If you, or your lucky recipient, are not practised gardeners, or won’t be planting the rose in the ground, then a potted plant, arriving in the Spring, will be easier. There’s maybe not an enormous amount of point to receiving a bare root rose in the middle of winter, if someone has to go out in the freezing cold to transfer it to a pot. (Unless you need an excuse to hang out in your cosy greenhouse.)
If you know what you’re doing and have ground to plant in, then bare root is excellent.