Bitwarden vs 1Password for CMMC, practice by practice
Published 2026-11-02
Short answer: if the vault will sit inside your CUI boundary, or ever hold CUI, Bitwarden is the one you can run on your own servers, and its encryption module has an active FIPS 140-3 certificate on NIST's list. If the vault holds passwords only, 1Password Business switches on more of the sign-in controls from one policy screen. Neither has a FedRAMP listing.
Either way the vault is in your assessment. The CMMC rule counts "passwords that grant access to the in-scope environment" as Security Protection Data, so the assessor will ask how the vault itself meets multifactor sign-in IA.L2-3.5.3, protected password storage IA.L2-3.5.10, least privilege AC.L2-3.1.5 and traceable audit records AU.L2-3.3.2. We read both vendors' own pages, the FedRAMP Marketplace and NIST's certificate list against those practices. For Keeper and LastPass as well, see password managers for CMMC.
- In force today
- DFARS 252.204-7012 still applies: NIST SP 800-171 Rev 2 on systems that hold covered defense information, cyber incidents reported to DoD within 72 hours, and FedRAMP Moderate or equivalent for any cloud that holds it. DFARS 252.204-7012(b)(2), (c)
- Suspended
- Phase 2, due in November 2026, is suspended for every contractor, whatever its size: contracts are not adding the third-party Level 2 (C3PAO) or Level 3 (DIBCAC) requirements. DoW CIO memo of 2026-07-13, applied by Class Deviation 2026-O0025 Rev 3
- Not yet known
- The outcome of the CMMC Reform Task Force review is not confirmed as of 2026-10-23: no report or rule change has been published. Federal Register search, 2026-10-23
Bitwarden
Self-host it on your own servers, air-gapped if you like, so the vault is assessed with the rest of your systems and the FedRAMP question never comes up. Its module holds an active FIPS 140-3 certificate.
Read the Bitwarden notes1Password
If CUI never goes in, one Business policy screen covers enforced two-factor, password rules, a failed sign-in limit and firewall rules by country or IP.
Read the 1Password notesBitwarden
Bitwarden keeps event logs indefinitely; 1Password keeps 365 days and tells you to send older events to a SIEM.
Read the Bitwarden notes
Bitwarden vs 1Password, practice by practice
Rows inside the boundary are what the CMMC practices ask of a vault that protects your CUI environment; the FedRAMP row binds only if CUI goes in. Rows outside it are conveniences. Vendor words were read on each vendor's own pages, FedRAMP in the Marketplace data and FIPS on NIST's certificate list, all on 2026-11-02; click a vendor name for its notes.
| What the rule asks | Bitwarden | 1Password |
|---|---|---|
| Inside the boundary | ||
| FedRAMP Moderate or higher, needed only if CUI goes into the vendor's cloudDFARS 252.204-7012(b)(2)(ii)(D); 32 CFR 170.19(c)(2) | Not in Marketplace | Not in Marketplace |
| Cryptographic module with an active FIPS 140 certificate on NIST's listSC.L2-3.13.11 | Active cert #5507 (140-3) | No certificate found |
| Admin can require multifactor sign-in for every userIA.L2-3.5.3 | Policy stated | Enforce stated |
| Sign-in through the shop's own identity provider (SSO)IA.L2-3.5.1, IA.L2-3.5.2 | SAML 2.0 or OIDC stated | OIDC stated |
| Admin sets minimum rules for users' own passwordsIA.L2-3.5.7 | Policy stated | Policy stated |
| Shared items limited by group, admin roles kept apartAC.L2-3.1.1, AC.L2-3.1.5 | Roles and collections stated | Custom groups stated |
| Failed sign-in attempts limitedAC.L2-3.1.8 | Not stated | Limit stated |
| Audit log of who did what, exportable or sent to a SIEMAU.L2-3.3.1, AU.L2-3.3.2 | Kept indefinitely; SIEM stated | 365 days; SIEM stated |
| Cut a leaver's access in one stepPS.L2-3.9.2 | Revoke stated | Suspend stated |
| Credentials for scripts and services, not tied to a personIA.L2-3.5.1, IA.L2-3.5.2 | Secrets Manager stated | Service accounts stated |
| Outside the boundary | ||
| Run it on your own servers | Stated | Not stated |
| US data region in the vendor's cloud | US or EU stated | US region stated |
| Allow or deny sign-ins by country or IP address | Not stated | Firewall rules stated |
What the words mean
- MeetsActive cert #5507 (140-3)Policy statedSAML 2.0 or OIDC statedRoles and collections statedKept indefinitely; SIEM statedRevoke statedSecrets Manager statedStatedUS or EU statedEnforce statedOIDC statedCustom groups statedLimit stated365 days; SIEM statedSuspend statedService accounts statedUS region statedFirewall rules stated
- The vendor's own documentation, or the official register, says so. Read on the date shown.
- Check with vendorNot in MarketplaceNot statedNo certificate found
- Not stated in what we read. Ask the vendor in writing before you rely on it.
