I've never seen .emacs anywhere other than $HOME/.emacs, or seen Emacs write files outside $HOME/.emacs.d. In what situation does Emacs use $HOME/.config/?
I would then say emacs supports XDG, but doesn't use it by default, right?
This is fair behaviour IMO, because migrating configs automatically might break user setups.
Refer to section 50.4.4 (How Emacs Finds Your Init File) of the manual for more information.