The door slammed shut on blind access

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.

Compliance means knowing exactly where every non-human identity lives, what it can touch, and how to shut it down fast. Static credentials hard-coded in scripts or embedded in images are now liability and risk. Rotate them automatically. Use short-lived tokens. Apply multi-factor authentication where possible, even for automated systems.

Security teams must integrate non-human identity management into their threat modeling and incident response. Real visibility comes from tools that map these identities across repos, clusters, and third-party services. Without that inventory, audits under NYDFS will expose gaps—gaps that attackers will fill before you patch them.

Non-human identities can be the quietest breach point you have. Treat them as first-class citizens in your security program. Audit them as you do human users. Kill unused accounts. Monitor the active ones.

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