Who enforces EmpCo?

Enforcement does not run through a supervisory authority but through competition law. Competitors, consumer associations and qualified entities can issue warnings and bring actions. There is therefore no prior review, only a risk after the fact that can be limited by robust evidence.

In practice this means the evidence is not requested before publication but after a warning letter, and then at short notice. Anyone who first has to obtain it at that point does not have it in time. Certification under a published programme is therefore less a marketing question than a question of having your proof ready.