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 Campaigns may have to be stopped at short notice, while communication materials may need to be amended or withdrawn altogether.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.
