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Encrypted backups and removable drives: four cases, each with an unlock and a restore test

CUI on a Windows computer's own drives, on a Mac, on a USB stick or external backup drive, is encrypted in the way that fits that case, every recovery key is kept where you can find it and can be read by the roles you name (and, for a Mac, by its user), unencrypted USB drives cannot be written to from company Windows computers while the approved hardware-encrypted backup model still can, and each case ends in an unlock or restore test you can repeat.

From vendor documentation, not run by Expert CMMC.

Each setting below quotes the vendor’s own page with the date it was read. Expert CMMC has not run this configuration. Run the tests at the end on your own systems before you rely on it.

Last reviewed November 12, 2026.

Before you choose this example

What this recipe was written against, what it needs, and whether its cryptography is established for CUI. Read this before the configuration: it decides whether the example fits you.

Written against

  • Windows 11 Pro, Enterprise or Education computers, Entra joined (or hybrid joined) and enrolled in Intune, with TPM 1.2 or later, native UEFI, Secure Boot and Windows Recovery Environment: Microsoft's conditions for silent encryption, which Case 1 uses.
  • The exclusion by hardware ID (Case 4) needs Windows 11 version 21H2 or later on the backup computers and is set through Intune: Microsoft lists no Group Policy setting for it.
  • BitLocker To Go with a SID protector (Case 2) needs Active Directory domain accounts.
  • Macs with Apple silicon or the T2 chip, enrolled in Intune and marked Corporate.
  • Microsoft's, Apple's and NIST's pages as read on 2026-11-10 to 2026-11-12 (see Versions under Applies to).

Licences and management components

  • Intune: an endpoint security disk encryption profile for Windows (BitLocker), a Windows settings catalog policy for the exclusion by hardware ID, a macOS FileVault policy and a macOS restrictions policy.
  • Entra ID or Active Directory to hold Windows and BitLocker To Go recovery passwords; Intune to hold each Mac's personal recovery key.
  • Active Directory for SID protectors on BitLocker To Go drives. An office without it uses hardware-encrypted drives for backups (Case 4).
  • The licences are under Before you start, from the product catalog.

Cryptography, end by end

  • Windows computers: BitLocker on the computer's own drives and on BitLocker To Go drives: not established

    Module and certificate
    BitLocker and XTS-AES are not certificates: Microsoft validates the cryptographic modules Windows uses, not Windows features. Its FIPS 140 page (updated 2026-09-02, read 2026-11-11) lists validated modules for Windows 11 versions 21H2 and 22H2 only. On NIST's pages (read 2026-11-12), 21H2's Cryptographic Primitives Library (#4825) is FIPS 140-2 and Historical, and 22H2's (#5410) is FIPS 140-3 and Active, sunset 8/30/2031. Microsoft's lifecycle pages show neither version serviced any longer.
    Operating environment
    For 22H2: build 10.0.22621.1, editions Enterprise, Home, IoT Enterprise, Pro and Education (Microsoft's Windows 11 FIPS page). No Windows 11 version that Microsoft still services is listed.
    Required configuration
    Microsoft: to run Windows in a FIPS 140 approved mode, the rules in each module's security policy must be followed. This recipe does not read the security policies. With TPM-only computers and no password protectors, Microsoft says the legacy FIPS policy is not needed (Case 1).
    Look up before relying on it for CUI
    For each CUI computer's Windows version and build: the module versions and their CMVP certificates (Microsoft's FIPS page, then NIST's page for each), and each module's security policy for its approved mode. Where none is listed, record the gap for SC.L2-3.13.11; do not hold computers on an unserviced build to keep a listed certificate.

    “To use Windows and Windows Server in a FIPS 140 approved mode of operation, all the specific configuration and security rules outlined in the module Security Policy documents must be followed. … Microsoft validates the cryptographic modules used in Windows and other products, not individual Windows services or applications.”

    Vendor page, read November 12, 2026. FIPS 140-2 and FIPS 140-3 validation, last updated 2026-09-02.
  • Macs: FileVault: not established

    Module and certificate
    Apple's macOS certifications page (published October 14, 2026, read 2026-11-11) listed corecrypto certificates for macOS 15 Sequoia (on Apple silicon: User #5184, Kernel #5387, Secure Key Store #5305) and none yet for macOS 26 Tahoe, whose modules were in review (the product catalog's FileVault case).
    Operating environment
    As Apple's page lists it for each macOS version and chip; not read further here.
    Required configuration
    Not read: each certificate's security policy.
    Look up before relying on it for CUI
    Your Macs' macOS version and chip, the corecrypto certificates Apple lists for it, their status on NIST's pages and their security policies. A Mac on a macOS version with no certificate is a gap to record.
  • Hardware-encrypted drives (Case 4): not established

    Module and certificate
    Depends on the model, and this recipe names none. What it requires is a model whose module has an Active FIPS 140-3 certificate on NIST's list, at a firmware version that certificate lists.
    Operating environment
    The drive's firmware version, as the certificate lists it.
    Required configuration
    Not read: the certificate's security policy, which says how the drive must be set up (for example its PIN rules) to run in its approved mode.
    Look up before relying on it for CUI
    The model's certificate number, standard, status and listed firmware versions on NIST's CMVP pages, and the security policy's required setup, before buying.

Not suitable when

  • Windows Home, or computers without a TPM.
  • Computers you would keep on Windows 11 21H2 or 22H2 to match a listed certificate: Microsoft no longer services either version.
  • An office with Entra ID and no Active Directory that wants BitLocker To Go backup drives unlocked by domain credentials: use hardware-encrypted drives (Case 4).
  • Backup computers managed only by Group Policy that must write to hardware-encrypted drives while Deny write access is on: the exclusion by hardware ID has no Group Policy setting.
  • Macs that are not enrolled in device management, or are marked Personal: administrators cannot see their recovery keys.
  • Phones, tablets and cloud backup services: not covered.
  • Macs that must be kept from writing to USB drives: the write-deny setting is a Windows policy. Control removable media on Macs separately in your device management, and test it.
  • Windows laptops that need a startup PIN (TPM and PIN): this recipe's path is TPM only, because Microsoft's silent encryption allows no startup PIN or key.

Stays with you, whichever product you use

  • Which Windows and macOS versions you run, and the record of each one's certificates or the gap.
  • The approved-media list, the media inventory and who holds each drive.
  • Who may read recovery keys, and reviewing that list.
  • The backup and restore test schedule, and where backup drives are kept.

“A device must meet the following conditions for silent BitLocker enablement: … Microsoft Entra joined or Microsoft Entra hybrid joined TPM (Trusted Platform Module) 1.2 or later Native UEFI BIOS mode Secure Boot enabled Windows Recovery Environment (WinRE) configured and available”

Vendor page, read November 12, 2026. Intune: Encrypt Windows devices with BitLocker, last updated 2026-04-15.

Practices this supports

Following this recipe supports these practices and objectives. It does not by itself meet any of them: each practice also needs what its page lists (policy, procedure, evidence and the parts this recipe leaves to you).

  • SC.L2-3.13.16[a]CUI at rest on computers and drives is encrypted.
  • MP.L2-3.8.6[a]Removable drives that carry CUI are encrypted before they leave.
  • MP.L2-3.8.9[a]Backup drives are encrypted, with a restore test.
  • MP.L2-3.8.7[a]Company Windows computers cannot write to an unencrypted removable drive, and only the backup computers can write to the approved hardware-encrypted model.
  • AC.L2-3.1.19[a] [b]The encryption report identifies the laptops, and each is encrypted.
  • SC.L2-3.13.11[a]Only where a CMVP certificate covers the exact Windows or macOS version, or the drive model and firmware; otherwise record the gap.

Applies to

Information
FCI and CUI
Systems
  • Windows 11 computers with a TPM, in Pro, Enterprise or Education (BitLocker), Entra joined and enrolled in Intune
  • Macs with Apple silicon or the T2 chip (FileVault)
  • USB sticks and external drives used for transport or backups (BitLocker To Go, or hardware-encrypted drives)
  • Devices managed in Intune; domain-joined Windows computers can take most of the same settings from Group Policy, but not Require device encryption or the exclusion by hardware ID, which Microsoft lists for the CSP (Intune) only
Tenant
Microsoft Entra ID and Intune for policies and recovery keys (Active Directory for domain-joined computers and for SID protectors). The drives themselves are your own equipment.
Versions
Microsoft's BitLocker documentation (Configure BitLocker updated 2025-07-29, the BitLocker CSP 2026-10-14, the FAQ 2026-10-08, the recovery overview 2025-07-29), Intune's BitLocker and FileVault pages (both updated 2026-04-15), Microsoft's FIPS 140 page (2026-09-02), the manage-bde reference, Microsoft's Windows 11 lifecycle pages, Apple's FileVault and device management restriction pages and NIST's CMVP pages, read 2026-11-10 to 2026-11-12.

Before you start

Licences

  • BitLocker · BitLocker in Windows Pro, Enterprise, Pro Education/SE and Education: BitLocker for a computer's own drives, BitLocker To Go for removable drives

    Encryption of Windows computers' drives and of removable drives; part of Windows in the editions the catalog lists.

    BitLocker can be turned on in Windows Pro, Enterprise, Pro Education/SE and Education. Source, checked November 11, 2026. Plans change; confirm before buying.

  • FileVault · FileVault in macOS, on a Mac with Apple silicon or an Intel Mac with the T2 chip

    Encryption of a Mac's internal drive; part of macOS.

  • Microsoft Intune · Microsoft Intune Plan 1, with Plan 2, the Intune Suite and standalone advanced capabilities

    The encryption policies, the exclusion by hardware ID and the escrow of recovery keys for Windows and Mac.

    Microsoft lists Intune (with Entra ID P1) as included in Microsoft 365 Business Premium, E3, E5, F3, G3 and G5, among others; it can also be bought separately. Source, checked November 11, 2026. Plans change; confirm before buying.

  • Hardware-encrypted USB drive · A USB flash or external drive that encrypts inside the drive and unlocks with a PIN on its keypad or the maker's unlock software, in a model with its own CMVP certificate

    Backup and transport drives that unlock the same way on any computer.

