February 8, 2026
EmpCo Compliance for Agencies: White-Label Solutions
From 27 September 2026, EU Directive 2024/825 (EmpCo) will tighten the rules for environmental claims in marketing. Agencies advising their clients in these areas face the challenge of understanding and implementing these new requirements. Empcora offers agencies specialised solutions to efficiently ensure their clients' compliance and generate added value.
White-Label Compliance as a Service
The EmpCo Directive prohibits, among other things, generic claims such as "sustainable" without concrete substantiation (Annex I No. 2 UCPD as amended by EmpCo) and places "climate neutral" with carbon offsetting under a per-se prohibition (Annex I No. 4a UCPD as amended by EmpCo). Agencies can use this new regulatory framework as an opportunity by offering their clients a comprehensive compliance service. This includes analysing existing marketing materials, identifying potential infringements and developing legally compliant communication strategies. By using Empcora as a white-label solution, agencies can offer these services under their own branding and thereby highlight their expertise.
Core Features for Agencies
Empcora offers agencies a range of features specifically tailored to their needs:
* **Multi-Domain Management:** Management of multiple client domains within a single account. * **Client Segregation:** Separate dashboards for each client to ensure data protection and transparency. * **White-Label Reports:** Creation of PDF reports with the agency logo and without Empcora branding. These reports can be presented to clients as proof of compliance review. * **Role and Access Management:** Assignment of specific access rights to agency staff to optimise collaboration. * **Bulk Scan:** Simultaneous review of all client domains for infringements of the EmpCo Directive. * **CSV Export:** Export of scan results for integration into external reporting tools.
Workflow and Process Integration
The integration of Empcora into the existing agency workflow is straightforward. A possible process could look as follows:
1. **Onboarding:** An initial consultation with the client in which the EmpCo Directive is explained and the prohibition list is presented. 2. **Pre-Check:** Before publication of marketing materials, an Empcora pre-check is carried out to identify potential infringements. 3. **AI Reformulation:** In the event of infringements, Empcora suggests AI-supported reformulations to make the claims legally compliant. 4. **Substantiation:** Collection of evidence for all environmental claims made, for example through recognised certifications (EU-Bio, Fairtrade, FSC, etc.). 5. **Final Approval:** Following successful review and adjustment, the marketing material is released. 6. **Continuous Monitoring:** Weekly automatic scans of all client domains to ensure compliance is maintained on an ongoing basis. In the event of infringements, both agency and client are notified immediately. 7. **Quarterly Reporting:** Creation of white-label PDF reports with all scan results, trends and practical recommendations.
Legal Basis and Case Law
The EmpCo Directive is based on the prohibition of unfair commercial practices under the UWG (§ 5, § 5b). Infringements can lead to cease-and-desist letters and claims for damages. The Bundesgerichtshof (BGH, German Federal Court of Justice) clarified in the Katjes judgment (I ZR 98/23) of 27 June 2024 that the use of "climate neutral" without transparent disclosure of offsetting measures is misleading. It is therefore crucial that agencies advise their clients of the need to make concrete and substantiated environmental claims. The substantiation obligation under Section 5 UWG and the EmpCo Directive (EU 2024/825) emphasises the importance of concrete evidence when using terms such as "natural" and "regional".
Pricing Models and ROI
Empcora offers flexible pricing models for agencies tailored to the number of domains managed. An agency subscription starts at €199/month for 10 domains and €499/month for 100 domains. Annual subscriptions offer additional cost benefits. The return on investment (ROI) for agencies is high, as they can offer compliance services as valuable added value and thereby deepen their client relationships. A client typically pays €1,500–3,500/month to the agency, while the costs for the compliance tool are €50–200/month per client.
Conclusion and Practical Recommendations
Agencies can view the EmpCo Directive not only as a challenge but also as an opportunity. By implementing Empcora as a white-label solution, they can offer their clients a comprehensive compliance service, underline their expertise and build long-term business relationships. It is advisable to familiarise yourself with the new requirements at an early stage and train agency staff accordingly. Proactive client advisory regarding the EmpCo Directive will pay off in the long term and strengthen trust in the agency.