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Beyond Human Access: Governing the Rise of the AI Workforce

Author: Raj Behal, Managing Director, Cybersecurity and Technology Risk, KPMG

Date: 08/10/2026

You’ve invested in IGA, PAM, and Zero Trust. But now you’re wondering how many of those controls apply to your AI agents. If the answer isn’t “all of them,” you have a gap that your adversaries may already be positioned to exploit.

Key findings

  • Non-human identities now outnumber human identities 80:11 in the average enterprise, yet 92%2 of AI agent deployments have no access review or recertification cycle.
  • Existing IGA, PAM, and SoD frameworks were not designed for AI agents. Each has a structural gap that may be exploited by adversaries via agent behavior.
  • A single orchestrating agent can invoke sub-agents whose combined permissions violate SoD rules without triggering a single conflict-detection alert.
  • Context & Intent-Aware Access Management (CIAM) evaluates not just whether an agent has permission, but whether it should act at this moment for this specific purpose.
  • A 90-day phased roadmap, from agent discovery through board-level reporting, gives CISOs a defensible governance posture without blocking AI adoption.

The non-human identity explosion

AI agents should not be treated like Service Accounts. They are autonomous, credentialed actors that authenticate across multiple systems, make context-dependent decisions, and execute multi-step workflows at machine speed without continuous human oversight. They represent a new class of principal that most existing identity frameworks were not designed to fully govern.

Beyond Human Access_Stats Graphic

 

>> CISO SIGNAL

If your NHI hygiene is already lacking (orphaned service accounts, embedded secrets, static tokens, etc.) AI agents will amplify every one of those failure modes at scale.

 


Where your identity stack breaks down

The failure modes are structural, not incidental. Patching them requires architectural change rather than incremental policy updates.

IGA: No HR hook for agent lifecycle

Agents are instantiated by developers, cloned for parallel runs, and decommissioned by stopping a process. None of their lifecycle events surface in traditional IGA platforms. As a result, agents accumulate access without recertification, a birthright definition, or a deprovisioning trigger.

PAM: Built for humans, not unattended pipelines

PAM assumes there’s a human behind the keyboard. This often leaves AI agents running unattended as they’re invoked thousands of times each day and conflicting with session check-in delays. Most PAM architectures lack a native model for agentic credential brokering, which leaves the problem to compound over time.

Access certification: Can't certify what it can't see

AI agents remain largely ungoverned by managers in the HR system. Certification tools provide access in a role-based format, but this doesn’t help govern agents that require API scope or OAuth claim language to restrict their access. Certifiers are often asked to approve access they cannot meaningfully interpret, leading to overpermissioning and potential risk down the road.

SoD: Blind to cross-agent permission aggregation

A single orchestrating agent can invoke sub-agents whose combined permissions span a full restricted transaction, defeating SoD rules without triggering a single conflict-detection rule.

Zero Trust: No verification without authentication

API keys and OAuth client credentials often lack behavioral baselines, device postures, and step-up capabilities, and most enterprises haven’t established the policy primitives for zero-trust with AI agents.

 


The AI agent threat surface

AI agents introduce attack vectors that differ qualitatively from threats posed by human identities. Most SOC playbooks are not currently designed to detect them.

Severity

Risk

Description

CRITICAL

Credential Exfiltration & Agent Takeover

Compromised API keys or OAuth tokens grant attackers full access to all systems the agent interacts with, often bypassing detection methods designed for human behavior.

CRITICAL

Prompt Injection & Semantic Hijacking

Malicious instructions embedded in documents or emails that the agent processes can override its behavior. Existing WAF, DLP, and SIEM rules often lack visibility into the semantic layer where this attack operates.

HIGH

Privilege Escalation via Agent Chaining

A low-privilege orchestrator invoking high-privilege sub-agents effectively escalates beyond its own credential scope. Traditional escalation detection also lacks a model for cross-agent permission aggregation.

HIGH

Lateral Movement via Broad Integration

Agents connected to CRM, ERP, HRIS, and cloud storage simultaneously are a single compromise away from lateral movement that exceeds anything a human account pivot typically enables.

MEDIUM

Exfiltration via Legitimate Scope

An agent with wide read access might unintentionally combine sensitive data, effectively causing exfiltration without malicious intent.

MEDIUM

Orphaned Agent Credentials

Agents decommissioned without formal offboarding leave active credentials in target systems indefinitely. Unlike orphaned human accounts, HR delta to trigger detection is often missing.

 

SOC Coverage Gaps: Check these against your current detection ruleset

  • Api key reused across agents: likely undetected; shared secrets not visible to UBA

  • Cross-agent privilege escalation monitoring: likely not covered; PAM doesn't track agent chains

  • Prompt injection detection: very likely identified; undetected by the semantic layer

  • Orphaned NHI credential sweep: partially completed, depends on completeness of agent registry.

  • Agent after-hours activity: Not applicable, as agents operate continuously. Traditional human heuristics do not apply in this context.

