stamped reviewEffective review
ScopeAll access, all users, once a yearFocused campaigns by application, role or risk
ReviewerWhoever is easiest to assignThe manager or owner who understands the access
InformationTechnical names onlyBusiness descriptions and usage context
Bulk actionsOne click approves everythingUsed on filtered lists, and reported on
RevocationA note in a spreadsheetAccess removed in the target system, with status tracked
EvidenceEmails and spreadsheets assembled before the auditDecision reports and audit trail exported straight from the campaign

What to Look for in an Access Certification Tool

If your reviews still run on spreadsheets and email, an Identity Governance and Administration (IGA) platform can automate most of the work. When evaluating one, check whether it can:

  • Run scheduled campaigns, for example quarterly or half-yearly, without manual setup each cycle
  • Scope campaigns by applications, roles, entitlements and user groups
  • Route items to managers, application owners or role owners
  • Collect the data automatically from connected applications, including very large ones
  • Offer bulk approve and revoke on filtered lists
  • Remove revoked access automatically, with a ticketing fallback for applications without APIs
  • Track the status of every revocation and retry failures
  • Export reviewer records and the full audit trail of each campaign as audit-ready reports

Final Considerations

Access certification works when it is treated as a routine control rather than a once-a-year exercise before the audit. Smaller campaigns, the right reviewers, clear information and revocations that actually take effect will do more for your security posture than a larger review that everyone approves.

IamLogic IGA runs scheduled certification campaigns across applications, roles, entitlements and permissions, with reviews assigned to managers, application owners or role owners. Reviewers can approve or revoke selected items or a whole filtered list, with usage context shown alongside each item so that unused access stands out. Orphan and dormant account reports help you find accounts that are not linked to anyone before a campaign starts. Every reviewer is emailed when a review run is ready. When a campaign passes its end date, you choose the default: pending items can be approved automatically, or left untouched while reviewers are emailed that action is required and must log in to make their decisions. Revocations are carried out through connectors or, for applications without APIs, through ticketing integration, with the result of each one tracked and failed revocations available to re-run. Reviewer records can be exported as a report, and after the review the audit trail can be exported too, giving your auditors a complete record. A capital markets exchange used this approach to replace an email-based quarterly review, as described in our access certification case study.

FAQs on Access Certification

What is access certification?

Access certification is a periodic review in which a manager or application owner confirms whether each user should keep the access they currently hold. Access that is no longer needed is revoked, and every decision is recorded as audit evidence.

What is rubber-stamping in access reviews?

Rubber-stamping is when reviewers approve access without genuinely checking it, usually because they have too many items to review or do not understand what the access allows. The review is completed on paper, but unneeded access stays in place.

How often should access reviews be done?

Many regulated organisations review high-risk systems and privileged access every quarter and other systems every six months. The right cadence depends on your regulators, your auditors and the sensitivity of each system.

Who should review access: the manager or the application owner?

Both have a role. A manager knows what a person's job needs, while an application owner knows what each permission inside the application allows. Many organisations use manager reviews for broad access and application-owner reviews for sensitive applications and entitlements.

How does access certification help with DPDP Act compliance?

The DPDP Rules expect organisations to control and review who can access personal data. Regular access certification shows that access to systems holding personal data is checked, that unneeded access is removed, and that there is a record of each decision.