Administrator roles

  • Intune Administrator (or an Intune role with the permissions for disk encryption policies): Disk encryption policies for Windows and Mac, and the Windows settings catalog policy with the exclusion by hardware ID.
  • Entra ID: a role that can read BitLocker recovery keys (Microsoft's device identities page lists Cloud Device Administrator, Helpdesk Administrator, Intune Administrator, Security Administrator and Security Reader, besides the device's owner: see Who can read Windows recovery keys, Case 1); in Intune, a role with the Remote tasks permission to view and rotate a Mac's FileVault key: Reading escrowed recovery keys. Give these roles only to the people your procedure names.
  • A media custodian named in your media protection procedure: Issuing, recording and testing removable drives and keeping their recovery records.

Devices

  • Windows computers with a TPM; Macs with Apple silicon or the T2 chip, marked Corporate in Intune (Microsoft: administrators can view the FileVault recovery key only for devices marked Corporate).
  • One backup or issuing computer where removable drives are encrypted and recovery keys stored. Keep it: a removable drive's key is recorded against the computer it was backed up from (Case 2).
  • Removable drives bought for the purpose; for hardware-encrypted drives, a model and firmware with an Active FIPS 140-3 certificate on NIST's CMVP list.

Already in place

  • A media protection procedure naming which drives may hold CUI, who issues them and where recovery keys are kept (MP.L2-3.8.1, MP.L2-3.8.7).
  • An approved-media list: the hardware-encrypted model(s) and firmware you allow, with their CMVP certificate numbers. It decides what goes in the exclusion by hardware ID (Case 4).
  • A media inventory with each drive's serial number, model and firmware, who holds it, and its recovery key ID or certificate.
  • A backup procedure that says what is backed up, to which drives, how many copies and where they are stored.

Do first, or alongside: Company Windows laptops reach company data only when they are compliant.

Configuration

Case 1: Windows computers' own drives (BitLocker)

These settings go in one Intune disk encryption profile (Endpoint security > Disk encryption > Create Policy, Platform: Windows, Profile: BitLocker), so they reach a computer together; assign it to a pilot group first. This path is TPM only, with no startup PIN, because Microsoft's silent encryption needs that. Encryption starts once Require device encryption arrives, and only after the recovery password is stored.

The case: Windows laptop or desktop: the computer's own drives (BitLocker)
Assumes
Windows Pro, Enterprise, Pro Education/SE or Education on a computer with a TPM, BitLocker turned on for the operating system drive and any fixed data drives before CUI is stored, and the cryptographic modules of your exact Windows version looked up. On 2026-11-11 Microsoft's FIPS 140 page listed validated modules for Windows 11 versions 21H2 and 22H2 only. NIST lists the 21H2 Cryptographic Primitives Library certificate (#4825) as FIPS 140-2 and Historical, and the 22H2 one (#5410) as FIPS 140-3 and Active (both read 2026-11-12). Microsoft no longer services either version: its lifecycle pages give 22H2's end as 2024-10-08 for Home and Pro and 2025-10-14 for Enterprise and Education, and 21H2's earlier. Do not hold computers on an unpatched build to keep a listed certificate: keep Windows on a version Microsoft services, look its module versions up on NIST's CMVP pages, and record a gap where none is listed (SC.L2-3.13.11).
Unlock or sign-in
The TPM releases the key at startup when the boot chain is unchanged (TPM only, the encryption recipe's path). A startup PIN (TPM and PIN) adds a factor before Windows starts; if you use one, it reads the legacy FIPS policy: turn that policy on before you create the PIN, or Windows turns the PIN into a key in a way Microsoft says is not FIPS-approved.
Recovery and fallback
A 48-digit recovery password stored in Entra ID (Entra-joined computers) or Active Directory (domain-joined), with the option set that keeps BitLocker off until the recovery information is stored. Microsoft's recovery overview says that option holds BitLocker back unless the backup to Entra ID or AD DS succeeds; the policy's own description names AD DS only, so confirm the key is in Entra ID before relying on the computer. Users can read their own devices' keys from the web, so decide who may. Never keep the only copy in a personal Microsoft account or in a file on the same computer.
Does not cover
USB sticks and external drives (the BitLocker To Go case); a computer that is on and unlocked; files copied to email, cloud storage or USB; Windows Home; and automatic device encryption on its own, which Microsoft says covers only the operating system and fixed drives and leaves a device with only local accounts unprotected.

From the product catalog, checked November 12, 2026 against Microsoft's FIPS 140 page updated 2026-09-02: Windows 11 22H2 (build 10.0.22621.1) is the newest Windows 11 version listed; NIST certificates #4825 and #5410 and Microsoft's Windows 11 lifecycle pages read 2026-11-12.

  1. Windows version, and its certificates

    Each CUI computer: Settings > System > About (the Windows version and OS build), compared with Microsoft's FIPS 140 page and NIST's certificate pages

    ValueA Windows 11 version Microsoft still services, kept patched, with its module certificates looked up and the result recorded. On 2026-11-12 no serviced Windows 11 version had modules listed on Microsoft's FIPS 140 page: the listed versions, 21H2 and 22H2, are out of servicing. Record the gap for SC.L2-3.13.11 rather than hold computers on 22H2. The compliant-devices recipe's Minimum OS version should therefore be a serviced build, which will be one without a listed certificate.

    WhyThe certificate covers a module at a version, not BitLocker in general. Staying on an unpatched build to keep a listed certificate trades a documented gap for unpatched computers.

    “Windows 11 releases Windows 11, version 22H2 Windows 11, version 21H2”

    Microsoft, source, read November 11, 2026 (product catalog: ms-fips-win11-versions-listed, nist-cmvp-4825-historical, nist-cmvp-5410-active, ms-win11-lifecycle-ent-edu, ms-win11-lifecycle-home-pro)
  2. Startup authentication

    The same profile > Operating System Drives: Require additional authentication at startup

    ValueRequire additional authentication at startup: Enabled. Configure TPM startup: Require TPM. Configure TPM startup PIN: Do not allow startup PIN with TPM. Configure TPM startup key: Do not allow startup key with TPM. Configure TPM startup key and PIN: Do not allow startup key and PIN with TPM.

    WhyMicrosoft: for silent encryption, the computer must not require a startup PIN or key. A security baseline can turn the PIN on and stop encryption, so check your baselines for conflicts.

    “For silent BitLocker to work, devices must not require TPM startup PIN or startup key, as these require user interaction. … Endpoint security policy - In the BitLocker profile under Operating System Drives, first set Require additional authentication at startup to Enabled. Once enabled, the following TPM settings become available: Configure TPM startup PIN = Do not allow startup PIN with TPM Configure TPM startup key = Do not allow startup key with TPM Configure TPM startup key and PIN = Do not allow startup key and PIN with TPM Configure TPM startup = Allow TPM or Require TPM … Watch for policies that enable use of a TPM startup PIN or key. For example, the Security baseline for Microsoft Defender can enable TPM startup PIN and key by default, which blocks silent enablement.”

    Vendor page, read November 12, 2026. Intune: Encrypt Windows devices with BitLocker, section TPM startup authentication for silent encryption; last updated 2026-04-15.
  3. Encryption method

    The same profile: Choose drive encryption method and cipher strength

    ValueEnabled, with each of the three drive types set: operating system drives, fixed data drives and removable data drives (the policy sets them separately). XTS-AES for each: 256-bit on computers fast enough, otherwise 128-bit, as Microsoft advises. Write the choice in your baseline. The removable-drive choice is what BitLocker To Go uses in Case 2.

    WhyMicrosoft recommends XTS-AES for all drives; left unset, BitLocker uses XTS-AES 128-bit. Setting it makes the choice deliberate and visible in the policy export. Microsoft notes the policy does not apply to drives that encrypt themselves (hardware-encrypted drives, Case 4).

    “Recommended settings: XTS-AES algorithm for all drives.”

    Microsoft, source, read November 12, 2026 (product catalog: ms-bitlocker-xts-default)

    “With this policy, you can configure an encryption algorithm and key cipher strength for fixed data drives, operating system drives, and removable data drives individually. Recommended settings: XTS-AES algorithm for all drives. The choice of key size, 128 bit or 256 bit depends on the performance of the device. … If you disable or don't configure this policy setting, BitLocker uses the default encryption method of XTS-AES 128-bit. Note This policy doesn't apply to encrypted drives. Encrypted drives utilize their own algorithm, which is set by the drive during partitioning.”

    Vendor page, read November 12, 2026. Configure BitLocker, Choose drive encryption method and cipher strength; last updated 2025-07-29.
  4. Recovery password stored before encryption

    The same profile > Operating System Drives: Choose how BitLocker-protected operating system drives can be recovered (and the same for fixed drives)

    ValueEnabled, for operating system drives and, separately, for fixed data drives (Choose how BitLocker-protected fixed drives can be recovered), with the same options in each. Configure user storage of BitLocker recovery information: require the 48-digit recovery password, and allow or do not allow the 256-bit recovery key (not require it: Microsoft's list of settings for silent encryption gives only Allow or Do not allow 256-bit recovery key). Save BitLocker recovery information to AD DS: the recovery password. Do not enable BitLocker until recovery information is stored: on (for fixed data drives too). For a domain-joined computer this stores the password in Active Directory; for an Entra-joined computer Microsoft says it is backed up to Entra ID. Where your profile shows them, Intune's own names for the Entra side are Save BitLocker recovery information to Microsoft Entra ID: Enabled and Store recovery information in Microsoft Entra ID before enabling BitLocker: Required. Also set Client-driven recovery password rotation: Enable rotation on Microsoft Entra joined devices, which the recovery test below uses.

