Pillar 08: AI Identity & Access Control

Control question: Under what identity, and with what access, does the AI act? Surface: See (and the foundation of Do).


Purpose

When an AI accesses systems or takes actions, it does so under some identity with some access. This pillar ensures that identity is distinct, bounded, least-privileged, and revocable, not a human user's standing credentials, and not a broad service account inherited by convenience. It is the difference between an actor you can attribute and constrain, and one you cannot.


Why it matters

The most common, and most dangerous, shortcut in enterprise AI is letting the AI act as the user, with the user's full access. It feels natural (the copilot helps me, so it uses my permissions) and it is a control failure: a probabilistic system now wields a human's entire standing authority, across everything that human can reach, with none of the human's judgment. Agents make it worse: they run continuously, at machine speed, often with credentials broad enough to "just work." Identity is where you decide whether the AI is a bounded actor or an unbounded one.


Control objectives

  • Give each AI use case a distinct non-human identity, separate from the users it serves.
  • Grant that identity least-privilege access scoped to the use case's actual need.
  • Make access promptly and completely revocable.
  • Make every consequential action attributable to the identity and the grant that authorized it.

Requirements

From the Requirements Catalogue:

ID Requirement From Boundary
ACA-08-01 AI acts under a distinct non-human identity, not a user's standing credentials. T4 Verified
ACA-08-02 AI identities are granted least-privilege access scoped to the use case. T4 Verified
ACA-08-03 AI access is revocable promptly and completely. T4 Verified
ACA-08-04 Consequential actions are attributable to the identity and grant that authorized them. T4 Enforced

Key controls

  • Dedicated AI identity: a service/workload identity per use case (or per agent), issued and governed like any other privileged identity, never a shared human login.
  • Scoped, least-privilege access: permissions derived from what the use case actually needs to See and Do, default-deny, reviewed as scope changes.
  • On-behalf-of with constraint: where the AI must act for a user, it does so through a delegation that is narrower than the user's full rights and carries the user's context for attribution, not the user's blanket authority.
  • Short-lived credentials & revocation: prefer short-lived, rotatable credentials; ensure a fast, complete kill path (ties to pillar 16).
  • Attribution: every action carries the AI identity and, where relevant, the human and grant behind it, so monitoring can reconstruct who authorized what.

No standing authority

Per principle 3, authority is granted for a purpose and revocable, not a permanent property of the AI. In practice: prefer just-in-time, scoped grants over broad standing access; treat every high-impact action as exercising a specific grant that can be withdrawn. This is what makes an AI's authority reversible at the identity layer.


Tier guidance

  T1 T2 T3 T4 T5
Distinct AI identity - - Recommended Required Required
Least-privilege scope - Recommended Recommended Required (verified) Required (verified)
Prompt revocation - - - Required (tested) Required (tested)
Per-action attribution - - - Required (enforced) Required (enforced)

Evidence

The AI Identity & Access Control template captures the identity, its scope, the grant model, and the revocation path. Boundary source reaches Verified when access scope is confirmed against the live system, and Enforced when a control point actually blocks out-of-scope access.


Standards crosswalk

Maps to NIST AI RMF Manage, ISO/IEC 42001 access and operational controls, EU AI Act (access governance for high-risk systems), NYDFS Part 500 (access controls, least privilege), and OWASP LLM (excessive agency / insecure access). See mappings/.


Failure modes

  • The AI runs as the user, with the user's full access.
  • A broad service account shared across many use cases, no scoping, no attribution.
  • Long-lived static credentials with no revocation path.
  • An agent whose actions cannot be traced to an identity or a grant.

Next: 09 · Data Boundary Control

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