Access governance failures from unclear RBAC ABAC models

Access governance is what turns identity and access management from a collection of ad hoc permissions into a controlled, auditable system.
When roles, attributes and policies are not clearly defined, organizations end up with toxic combinations of access, dormant accounts, and
regulatory findings that could have been avoided. Starting with a simple but well-structured RBAC/ABAC policy and matrix helps bring order,
consistency and transparency to who can do what, where and under which conditions.

Understanding access governance and the roles of RBAC and ABAC

Access governance brings together processes, policies and technical controls to ensure that access to systems and data is appropriate,
justified and monitored over time. It goes beyond authentication and focuses on authorization: which users, in which roles, may perform
which actions on which resources, under which circumstances. This is where Role-Based Access Control (RBAC) and Attribute-Based Access
Control (ABAC) come into play as core models.

RBAC organizes permissions into roles that map to job functions, such as “HR analyst” or “Accounts payable manager”.
Users receive permissions by being assigned to one or more roles. ABAC, in turn, evaluates policies based on attributes of the user,
resource, action and context, such as location, time of day, device health, data sensitivity or employment status. In modern environments,
access governance rarely chooses one or the other; instead, it combines RBAC for clarity and ABAC for fine-grained conditions.

Why access governance matters for risk and compliance

Regulations and frameworks such as GDPR, HIPAA, SOX, PCI DSS and ISO 27001 expect organizations to enforce least privilege, separation of
duties and proper lifecycle management of user accounts. Access governance is the mechanism that links these expectations to daily operations.
It ensures that high-risk systems (such as payments, HR, clinical or customer data platforms) are not exposed to unnecessary or conflicting
access.

From a practical perspective, a robust RBAC/ABAC design makes audits smoother: it is easier to demonstrate that privileged access is limited,
justified and periodically reviewed. It also reduces operational friction: instead of granting custom permissions every time someone joins a
team, the organization can assign a predefined role and rely on attribute-based policies to adapt behavior to context.

Policy foundations for RBAC and ABAC in access governance

A starter access governance policy should clearly define objectives, scope, responsibilities and the chosen control model. It must state
that access is granted based on roles and attributes aligned with business functions and risk. The policy should also define who owns which
applications (business owners), who administers access (IT or security teams), and how often access must be reviewed.

For RBAC, the policy should require that each role has a documented purpose, list of entitlements, and associated business owner. For ABAC,
it should require that attributes and their sources of truth (HR system, directory, device management, location data) are documented and
that policies using these attributes are reviewed when business or regulatory requirements change.

The policy should also emphasize segregation of duties: certain combinations of roles must be prohibited (for example, a user should not be
able to both create and approve payments above a given threshold). ABAC can support such constraints by evaluating contextual attributes
(amount, transaction type, business unit) in real time.

Building a starter access governance policy: practical steps

A practical way to start is to select a small set of high-impact applications and design a focused RBAC/ABAC policy around them. Instead of
trying to model the entire organization at once, the team chooses two or three critical systems and creates a pilot governance scope. This
allows faster learning and visible benefits without overwhelming stakeholders.

The following steps provide a simple path to a starter policy:

• Identify the systems and data in scope (for example, HR, finance, customer data platform).
• Document key business processes linked to these systems (hiring, termination, payroll, refunds, escalations).
• Define business roles that reflect these processes (HR recruiter, payroll specialist, refund approver).
• Map permissions required for each role (read, create, approve, export, administer).
• Identify relevant attributes (employment status, department, region, device compliance, data classification).
• Write ABAC rules that constrain or refine role permissions based on these attributes.
• Formalize approval workflows and periodic reviews for each system.

Examples of RBAC and ABAC working together

Consider an HR application. RBAC defines roles such as “HR recruiter” and “HR administrator” with different permissions. ABAC adds
conditions such as allowing a recruiter to view only candidates associated with their region and only during active recruitment campaigns.
If the recruiter moves to another region, attribute changes automatically adjust what they can see.