    WhyMicrosoft's recovery overview says this option keeps BitLocker off unless the backup to Entra ID or AD DS succeeds, and Intune's page says silent encryption backs the key up before it starts encrypting. The policy's own description names AD DS only, so for Entra-joined computers confirm the key is in Entra ID before relying on the computer (Rolling it out). Fixed data drives need their own setting: with the warning for other disk encryption turned off (below), Microsoft says a fixed data drive's key goes to the first of the user's Active Directory account, Entra ID account or personal OneDrive that succeeds. Whether the fixed-drive setting keeps the key out of OneDrive is not stated, so check each fixed drive's key in Intune (the device > Monitor > Recovery keys, which lists each key's Drive Type) in the first passing test.

    “Use the option Do not enable BitLocker until recovery information is stored in AD DS to prevent users from enabling BitLocker unless the backup of BitLocker recovery information for the drive to Microsoft Entra ID or AD DS succeeds.”

    Microsoft, source, read November 12, 2026 (product catalog: ms-bitlocker-recovery-before-enable)

    “Configure user storage of BitLocker recovery information: select whether users are allowed, required, or not allowed to generate a 48-digit recovery password or a 256-bit recovery key … Do not enable BitLocker until recovery information is stored in AD DS for operating system drives: prevents users from enabling BitLocker unless the device is connected to the domain and the backup of BitLocker recovery information to AD DS succeeds. When using this option, a recovery password is automatically generated. … For Microsoft Entra hybrid joined devices, the BitLocker recovery password is backed up to both Active Directory and Entra ID. For Microsoft Entra joined devices, the BitLocker recovery password is backed up to Entra ID.”

    Vendor page, read November 12, 2026. Configure BitLocker, policy Choose how BitLocker-protected operating system drives can be recovered; last updated 2025-07-29.

    “Microsoft Entra ID supports a maximum of 200 BitLocker recovery keys per device. If you reach this limit, silent encryption fails due to the failing backup of recovery keys before starting encryption on the device. … Client-driven recovery password rotation = Enable rotation on Microsoft Entra joined devices or Enable rotation on Microsoft Entra ID and hybrid joined devices Save BitLocker recovery information to Microsoft Entra ID = Enabled Store recovery information in Microsoft Entra ID before enabling BitLocker = Required”

    Vendor page, read November 12, 2026. Intune: Encrypt Windows devices with BitLocker, last updated 2026-04-15.

    “User creation of recovery key = Allow or Do not allow 256-bit recovery key User creation of recovery password = Allow or Require 48-digit recovery password … Select a device from the list, and then under Monitor, select Recovery keys. Select Show Recovery Key. This generates an audit log entry under 'KeyManagement' activity. When keys are available in Microsoft Entra ID, the following information is displayed: BitLocker Key ID BitLocker Recovery Key Drive Type”

    Vendor page, read November 12, 2026. Intune: Encrypt Windows devices with BitLocker. The recovery-key values are listed for silent BitLocker in the Endpoint protection template; this recipe applies the same values in the disk encryption profile.

    “When you disable the warning prompt, the OS drive's recovery key will back up to the user's Microsoft Entra ID account. When you allow the warning prompt, the user who receives the prompt can select where to back up the OS drive's recovery key. The endpoint for a fixed data drive's backup is chosen in the following order: The user's Windows Server Active Directory Domain Services account The user's Microsoft Entra ID account The user's personal OneDrive (MDM/MAM only) Encryption will wait until one of these three locations backs up successfully.”

    Vendor page, read November 12, 2026. Configure BitLocker, Allow warning for other disk encryption; last updated 2025-07-29.
  5. Restrict non-admin users from recovering the BitLocker key(s) for their owned devices

    Microsoft Entra admin center: device settings (Microsoft's page Manage device identities > Configure device settings); a Privileged Role Administrator or higher can change it

    ValueYes. Then the people who can read a Windows computer's recovery key are those holding a role with the BitLocker read permission (Microsoft lists Cloud Device Administrator, Helpdesk Administrator, Intune Administrator, Security Administrator and Security Reader); keep their membership to the people your procedure names, and review it. Each Show Recovery Key is recorded in the audit log (KeyManagement).

    WhyMicrosoft's default is No: a device's owner can read its BitLocker key themselves, from Company Portal, the My Account portal or Entra ID. Macs differ: Microsoft says users can view and retrieve their own FileVault personal recovery key, and this recipe has no setting that stops it; the rotation in the Mac recovery test is what limits a key's life once it has been seen.

    “Restrict non-admin users from recovering the BitLocker key(s) for their owned devices: Admins can block self-service BitLocker key access to the registered owner of the device. Default users without the BitLocker read permission are unable to view or copy their BitLocker key(s) for their owned devices. You must be at least a Privileged Role Administrator to update this setting. … To view or copy BitLocker keys, you need to be the owner of the device or have one of these roles: Cloud Device Administrator Helpdesk Administrator Intune Administrator Security Administrator Security Reader”

    Vendor page, read November 12, 2026. Manage device identities using the Microsoft Entra admin center, last updated 2026-06-17.

    “Company Portal app: Users can access BitLocker recovery keys through the Company Portal app My Account portal: Available at account.microsoft.com for Microsoft Entra joined devices Microsoft Entra ID: Direct access for Microsoft Entra joined devices Administrative controls for self-service access: Tenant-wide toggle: Determines if non-admin users can use self-service to recover BitLocker keys: Default: No (allows all users to recover their keys) Yes: Restricts non-admin users from seeing BitLocker keys for their own devices”

    “Admins can view the personal recovery key for only managed macOS devices that are marked as Corporate. They can't view the recovery key for Personal devices. Users can view and retrieve their personal recovery key from supported locations.”

  6. Require device encryption

    The same profile: Require device encryption (a CSP setting: Microsoft lists no Group Policy setting for it)

    ValueRequire device encryption: Enabled. Allow warning for other disk encryption: Disabled, and Allow standard user encryption: Enabled, so encryption starts without a prompt on Entra-joined laptops whose users are not administrators. First check that no other disk encryption product is installed.

    WhyThe drives of the company Windows computers the profile is assigned to are encrypted without depending on the user; the encryption report (evidence below) shows each computer's state. Microsoft warns that BitLocker on a computer with another vendor's encryption may make it unusable.

    “This policy setting determines whether BitLocker is required: If enabled, encryption is triggered on all drives silently or non-silently based on Allow warning for other disk encryption policy … With this policy you can enforce the Require device encryption policy for scenarios where the policy is applied while the current logged-on user doesn't have administrative rights. … The Allow warning for other disk encryption policy must be disabled to allow standard user encryption. … When you enable BitLocker on a device with non-Microsoft encryption, it may render the device unusable and will require reinstallation of Windows.”

    Vendor page, read November 12, 2026. Configure BitLocker (policy settings), last updated 2025-07-29. The table for Require device encryption gives the CSP path and "GPO Not available".

    “For Endpoint security Disk encryption policy, configure these settings in the BitLocker profile: Require Device Encryption = Enabled Allow Warning For Other Disk Encryption = Disabled … Allow Standard User Encryption = Enabled This setting is required if devices are used by standard (non-administrator) users.”

  7. Used space only encryption, and the free space it leaves

    Each computer that held CUI before it was encrypted: manage-bde -status C: (and each fixed drive), in a command prompt run as administrator; for computers not yet encrypted, a Windows settings catalog policy: Windows Components > BitLocker Drive Encryption > Operating System Drives > Enforce drive encryption type on operating system drives

    ValueCheck Conversion Status. On a computer that held CUI before it was encrypted and shows Used Space Only Encrypted, wipe the free space: manage-bde -w C: (the same for each fixed drive). For computers not yet encrypted, you can set Enforce drive encryption type on operating system drives: Enabled, Full encryption; Microsoft's same page also says the encryption type cannot be customized for silent encryption, so check Conversion Status on the pilot computer either way. A computer that never held CUI before encryption needs neither.

    WhyMicrosoft: silent encryption on a modern standby laptop encrypts used space only. Data deleted before encryption can remain in the free space, which is not encrypted; Microsoft says wiping the free space of a Used Space Only volume gives the same protection as full encryption, and that changing the encryption type has no effect on a drive already encrypted.

    “When BitLocker is enabled silently, the system automatically uses full disk encryption on non-modern standby devices and used space only encryption on modern standby devices. The encryption type depends on hardware capabilities and can't be customized for silent encryption scenarios. … To check the current encryption type, run from an elevated command prompt: manage-bde -status c: The 'Conversion Status' field shows either Used Space Only Encrypted or Fully Encrypted. … To change the disk encryption type between full disk encryption and used space only encryption, use the Enforce drive encryption type on operating system drives setting in Settings Catalog: Create a Settings Catalog policy Navigate to Windows Components > BitLocker Drive Encryption > Operating System Drives Select and set Enforce drive encryption type on operating system drives to Enabled”

    Vendor page, read November 12, 2026. Intune: Encrypt Windows devices with BitLocker. The page says both that the type can't be customized for silent encryption and how to change it in Settings Catalog.

    “Wipes the free space on the volume, removing any data fragments that may have existed in the space. Running this command on a volume encrypted using the Used Space Only encryption method provides the same level of protection as the Full Volume Encryption encryption method. … To wipe the free space on drive C, type either: manage-bde -w C: manage-bde -wipefreespace C:”

    Vendor page, read November 12, 2026. manage-bde wipefreespace.

    “Note Changing the encryption type has no effect if the drive is already encrypted or if encryption is in progress.”

    Vendor page, read November 12, 2026. Configure BitLocker, Enforce drive encryption type on operating system drives; last updated 2025-07-29.
  8. Legacy FIPS policy: only before a PIN or password protector

    Group Policy or Intune: the legacy FIPS policy (System cryptography: Use FIPS compliant algorithms for encryption, hashing, and signing)

    ValueLeave it as it is on these TPM-only computers. If you later give some laptops a startup PIN (not covered here: Microsoft says a PIN needs user interaction, so it is not silent encryption), the policy must reach those laptops before the PIN protector is created. Microsoft ties the policy to creating the PIN or password protector, not to the start of encryption.

    WhyMicrosoft: only BitLocker's PIN and password protectors read the legacy FIPS policy; without them no further setting is needed for a FIPS 140 approved mode. With the policy on, a PIN is derived with PBKDF2; without it, in a way Microsoft says is not FIPS-approved. The same policy makes password-protected removable drives read-only (Case 2).

