FYI BitLocker is on by default in Windows 11. The defaults will also upload the BitLocker key to a Microsoft Account if available. This is why the FBI can compel Microsoft to provide the keys. It's possible, perhaps even likely, that the suspect didn't even know they had an encrypted laptop. Journalists love the "Microsoft gave " framing because it makes Microsoft sound like they're handing these out because they lik…
Once the feature exists, it's much easier to use it by accident. A finger slip, a bug in a Windows update, or even a cosmic ray flipping the "do not upload" bit in memory, could all lead to the key being accidentally uploaded. And it's a silent failure: the security properties of the system have changed without any visible indication that it happened.