In a finance system, RBAC may assign a “payment initiator” role to certain users. ABAC can then restrict payment creation above
a given amount to business hours, from managed devices, and only for suppliers with a valid onboarding status. This reduces risk without
creating an excessive number of static roles.

For a customer service platform, RBAC might provide “support agent” and “case supervisor” roles. ABAC can layer on data classification
and jurisdiction attributes, ensuring that only agents in the correct region can access sensitive records, and that cases tagged as
high-risk require supervisor approval before being closed.

Designing a practical RBAC and ABAC starter matrix

A simple access matrix provides a visual summary of who can do what. At minimum, the matrix lists roles on one axis and key actions or
entitlements on the other. For ABAC, additional columns or inline notes indicate which attributes or conditions apply to each combination.

An illustrative matrix for an HR system could be drafted as follows:

• HR viewer — view employee profiles; view organization chart; no export; read-only; subject to region attribute.
• HR editor — update employee records; initiate onboarding; initiate termination; changes limited to assigned department.
• Payroll specialist — manage payroll data; generate payroll runs; export reports for finance; higher level logging required.
• HR administrator — configure system; manage roles and attributes; access all records; strong authentication required.

ABAC then refines the matrix. For example, a policy may say: “HR editors can modify records only when the employee status is active and the
editor’s department attribute matches the employee’s department.” Another rule may state: “Payroll specialists may export data only when
the classification attribute is set to ‘aggregated’ or ‘masked’.”

It is helpful to maintain the matrix as a living document under change control. When new systems or attributes are introduced, the matrix
is updated and aligned with the overall access governance policy. This document becomes a key reference during onboarding, role changes
and audits.

Technical considerations, tools and ongoing updates

From a technical perspective, implementing RBAC and ABAC requires reliable identity data, consistent attribute sources and integration
with applications. Directory services, identity governance and administration (IGA) platforms, and policy decision points often play a
central role. If attribute quality is poor or roles are not kept up to date, even the best policy on paper will fail in practice.

Periodic recertification campaigns are essential. Business owners should receive clear, role-based views of who has access to their
systems and be able to approve, revoke or modify access without interpreting low-level permissions. Logs and reports must capture which
policies were evaluated and why access was granted or denied.

Over time, organizations should review their role catalog and ABAC rules for redundancy and complexity. New regulations, reorganizations
or acquisitions can quickly make old assumptions obsolete. A lightweight governance process, with a small steering group representing
security, IT and business owners, helps keep the RBAC/ABAC model aligned with reality.

Common mistakes in RBAC and ABAC access governance

• Defining roles too granularly and creating hundreds of barely used variants.
• Relying only on manual approvals without documenting clear policies or conditions.
• Ignoring attribute quality, leading to inconsistent or incorrect policy decisions.
• Failing to involve business owners in designing and reviewing roles and rules.
• Allowing broad exceptions that bypass the RBAC/ABAC model instead of improving it.
• Not revisiting the matrix after major organizational or regulatory changes.

Conclusion: starting small while thinking long term

A starter access governance policy and matrix based on RBAC and ABAC does not need to be perfect to deliver value. By focusing on a few
critical systems, defining business-aligned roles, and introducing attributes where they clearly reduce risk, organizations can quickly
improve visibility and control over access. The key is to treat the model as a living framework that evolves with the business.

Over time, this disciplined approach to RBAC and ABAC transforms access governance from a reactive set of approvals into a proactive,
auditable and business-driven control that supports both security and productivity.

Quick guide

This quick guide summarizes the core decisions and actions required to design an access governance model based on RBAC and ABAC.
It is intended as a practical starting point for organizations that want to move away from ad hoc permissions and towards a
documented, auditable policy and matrix.

