Kai Klicker-Brunner, Author at Faktor 3 AG

EmpCo: Why green claims are now coming under scrutiny

Corporate sustainability communications are entering a new phase. With the Empowering Consumers Directive, known as EmpCo, the EU is significantly tightening the rules around sustainability-related claims. From 27 September 2026, new standards will apply in relation to transparency, verifiability and credibility.
Terms such as ‘sustainable’, ‘environmentally friendly’, ‘green’ or ‘climate-neutral’ will only be permitted if they can be substantiated. In other words, companies must be able to provide clear and precise evidence for the claims they make.

The directive will have far-reaching implications for marketing, corporate communications, brand management and sales – and it is already reshaping the rules of communicative credibility. In the future, sustainability communication will need to do more than attract attention and support brand positioning. It will also need to be robust, traceable and properly documented.

Virtually any communication that touches on sustainability may fall within scope. Particular areas of concern include:

General environmental claims such as ‘sustainable’ or ‘environmentally friendly’
Climate-neutrality claims
Forward-looking commitments such as “Net zero by 2035”
Labels and certifications
Insufficient transparency around data sources and methodology

EmpCo: Sustainability communication becomes a matter of reputation and liability

Once the EmpCo Directive comes into force, many market observers expect stricter scrutiny and a growing number of warnings from competitors and industry associations. The potential consequences range from injunctions and claims for damages to significant reputational harm. Campaigns may have to be stopped at short notice, while communication materials may need to be amended or withdrawn altogether.

This creates a particular challenge for communicative brand management. Companies must continue to talk about sustainability, but without exposing themselves to unnecessary risk. What is needed are robust communication standards that combine regulatory requirements with credible brand management. This calls for a structured assessment of existing statements, risks and communication opportunities.

Companies need to understand:

Which statements are particularly sensitive
Which claims can be substantiated
Where transparency is lacking
How messages can be phrased in a clearer and more credible way
Which processes will be required in the future

At the same time, companies must remain able to communicate effectively. Sustainability communication should not be viewed solely through a legal lens. It remains a central element of reputation, trust and brand positioning. EmpCo therefore makes strategically structured and clearly prioritised sustainability communication essential.

Factor 3 develops EmpCo-compliant strategic communication

As challenging as the new requirements may appear, they also offer companies an opportunity to develop their sustainability communication strategically. Those that establish robust standards early on will not only reduce risk, but also strengthen trust and differentiation over the long term.

At Faktor 3, we support companies in systematically preparing their sustainability communication for the new requirements. Our consulting approach combines communication strategy, risk analysis and concrete operational implementation.

Our services include:

EmpCo readiness and risk analysis – we systematically identify existing and potentially critical sustainability statements, claims and labels
Development of a risk scale – we create a practical assessment framework tailored to the industry, communication channels and the company’s specific circumstances.
Strategic sustainability messaging – we develop clear, credible and EmpCo-compliant core messages designed to remain viable over the long term.
Piloting and adaption of communication materials – we apply the agreed standards to real-world materials, including specific recommendations for wording and optimisation.
Empowerment of communications and marketing teams – we raise awareness among relevant stakeholders and support the development of internal guidelines and processes for future sustainability communications.
Optional legal support from partner law firms – on request, we can complement our communications advice with legal expertise.

In conclusion:
Our training programs are grounded in the reality of leadership. We bring together expertise in executive positioning, strategy, and crisis management—and make it directly applicable to your day-to-day work.

Interested in discussing EmpCo and your communication risks?
We would be delighted to hear from you.

Simon Philipps

Senior Consultant & Mediatrainer

s.philipps@faktor3.de

+49 (0)40 67 94 46 – 6328

Tailored Networks for Expansion in Europe

International companies are facing a new reality. Global markets are fragmenting, and geopolitical tensions, new trade and sanctions regimes, as well as varying regulatory frameworks are fundamentally changing the conditions for growth and expansion.

While the U.S. is increasingly acting unilaterally in terms of industrial and trade policy and China is linking market access more closely to political and regulatory expectations, Europe is evolving into one of the world’s most complex economic and regulatory environments.

Europe is becoming a benchmark for international brands

As a highly regulated market with significant political and social diversity, Europe is becoming a benchmark for many international companies in shaping their global market and communication strategies. Those who operate successfully here must reconcile global goals with national political, regulatory, and societal expectations.

International mobility, technology, and industrial companies, in particular, are under close scrutiny in Europe. Regulatory requirements, industrial policy objectives, sustainability demands, and public debates are closely intertwined here. Studies on media consumption by Generation Z reveal that this generation is “always-on,” Wir holen sie am effektivsten mit regelmäßigen, kurzen Updates zum Unternehmensgeschehen ab und bedienen damit den Wunsch, nahe am Newspuls des Unternehmens zu sein.Andere interne Zielgruppen dagegen wünschen sich seltenere und gebündelte Informationen. In contrast, other internal target groups may prefer less frequent but more comprehensive updates. Our cross-generational approach—though it might sound unconventional—is to communicate as little as possible but as much as necessary for each target group. By carefully selecting and targeting communications, we enhance message relevance and reduce the risk of information overload.

Strategic Communication as a Success Factor for Market Entry in Europe

These conditions are also changing the role of communication. It is no longer merely a supporting tool, but a strategic success factor. Communication provides direction in complex markets, translates global strategies into local relevance, and connects market, brand, and corporate communication with regulatory and societal realities.

Traditional global network agencies often encounter structural limitations in this environment. Rigid network structures, numerous interfaces, standardized processes, and varying national industry focuses make it difficult to achieve communication that is both locally relevant and consistent across different markets.

