Not CUI Compliant
4 NIST 800-171 gaps detected. Not FedRAMP authorized. Using this tool for CUI creates compliance violations under NIST 800-171 and DFARS 252.204-7012.
Wave Accounting
by H&R Block
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
Accounting
Overview
Wave Accounting is a free commercial accounting platform owned by H&R Block, designed for freelancers and small businesses. It is not FedRAMP authorized and unsuitable for defense contractor financial management.
CUI Risk Assessment
Not FedRAMP authorized. Using this tool for CUI creates compliance violations under NIST 800-171 and DFARS 252.204-7012.
Deployment & Architecture
Deployment Model: Cloud SaaS (vendor-hosted)
Wave Accounting has no FedRAMP authorization on record. DFARS 252.204-7012(b)(2)(ii)(D) requires an external cloud service provider to meet security requirements equivalent to the FedRAMP Moderate baseline — an authorization is the straightforward way to show that, but it is not the only one. Without one, the burden is on you to establish, document, and defend equivalency, and to meet the clause's incident-reporting and media-preservation obligations. Most contractors find an authorized alternative cheaper than carrying that burden.
Migration Checklist
- 1ISSO must immediately create POA&M entry documenting Wave Accounting as Category 1 NIST 800-171 violation with 30-day remediation timeline per DFARS 252.204-7012.
- 2Contracts officer must review all active DoD contracts to identify CUI data categories processed through Wave Accounting system.
- 3ISSO must update SSP authorization boundary diagram to document Wave Accounting as out-of-scope pending migration.
- 4System administrator must export all financial data from Wave using encrypted transfer methods compliant with NIST 800-171 3.13.8 requirements.
- 5ISSO must evaluate FedRAMP authorized accounting alternatives including Deltek Costpoint and NetSuite Federal for CUI compatibility.
- 6System administrator must implement chosen compliant accounting solution with proper STIG configuration baselines.
- 7ISSO must conduct security control assessment of new accounting system focusing on NIST 800-171 3.1.1, 3.1.2, 3.13.1, and 3.13.8 controls.
- 8Legal counsel must verify new accounting system meets DFARS 252.204-7021 adequate security requirements before CUI processing.
- 9ISSO must update SSP with new accounting system technical specifications and security control implementations.
- 10Contracts officer must notify DCMA of accounting system change and provide updated SPRS scores reflecting compliance status.
NIST 800-171 Violations
Using Wave Accounting for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
Need a CUI-Compliant Alternative?
Wave Accounting has 4 NIST 800-171 gaps. Get real-time alerts when compliant alternatives launch, plus AI-matched contract opportunities.
FedRAMP Compliant Alternatives
Frequently Asked Questions
Is Wave Accounting FedRAMP authorized?
No. Wave Accounting is a free consumer product that does not hold FedRAMP authorization.
Can I use Wave Accounting for defense contract finances?
No. Wave Accounting is not FedRAMP authorized and lacks the cost accounting and compliance features required for government contracting.
What is a compliant alternative to Wave Accounting?
Deltek Costpoint (FedRAMP Moderate) and Oracle Financials Government Cloud (FedRAMP High) are authorized for defense contractor accounting.
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Schedule architecture reviewRelated: how much CMMC certification costs — DoD’s own priced figures