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Microsoft Entra access reviews for US businesses

Permissions only ever go one direction. A review is the single mechanism that ever pulls any of them back.

Reviews recertify who is in which group, who is assigned to which application and who holds which role, on a schedule, with the person who owns the resource making the call instead of IT guessing at it. Too much access causes two separate problems: it makes a compromise worse, and it produces an audit finding in its own right, because it demonstrates that nobody is controlling access. User access review turns up in every SOC 2 examination and every HIPAA assessment without fail.

Book an access review design sessionSee what can be reviewed
Microsoft Entra access reviews for US organizations
  • Weekly to annuallyRecurring review frequencies
  • Owner or selfReviewers can be either, or named
  • Groups, apps, rolesPlus access packages and Azure roles
  • Governance licenseSome capabilities work with P2
What you can review

Six review types, created in four different places.

Here is the thing that trips people up. Where you go to create a review depends entirely on what is being reviewed, and the reviewer sees a different screen depending on the type. Groups and applications are reviewed in the Access panel. Roles are reviewed in the admin center. Nothing in the portal navigation tells you this.

Security group and Microsoft 365 group membership

Set up either in access reviews or from the groups area itself. The reviewer can be a named person, the group owner, or the members reviewing their own membership. They work in the Access panel. This is the highest volume type in almost every company, and it is where handing the decision to the group owner rather than keeping it with IT changes the result most, for the simple reason that the owner knows who belongs and IT does not.

Enterprise application assignments

Set up from access reviews or from the enterprise applications area, with named reviewers or self-review, again through the Access panel. Business critical applications get called out specifically, on the basis that a compliance process may well require people to reconfirm and to write down why they still need access. It is that written reason an auditor will ask to see.

Microsoft Entra role assignments

These are set up in Privileged Identity Management rather than in access reviews, and the reviewer works in the admin center. The reason to run one is put plainly: find out how many people hold administrative access, how many of them are Global Administrators, and whether any guest or partner account was ever removed after the task it was invited for.

Azure resource role assignments

Also set up in Privileged Identity Management and also reviewed in the admin center, with User Access Administrator given as the worked example. These are the assignments that pile up quietly over the course of a project and then sit there for years, because nobody was ever given the cleanup and the project team has long since dispersed.

Access package assignments

Set up within entitlement management, with the reviewer being a named person, the members of a group, or the assignee reviewing their own, all in the Access panel. Where entitlement management is already running, this is the obvious place to recertify, because the package already carries the business context that makes the question answerable.

Access rights from custom data resources, in preview

Managers do the reviewing, set up in access reviews and answered in the Access panel. This is still listed as a preview capability. Reviewing by manager is a genuinely different model from reviewing by resource owner, and it suits companies where access decisions really do sit with line management rather than with whoever owns the system.

Recurrence, which is what makes it a control

Reviews can recur weekly, monthly, quarterly or annually, with the reviewer notified when each round opens and given recommendations alongside the approve and deny buttons. A review run once is a cleanup exercise. A review that recurs is a control. Only the second one survives the audit question about how you know today that access is still appropriate.

Guest access, which nothing else cleans up

The gap is stated bluntly. Access for your own staff can be automated through lifecycle workflows driven by HR data. Access for invited guests cannot. Where a group opens business sensitive content to guests, confirming those guests still have a genuine business need falls to the group owner. In practice, reviewing guests is where the first cycle finds by far the most.

Check this before you plan

P2 gets you part of this. It does not get you the useful part.

The feature calls for either Entra ID Governance or the Entra Suite, with the caveat that some of what sits inside it will run on a P2 subscription.

