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An identity provider (IdP) login log shows that an identity authenticated and when. It does not, by itself, show which permissions that identity held, whether those permissions were still appropriate, who reviewed them, or whether any changes were completed. Authentication monitoring and access certification are different control activities.
What login logs establish—and what they do not
A sign-in record can help answer: “Did this identity authenticate, and when?” That is useful evidence for authentication monitoring. An access review asks a different set of questions: “What could this identity access? Is that access still appropriate for its responsibilities? Who decided? What changed as a result?”
A collection of sign-in events may support security monitoring while leaving the entitlement-review decision and its approval trail undocumented. That distinction does not mean an auditor will always reject login logs; evidence is assessed in the context of the organization’s control design. But login events alone do not document the review of current permissions.
What an access review should document
A useful review record makes it possible to reconstruct the population considered, the decision made, and the follow-up. Cloud Security Alliance (CSA) IAM-08 shared implementation guidance says to track review outcomes with timestamps and approver IDs.
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- Scope: the identities, systems, roles, and entitlements included in the review.
- Decision: whether each entitlement is retained, modified, or removed, with rationale where access is persistent or elevated.
- Accountability: the reviewer or approver’s identity and the time the decision was completed.
- Remediation: changes arising from the decision, tracked through completion.
CSA’s cloud service provider guidance also calls for audit review guidance to include manual roles and programmatic access, such as service accounts. Review scope should therefore account for non-human identities and access paths where they apply, rather than assuming an employee-only list is complete.
How to run a defensible review
- Define the population. Identify in-scope systems, identities, roles, privileged access, and programmatic identities for the cycle. Confirm that the population reflects actual access, not just a list of recent logins.
- Assign knowledgeable reviewers. Route each review to resource owners or others able to judge whether access fits the person’s or service’s current responsibilities.
- Assess necessity and risk. Ask reviewers to revalidate least privilege and separation-of-duties concerns. Record the rationale for retaining elevated or otherwise sensitive access.
- Capture decisions and timing. Record the reviewer or approver, completion time, and whether access will be retained, modified, or removed.
- Complete and preserve remediation. Track resulting changes through completion and retain the review records and evidence of the changes.
Set review timing without overstating the rule
The AICPA identifies the Trust Services Criteria as the SOC framework; its resource library lists the “2017 Trust Services Criteria (with Revised Points of Focus – 2022).” The criteria help evaluate and report on controls relevant to security, availability, processing integrity, confidentiality, or privacy. See the AICPA SOC resource library and the 2017 Trust Services Criteria resource.
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The specific frequency language often cited here comes from CSA IAM-08, not a universal AICPA or SOC 2 cadence. IAM-08 says to review and revalidate identity access for least privilege and separation of duties at a frequency commensurate with organizational risk tolerance and at least annually, or upon significant changes. CSA’s CSP implementation guidance gives quarterly reviews as an example and describes scheduling based on risk and data or system sensitivity. Treat these as CSA guidance and examples, not a blanket SOC 2 requirement. Read the CSA AICMv1.1 implementation guidelines for cloud service providers.
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When access-review automation helps
For organizations coordinating reviews across many systems, software can help route certifications and preserve evidence. Evaluate capabilities against the work the process must accomplish, rather than assuming that a tool’s presence proves the review is complete.
- Does it cover the relevant systems, identities, and entitlements?
- Can it include both manual roles and programmatic access such as service accounts?
- Does it route reviews to people with enough context and authority to decide?
- Can it identify stale, orphaned, or excessive entitlements?
- Can it reconcile reviewer decisions with actual permissions and track remediation to completion?
- Does it retain exportable records of decisions, timestamps, and approver IDs?
Automation is only as useful as its coverage and evidence trail. A process that collects decisions but does not reconcile them to actual permissions or confirm remediation can still leave important gaps.
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