    • Needs firstStartup authentication. Leaving the legacy FIPS policy as it is holds only while the startup settings allow no PIN; a recipe that adds a startup PIN must set the FIPS policy before the PIN protector is created.

    “If neither protector is used in your BitLocker setup, no additional configuration is required to operate Windows in a FIPS 140 approved mode”

    Microsoft, source, read November 11, 2026 (product catalog: ms-bitlocker-fips-protectors, ms-bitlocker-pin-kdf, ms-bitlocker-password-readonly)

Case 2: USB sticks and external drives (BitLocker To Go)

For an office with Active Directory: the unlock method below uses domain credentials. Do the steps in order on the issuing computer, with the new drive as E:. An office with Entra ID and no Active Directory uses hardware-encrypted drives for backups (Case 4).

The case: Windows removable drive (BitLocker To Go): USB sticks and external backup drives
Assumes
A USB or external drive encrypted with this feature before any CUI is copied to it; a device policy that refuses writes to removable drives it does not protect; unlock methods chosen for the drive itself, which carries its own protectors; and computers that encrypt and read it on an operating system version whose cryptographic modules you have looked up, as in the system-disk case (on 2026-11-11 Microsoft's FIPS page listed only two versions, 21H2 and 22H2, and Microsoft no longer services either).
Unlock or sign-in
Prefer a smart card protector, or a SID protector (domain credentials, set with manage-bde). Microsoft names only the PIN and password protectors as depending on the legacy FIPS policy; confirm the smart card protector's mode in the module's security policy. Microsoft's pages read for this case do not say how a SID-protected drive behaves when the computer cannot reach a domain controller: test it before a backup depends on it. A password protector is the weak choice for CUI: Microsoft states password protectors are always built with iterative SHA2-256 stretching, and calls SHA2-256 key derivation from a PIN "not a FIPS-approved way to derive a key from a password". It also states that a password-protected removable drive mounts read-only on a computer with the legacy FIPS policy enabled. For a backup drive this means: if the backup computer has that policy on (for example because your laptops use a BitLocker PIN), a password-protected drive stops accepting backups. Use a smart card or SID protector, or a hardware-encrypted drive with its own certificate.
Recovery and fallback
Microsoft states there is no automatic way to store a removable drive's recovery key in Entra ID or Active Directory. When you encrypt the drive, add a recovery password and store it there with PowerShell or manage-bde, or in a folder only administrators can open, and record its key ID against the drive's serial number in the media inventory. Before you retire or delete the computer the keys were backed up from, check where they are kept (the encryption recipe, Case 2). Windows otherwise offers a folder, a Microsoft account or a printout: do not use a personal Microsoft account, and never keep the key on the drive.
Does not cover
Files once copied off the drive; a drive left unlocked in a computer; drives encrypted before the write-refusal policy until you re-check them; automatic device encryption, which Microsoft says does not encrypt external or USB drives; and the computer's own drives (the system-disk case). The computer's TPM plays no part in unlocking the drive.

From the product catalog, checked November 12, 2026 against Windows 11: BitLocker FAQ updated 2026-10-08, Microsoft's FIPS 140 page updated 2026-09-02.

  1. Deny write access to removable drives not protected by BitLocker

    Intune (disk encryption or settings catalog policy) or Group Policy: BitLocker Drive Encryption > Removable Data Drives

    ValueEnabled, assigned to a pilot group first (Rolling it out), then to every company Windows computer.

    WhyA company Windows computer the policy reaches can copy files to a USB drive once the drive is encrypted with BitLocker, and a drive BitLocker does not protect becomes read-only there, hardware-encrypted drives included: Case 4 gives the exclusion that keeps the approved backup model writable on the backup computers.

    ThenAssigned to every company Windows computer, once the pilot's tests pass (Rolling it out).

    • Conflicts withthe case Hardware-encrypted USB drive (keypad or software unlock). A hardware-encrypted drive is not BitLocker-protected, so with this policy on it is mounted read-only and the backup drive Case 4 recommends cannot be written. Resolved by Removable Drives Excluded From Encryption.

    “This policy setting configures whether BitLocker protection is required for a device to be able to write data to a removable data drive. If you enable this policy setting: all removable data drives that are not BitLocker-protected are mounted as read-only if the drive is protected by BitLocker, it's mounted with read and write access”

  2. Encrypt the drive and add its recovery password

    On the issuing computer, in a command prompt run as administrator: manage-bde -on E: -recoverypassword

    ValueRun the command on the new, empty drive, on an issuing computer that already has the encryption method policy (Case 1, removable data drives). Note the recovery password it shows only long enough to finish the next steps, and wait until manage-bde -status E: reports the drive fully encrypted, with the Encryption Method you chose, before copying anything to it.

    WhyThis turns BitLocker on for the drive and gives it a recovery password, the protector the key backup below stores. Microsoft's example is for drive C; the command takes any drive letter. The cipher comes from the encryption method policy's removable-drive setting, so check it in manage-bde -status before the drive is used.

    • Needs firstEncryption method. The drive is encrypted with the cipher the policy sets for removable data drives; without the policy BitLocker uses its default.

    “Encrypts the drive and turns on BitLocker. … -recoverypassword Adds a numerical password protector. … To turn on BitLocker for drive C, and to add a recovery password to the drive, type: manage-bde -on C: -recoverypassword”

    Vendor page, read November 12, 2026. manage-bde on, last updated 2023-02-03.
  3. Unlock method (protector) for a backup drive

    On the issuing computer, right after encryption: manage-bde -protectors -add E: -sid <DOMAIN\group>

    ValueA SID protector for a domain group: the people (or computers) who may open the drive. Not a password protector. Microsoft also allows a smart card protector; this recipe gives no steps for one, so follow Microsoft's documentation and the module's security policy if you choose it. The drive unlocks by itself for anyone in the group (Microsoft: it unlocks automatically if the user or computer has the proper credentials), so the tests that expect it locked are run by a user on a computer outside the group. Off the network: Microsoft's pages read for this recipe do not say whether a SID-protected drive unlocks when the computer cannot reach a domain controller. Until your own test (When the service is unreachable) shows that it does, do not make a SID-protected drive the only way to restore a backup.

    WhyMicrosoft states that a password-protected removable drive mounts read-only on a computer with the legacy FIPS policy on, which stops backups, and that password protectors always use iterative SHA2-256 stretching. An office with Entra ID and no Active Directory has no domain credentials for a SID protector.

    “Password-protected removable drives are mounted read-only when the legacy FIPS policy is enabled.”

    Microsoft, source, read November 11, 2026 (product catalog: ms-bitlocker-removable-unlock, ms-bitlocker-password-readonly)

    “-ADaccountorgroup Adds a SID-based identity protector for the volume. The volume will automatically unlock if the user or computer has the proper credentials.”

    “To add an adaccountorgroup key protector, identified by domain and user name, to drive E, type: manage-bde -protectors -add E: -sid DOMAIN\user”

  4. Store the drive's recovery password

    On the issuing computer, right after the protector: manage-bde -protectors -get E: (note the ID of the Numerical Password protector), then manage-bde -protectors -aadbackup E: -id {ID} (Entra ID) or -adbackup E: -id {ID} (Active Directory)

    ValueStored in Entra ID or Active Directory, and its key ID written against the drive's serial number in the media inventory. Never on the drive and never in a personal Microsoft account. Confirm it is there: in Intune, the issuing computer > Monitor > Recovery keys (it lists each key's ID and drive type); in Active Directory, the issuing computer's object. Before you retire or delete the issuing computer, back each drive's key up again from its replacement (drive plugged in and unlocked, the same two commands) and confirm it.

    WhyWindows does not store a removable drive's recovery key in the directory by itself. Where the key then sits: Active Directory keeps BitLocker recovery information as a child of the computer object, and Microsoft Graph records an Entra ID key against the device it was backed up from. Microsoft says deleting a device in Entra ID deletes the BitLocker keys stored on it, with no way to recover them. Its pages do not single out removable-drive keys, so assume they go with the issuing computer. Deleting the issuing computer's Intune object, if it is Entra joined, also removes the key protectors of its own operating system volume and leaves BitLocker suspended there. Microsoft limits Entra ID to 200 BitLocker recovery keys per device, and when that is reached silent encryption fails; whether removable-drive keys backed up from the issuing computer count toward it is not established, so on an issuing computer that backs up many drives, watch the count of keys under its Recovery keys.

    “There's no automatic way to store the recovery key for removable storage devices in Microsoft Entra ID or AD DS. However, you can use PowerShell or the manage.bde.exe command to do so.”

    Microsoft, source, read November 11, 2026 (product catalog: ms-bitlocker-removable-no-auto-escrow)

    “-aadbackup Backs up all recovery information for the drive specified to Microsoft Entra ID. Append the -id parameter and specify the ID of a specific recovery key to back up. The -id parameter is required.”

    Vendor page, read November 12, 2026. manage-bde protectors reference, last updated 2023-02-03.

    “deviceId String Identifier of the device the BitLocker key is originally backed up from. … volumeType volumeType Indicates the type of volume the BitLocker key is associated with. The possible values are: 1 (for operatingSystemVolume), 2 (for fixedDataVolume), 3 (for removableDataVolume), and 4 (for unknownFutureValue).”

    Vendor page, read November 12, 2026. Microsoft Graph, bitlockerRecoveryKey resource type, last updated 2026-04-20.

    “When configured, BitLocker keys for Windows 10 or newer devices are stored on the device object in Microsoft Entra ID. If you delete a stale device, you also delete the BitLocker keys that are stored on the device. … There's no way to recover BitLocker recovery keys after deleting the associated device.”

    Vendor page, read November 12, 2026. How to manage stale devices in Microsoft Entra ID, last updated 2025-06-27.

    “The BitLocker recovery information for a device joined to an Active Directory domain can be stored in AD DS. The information is stored in a child object of the computer object itself.”