  • The published caveat is precise about where P2 stops. Reviewing inactive accounts, running a review with affiliation recommendations comparing a person against their peers in a group, and reviewing several resources together, still in preview, all need a Governance license.
  • Those three happen to be exactly what makes reviewing efficient once there is any volume involved. Reviewing dormant accounts is the highest yielding first campaign in almost every company, and the affiliation recommendations are the thing that stops a reviewer approving the whole list without reading it.
  • Build a plan on the assumption that P2 covers everything and you end up with the least useful version of the feature, with the gap only appearing at the moment somebody sits down to configure the one review that would genuinely have found something.
  • Which license the tenant genuinely holds, and which of the reviews you want fall inside it, gets established before a single design decision is made. It is a fifteen minute check and it regularly changes the shape of the whole program.
Ask us to check your entitlement
How we approach it

Four things that stop reviews becoming a rubber stamp.

These fail in one particular way, and it is always the same. Reviewers approve the lot, the numbers never move, and after the second cycle somebody quietly stops scheduling them. Everything below exists to stop that happening.

We fix group ownership before we schedule anything

Sending the review to the group owner is the highest impact decision in the whole design, and it collapses instantly in an estate where half the groups have no owner or list somebody who left in 2022. Establishing genuine ownership is dull work and it comes first, because a review sent to nobody either expires unanswered or gets approved by default.

Start where the risk sits, not where the numbers are

Too many people holding privileged roles is named as the first reason to run one, and that is the right instinct. How many Global Administrators there are, which partner and guest accounts survived some administrative task nobody remembers, and who holds User Access Administrator over Azure resources. Short list, high yield. Open with three hundred distribution groups instead and you have simply trained everybody to click approve.

We treat guest review as its own campaign

Lifecycle workflows driven by HR data will automate access for your own staff and will not touch invited guests, and confirming a guest still has a genuine business need falls squarely to the group owner. Guests are nearly always the richest first cycle, and they are also the single finding an auditor is most likely to write up.

We design what happens after the review, first

A denial that removes nothing is theater. Silence that counts as approval is worse than that, because it manufactures evidence claiming the access was reviewed when nobody looked at it. What happens on apply, what happens when somebody does not respond, and how a person appeals all get decided before the first campaign, because those three answers determine whether any of this changes anything.

Where this matters most

Six US situations where reviews earn their place immediately.

The problem is framed in language every American compliance function will recognize. Excessive access makes compromises worse, and it produces audit findings in its own right, because it is evidence that nobody is controlling access.

A regulated financial firm that has just been written up for this

User access review comes up in every SOC 2 examination, in GLBA and FTC Safeguards programs, and in internal audit. Running these on a schedule produces the evidence as a side effect rather than as an annual project, with a record of who reviewed what and on which date. That answers the question considerably better than a spreadsheet with a signature at the bottom of it.

A group that grew by acquisition

Every acquisition arrives with groups whose purpose was never written down and applications whose assignment lists nobody has opened in years. Reviews delegated to owners inside each acquired business surface all of that far faster than a central team trying to reverse engineer it, and they carry on working long after the integration project has closed.

A professional services firm working with external partners

A guest joins for one project and stays indefinitely, because nothing exists to remove them. The responsibility for confirming they still have a genuine business need for business sensitive content sits with the group owner. In a firm where client work is organized into groups and Teams, that one review type usually strips out more standing access than every other type combined.

An operator with contractors and seasonal staff

Access handed out for a plant shutdown, a commissioning window or a seasonal peak almost never gets revoked on time, because whoever granted it has moved on to the next thing before the window closes. Monthly or quarterly reviews aimed at exactly the groups carrying that access shut the loop without anybody having to remember.

A healthcare organization with clinical system access

A clinical system is precisely what is meant by a business critical application where the compliance process may require somebody to reconfirm and justify continued access, and periodic review of who can reach electronic protected health information is exactly what a HIPAA assessor turns up expecting to see. Demanding a written reason rather than a yes or no changes the quality of what comes back, and it gives the auditor something to actually read.

An education institution with high annual turnover

Students, researchers, visiting academics and short contracts generate more access churn in a single year than a corporate estate manages in five. Reviews timed to the academic calendar, using self-review where that is defensible and owner review wherever the resource is sensitive, keep the place honest without funding a permanent cleanup team.

Three positions

How US organizations recertify access today.

