Under the NYDFS Cybersecurity Regulation, non-human identities—service accounts, API keys, machine-to-machine credentials—are now squarely in scope. They are no longer invisible actors hidden in pipelines and backend systems. Regulators expect you to treat them as you would any high-risk user.
Non-human identities often hold broad privileges. They authenticate to databases, orchestrate CI/CD workflows, and execute automated tasks without human intervention. If left unmanaged, they become attack vectors that bypass standard access controls. Under NYDFS Part 500, the mandate is clear: inventory them, assign owners, enforce least privilege, rotate credentials, and monitor usage in real time.
The regulation’s text makes no distinction between a human and a bot when it comes to potential damage. Section 500.7 demands robust access controls. Section 500.14 requires training and awareness—yes, for developers and admins responsible for those service accounts. Section 500.15 pushes boundary monitoring to catch unusual behavior, whether it’s a compromised engineer’s account or a rogue container key.