Counterfactual explanations provide a popular method for analyzing the predictions of black-box systems, and they can offer the opportunity for computational recourse by suggesting actionable changes on how to change the input to obtain a different (i.e. more favorable) system output. However, recent work highlighted their vulnerability to different types of manipulations. This work studies the vulnerability of counterfactual explanations to data poisoning. We formalize data poisoning in the context of counterfactual explanations for increasing the cost of recourse on three different levels: locally for a single instance, or a sub-group of instances, or globally for all instances. We demonstrate that state-of-the-art counterfactual generation methods \& toolboxes are vulnerable to such data poisoning.

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