The middle column is overwhelmingly the most common. A spreadsheet goes out to managers once a year, most of it comes back approved by people who never read it, and the resulting evidence satisfies the auditor while changing nothing whatsoever.
Group membership recertified
Recurring Entra reviewsYes
Annual spreadsheet exercisePartly
No recertificationNo
Application assignments recertified
Recurring Entra reviewsYes
Annual spreadsheet exerciseRarely
No recertificationNo
Privileged roles recertified
Recurring Entra reviewsYes
Annual spreadsheet exerciseSometimes
No recertificationNo
Reviewed by the person who knows
Recurring Entra reviewsYes
Annual spreadsheet exerciseNo
No recertificationNot applicable
Denials actually remove access
Recurring Entra reviewsYes
Annual spreadsheet exerciseSometimes
No recertificationNot applicable
Guests reviewed separately
Recurring Entra reviewsYes
Annual spreadsheet exerciseNo
No recertificationNo
Recurs without anyone starting it
Recurring Entra reviewsYes
Annual spreadsheet exerciseNo
No recertificationNo
Evidence produced automatically
Recurring Entra reviewsYes
Annual spreadsheet exerciseManually
No recertificationNo
Recommendations assist the reviewer
Recurring Entra reviewsYes
Annual spreadsheet exerciseNo
No recertificationNo
Effort per cycle
Recurring Entra reviewsLow
Annual spreadsheet exerciseHigh
No recertificationNone
Feature
Recurring Entra reviews
Annual spreadsheet exercise
No recertification
Group membership recertified
YesPartlyNo
Application assignments recertified
YesRarelyNo
Privileged roles recertified
YesSometimesNo
Reviewed by the person who knows
YesNoNot applicable
Denials actually remove access
YesSometimesNot applicable
Guests reviewed separately
YesNoNo
Recurs without anyone starting it
YesNoNo
Evidence produced automatically
YesManuallyNo
Recommendations assist the reviewer
YesNoNo
Effort per cycle
LowHighNone
Where each review lives

What you are reviewing decides where you create it.

The left of this comes from the published table. The right hand column is what it means in practice, and that part is ours.

Access being reviewed

Security group members

Created in
Access reviews, or Microsoft Entra groups
Who can review
Specified reviewers, group owners, or self-review
Practical consequence
Handing the decision to the owner is the one change that improves quality most

Access being reviewed

Microsoft 365 group members

Created in
Access reviews, or Microsoft Entra groups
Who can review
Specified reviewers, group owners, or self-review
Practical consequence
This also decides the Team, the SharePoint site and everything else hanging off that group

Access being reviewed

Assigned to a connected app

Created in
Access reviews, or Microsoft Entra enterprise apps
Who can review
Specified reviewers, or self-review
Practical consequence
Where to insist on a written reason for anything business critical

Access being reviewed

Microsoft Entra role

Created in
Privileged Identity Management
Who can review
Specified reviewers, or self-review
Practical consequence
The reviewer is in the admin center rather than the Access panel, so brief them separately

Access being reviewed

Azure resource role

Created in
Privileged Identity Management
Who can review
Specified reviewers, or self-review
Practical consequence
Where leftover project access hides, User Access Administrator especially

Access being reviewed

Access package assignments

Created in
Entitlement management
Who can review
Specified reviewers, group members, or self-review
Practical consequence
The package already carries the business context, which is what makes the question answerable

Access being reviewed

Custom data resources, in preview

Created in
Access reviews
Who can review
Managers
Practical consequence
Managers decide here rather than resource owners
Access being reviewedCreated inWho can reviewPractical consequence
Security group membersAccess reviews, or Microsoft Entra groupsSpecified reviewers, group owners, or self-reviewHanding the decision to the owner is the one change that improves quality most
Microsoft 365 group membersAccess reviews, or Microsoft Entra groupsSpecified reviewers, group owners, or self-reviewThis also decides the Team, the SharePoint site and everything else hanging off that group
Assigned to a connected appAccess reviews, or Microsoft Entra enterprise appsSpecified reviewers, or self-reviewWhere to insist on a written reason for anything business critical
Microsoft Entra rolePrivileged Identity ManagementSpecified reviewers, or self-reviewThe reviewer is in the admin center rather than the Access panel, so brief them separately
Azure resource rolePrivileged Identity ManagementSpecified reviewers, or self-reviewWhere leftover project access hides, User Access Administrator especially
Access package assignmentsEntitlement managementSpecified reviewers, group members, or self-reviewThe package already carries the business context, which is what makes the question answerable
Custom data resources, in previewAccess reviewsManagersManagers decide here rather than resource owners
How an engagement runs

