Foreseeable misuse analysis asks what users, administrators, connected systems or technical processes are realistically likely to do even when that behaviour is not the preferred use described by the manufacturer. Useful scenarios include predictable misconfiguration, exposure of management interfaces, repeated reuse of insecure settings, connection to common external systems and other behaviour that materially changes cybersecurity risk.
Article 13 Uses the Term Reasonably Foreseeable Use
The legal terminology needs to be handled carefully. Article 13 requires the cybersecurity risk assessment to analyse risks based on intended purpose and reasonably foreseeable use. Article 3 defines reasonably foreseeable use as use that is not necessarily the intended purpose specified by the manufacturer but is likely to result from reasonably foreseeable human behaviour or technical operations or interactions. This concept prevents a risk assessment from assuming only ideal operation. The analysis should consider realistic behaviour and technical interactions beyond the exact intended-use description.
- Use Article 13 terminology accurately.
- Consider foreseeable human behaviour.
- Consider foreseeable technical operations.
- Consider foreseeable technical interactions.
- Do not limit the assessment to ideal use.
Annex II Separately Refers to Reasonably Foreseeable Misuse
Annex II point 5 uses the wording reasonably foreseeable misuse when describing information that should accompany the product. It requires information about known or foreseeable circumstances related to use in accordance with intended purpose or under conditions of reasonably foreseeable misuse that may lead to significant cybersecurity risks. The two provisions serve related but different functions. Article 13 establishes the risk-analysis basis, while Annex II helps users understand circumstances that can create significant cybersecurity risk.
- Article 13: reasonably foreseeable use.
- Annex II: reasonably foreseeable misuse.
- Keep both concepts connected to product risk.
- Avoid presenting the terms as though they appear identically everywhere.
Foreseeable Does Not Mean Every Possible Behaviour
The assessment does not need to catalogue every physically or logically possible misuse. The focus is behaviour or interaction that is reasonably foreseeable. Evidence can come from common industry deployment patterns, support experience, product testing, similar products, administrator practices and ordinary human behaviour. Extremely contrived scenarios can be recorded separately where useful, but they should not crowd out common conditions that are much more likely to influence cybersecurity risk.
- Prioritise realistic behaviour.
- Use product and industry experience.
- Consider frequency and plausibility.
- Separate foreseeable scenarios from remote hypotheticals.
Predictable Misconfiguration Can Be Foreseeable
Users and administrators often change configuration in predictable ways. They may expose management services, select weak access policies, disable an optional security feature, connect the product to an untrusted network or leave a temporary configuration in production. Secure defaults can reduce some of these risks, but the risk assessment should still consider configuration states that users are reasonably likely to create. Where a dangerous state is easy to reach, the manufacturer should consider whether stronger technical controls or clearer warnings are appropriate.
- Identify common insecure configurations.
- Identify easy-to-reach dangerous states.
- Review administrative workflows.
- Use secure defaults to reduce foreseeable risk.
- Provide warnings where configuration still matters.
Exposure of Interfaces Can Be Foreseeable
An interface documented for local management can sometimes become internet-accessible because of common network configuration, port forwarding, cloud tunnelling or deployment practices. If such exposure is reasonably foreseeable, the manufacturer should not automatically assume that local placement removes the security risk. The risk assessment should determine whether the interface still requires authentication, rate control, attack-surface reduction or other safeguards appropriate to the foreseeable environment.
- Consider local interfaces becoming remotely reachable.
- Consider common network deployment patterns.
- Review assumptions about trusted networks.
- Protect high-risk interfaces proportionately.
Connected Systems Can Create Foreseeable Interactions
Article 3's definition expressly includes technical operations or interactions. A product can therefore encounter foreseeable behaviour that does not come directly from a human user. Connected devices, automated clients, APIs, scheduled jobs, management platforms or retry mechanisms can create interactions that alter cybersecurity risk. Manufacturers should identify common interoperability and automation patterns and determine whether unexpected input rates, malformed data, repeated commands or dependency failures create relevant attack or resilience scenarios.
- Identify automated clients.
- Identify connected-device behaviour.
- Identify scheduled and repeated operations.
- Consider malformed or unexpected interactions.
- Consider dependency failure behaviour.
Foreseeable Misuse Is Not the Same as a Malicious Attack
Misuse and hostile attack should not be collapsed into one category. A user can misuse a product without malicious intent, for example by deploying it outside the expected environment or weakening a configuration for convenience. An attacker can then exploit the resulting exposure. The risk assessment should distinguish the misuse condition from the attack scenario so that product teams understand whether the manufacturer can reduce the misuse likelihood, reduce the resulting exposure or contain the attack itself.
- Identify non-malicious misuse conditions.
- Identify malicious attack scenarios separately.
- Map controls to the correct stage.
- Consider how misuse enables attack paths.
Use Product Evidence to Identify Foreseeable Scenarios
Product teams can use support tickets, beta testing, usability studies, field observations, common deployment guides, vulnerability reports and configuration telemetry where appropriately collected to understand how products are actually used. Similar products can also reveal recurring misuse patterns. The objective is to base foreseeable-use analysis on evidence rather than imagination alone. The evidence source and resulting conclusion can be recorded in the risk assessment where the scenario materially affects cybersecurity.
- Support and field experience.
- Usability testing.
- Deployment patterns.
- Researcher reports.
- Similar-product experience.
- Security test observations.
Connect Foreseeable Misuse to Annex I Controls
A foreseeable misuse scenario becomes useful when it changes a security decision. Predictable exposure of an interface can affect authentication and attack-surface controls. Predictable disabling of security updates can affect user information and update design. Repeated weak configuration choices can justify stronger secure defaults. Each material scenario should therefore identify the relevant Annex I requirement, existing control and remaining risk rather than being stored as an isolated misuse list.
- Map misuse scenarios to Annex I requirements.
- Identify existing preventative controls.
- Identify detection or mitigation controls.
- Assess residual risk.
- Update user information where necessary.
Document Significant Circumstances for Users
Annex II requires information about known or foreseeable circumstances related to intended use or reasonably foreseeable misuse that may lead to significant cybersecurity risks. Where a risk depends materially on how the user deploys or operates the product, user instructions should communicate the relevant condition clearly. Documentation should not be used as a substitute for reasonable product security controls, but it can help users avoid or manage risks that genuinely depend on deployment choices.
- Identify significant user-controlled circumstances.
- Describe the cybersecurity consequence.
- Provide practical risk-reduction instructions.
- Keep instructions aligned with actual product behaviour.
Maintain a Foreseeable-Use and Misuse Register
A practical register can capture scenario identifier, behaviour or interaction, evidence supporting foreseeability, relevant product version, affected asset, security consequence, related Annex I requirement, control, user-information need and review status. The CRA does not prescribe such a register, but it provides useful traceability between Article 13 risk analysis and Annex II user information. Product changes can then be reviewed against existing scenarios rather than rebuilding the analysis from the beginning.
- Scenario identifier.
- Foreseeable behaviour or interaction.
- Basis for foreseeability.
- Affected assets.
- Cybersecurity consequence.
- Mapped control.
- User-information requirement.
- Review status.
Official sources
Read the full legal text and Commission material for precise wording, qualifications and updates.