Faktor 3 acts as the lead agency in Europe

As the lead agency, we at Faktor 3 manage communication in Europe and combine strategic leadership with a strong local presence. We develop central narratives, positioning, and communication principles and, together with selected agencies, translate them precisely into the respective markets.

In doing so, we collaborate with experienced partners from across Europe who possess a deep understanding of the market, media, and stakeholders. Clear governance structures, short decision-making paths, and a shared understanding of quality ensure consistency, relevance, and effectiveness across countries and disciplines.

Our approach is integrated. We combine brand and corporate communications, employer branding, internal communications, as well as change, transformation, and crisis communications into a holistic communications model that remains viable even in politically or regulatory-sensitive contexts.

Our Services:

Strategic communications consulting for international brands – we support market entry, repositioning, and growth in Europe
European lead agency as a single point of contact – we centrally manage international communications projects, ensuring quality assurance
Establishment and management of client-specific, agile agency networks – we have an extensive network of selected local partner agencies in relevant markets
Local market expertise with global consistency – we bring a deep understanding of local markets, media, and stakeholders and align global communications coherently with these
Proven industry expertise, particularly in the technology and mobility sectors – thanks to our many years of experience in complex, regulated markets, we deliver results with high strategic and public relevance

Interested in discussing European agency networks? We look forward to hearing from you.

Kai Klicker-Brunner

Head of Corporate Affairs

hallo@faktor3.de

+49 40 67 94 46 0

The new role of corporate affairs in the intersection of innovation, regulation, and communication

At this year’s World Economic Forum in Davos, Microsoft CEO Satya Nadella highlighted the responsibility of tech companies to “consider the unintended consequences of new technology” and to communicate these openly. He also voiced hope for global agreement on common norms for artificial intelligence. Microsoft has long been a vocal advocate for the regulation of certain technologies, such as facial recognition software.

t’s uncommon for companies to call for government regulation of their own innovations, but Microsoft recognizes a crucial insight that many others are still grappling with innovation, regulation, and communication must be addressed as an interconnected triad.

Lack of Trust in Innovations

The critical interplay of innovation, regulation, and communication is underscored by the latest Edelman “Trust Barometer.” The report reveals a significant lack of trust in innovations among Germans: only 17% support AI, and just 20% back gene-based medicine, while 50% and 45%, respectively, fundamentally reject these technologies.

The report highlights that acceptance of innovations increases when people believe they are managed well—yet currently, only 14% of Germans have this confidence. A positive takeaway for decision-makers is that the economy is seen as the most trusted sector to implement innovations safely and responsibly. However, over half of respondent’s desire closer cooperation between companies and the government in introducing new technologies. Moreover, a clear majority (59%) expect CEOs to address the societal impacts of these advancements publicly.

Corporate affairs become the key to sustainable success.
Sabine Richter – Founder Faktor 3

These numbers underscore a critical insight: at the intersection of innovation, regulation, and communication, corporate affairs play a pivotal role in building trust—an essential component for sustainable progress. It’s not just about adhering to compliance requirements but about embedding these requirements into a robust communication strategy.

The trend towards proactive innovation regulation, as seen with initiatives like the AI Act, DMA, and DAS, presents companies with a unique opportunity to foster trust through transparent and proactive communication. By engaging in preventive dialogue and offering political advice grounded in practical experience, innovative companies can share their expertise and build essential know-how. This approach helps to mitigate the risks of excessive regulation—often driven by fear—by fostering informed, balanced regulatory frameworks.

Regulation as an opportunity

Modern innovation regulation demands something not traditionally found in the German and European regulatory frameworks: flexible, adaptive laws that can evolve with technological advancements. The AI Act begins to address this with initial flexible approaches, and the DMA’s emphasis on “preventive stakeholder dialogue” in competition issues signals progress in the right direction. For future regulations, it is essential for companies to actively advocate for these adaptive approaches to ensure they retain their license to operate and avoid the pitfalls of excessive regulation.

In this context, corporate affairs play a crucial role. It helps clarify the company’s stance on regulatory matters and underscores the importance of compliance. Ideally, regulation should be viewed not as a constraint but as an opportunity to enhance transparency in innovation processes and demonstrate a commitment to responsible advancement.

Support in corporate affairs

We offer a comprehensive array of services designed to support companies in achieving sustainable success. At the heart of our approach is strategic, well-founded communication.

Our services:

Stakeholder engagement: Effective corporate affairs strategies hinge on robust stakeholder engagement. This involves clear and proactive communication with regulatory authorities, customers, investors, and the public to build understanding and support for both self-imposed regulations and the company’s responses.
Transparency and accountability: In an era where regulation increasingly demands transparency and accountability, it’s crucial for companies to embed these values into their communication strategies. Openly presenting compliance efforts and innovation processes not only fosters trust but also showcases responsible management of potential risks and societal impacts.
Risk Communication: Corporate affairs must adeptly simplify complex regulatory issues, clearly conveying how the company manages potential risks and aligns its innovations with regulatory requirements. This involves making regulatory topics comprehensible and demonstrating a proactive approach to risk management.
Internal Communication and Training: Communicating values and guidelines related to regulation internally is essential for ensuring a unified and effective external brand image. Proper training and internal messaging help maintain consistency and coherence in how the company presents itself.
Building Reputation and Brand Positioning: Integrating regulatory topics into the brand strategy can enhance a company’s reputation as a responsible and innovative leader. By positioning regulatory compliance and innovation as core elements of the brand, companies can strengthen their market presence and appeal.

Interested in discussing corporate affairs? We look forward to hearing from you.