Five steps, and everything you need to know comes out of the first cycle.

Four to six weeks to something genuinely running, all delivered remotely. The design itself is quick. Working out who owns each group, and agreeing what a denial actually causes, are the parts that consume real calendar time.
  1. 1

    Confirm entitlement and scope

    Which license the tenant actually holds, given that this needs Governance or the Entra Suite while parts of it will run on P2, and that reviewing dormant accounts, using affiliation recommendations and reviewing several resources at once all specifically require Governance. Then which groups, applications and roles are in scope, and the order they get done in.

  2. 2

    Fix ownership and reviewer assignment

    Every group in scope gets a genuine owner or a named reviewer, with a written fallback for the day that person resigns. Where self-review is going to be used, we settle in advance what makes it defensible. This single step decides whether any of the reviews get answered at all.

  3. 3

    Design the review types in the right places

    Group and application reviews are built in access reviews or in the relevant area, directory role and Azure resource role reviews in Privileged Identity Management, and package reviews in entitlement management. Reviewers are told in advance which screen they will be looking at, because role reviews land in the admin center rather than the Access panel and an unbriefed reviewer simply does not respond.

  4. 4

    Run the first cycle deliberately smaller than you want

    Privileged roles and guests go first, because that is where the yield sits and where a badly designed process reveals itself within days. We watch how many people respond, how many appeal and how many denials come back, then adjust the scope, the wording and the frequency before widening it to anything else.

  5. 5

    Make it recurring and hand it over

    Each scope gets its own frequency somewhere between weekly and annual, reviewers hear about it when a cycle opens, evidence accumulates as a side effect, and one named person owns the program. Leave that last part out and the schedule keeps running long after anybody stopped paying attention to it.

Straight answers

What US organizations ask about Entra access reviews.

Your staff need either Entra ID Governance or the Entra Suite, though parts of the feature will run on a P2 subscription. Three things are then named as requiring Governance specifically: reviewing dormant accounts, running a review with affiliation recommendations that compare somebody against their peers, and reviewing several resources together, which is still in preview. Rather than assume anything, we look at your tenant.

Members of security groups, members of Microsoft 365 groups, people assigned to a connected application, directory role assignments, Azure resource role assignments, package assignments, and in preview access rights coming from custom data sources. The detail that matters is that each of those is created somewhere different, so a program covering the lot touches access reviews, the groups area, enterprise applications, Privileged Identity Management and entitlement management.

That varies by type. Group membership can go to named reviewers, to the group owner or to the members themselves. Applications and roles allow named reviewers or self-review. Packages can go to the members of a group. The custom data preview uses managers. In practice, group owners make the best decisions, named reviewers respond fastest, and self-review holds up wherever the person can be held to whatever they answered.

Weekly, monthly, quarterly or annual are all supported, with reviewers notified each time a cycle opens. Our usual recommendation is privileged roles no less often than quarterly, guests quarterly, business critical applications twice a year, and ordinary group membership once a year. Putting everything on a monthly cycle is the quickest possible way to teach reviewers to approve without reading.

Yes. Reviewers approve or deny through a straightforward interface with recommendations alongside. One of those categories, comparing a person against their peers in the group, explicitly needs a Governance license, as does reviewing dormant accounts. Those two happen to be the recommendations that improve decision quality most, which is exactly why the licensing question is not a footnote.