    “Important If you delete the Intune object for a Microsoft Entra joined device protected by BitLocker, the deletion triggers an Intune device sync and removes the key protectors for the operating system volume. This leaves BitLocker in a suspended state on that volume. … Note Microsoft Entra ID supports a maximum of 200 BitLocker recovery keys per device. If you reach this limit, silent encryption fails due to the failing backup of recovery keys before starting encryption on the device.”

    Vendor page, read November 12, 2026. Intune: Encrypt Windows devices with BitLocker.

Case 3: Macs (FileVault)

The case: Mac: the internal drive (FileVault)
Assumes
A Mac with Apple silicon (or an Intel Mac with the T2 chip) on a macOS version for which Apple's certifications page lists CMVP certificates, enrolled in device management, with FileVault turned on before any CUI is stored. On 2026-11-11 Apple's page listed certificates for macOS 15 Sequoia and showed the macOS 26 Tahoe modules still in review with no certificate, so a Mac on macOS 26 has no certificate to cite yet: record it as a gap (SC.L2-3.13.11) until one is listed.
Unlock or sign-in
The user's macOS login password at startup. On Apple silicon and T2 Macs the key handling happens in the Secure Enclave.
Recovery and fallback
A personal recovery key escrowed to your device management service (Intune or Jamf), which Apple recommends instead of an institutional recovery key. Apple states that with iCloud Keychain the recovery key syncs with the user's other passwords, so on company Macs turn on Apple's device management restriction that stops iCloud Keychain being used (the encryption recipe quotes it) and check on a pilot Mac that it is off.
Does not cover
External and USB drives (Apple states that encrypting removable storage does not use the Secure Enclave; use a hardware-encrypted drive); a Mac that is on and signed in; a macOS version with no certificate yet; and files copied to email, cloud storage or USB.

From the product catalog, checked November 12, 2026 against Apple's macOS security certifications page published October 14, 2026: macOS 15 Sequoia certified, macOS 26 Tahoe in review.

  1. FileVault

    Intune admin center > Devices > By platform > macOS > Manage devices > Configuration > Create > New policy > Settings catalog > + Add settings > Full Disk Encryption

    ValueEnable: On; Defer: Enabled; recovery key escrow Location: a sentence telling users how to get their key; Recovery Key Rotation In Months: the period you choose.

    WhyThe internal drive of each company Mac the policy reaches is encrypted, and the personal recovery key goes to Intune before encryption starts. With Defer, encryption waits for the user: Apple says deferred enablement needs the user to log out or log in, so a Mac is not encrypted until then (Rolling it out).

    “a personal recovery key (PRK) should be used.”

    Apple, source, read November 11, 2026 (product catalog: apple-filevault-prk-escrow)

    “Select Devices > By platform > macOS > Manage devices > Configuration > Create > New policy. Select Settings catalog for the Profile type. On the Configuration settings page, select + Add settings and navigate to Full Disk Encryption. … FileVault: Enable = On Defer = Enabled (required for successful FileVault application) … After the key is escrowed, the disk encryption can start. … Admins can view the personal recovery key for only managed macOS devices that are marked as Corporate.”

    Vendor page, read November 11, 2026. Intune FileVault page, updated 2025-12-03 (revised 2026-09-28).

    “When FileVault isn’t turned on during Setup Assistant, you can use a device management service to turn it on after enrollment, a process is referred to as deferred enablement. Deferred enablement requires a logout or login event from the user.”

    Vendor page, read November 12, 2026. Apple Platform Deployment: Manage FileVault with device management.
  2. iCloud Keychain

    Intune admin center > Devices > macOS > Configuration > Create > New policy > Settings catalog: Apple's iCloud Keychain restriction (Restrictions). Apple notes that not every device management service offers every restriction, so confirm Intune lists it.

    ValueRestricted on company Macs (Apple: "iCloud Keychain can't be used"), assigned before or with the FileVault policy. On a pilot Mac, check that iCloud Keychain is not in use.

    WhyApple states that with iCloud Keychain the FileVault recovery key syncs with the user's other passwords, which can include personal devices. With the restriction, the condition Apple describes does not arise. Whether a key synced before the restriction is removed from iCloud is not established, so set the restriction first.

    “When using iCloud Keychain, the recovery key is securely synchronized along with other user passwords.”

    Apple, source, read November 11, 2026 (product catalog: apple-filevault-icloud-keychain)

    “Note: Not all restrictions are available in all device management services and they have the ability to change the default state for any restriction. … iCloud Keychain macOS 10.12 No iCloud Keychain can’t be used.”

    Vendor page, read November 12, 2026. Apple Platform Deployment: Device management restrictions for Mac computers.

Case 4: hardware-encrypted USB and backup drives

With Deny write access on (Case 2), every removable drive that BitLocker does not protect is read-only on company Windows computers, and a hardware-encrypted drive is one of them. Microsoft's exclusion by hardware ID, assigned only to the backup computers, keeps the approved model writable there and nowhere else. The approved-media list says which models; the media inventory says which drives, by serial number, and who holds each.

The case: Hardware-encrypted USB drive (keypad or software unlock)
Assumes
A drive model whose cryptographic module has an Active FIPS 140-3 certificate on NIST's CMVP list, at a firmware version the certificate lists, set up with a PIN that meets your PIN rules before any CUI is copied to it. NIST moved every FIPS 140-2 certificate to the Historical list after September 21, 2026, for existing systems only: keep such drives only on a recorded risk decision, and buy FIPS 140-3 models. Company computers that refuse writes to removable drives their own disk encryption does not protect need the model excluded by hardware ID before they can write to it (the encryption recipe, Case 4).
Unlock or sign-in
The PIN on the drive's keypad, or the maker's unlock software for models without a keypad. What the drive does after repeated wrong PINs (many models erase their key) is in the model's manual and was not checked here: read it, and record the number in the media inventory.
Recovery and fallback
Whether the model offers any recovery, such as an administrator PIN, is in its manual; this case was not checked against the makers' pages. Plan as if there is none: where the model has an administrator PIN, set it when you issue the drive and keep it sealed with the media custodian, and never keep the only copy of CUI, or the only backup set, on one drive.
Does not cover
Files once copied off the drive; a drive left unlocked and plugged in; models sold as "FIPS compliant" or "military grade" without a certificate of their own; and firmware versions the certificate does not list.

From the product catalog, checked November 12, 2026.

  1. Model and firmware

    NIST's CMVP search (csrc.nist.gov), before buying and when each drive arrives

    ValueA model whose cryptographic module is on the Active list with a FIPS 140-3 certificate, at a firmware version that certificate lists. Record the certificate number in the approved-media list and in the media inventory.

    WhyThe certificate belongs to a model and its firmware, not to the brand; a FIPS 140-2 certificate is now on the Historical list, for existing systems only.

    “Upon validation, modules will be placed on the Active list for 5 years (or 2 years for Interim Validations) and may be used for new and existing systems.”

    Several makers (for example Kingston IronKey, Apricorn Aegis, DataLocker), source, read November 10, 2026 (product catalog: cmvp-active-meaning, cmvp-140-2-historical-2026, cmvp-module-not-algorithm)
  2. Removable Drives Excluded From Encryption

    Intune admin center: a Windows policy that sets the BitLocker CSP's RemovableDrivesExcludedFromEncryption (Windows 11 21H2 and later; Microsoft lists it as Removable Drives Excluded From Encryption, with no Group Policy setting; look for that name in the settings catalog), assigned only to the backup computers

    ValueOne entry per approved model and firmware revision, in the form of Microsoft's example: USBSTOR\ followed by the drive's vendor, product and revision (Microsoft's example is USBSTOR\SEAGATE_ST39102LW_______0004). Read the drive's identifiers on a backup computer with the drive plugged in and unlocked: Device Manager > Disk drives > the drive > Properties > Details > Hardware Ids. Never a shorter form that names only the vendor or the drive type.

    WhyMicrosoft: an excluded drive cannot be encrypted with BitLocker, and with Deny write access on it is mounted read/write. What the entry matches: Microsoft's USB storage page builds these identifiers from the drive's vendor, product and revision, with no serial number, so an entry names a model at a revision, not one drive. Every drive of that model and revision becomes writable on these computers, including one bought privately; that is why the exclusion goes only on the backup computers, and why the media inventory, not the exclusion, says which drives are company drives. Microsoft calls the value a hardware ID, but its example has the form its USB storage page gives for the device ID (no device-type code), while the hardware IDs Windows generates begin with the type code. Which form the setting matches is not established: use the example's form, run the three Case 4 tests, and if the approved drive stays read-only, add the full first hardware ID and test again.

    “When enabled, allows you to exclude removable drives and devices connected over USB interface from BitLocker Device Encryption. Excluded devices can't be encrypted, even manually. Additionally, if "Deny write access to removable drives not protected by BitLocker" is configured, user won't be prompted for encryption and drive will be mounted in read/write mode. Provide a comma separated list of excluded removable drives\devices, using the Hardware ID of the disk device. Example USBSTOR\SEAGATE_ST39102LW_______0004.”

    Vendor page, read November 12, 2026. BitLocker CSP, RemovableDrivesExcludedFromEncryption (applicable OS: Windows 11, version 21H2 [10.0.22000] and later); last updated 2026-10-14.

    “The device ID format is as follows: USBSTOR\v(8)p(16)r(4) Where: v(8) is an 8-character vendor identifier. p(16) is a 16-character product identifier. r(4) is a 4-character revision level value. An example of a device ID for a disk drive would be as follows: USBSTOR\SEAGATE_ST39102LW_______0004 The hardware IDs that the USB storage port driver generates are as follows: USBSTOR\t*v(8)p(16)r(4) USBSTOR\t*v(8)p(16) USBSTOR\t*v(8) USBSTOR\v(8)p(16)r(1) v(8)p(16)r(1) USBSTOR\GenericTypeString GenericTypeString”

    Vendor page, read November 12, 2026. Identifiers Generated by USBSTOR.SYS, last updated 2021-12-15.