Is Bitwarden or 1Password FedRAMP authorized?
No. We searched the FedRAMP Marketplace's own data on 2026-11-02 for both names and for AgileBits, the company behind 1Password.
| Vendor | In the Marketplace | What the vendor says |
|---|---|---|
| Bitwarden | No offering of its own. | Actively pursuing FedRAMP Class D (High) for its cloud; agencies self-host it today. Source |
| 1Password | No offering of its own. Named only inside other providers' packages, as a tool they use. | No FedRAMP claim on the security and compliance pages we read. Source |
That is fine for most shops, because the vault only needs FedRAMP if CUI goes into it. A cloud vault that holds nothing but passwords for in-scope systems is a Security Protection Asset: it goes in your SSP and is assessed, but no FedRAMP test applies. The full scoping table is on password managers for CMMC.
FIPS is the other split. NIST SP 800-171 asks for FIPS-validated cryptography "when used to protect the confidentiality of CUI", and an assessment scores encryption without it 3 points down. NIST's list shows certificate #5507, the Bitwarden Cryptographic Module, at FIPS 140-3, Active, Level 1, until 2029-08-26. A search for AgileBits or 1Password finds no certificate. For a vault that holds passwords only, this row matters less; for a self-hosted vault that holds CUI, it is the reason to choose Bitwarden. Running your own server inside an enclave is how a small shop gets there.
Sign-in and access settings, by name
Your SSP has to say how each practice is met, and an assessor will ask to see the setting. Here is what each vendor calls it, so the sentence in your SSP matches the screen. Pick your vendor and print the sheet for the SSP binder. Bitwarden puts these policies and SSO on its Enterprise plan; 1Password puts them on Business.
Password vault settings for the SSP, cuideck.com
| What the practice asks | Bitwarden | 1Password |
|---|---|---|
| Multifactor sign-in for every userIA.L2-3.5.3 | Policy “Require two-step login” (any two-step method) | Two-factor policy set to enforce (authenticator app, security key or Duo) |
| Sign-in through your identity providerIA.L2-3.5.2 | SSO over SAML 2.0 or OIDC, plus the policy “Require single sign-on (SSO)” for non-admin members | Unlock with SSO, OIDC only: Entra ID, Okta, Google, JumpCloud, Duo and others |
| Minimum password rulesIA.L2-3.5.7 | Policy “Master password requirements” | Account password policy: a minimum length or a custom policy |
| Limit failed sign-in attemptsAC.L2-3.1.8 | Not named on the pages we read; set it in your identity provider if you use SSO | Sign-in attempts policy: members are blocked for a while after the set number |
| Least privilegeAC.L2-3.1.5 | Owner, Admin, User and Custom roles; permissions set per collection | Owners, Administrators, Team Members, plus custom groups with custom permissions |
| Access cut when someone leavesPS.L2-3.9.2 | Revoke the member: no access to any organization item until restored | Move their work items, suspend, change the passwords they knew, then remove |
6 practices, both vendors
SSO changes where the evidence lives. With 1Password's Unlock with SSO, members sign in through the identity provider instead of their account password and Secret Key. With Bitwarden, SSO signs members in and a separate decryption step opens the vault: the master password, a trusted device, or Key Connector, which Bitwarden offers only to self-hosted organizations. In both cases, show the assessor the multifactor rule in your identity provider as well as the vault's own policy, because that is where the sign-in happens.
If your Microsoft tenant is GCC High, ask either vendor in writing whether its SSO connects to it before you buy; neither page we read says. Which tenant you are on is laid out in GCC vs GCC High.
Audit logs an assessor can sample
NIST SP 800-171 asks you to "create and retain system audit logs and records to the extent needed to enable the monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity" AU.L2-3.3.1. It sets no number of days. Your SSP names your own retention period, and the vault, or the SIEM it feeds, has to hold it.
| Question | Bitwarden | 1Password |
|---|---|---|
| Plans that have it | Teams and Enterprise | Business |
| How long the vendor keeps it | Indefinitely; view up to 367 days at a time | 365 days |
| Export | CSV for a date range you pick | CSV |
| API | Public API /events endpoint, JSON | Events API: sign-in attempts, item usage, audit events |
| SIEMs named by the vendor | Elastic, Microsoft Sentinel, Panther, Rapid7, Sumo Logic, Splunk, plus MSP tools Huntress and Blumira | Microsoft Sentinel, Splunk, Elastic, Datadog, Sumo Logic, Rapid7, plus MSP tools such as Huntress, Blumira, Blackpoint Cyber and Todyl |
If your SSP says you keep a year or less, either log covers it. If it says longer, Bitwarden's own copy does the job, while 1Password itself advises sending events to a SIEM through its Events Reporting. If an MSP already watches your logs, check its tool against the integration lists above: both name Huntress and Blumira, and 1Password also names Blackpoint Cyber and Todyl. Who runs that watch is covered in CMMC MSPs compared, and the SSP template has the line where the retention period goes.