In Privileged Identity Management rather than in access reviews, with the reviewer working in the admin center instead of the Access panel. That holds for directory roles such as Global Administrator and for Azure resource roles such as User Access Administrator alike. Brief those reviewers separately, because what they see looks nothing like what their colleagues are describing.

This is dealt with head on. Access for your own staff can be automated through lifecycle workflows fed by HR data, and invited guests fall entirely outside that. Where a group opens business sensitive content to guests, confirming they still have a genuine business need sits with the group owner. Reviewing guests is normally the richest first campaign we run anywhere.

The guidance answers this itself. Rules can drive dynamic membership on security groups and Microsoft 365 groups, but the data those rules depend on may not live in the directory at all, and there are entirely legitimate exceptions, such as somebody who has left a team and still needs access for another month to train whoever replaced them. Reviews cover the cases no rule can express, and in most companies that set is considerably larger than anybody expects.

It is a setting on each individual review, and it is the most consequential decision in the entire design. We choose it deliberately rather than accepting whatever the default happens to be, because silence that counts as approval manufactures evidence claiming the access was reviewed when in fact nobody opened it. Settling that before the first cycle avoids a genuinely uncomfortable conversation with an auditor eighteen months later.

It produces exactly the artifact those processes ask for: a record of who reviewed which access, when, what they decided, and what changed as a result, recurring on a defined schedule. Your auditor or assessor owns the judgment about sufficiency and scope, and we configure the reviews so the evidence exists as a by-product of the control operating rather than as a document someone assembles the week before fieldwork.

In the opening cycle, usually yes and often by a lot, guests and privileged roles above all. After that the value moves from removing access to preventing it, because permissions stop piling up once owners understand somebody will ask about them. Companies that see no reduction at all are almost invariably the ones where a denial does not actually remove anything.

Four to six weeks to something genuinely running on an estate of ordinary size. Building the reviews takes days. What eats the calendar is working out who really owns each group, agreeing what a denial and a silence each cause, and briefing reviewers on a screen most of them have never laid eyes on. Skip any one of those three and you get a program that runs on schedule and achieves nothing at all.
Designing the program

Fifteen decisions that determine whether reviews work.

The first block is scope, the second is who does the reviewing, the third is what happens once they have. Programs that fail almost always fail on the third, because nobody settled beforehand what a denial actually causes.

Scope

  • Which groups genuinely need reviewing?
    Reviewing everything trains reviewers to click approve.
  • Which applications are business critical?
    Those are the ones worth a justification field.
  • Are privileged roles in the first wave?
    Microsoft names this trigger first.
  • Do you have Azure resource roles to review?
    They are created in PIM, not access reviews.
  • Are guests scoped separately?
    Lifecycle workflows do not cover them.

Reviewers

  • Group owner or named reviewer?
    Owners know more, named reviewers respond faster.
  • Is self-review appropriate anywhere?
    Self-review works only where somebody can be held to the answer they gave.
  • Do your groups have real owners?
    Plenty of groups have no owner at all, and that gets fixed first.
  • Who reviews when the owner has left?
    Decide the fallback before the first cycle.
  • Are reviewers trained on which portal?
    Role reviews use the admin center.

Afterwards

  • What happens on a denial?
    Automatic removal or a manual queue.
  • What happens when nobody responds?
    Configure it deliberately, do not inherit it.
  • Who handles the appeals?
    There will be appeals in cycle one.
  • Where is the evidence kept?
    This is what the auditor asks for.
  • What frequency for each scope?
    Weekly through annually is supported.
Related reading

The pages around this one.

Entra ID Governance

The suite these reviews belong to, and the license the fuller capabilities require.

Learn more

Privileged Identity Management

Where the directory role and Azure resource role reviews actually get built.

Learn more

Privileged access audit

The point-in-time audit of who holds administrative access across your estate.

Learn more
Next step

Begin with privileged roles and with guests. Each takes about a week, and each turns something up.

Privileged role counts and stale guest access are the two places a first review cycle finds the most, and the same review runs again next quarter without anyone starting it. That recurrence is what turns a cleanup into a control.

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