    “Removable drives excluded from encryption Path CSP ./Device/Vendor/MSFT/BitLocker/RemovableDrivesExcludedFromEncryption GPO Not available”

Rolling it out

Pilot first

  • Encrypt one Windows computer, one Mac, one BitLocker To Go drive and one hardware-encrypted drive first, and run every test below on them before the policies reach everyone. On the pilot Mac, FileVault starts only after the user logs out or logs in (Apple: deferred enablement needs a logout or login event): ask the user to do so, and check fdesetup status afterwards.
  • Turn Deny write access to removable drives not protected by BitLocker on for a pilot group first, with the exclusion by hardware ID already assigned to the pilot backup computer. Every other unencrypted USB drive in that group becomes read-only, which is the point and also what will surprise people: tell them how to get an encrypted drive.
  • Before any backup drive holds the only copy of anything, restore one file from it on a different company computer.
  • When the pilot's tests pass, widen the assignments: the BitLocker disk encryption profile and the write-deny policy to every company Windows computer, and the FileVault and restriction policies to every company Mac. The exclusion by hardware ID stays on the backup computers only. Tell people first how to get an encrypted drive. Then run the passing and refused tests again on a computer outside the pilot group: an unencrypted USB stick is read-only there too.

Not locking yourself out

  • Confirm each Windows recovery key is in Entra ID (or Active Directory) and each Mac's personal recovery key is in Intune before relying on the device. For Macs, Microsoft says the disk encryption can start after the key is escrowed; for Windows, the recovery settings of Case 1 hold encryption until the key is stored, but the policy text names Active Directory only, so look for the key in Entra ID before you rely on the computer.
  • Keep at least two backup drives, stored apart, so one forgotten PIN or failed drive does not lose the backup. Plan as if a hardware-encrypted drive has no recovery key.
  • Backup drives in this recipe carry no password protector. If one ever does, the legacy FIPS policy on the backup computer makes that drive read-only (Case 2), so check before turning the policy on there.
  • Set a hardware-encrypted drive's administrator PIN, where the model has one, when you issue it, and keep it sealed with the media custodian.
  • Do not retire or delete the issuing computer before its removable-drive keys are backed up again from its replacement (Case 2). If it is Entra joined, deleting its Intune object also removes its own operating system volume's key protectors and leaves BitLocker suspended there.

Rolling back

  • Remove a policy's assignment: drives already encrypted stay encrypted, and only new devices stop being encrypted. Decrypting is a separate, deliberate step.
  • A drive made read-only by the write-deny policy can still be read: copy what is needed off it, encrypt it, then write to it.
  • Remove a model from the exclusion by hardware ID when it leaves the approved-media list; its drives become read-only on the backup computers again.
  • Record each change in your change log and in the media inventory.

Tests

Run these on your own systems and keep the dated results. Each says what you should see.

Should pass

  • DoOn a sample Windows computer, with a BitLocker To Go drive plugged in and unlocked, run manage-bde -status, and open the computer in Intune (Devices > All devices > the device > Monitor > Recovery keys). On a sample Mac run fdesetup status.

    ExpectWindows: for the operating system drive and each fixed drive, Protection On, the Encryption Method you set (XTS-AES), and Conversion Status Fully Encrypted (or Used Space Only Encrypted on a computer that never held CUI before encryption, or whose free space you wiped: Case 1); the BitLocker To Go drive shows the removable-drive Encryption Method you set. Intune lists a key for the operating system drive and one for each fixed drive (Drive Type), and each key ID matches manage-bde -protectors -get for that drive; a fixed drive with no key there may have gone to the user's OneDrive (Case 1). Mac: FileVault is On.

  • DoBack up to an encrypted backup drive, take it to a different company computer, unlock it with its own method and restore one file.

    ExpectThe file opens intact.

  • DoOn a backup computer that has the exclusion by hardware ID, unlock an approved hardware-encrypted drive with its PIN and write a backup to it; then restore one file from it on a different company computer.

    ExpectThe write succeeds and the file opens intact.

Should be refused

  • DoPlug an unencrypted USB stick into a company Windows computer, including a backup computer that has the exclusion, and try to save a file to it.

    ExpectRefused: the drive is mounted read-only.

  • DoOn the backup computer, unlock a hardware-encrypted drive of a model that is not on the approved-media list (not in the exclusion) and try to save a file to it.

    ExpectRefused: the drive is mounted read-only.

  • DoPlug a BitLocker To Go drive into a computer, signed in as a user, where neither the user nor the computer is in the group its SID protector names (or a computer outside the domain), and do not unlock it.

    ExpectIt stays locked and asks for an unlock method: the computer's TPM plays no part in unlocking it. On a computer or for a user in the group it would unlock by itself, which is why this test is run outside the group.

    “-ADaccountorgroup Adds a SID-based identity protector for the volume. The volume will automatically unlock if the user or computer has the proper credentials.”

  • DoEnter a wrong PIN on a hardware-encrypted drive.

    ExpectThe drive refuses to unlock.

A way around that should fail

  • DoStart a test Windows computer from a USB operating system (for example a Linux live USB) and try to read its internal drive.

    ExpectThe volume cannot be read without the recovery password.

  • DoTake a backup drive to a computer outside the company and try to open it without its unlock method.

    ExpectIt stays locked; only its own protector, its recovery key or its PIN opens it.

  • DoOn a test Mac, start recoveryOS and try to open the internal volume without the user's password or the recovery key.

    ExpectThe volume stays locked.

When the service is unreachable

  • DoWith the internet unplugged, start an encrypted Windows computer and a Mac, and unlock a hardware-encrypted drive with its PIN.

    ExpectThey unlock as normal: the TPM, the macOS password and the drive's keypad need no online service. Only fetching a recovery key from Entra ID or Intune needs the service, so keep your key retrieval procedure for an outage.

  • DoWith the network unplugged on the backup computer, unlock a SID-protected backup drive with the signed-in domain account.

    ExpectRecord what happens. If it needs the domain controller, your backup procedure must say so, or use a hardware-encrypted drive.

Recovery

  • Changesmanage-bde -forcerecovery deletes the test computer's TPM protectors, and the recovery password is seen by whoever unlocks it.

    BeforeRetrieve its recovery password from Entra ID or Active Directory as the people you allowed would, check its ID against manage-bde -protectors -get C:, and note that ID.

    DoOn a test Windows computer, run manage-bde -forcerecovery C:, which deletes the computer's TPM protectors, restart, and unlock with the recovery password.

    AfterwardsPut the TPM protector back: manage-bde -protectors -add C: -tpm (skip it if -protectors -get already lists a TPM protector), restart, and run manage-bde -status C: and manage-bde -protectors -get C:. Because the password has now been seen, replace it. Entra joined, with Client-driven recovery password rotation on (Case 1): Windows may already have rotated it after the unlock (Microsoft: rotation upon use), so compare the Numerical Password ID in -protectors -get with the one you noted; if it has not changed, use the device's BitLocker key rotation action in Intune. Domain joined: add a new one with manage-bde -protectors -add C: -recoverypassword, read its ID with -protectors -get, back it up with manage-bde -protectors -adbackup C: -id {new ID}, confirm it is in Active Directory, and only then delete the seen one with manage-bde -protectors -delete C: -id {old ID}. Always give -id: without it, -delete removes every protector, and Microsoft says that when the last protector is deleted, BitLocker protection of the drive is disabled.

    ExpectThe stored password unlocks it, and the directory's audit log records who read it (Entra ID: a KeyManagement entry for each Show Recovery Key); check that the reader holds a role your procedure names (Case 1, who can read recovery keys). Afterwards the computer starts without asking for the recovery password, protection is On, the protectors listed are the TPM and one numerical password whose ID is not the one you noted, and the directory holds that new password.

    “Forces a BitLocker-protected drive into recovery mode on restart. This command deletes all Trusted Platform Module (TPM)-related key protectors from the drive. When the computer restarts, only a recovery password or recovery key can be used to unlock the drive.”

    Vendor page, read November 12, 2026. manage-bde forcerecovery, last updated 2023-02-03. No recovery test that keeps the protectors was found on Microsoft's BitLocker recovery pages.

    “manage-bde -protectors -add [<drive>] [-forceupgrade] [-recoverypassword <numericalpassword>] [-recoverykey <pathtoexternalkeydirectory>] [-startupkey <pathtoexternalkeydirectory>] [-certificate {-cf <pathtocertificatefile>|-ct <certificatethumbprint>}] [-tpm] [-tpmandpin] … To list all key protectors for drive C, type: manage-bde -protectors -get C:”

    “-delete Deletes key protection methods used by BitLocker. All key protectors will be removed from a drive unless the optional -delete parameters are used to specify which protectors to delete. When the last protector on a drive is deleted, BitLocker protection of the drive is disabled to ensure that access to data is not lost inadvertently. … manage-bde -protectors -delete <drive> [-type {recoverypassword|externalkey|certificate|tpm|tpmandstartupkey|tpmandpin|tpmandpinandstartupkey|Password|Identity}] [-id <keyprotectorID>]”

    Vendor page, read November 12, 2026. manage-bde protectors reference.

    “With this policy you can configure a numeric recovery password rotation upon use for OS and fixed drives on Microsoft Entra joined and Microsoft Entra hybrid joined devices. Possible values are: 0: numeric recovery password rotation is turned off 1: numeric recovery password rotation upon use is on for Microsoft Entra joined devices. This is also the default value”

    Vendor page, read November 12, 2026. Configure BitLocker, Configure recovery password rotation; last updated 2025-07-29.

    “You can use an Intune device action to remotely rotate the BitLocker recovery key of a device that runs Windows 10 version 1909 or later, and Windows 11. Prerequisites for key rotation: … Microsoft Entra joined and hybrid joined devices must have key rotation enabled via BitLocker policy: Client-driven recovery password rotation = Enable rotation on Microsoft Entra joined devices or Enable rotation on Microsoft Entra ID and hybrid joined devices Save BitLocker recovery information to Microsoft Entra ID = Enabled Store recovery information in Microsoft Entra ID before enabling BitLocker = Required”

  • ChangesReplaces the drive's recovery password, whose old value has been seen: it deletes the old numerical password protector and changes the key ID the media inventory and the directory hold.