 


The NHI identity governance framework

Your identity fabric must expand to cover non-human identities. NHI governance doesn’t replace IGA or PAM. Rather, it serves as a framework and connecting force that enables your application for AI agents.

Start with discovery: You cannot govern what you cannot see

The first step is a comprehensive audit and identification of all agents within your environment, including those deployed by specific teams, embedded within SaaS platforms (such as Copilot, Agentforce, ServiceNow), and any shadow deployments. For each agent, create an authoritative record that details the agent ID, owner, mandate scope, credential inventory, access footprint, lifecycle status, and the most recent review date.

 Beyond Human Access_Gov Framework

 

What do secure AI agent credentials look like?

AGENT CREDENTIAL MINIMUMS

credential_type → Short-lived OAuth2 tokens | SPIFFE SVIDs | mTLS certs

max_token_lifetime → 15 min (interactive) | 1 hour (batch) | Never unlimited

scope_binding → Per-task resource scope | No wildcards | Explicit allowlist

secret_storage → PAM vault or secrets manager | Never env vars or config files

rotation_policy → Automated | Triggered on anomaly | No manual rotation

 

IGA extension: Six capabilities to strengthen your approach

Beyond Human Access_Six Capabilities

PAM and Zero Trust adaptations for AI agents

Instead of storing them in agent configurations, broker them at task time and record agent workflow execution (including the input-output chain, not just keystrokes). For zero trust, enforce policy at the API call level, not the session level, using workload attestation, task scope verification, and data classification awareness as the verification primitives.

 


What is context and intent-aware access management (CIAM)?

Traditional IAM focuses on whether a principal has permission to access a resource. CIAM considers whether the principal should take action at this moment for this precise purpose. For AI agents, intent-based evaluation offers control that genuinely mitigates risk.

CIAM continuously checks each access request against five context dimensions and an intent claim at the API level, rather than only at session start.

Dimension

Context Signal

What It Captures

Access Effect

Operational

Task type, workflow phase, upstream trigger

Is this access consistent with the agent’s declared task and workflow sequence?

Deny or flag if the task type does not justify the resource request.

Data

Classification, volume, recipient, downstream action

Is the data sensitivity and volume proportionate to the stated purpose?

Step-up approval required for regulated or high-classification data.

Temporal

Time of day, business calendar, change windows

Is this access occurring at a time consistent with the agent’s normal profile?

Anomalous-hour access triggers human notification or suspension.

Behavioral

Deviation score vs. baseline, velocity, and access pattern

Does this request deviate from the agent’s established behavioral fingerprint?

High deviation triggers real-time risk escalation or throttling.

Environmental

Deployment env, compute attestation, invocation source

Is the agent running from expected infrastructure, invoked by an authorized source?

Deny if the workload attestation fails or the invocation source is unrecognized.

 

Intent declaration: The new access control primitive

Agents must submit a structured intent claim detailing the task, data scope, action type, and recipient before accessing sensitive resources. The PDP checks this claim against the agent’s mandate before approval, applying PAM break-glass logic as a standard control at machine speed.  

INTENT CLAIM SCHEMA

agent_id → agt_fin_reporting_v2.3

task_declaration → Q3_EXECUTIVE_BRIEFING_PREPARATION

target_resource → finance.dw.quarterly_results | classification: CONFIDENTIAL

intent_type → READ_AGGREGATE | no PII | no external transmission

data_scope → revenue_by_region, opex_summary | date_range: 2025-Q3

mandate_ref → MANDATE-2025-FIN-007 | approved: CFO | valid_until: 2025-12-31

Risk-adaptive access: Dynamic tightening by context score

Risk Score Range

Access Decision

Step-Up Required

Example Scenario

0–24 Low

Permit + standard log

None — automated execution

Routine pull matching mandate, normal hours, baseline behavior

25–49 Elevated

Permit + enhanced audit

UEBA alert raised; reviewed within 24h

Data volume 40% above baseline; task within mandate

50–74 High

Throttled + hold

Async human approval; 4-hour window

PII in scope not declared in intent claim; marginal attestation

75–100 Critical

Deny — immediate block

Synchronous CISO alert; agent suspended

Cross-agent escalation detected; intent inconsistent with pattern

Least-intent privilege: Going beyond least privilege

While least privilege limits access for agents, least-intent privilege restricts actions to specific purposes. For example, using customer records for support differs from using them for marketing, as clarified by intent claims enforced by the PDP.

CIAM READINESS CHECK

(1) Does your PDP support ABAC with real-time context signals?

(2) Can your context aggregation layer feed normalized signals at sub-second latency?

(3) Is your agent mandate registry machine-readable and API-accessible?

(4) Can your PAM inject task-scoped credentials conditional on PDP approval?

(5) Do your audit logs capture intent claims alongside access decisions? Each “no” is a CIAM implementation gap.

 


Observability and incident response for AI agents

The effectiveness of governance depends on transparency. For AI agents, this means going beyond the list of called APIs to understand why each API is being used.

