How to rollout access reviews

Rolling out access reviews in Microsoft 365 requires more than following a checklist. Before learning how to do an access review rollout effectively, it might be prudent to walk you through the common pitfalls, their real-world examples, and compliance expectations that shape a successful rollout.

Most failed implementations don’t fail because the process is complicated, they fail because the groundwork wasn’t set. The sections below outline the mistakes to avoid, examples of what can go wrong, and the compliance frameworks that make access reviews a non-negotiable governance requirement.

Common mistakes to avoid

  • Allowing workspaces to remain ownerless.
  • Assuming sensitivity labels are always correctly applied.
  • Ignoring shadow users created through sharing links.
  • Letting externals persist indefinitely.
  • Treating reviews as one-off cleanups rather than recurring governance.

Real-world examples

Here are a few quick examples that help paint the picture of how easily risks can compile:

  1. An HR site was initially shared broadly for collaboration. Years later, payroll spreadsheets were added without realizing the exposure.
  2. A marketing Team retained over 50 external accounts two years after the campaign ended.
  3. A finance workspace mislabeled as ‘General’ was discovered during a review to contain highly sensitive data. It was reclassified as Highly Confidential, with access locked down.

Compliance alignment

ISO 27001 and SOC2 explicitly require periodic access rights reviews. GDPR obligates organizations to minimize unnecessary access to personal data. NIS2 emphasizes systematic identity and access management for critical infrastructure.

Access Reviews provide the documented evidence needed to demonstrate compliance with these frameworks, turning what could be an audit liability into an audit strength.  

How to roll out access reviews

Organizations new to Access Reviews should start small. Begin with the most sensitive sites — HR, Finance, Legal — and run quarterly reviews. As the process matures, expand reviews across all Teams and SharePoint sites. Automate where possible using Microsoft Entra ID or Syskit Point to generate reports and reminders.

Ensure reviews are documented, creating an audit trail. Over time, Access Reviews should become part of the organizational rhythm, no different than financial reconciliations or system backups.