    BeforeOn the issuing computer, with the drive unlocked, run manage-bde -protectors -get E: and check that it lists the SID protector and the numerical password whose ID the media inventory holds; note that ID. Use a user and a computer outside the SID protector's group for the unlock, or the drive opens by itself.

    DoOn a computer outside the group, signed in as a user outside it, find the drive's recovery password by the key ID in the media inventory, unlock the drive with it and restore one file. Then, because the password has been seen, take the drive to the issuing computer and replace it: manage-bde -protectors -add E: -recoverypassword, read the new ID with manage-bde -protectors -get E:, back it up with manage-bde -protectors -aadbackup E: -id {new ID} (or -adbackup), confirm it is stored (Case 2), and only then delete the seen one with manage-bde -protectors -delete E: -id {old ID}.

    AfterwardsRun manage-bde -protectors -get E: and check that it lists the SID protector and one numerical password, the new one. Write the new key ID in the media inventory against the drive's serial number. Remove the drive and plug it into the computer outside the group again: it is locked and asks for its unlock method.

    ExpectThe drive unlocks and the file opens intact. Afterwards the drive has its SID protector and the new recovery password, the directory and the inventory hold the new key ID, and, removed and plugged in again outside the group, it is locked: it ends as it started, with a password nobody has seen.

    “-delete Deletes key protection methods used by BitLocker. All key protectors will be removed from a drive unless the optional -delete parameters are used to specify which protectors to delete. When the last protector on a drive is deleted, BitLocker protection of the drive is disabled to ensure that access to data is not lost inadvertently.”

    “A removable data drive will also be locked automatically when the drive is removed from the computer.”

    Vendor page, read November 12, 2026. BitLocker FAQ, last updated 2026-10-08.
  • DoAs an administrator, retrieve a test Mac's personal recovery key from Intune (the device's Monitor > Recovery keys; Microsoft shows administrators the key for Macs marked Corporate and not for Personal ones, so set the ownership first) and use it at the login window (Shift-Option-Return) or in recoveryOS. Then rotate the key, since it has now been seen: in Intune, the device's Secure > Rotate FileVault recovery key.

    ExpectThe escrowed key unlocks the Mac. After the rotation, Intune holds a new key, and the key that was used no longer works.

    “Previous keys become invalid after successful rotation … Administrators can manually rotate recovery keys: Sign in to the Microsoft Intune admin center Select Devices > All devices Select the encrypted device At the top of the device overview pane, find the row of action icons. Select Secure > Rotate FileVault recovery key.”

    Vendor page, read November 12, 2026. Intune: Encrypt macOS devices with FileVault, last updated 2026-04-15.
  • DoFor a hardware-encrypted drive, use the administrator PIN if the model has one; otherwise restore from the second backup drive. If the model's manual says the administrator PIN resets the user PIN, set a new user PIN as the manual describes and record the change in the media inventory.

    ExpectThe data is back from one of the two, which is why there are two, and the drive ends with a user PIN only its holder knows.

Evidence package: what to keep

Each record to keep once the recipe is in place: where it comes from in this recipe, what an assessor should see in it, the practices it supports, when to take it again and what it does not show. Written from the vendors' documentation: Expert CMMC has not run this configuration, and nothing here is a capture of a real system. A layout marked Illustration uses placeholder values.

  • The encryption report for every Windows computer and Mac

    ev-encryption-compliance-report

    Evidence register: Encryption compliance report

    Taken from

    Intune admin center: the encryption report, exported

    It must show
    Device name; Operating system version; Encryption state; Encryption method (XTS-AES); Recovery key escrowed (yes or no); Conversion Status of each drive (manage-bde -status) where a computer held CUI before encryption, and the free-space wipe if it was used-space-only.
    An assessor should see
    • Intune's encryption report: every company Windows computer and Mac with its encryption state, and for Windows the XTS-AES method your baseline records (256-bit or 128-bit).
    • manage-bde -status on a sample Windows computer: Protection On, the Encryption Method you set, and Conversion Status Fully Encrypted (or Used Space Only Encrypted where Case 1 allows it) for the operating system drive and each fixed drive.
    • For a computer that held CUI before it was encrypted and showed Used Space Only Encrypted: the date manage-bde -w was run.
    • fdesetup status on a sample Mac: FileVault is On.
    Supports
    SC.L2-3.13.16 [a]; AC.L2-3.1.19 [a] [b]
    Taken again
    When a computer is added, and exported again, dated, at each review on the schedule you set.
    Does not show
    That the encryption is FIPS-validated (SC.L2-3.13.11): that is the certificate record, and Case 1 records that the Windows 11 versions Microsoft still services have no module listed. Nor removable drives (the media inventory), nor a computer left on and unlocked.
  • Where each recovery key is kept and who can read it

    ev-key-escrow-report

    Evidence register: Disk encryption key escrow report

    Taken from

    Entra ID or Active Directory (Windows and BitLocker To Go), Intune (Mac), and the role assignments that can read them

    It must show
    Device or drive serial number; Key ID; Where stored (for a removable drive, the issuing computer it was backed up from); Who can read it: the roles with the BitLocker read permission and their members; Restrict non-admin users from recovering the BitLocker key(s) for their owned devices: Yes; For Macs: that users can see their own personal recovery key.
    An assessor should see
    • Each Windows computer in Intune (the device > Monitor > Recovery keys): a key for the operating system drive and one for each fixed drive, each key ID matching manage-bde -protectors -get for that drive.
    • Each BitLocker To Go drive's key ID under its issuing computer, matching the media inventory.
    • Restrict non-admin users from recovering the BitLocker key(s) for their owned devices: Yes; and the members of each role with the BitLocker read permission, matching the people your procedure names.
    • The forced-recovery test's audit log entry (KeyManagement, Show Recovery Key), by a reader your procedure names.
    • Each Mac's personal recovery key escrowed in Intune.
    Supports
    SC.L2-3.13.16 [a]; MP.L2-3.8.6 [a]; MP.L2-3.8.9 [a]
    Taken again
    When a computer or drive is encrypted, after a key is rotated or replaced, before an issuing computer is retired (each drive's key backed up again from its replacement), and at each review of who can read keys on the schedule you set.
    Does not show
    That a key unlocks its device: only the recovery tests show that. Nor a hardware-encrypted drive, which has no recovery key in the directory (plan as if it has none), nor who read a key outside the directory's audit log.
  • The certificate for each module protecting CUI at rest, or the recorded gap

    ev-cmvp-certificates

    Evidence register: CMVP certificates and vendor FIPS statements

    Taken from

    Microsoft's FIPS 140 page for your Windows version, Apple's macOS certifications page, NIST's CMVP entry for each certificate and each drive model

    • Windows version, and its certificates: Each CUI computer: Settings > System > About (the Windows version and OS build), compared with Microsoft's FIPS 140 page and NIST's certificate pages
    • Model and firmware: NIST's CMVP search (csrc.nist.gov), before buying and when each drive arrives
    It must show
    Module name and version; Certificate number; Status (Active or Historical) and the date looked up; FIPS 140-3 or 140-2; The Windows or macOS version and build, or the drive firmware, it covers; Whether Microsoft or Apple still services that version; Where none is listed: the gap and the decision recorded.
    An assessor should see
    • For each Windows version in use: what Microsoft's FIPS 140 page and NIST's certificate pages list for it, with the date looked up; where nothing is listed for a version Microsoft still services, the gap and the decision recorded.
    • For each hardware-encrypted model: the certificate number, FIPS 140-3, Active, and the firmware version it lists, matching the drives' firmware.
    • For Macs, the macOS version looked up on Apple's certifications page in the same way.
    Supports
    SC.L2-3.13.11 [a]
    Taken again
    When a Windows or macOS version changes, before a drive model is bought and when each drive arrives, and at each review on the schedule you set; each lookup dated, since a certificate can move to Historical.
    Does not show
    That a version without a certificate is validated: a recorded gap stays a gap, and a certificate for 21H2 or 22H2 does not cover a later build. Nor that the module runs in the configuration its security policy requires on your devices.
  • The removable drive write-deny setting and the exclusion by hardware ID

    ev-device-control-config

    Evidence register: Removable media control configuration

    Taken from

    Intune policy or Group Policy report

    It must show
    Deny write access to removable drives not protected by BitLocker: Enabled; The devices or groups it applies to; Removable Drives Excluded From Encryption: each entry, and the approved model it names; The backup computers the exclusion is assigned to, and no others; The date the write-deny policy was widened from the pilot group to every company Windows computer.
    An assessor should see
    • Deny write access to removable drives not protected by BitLocker: Enabled, assigned to every company Windows computer once the pilot is done, with the date it was widened.
    • Removable Drives Excluded From Encryption: one USBSTOR\ entry per approved model and firmware revision, assigned to the backup computers and no others.
    • The refused tests: an unencrypted USB stick and a hardware-encrypted drive of a model not on the list, each mounted read-only, the backup computer included; the passing test: the approved drive accepting a backup there.
    Supports
    MP.L2-3.8.7 [a]; MP.L2-3.8.6 [a]
    Taken again
    When a model joins or leaves the approved-media list, when an assignment changes, and at each configuration review on the schedule you set.
    Does not show
    Macs: the write-deny policy is a Windows policy, and Macs writing to USB drives are outside this recipe. Nor that a writable drive is a company drive: an entry names a model at a revision, so any drive of that model is writable on the backup computers, and the media inventory says which drives are the company's.
  • The media inventory and the approved-media list

    ev-media-inventory

    Evidence register: CUI media inventory

    Taken from

    Your inventory (spreadsheet or asset system)