Semantic audit trails

Each agent action log must capture the agent’s identity and credentials, task context and goal, input received, reasoning for decisions, action taken, and anomaly flags. Since it’s difficult (if not impossible) to gather this information retroactively, your audit trails should be built into the deployment lifecycle.

Behavioral baselines

Adjust your UEBA to monitor agent behavior, including typical API usage, target systems, data quantities, and timing patterns. When an agent connects to systems beyond its usual scope, this should be viewed as a significant indicator rather than mere background noise.

IR playbooks: the minimum viable set

  • Credential compromise: cascade revocation SLA, blast radius assessment, forensic collection
  • Prompt injection: agent isolation, input source analysis, semantic log review
  • Scope expansion: entitlement review trigger, access footprint diff, root cause determination
  • Orphaned credential: immediate revocation, historical log review for anomalous usage
  • SoD violation via chain: workflow freeze, cross-agent permission analysis, compliance notification


The CISO action plan: A 90-day roadmap to defensible AI governance

From zero visibility to a defensible governance posture in six phases.

Phase

Timeline

Actions

Phase 1

Days 1–14

Agent Discovery & NHI Inventory

Active scan across cloud, SaaS, and on-prem. Pull OAuth registrations, enumerate API keys, and survey dev teams. Build initial NHI registry. A 60% complete inventory with automation beats a perfect spreadsheet that goes stale.

Phase 2

Days 15–30

Risk Stratification & Quick Wins

Rank agents by access footprint, data sensitivity, and credential hygiene. Immediately rotate long-lived credentials, assign owners to unowned agents, and right-size the top 10% most over-provisioned.

Phase 3

Days 31–45

IGA & PAM Extension

Define agent entity types in your IGA data model. Build agent-owner certification workflows. Extend SoD rules to agent chains. Configure PAM brokering for high-risk agents or implement Secrets Manager as an interim solution.

Phase 4

Days 46–60

Detection & Observability

Configure UEBA behavioral baselines for top-risk agents. Write detection rules for the five SOC coverage gaps. Enable semantic audit log collection. Publish IR playbooks for agent-specific incident types.

Phase 5

Days 61–75

CIAM Foundation

Deploy an intent-aware PDP with ABAC context evaluation. Build a machine-readable mandate registry. Instrument high-risk agents with intent claim submission. Run risk-adaptive policy pilot on most sensitive data resources.

Phase 6

Days 76–90

Policy, Governance & Board Reporting

Formalize AI agent security policy. Run the first NHI access certification campaign. Build board-level narrative with five key metrics (see below).

 

FIVE BOARD METRICS FOR AI AGENT GOVERNANCE

(1) NHI inventory completeness % — coverage of the agent population under governance.

(2) Over-provisioned NHI credential ratio — access exposure quantified.

(3) Mean time to revoke for agent credential incidents.

(4) CIAM coverage % — proportion of high-risk requests evaluated by intent-aware policy.

(5) Risk-adaptive access interventions per week — how often the system auto-tightens based on context signals.

 


The governance imperative: Why CISOs who lead on AI agents win

“The organizations deploying AI at scale in 2027 are not the ones moving fastest today. They are the ones building identity governance infrastructure now that makes fast, safe deployment possible. Speed without governance is just a faster path to a breach."

CISOs who block AI adoption lose the argument today and the room tomorrow. CISOs who govern it become the reason their organization can move fast without losing security. Identity governance isn’t necessarily a tax on AI adoption; it is the infrastructure that makes scale possible and the evidence that makes it defensible.

The regulatory pressure makes this a deadline, as opposed to a preference. The EU AI Act, NIST AI RMF, and SEC disclosure obligations aren’t limited to rewarding documented governance programs; they increasingly penalize the absence of one. Auditable controls are becoming table stakes for any organization deploying AI at scale.

But the stronger argument isn't compliance. It's exposure. Right now, AI agents are operating inside your enterprise with real credentials, real permissions, and real access to sensitive systems — and most identity stacks weren't built to see them, let alone govern them. They have credentials your IGA doesn't manage, permissions your PAM doesn't broker, and behavior your SOC has a limited baseline for.

That gap is not theoretical. It represents an emerging attack surface and may increase the likelihood of future incidents if not addressed. Close it before your agents define your next incident (or your next disclosure).

 

Learn more about our KPMG & Saviynt alliance here.

Frequently asked questions about AI agent identity governance

What is the difference between a service account and an AI agent in identity governance?

How does SoD enforcement work when multiple AI agents collaborate?

What credentials should AI agents use instead of static API keys?

How do you detect prompt injection attacks on AI agents?

What is least-intent privilege, and how is it different from least privilege?

How long does it take to establish AI agent governance from scratch?

 

 

Citations:



 

Raj Behal

Managing Director, Cybersecurity and Technology Risk

KPMG

Email: rbehal@kpmg.com

 

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