Identity and Access Reviews (Control 2-2-4 under ECC – 2 : 2024) are a foundational Compliance Framework practice: they ensure that people, accounts, and services have only the access they need and that access is reviewed, approved, and documented on a regular cadence. This post gives a step-by-step checklist and practical, small-business friendly implementation advice to help you meet the compliance requirement and reduce identity-related risk.
Why Identity and Access Reviews matter for Compliance Framework
At its core, Control 2-2-4 requires periodic verification of identities, group memberships, and privileges to confirm appropriateness and to detect stale, orphaned, or excessive access. For Compliance Framework assessments you must demonstrate repeatable reviews, documented decisions, and remediation evidence — not just a one-off cleanup. The objective is to enforce least privilege, prevent privilege creep, and provide audit evidence that access was validated by accountable owners.
Step-by-step checklist to implement Control 2-2-4
Step 1 — Inventory identities, accounts, and access entitlements
Begin with a comprehensive inventory. Include human user accounts, service/service-to-service accounts, API keys, shared accounts, privileged administrative accounts, and group memberships. Pull data from your Identity Provider (IdP) and directory services (e.g., Azure AD, Okta, Google Workspace, Windows Active Directory). Useful commands: Get-ADUser -Filter * -Properties Enabled, or in Azure AD use Get-MgUser (Microsoft Graph) to export current users and their group memberships. For SaaS apps, export application user lists and application roles. This inventory is the baseline for every review.
Step 2 — Classify accounts and define review scope and cadence
Classify accounts by risk and function: privileged (domain admins, cloud owners), mission-critical service accounts, contractors, and regular employees. For Compliance Framework alignment: set high-risk accounts to monthly reviews, standard employee access to quarterly reviews, and low-use/service accounts to semi-annual reviews. Small-business example: with ~25 employees using Azure AD and a single on-premises file server, review privileged roles monthly (global admin, server admins), group memberships quarterly, and service accounts every six months.
Step 3 — Assign owners and implement a review workflow
Assign an owner for each identity group and resource — typically managers for user access and application owners for app roles. Implement a lightweight workflow using your ticketing system (Jira, ServiceNow, Freshservice) or even shared spreadsheets with digital signatures if tools are limited. For automated options, enable Azure AD Access Reviews (P2) or Okta access certifications to push attestations to managers. Ensure reviews include explicit accept/revoke actions, a comments field for justification, and a remediation ticket created automatically when access is revoked.
Step 4 — Execute reviews and remediate promptly
Conduct reviews according to schedule. Reviewers should verify: person still requires access, role aligns with job duties, MFA is enabled, and any privileged access is justified. For remediation, perform actions such as disabling accounts (PowerShell: Disable-ADAccount -Identity
Step 5 — Log decisions, collect evidence, and report
Record each review outcome and remediation action. Evidence should include the review roster, reviewer identity, timestamp, the decision (approve/revoke), and proof of remediation (change ticket ID, system log export). Retain evidence according to your Compliance Framework policy — commonly at least 12 months for operational reviews and longer if your industry requires it. Integrate logs into your SIEM where possible so you can prove that a disabling action generated the expected audit event.
Implementation notes with technical details
Practical technical details: for on-prem Active Directory use scheduled PowerShell scripts (Get-ADUser/Get-ADPrincipalGroupMembership) to export membership snapshots; for Azure AD use Microsoft Graph API or the PnP PowerShell modules to enumerate assignments and roles. If you lack premium IdP features, consider combining simple automation (scheduled exports to CSV + emailed review prompts) with strict procedural controls (manager sign-off). For privileged accounts, implement just-in-time (JIT) elevation via a PAM solution or use break-glass accounts with separate controls and monitoring.
Risks of not implementing Identity and Access Reviews
Failure to perform Control 2-2-4 reviews increases the risk of unauthorized access, data exfiltration, and lateral movement. In a small-business example, an ex-employee with an unrevoked cloud admin account could deploy ransomware or export customer data. From a Compliance Framework perspective, lack of review evidence will likely produce non-conformities during an assessment, leading to remediation orders, reputational damage, and potential fines depending on regulatory overlap.
Compliance tips and best practices
Adopt least-privilege by default, enforce MFA for all administrative and remote access, and use role-based groups to simplify reviews (review group membership rather than dozens of individual permissions). Automate where possible: schedule exports, enable access certifications in your IdP, and send automated reminders to reviewers. Maintain a naming convention for service accounts (svc-*, app-*) and separate human from non-human accounts so reviewers can make decisions quickly. Finally, test your review process — run a mock audit and track review completion time and remediation SLAs.
Summary: Implementing Control 2-2-4 Identity and Access Reviews under the Compliance Framework is achievable for small businesses with a disciplined checklist: inventory accounts, classify and set cadences, appoint owners, execute reviews, remediate quickly, and retain evidence. Combining lightweight automation, clear owner responsibilities, and enforced privileged controls will satisfy compliance requirements and materially reduce identity-related risk.