    • Unlock method (protector) for a backup drive: On the issuing computer, right after encryption: manage-bde -protectors -add E: -sid <DOMAIN\group>
    • Store the drive's recovery password: On the issuing computer, right after the protector: manage-bde -protectors -get E: (note the ID of the Numerical Password protector), then manage-bde -protectors -aadbackup E: -id {ID} (Entra ID) or -adbackup E: -id {ID} (Active Directory)
    • Model and firmware: NIST's CMVP search (csrc.nist.gov), before buying and when each drive arrives
    It must show
    Drive serial number; Model and firmware, and whether the model is on the approved-media list; BitLocker protector type or CMVP certificate; Recovery key ID (BitLocker To Go) and the issuing computer; Custodian or holder; Storage location.
    An assessor should see
    • Each drive by serial number: model and firmware, whether the model is on the approved-media list, its protector (the SID group) or CMVP certificate, its recovery key ID and issuing computer (BitLocker To Go), its custodian or holder and its storage location.
    • At least two backup drives, stored apart.
    • The changes recorded: a drive issued, moved or retired, a model taken off the list, a recovery password replaced after the recovery test.
    Supports
    MP.L2-3.8.6 [a]; MP.L2-3.8.7 [a]; MP.L2-3.8.9 [a]
    Taken again
    Each time a drive is issued, moved, re-keyed or retired, and reconciled on the schedule you set.
    Does not show
    That a drive is encrypted: the inventory records what was done, and manage-bde -status or the model's certificate shows it. Nor drives nobody entered.
    IllustrationA layout for this record with placeholder values in angle brackets. Not a capture of a real system.
    SerialModel and firmwareOn the approved listProtector or certificateRecovery key ID and issuing computerHolderStored at
    <serial><model>, firmware <revision>YesSID protector: <DOMAIN\group><key ID>, <issuing computer><media custodian><location>
    <serial><hardware-encrypted model>, firmware <revision>YesCMVP certificate <number>None: no recovery key<holder><second location>
  • The restore and recovery test record

    ev-backup-protection-check

    Evidence register: Backup logs and protection check records

    Taken from

    Your dated test record

    It must show
    Date; Drive or computer; File restored or device recovered; Computer used; Result; Afterwards: protectors restored and keys rotated; Who did it.
    An assessor should see
    • The restore test: a file backed up to an encrypted drive opened intact on a different company computer.
    • The forced-recovery test: the stored password unlocked the computer; afterwards it starts without asking, protection is On, and the protectors are the TPM and a new numerical password that the directory holds.
    • The drive recovery test: the drive unlocked with its recovery password, then a new password added, backed up and confirmed before the one that was seen was deleted.
    • The Mac test: the escrowed key unlocked the Mac, and the key was rotated afterwards.
    • The hardware-encrypted drive: the data back from the administrator PIN or the second drive, and a new user PIN recorded where the manual calls for one.
    Supports
    MP.L2-3.8.9 [a]; SC.L2-3.13.16 [a]
    Taken again
    Before any backup drive holds the only copy of anything, then on the restore test schedule you set; each test dated.
    Does not show
    That every backup is encrypted or can be restored: each record covers the drive and file tested. Nor where backup drives are stored and how they travel, which stay with you.
    IllustrationA layout for this record with placeholder values in angle brackets. Not a capture of a real system.
    DateDrive or computerTestComputer usedResultAfterwardsWho
    <date><backup drive serial>Restore one file<a different company computer><file name> opened intactNothing to put back<name>
    <date><test computer>Forced recovery<test computer>Unlocked with the stored recovery passwordProtection On; TPM and new numerical password <new key ID> in the directory<name>
  • The dated record of each refused and bypass test, and of the tests with the service unreachable

    ev-control-test-record

    Evidence register: Control test record

    Taken from

    Your test notes, one per test

    It must show
    Date and who ran it; The test, and the computer, Mac or drive used; The result seen, and whether it is what the recipe expects; What was put back afterwards.
    An assessor should see
    • A BitLocker To Go drive plugged in outside its SID group: it stays locked and asks for an unlock method.
    • A wrong PIN on a hardware-encrypted drive: it refuses to unlock.
    • A USB operating system cannot read the computer's internal drive; a backup drive on a computer outside the company stays locked; recoveryOS does not open the Mac's volume.
    • With the network unplugged: the computers, the Mac and the hardware-encrypted drive unlock as normal, and what happened with the SID-protected drive, as seen.
    Supports
    SC.L2-3.13.16 [a]; MP.L2-3.8.6 [a]; AC.L2-3.1.19 [b]
    Taken again
    After the pilot, after each change to the encryption or removable-drive policies, and on the test schedule you set.
    Does not show
    Computers, Macs and drive models that were not tested, or a device left on and unlocked.

What this does not cover

Not covered by this recipe

  • Cloud backup services and the backup software's own encryption: check the service with Before CUI goes into a cloud service.
  • Phones and tablets.
  • Files once copied off a drive, and a computer or drive left on and unlocked.
  • Macs writing to USB drives, and a startup PIN on Windows laptops: see Before you choose this example.
  • FIPS certificates for the versions you run: on 2026-11-11 Microsoft listed none for Windows 11 builds later than 22H2 and Apple none for macOS 26 Tahoe; see Before you choose this example.

Still yours (or your provider's)

  • The media inventory, the approved-media list and the recovery key records, kept current.
  • Deciding who may read recovery keys, and reviewing that list.
  • Where backup drives are stored and how they travel (MP.L2-3.8.9, MP.L2-3.8.5).
  • The backup schedule, the number of copies and the restore test schedule.

Cost and effort

Licences
BitLocker and FileVault are part of the operating systems in the editions the catalog lists; Intune per user for the policies and key escrow (the catalog facts under Prerequisites).
Hardware
Hardware-encrypted drives for backups and transport, at least two per backup set so one can be stored away from the other; a TPM in each Windows computer.
Setup
Expert CMMC's estimate: half a day for the policies, then about fifteen minutes per drive to encrypt, record and test.
Upkeep
Check the FIPS certificate lists when Windows or macOS gets a feature update, keep the approved-media list and the exclusion in step, run the restore test on the schedule you set, and reconcile the media inventory.

No prices: they change and depend on what you already hold.

Vendor statements this rests on

The product catalog records this recipe cites, with the date each was checked. When one is reworded, the recipe is marked for review; when one is only re-checked and still says the same, the new date shows here.

  • Microsoft's FIPS 140 page lists Windows 11 versions 22H2 and 21H2 as the Windows 11 releases whose cryptographic modules completed FIPS 140 validation. Source, checked November 11, 2026.
  • NIST lists certificate #4825, the Cryptographic Primitives Library that Microsoft's FIPS page gives for Windows 11 version 21H2, as FIPS 140-2 and Historical, moved there due to sunsetting. Source, checked November 12, 2026.
  • NIST lists certificate #5410, the Cryptographic Primitives Library that Microsoft's FIPS page gives for Windows 11 version 22H2, as FIPS 140-3 and Active, with a sunset date of 8/30/2031. Source, checked November 12, 2026.
  • Microsoft's lifecycle page for Windows 11 Enterprise and Education lists servicing for version 22H2 as ended on 2025-10-14 and for version 21H2 on 2024-10-08 (Pacific time). Source, checked November 12, 2026.
  • Microsoft's lifecycle page for Windows 11 Home and Pro (which also covers Pro Education) lists servicing for version 22H2 as ended on 2024-10-08 and for version 21H2 on 2023-10-10 (Pacific time). Source, checked November 12, 2026.
  • Microsoft recommends the XTS-AES algorithm for all drives, and says BitLocker uses XTS-AES 128-bit when the encryption method policy is not configured. Source, checked November 12, 2026.
  • A BitLocker recovery password is a 48-digit number, and Microsoft's recovery overview says the option "Do not enable BitLocker until recovery information is stored in AD DS" keeps users from turning BitLocker on unless the backup of the recovery information to Entra ID or AD DS succeeds. Source, checked November 12, 2026.
  • Only BitLocker's PIN and password protectors read the legacy FIPS policy; without them Microsoft says no extra configuration is needed for a FIPS 140 approved mode. Source, checked November 11, 2026.
  • Without the legacy FIPS policy, BitLocker turns a PIN into a key with SHA2-256, which Microsoft says is not a FIPS-approved way to derive a key from a password; with the policy on it uses PBKDF2, so set the policy before creating the PIN protector. Source, checked November 11, 2026.
  • BitLocker password protectors always use iterative SHA2-256 stretching, and a password-protected removable drive mounts read-only on a computer with the legacy FIPS policy enabled. Source, checked November 11, 2026.
  • A removable drive unlocks with a password or a smart card, a SID protector (domain credentials), or automatic unlock on one computer for one user account. Source, checked November 11, 2026.
  • Removable-drive recovery keys are not stored in Entra ID or Active Directory automatically; PowerShell or manage-bde can store them there. Source, checked November 11, 2026.
  • Apple recommends a personal recovery key, which device management can escrow, rather than an institutional recovery key. Source, checked November 11, 2026.
  • With iCloud Keychain, the FileVault recovery key syncs with the user's other passwords. Source, checked November 11, 2026.
  • A FIPS 140-3 module on the Active list may be used for new and existing systems. Source, checked November 10, 2026.
  • FIPS 140-2 modules moved to the Historical list after September 21, 2026, for existing systems only. Source, checked November 10, 2026.
  • The product must be a validated module itself or use an embedded validated module; approved algorithms alone are not validation. Source, checked November 10, 2026.
  • BitLocker can be turned on in Windows Pro, Enterprise, Pro Education/SE and Education. Source, checked November 11, 2026.
  • Microsoft lists Intune (with Entra ID P1) as included in Microsoft 365 Business Premium, and in Microsoft 365 E3, E5, F3, G3 and G5, among others; it can also be bought separately. Source, checked November 11, 2026.
  • Case: Windows laptop or desktop: the computer's own drives (BitLocker), checked November 12, 2026.
  • Case: Windows removable drive (BitLocker To Go): USB sticks and external backup drives, checked November 12, 2026.
  • Case: Mac: the internal drive (FileVault), checked November 12, 2026.
  • Case: Hardware-encrypted USB drive (keypad or software unlock), checked November 12, 2026.

Expert CMMC's editorial guidance, not official text and not an endorsement of any product. Vendors change their products and pages; confirm each setting on the vendor's current page.