Bitwarden Secrets Manager vs 1Password service accounts
The identification practice covers more than people: "Identify system users, processes acting on behalf of users, and devices" IA.L2-3.5.1. A nightly backup job, a script that pulls files to the CAM station, a deploy pipeline: each one signs in to something. If its password sits in a text file or under a person's name, the assessor sees a process you cannot trace to an identity. If your shop runs no scripts like these, skip this section.
A separate product beside the password manager, with its own subscriptions on the Free, Teams and Enterprise plans. Scripts sign in as machine accounts with access tokens, and secrets are grouped into projects. Encryption happens on the client side.
It can be self-hosted, so the keys your scripts use can stay on the same servers as a self-hosted vault. Bitwarden names a CLI, an SDK and integrations such as GitHub Actions, Ansible, Jenkins and Terraform.
Bitwarden's overviewA sign-in for 1Password CLI that is not tied to a person. You choose which vaults each one can reach and what it may do, up to 100 of them, and a usage report shows which items each one opened.
They run against 1Password's cloud. 1Password also offers Connect, a server you set up yourself, as the other route for scripts.
1Password's overviewBoth give each script its own identity and a record of what it used, which is what the practice asks. The deciding question is the same as for the vault: if those scripts touch CUI systems and you want nothing in a vendor's cloud, Bitwarden is the one that runs on your own hardware. Put each machine account in your SSP's asset list with the system it signs in to.
The two, one by one
Bitwarden
What it is. An open-source password manager that runs in Bitwarden's cloud (Microsoft Azure, in the US or the EU) or on your own servers in Docker containers, offline and air-gapped included. Its Enterprise plan adds SSO over SAML 2.0 or OIDC and the admin policies; Secrets Manager is a separate subscription for machine credentials. Bitwarden says it is actively pursuing FedRAMP Class D (High) for its cloud.
Who it fits. A shop with an enclave or a server room that wants the vault, and the keys its scripts use, inside its own boundary, assessed with the rest of its systems.
| What the rule asks | What we found |
|---|---|
| Run it on your own servers | Stated |
| Cryptographic module with an active FIPS 140 certificate on NIST's list | Active cert #5507 (140-3) |
| FedRAMP Moderate or higher, needed only if CUI goes into the vendor's cloud | Not in Marketplace |
Checked on bitwarden.com, 2026-11-02
Check with the vendor before you buy.
1Password
What it is. A cloud password manager whose Business plan adds the admin policies (enforced two-factor, account password rules, a failed sign-in limit, firewall rules by country or IP), custom groups, an audit log kept 365 days, an Events API for a SIEM, Unlock with SSO over OIDC, and service accounts for scripts. Accounts on 1Password.com keep their data in the United States. It holds SOC 2 Type 2 and ISO 27001, 27017, 27018 and 27701 certificates.
Who it fits. A shop that keeps passwords and admin keys in the vault, never CUI, and wants the sign-in controls an assessor samples switched on from one policy screen.
| What the rule asks | What we found |
|---|---|
| Admin can require multifactor sign-in for every user | Enforce stated |
| Failed sign-in attempts limited | Limit stated |
| Cryptographic module with an active FIPS 140 certificate on NIST's list | No certificate found |
Checked on support.1password.com, 2026-11-02
Check with the vendor before you buy.
How we read the vendors
Questions small shops ask
Is Bitwarden or 1Password better for CMMC?
It turns on where the vault sits. Inside your boundary, on your own servers, or holding anything that might be CUI: Bitwarden, the one of the two you can self-host, with an active FIPS 140-3 certificate. In the vendor's cloud, holding passwords only: either works, and 1Password Business has more of the sign-in policies on one screen, including a failed sign-in limit. Neither product makes you compliant; your settings and your SSP do.
Is Bitwarden FedRAMP authorized?
Not yet. Bitwarden says it is actively pursuing FedRAMP Class D (High) for its cloud, and it has no listing in the FedRAMP Marketplace. Agencies that need FedRAMP today self-host it, which Bitwarden supports offline and air-gapped.
Is 1Password FIPS 140 validated?
We found no certificate on NIST's validated-modules list under AgileBits or 1Password. That matters if the vault would protect CUI: 3.13.11 asks for FIPS-validated cryptography there, and encryption without it costs 3 points on the assessment. For a vault that holds passwords only, it is a weaker reason to choose.
Can 1Password be self-hosted?
Not on any 1Password page we read. Accounts live in one of three regions: 1Password.com in the United States, 1Password.ca in Canada and 1Password.eu in the European Union. A US shop on 1Password.com keeps its data in the US. For a vault on your own servers, Bitwarden is the option of the two.
Does SSO count as multifactor authentication for IA.L2-3.5.3?
Only if your identity provider asks for a second factor. SSO moves the sign-in to Entra ID, Okta or Google; the multifactor rule then lives there, and that is the screen the assessor will want. Set the vault's own two-step policy as well, for any account that can still sign in without SSO: Bitwarden's SSO policy leaves owners and admins out. The rest of the identification family is on the 110 Rev 2 requirements by family.