Area 9.3

Model the Threats Before You Build

Have we deliberately imagined how this could be attacked or misused — before it ships?

Enhanced: 3 3 controls

Who it applies to

Enter for every AI system whose letter is E or A (this area has no Baseline controls). Go as deep as your system letter, and implement in your mode.

Why it exists

Before building or deploying, systematically imagine how the system could be attacked, misused, or fail — rather than waiting to find out in production. This deliberate exercise of thinking through the ways a system could be turned against its purpose is cheap before the system exists and expensive afterwards. Complement it by imagining the scenarios in which the system could cause harm even without an attacker — misuse, edge cases, unintended consequences — and planning for them. The point is to meet the failure on paper first.

What to actually do

Controls

Enhanced 3 controls

Control 224

Conduct threat modelling before building or deploying significant AI.

EnhancedPreventiveall rolesper system

What it is

Attack and abuse paths identified and designed against from the start.

How to implement it · Steps
  1. Draw the system: users, inputs, model, data stores, connected tools, outputs and trust boundaries
  2. Per component, list attack paths: injected instructions in inputs or retrieved documents, data poisoning, extraction of model or data, misuse of tools and permissions
  3. Rate each path on likelihood and impact
  4. Decide the defence to design in for each path that matters, and add it to the design requirements
  5. Record the result in the system's threat register; repeat on significant change
How to start

Run a two-hour whiteboard session for the next significant system with whoever builds or configures it, a security person and the business owner.

Evidence

The threat model and the defences it added to the design requirements.

Mode: light / standard / full
light
The configurer and an external adviser run one session and keep a one-page record.
standard
The system owner runs it with the security lead using a standard template.
full
Security architects run it as a mandatory design activity, tracking findings to closure.

Control 225

Plan for harmful scenarios that require no attacker.

EnhancedPreventiveall rolesper system

What it is

Misuse, edge cases, and unintended consequences anticipated and mitigated.

How to implement it · Steps
  1. Ordinary misuse: users relying on outputs beyond the intended purpose or using the system for unapproved tasks
  2. Edge cases: unusual inputs, other languages, missing data, groups under-represented in the data
  3. Unintended consequences: over-reliance by reviewers, people wrongly excluded, extra load on downstream teams
  4. Rate each scenario on likelihood and severity and select those that matter
  5. Set a mitigation for each: guardrail, user guidance, human check or monitoring signal
  6. Test the selected edge cases before launch
How to start

In the threat-modelling session, add 30 minutes on one question: how could this hurt someone with nobody attacking it?

Evidence

The scenario analysis with the mitigations chosen and the edge-case test results.

Mode: light / standard / full
light
Management and the configurer list scenarios in one session, on the same page as the threats.
standard
The system owner runs it with users and support staff, recorded beside the threat model.
full
A cross-functional review including affected-group representatives, with mitigations tracked.

Control 226

Maintain a per-system AI threat register.

EnhancedPreventiveall rolesper system

What it is

Listing the named threats that apply to the system and naming, for each threat that applies the control of Domain 2 that treats it. One page at light mode.

How to implement it · Minimum content
  • System name and owner
  • Named threat: e.g. instruction injection, data poisoning, model or data extraction, excessive agent permissions, sensitive-data leakage
  • Applies: yes or no, with a one-line reason
  • Treating control: the Domain 2 control, by identifier, for each threat that applies
  • Control status: in place, planned, or gap
  • Last review date; review on any change of model, provider, data or connected tools
How to start

Take the named threats from the risk catalogue, mark which apply to the system and write next to each the Domain 2 control that treats it.

Evidence

The current threat register per system and the record of its last review.

Mode: light / standard / full
light
One page listing the threats that apply and the control treating each.
standard
A shared template per system, kept by the owner and checked by the security lead.
full
A maintained register per system in the security tooling, reviewed on every change.

Evidence

The threat models and the defences they drove; the harmful-scenario analyses and their mitigations. The threat register per system and its review on change.