Before attaining the first bhūmi, bodhisattvas have not yet eradicated afflictions; there are still slight afflictions that may at times manifest. In severe cases, they may even create relatively great unwholesome karma. Such great unwholesome karma is generally related to the cultivation and realization of the Buddha-dharma; great unwholesome karma in worldly matters is generally no longer created—for example, things like killing and arson. Even those who have not eradicated the view of self (satkāya-dṛṣṭi) would not create such great unwholesome karma, and neither would those who do not study Buddhism.
The unwholesome karma that bodhisattvas before the first bhūmi are relatively prone to creating is roughly: altering the object and course of the Buddha's cultivation and realization, expounding dharma meanings that are not the Buddha's intent, distorting the Buddha's teachings, and thereby harming the Dharmakāya and the wisdom-life of sentient beings, and so on. There is also mutual contention over certain things; jealousy still exists, and they may still create some karma of slander.
Regarding this point, several Buddhist sūtras record the causes, conditions, and retributions of unwholesome karma created by bodhisattvas, and the retributions were extremely severe.
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