• Define the scope: select 2–3 critical systems for the initial governance wave.
• Identify business processes and owners for each system in scope.
• Design business-aligned roles (RBAC) that map to job functions, not individuals.
• List entitlements for each role in clear, non-technical language where possible.
• Choose key attributes (ABAC) that refine access: department, region, employment status, device, data sensitivity.
• Write simple, testable policies combining roles and attributes into conditions and rules.
• Document a starter matrix showing roles, actions and attributes on a single page for each system.
• Implement approvals, recertification cycles and logging aligned with the matrix.
• Review the model after every major business or regulatory change.

FAQ

What is the main difference between RBAC and ABAC in access governance?

RBAC groups permissions into roles aligned with job functions, while ABAC applies dynamic rules based on attributes such
as department, region, device or data classification. RBAC provides clarity and stability; ABAC adds context and fine-grained
control without creating hundreds of static roles.

When should an organization start using ABAC instead of only RBAC?

ABAC becomes particularly useful when roles alone cannot express risk-sensitive conditions, such as time of access, device
compliance, location or data sensitivity. Organizations typically add ABAC after they have a basic role model and need to
handle exceptions and contextual requirements without multiplying roles.

Who should own the RBAC and ABAC policy and matrix?

The formal policy is usually owned by information security or risk management, but each application and process in scope
must have a business owner. These owners are responsible for validating roles, approving access and participating in
periodic recertification campaigns based on the matrix.

How detailed should a starter access matrix be?

A starter matrix should be detailed enough to show which roles can perform which key actions and which attributes or
conditions apply, but simple enough to fit on one or two pages per system. It is better to begin with a concise, understandable
matrix and refine it over time than to produce a complex model that business stakeholders cannot read.

How often should roles and ABAC rules be reviewed?

Roles and rules should be reviewed at least annually, and whenever there are significant organizational, regulatory or
technology changes. High-risk systems may require more frequent recertification cycles, for example every quarter or every
six months, depending on internal policy.

Can access governance be effective without an identity governance tool?

A clear RBAC/ABAC policy and matrix can be defined and used even without a dedicated tool, but automation significantly
improves consistency, scalability and auditability. In smaller environments, spreadsheets and documented workflows may be
sufficient at first, but over time a specialized platform tends to become necessary.

How should exceptions to the RBAC and ABAC model be handled?

Exceptions should be formally requested, time-limited and approved by the appropriate business owner. They must be recorded
and periodically reviewed. If many similar exceptions arise, this is a signal that the underlying role or attribute model
should be adjusted rather than relying on permanent deviations.

Normative and governance framework for RBAC and ABAC

A structured access governance program must be anchored in internal policies and external obligations. The normative and
governance framework clarifies which regulations apply, which internal standards must be followed, and how RBAC and ABAC
are used to implement these requirements in practice.

Typically, the framework references information security policy, data protection rules, sector-specific regulations and
contractual obligations. It also defines decision-making bodies, such as an identity governance committee, and the role of
internal audit when evaluating the effectiveness of access controls.

The framework should also address cross-border considerations, such as access to data stored in different jurisdictions and
limitations on remote access by users in certain countries. ABAC can support these restrictions by evaluating location and
data residency attributes in real time.

By combining these elements, the framework makes it possible to demonstrate to regulators, customers and auditors that
access decisions are not arbitrary, but grounded in documented policies and consistently enforced models.

Final considerations

Establishing a starter RBAC and ABAC policy and matrix is a practical way to bring structure and transparency to access
governance. Even a relatively simple model can significantly reduce unmanaged permissions and make approvals, recertifications
and audits more predictable.

Over time, the model should evolve with the organization. New applications, new regulatory requirements and new business
processes may justify additional roles, attributes or constraints. The most effective programs treat the matrix as a living
instrument, updated under change control rather than a one-off project artifact.

The information presented in this text has a general and educational character and does not replace tailored advice from a
qualified lawyer, security professional or compliance specialist. Specific access governance decisions should always be taken
with reference to applicable laws, internal policies and expert guidance.