Why Array Modifier can't work with empties for easy array instances?

I know there is a rule that says " modifiers do not affect objects , they affect geometries (i.e. object’s data). Since empties have no data/geometry, they cannot have modifiers…"

But, could developers break that rule in order to work with empty elements and modifiers? (at least some of them, for example Array in conjunction with Warp)

I know there are workarounds there, but they require more work or add extra vertices to complex arrays of elements.

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