What is the complement of ACFG
First of all, the complement of a set is only defined when there is an (understood) universal set. In this case, the universal set is probably the set of all context-free grammars, but it could plausibly be the set of all grammars.

The complement of a set $A$ given a universal set $U$ is defined as the set of elements in $U$ but not in $A$; it is understood that all elements in $A$ are also in $U$. So if $U$ is the set of all context-free grammars, then the complement of ACFG is the set of all context-free grammars $G$ such that $L(G) \neq \Sigma^*$.
If $U$ is the set of all grammars then the complement of ACFG is slightly more complicated: it consists of all non-context-free grammars together with all context-free grammars $G$ such that $L(G) \neq \Sigma^*$.

If $G$ is a context-free grammar and $L(G) = \emptyset$ then $G$ certainly belongs to the complement of ACFG1; but other context-free grammars also belong there.

1This actually depends on your definition of grammar and on the value of $\Sigma$. If $\Sigma$ is understood and non-empty then what I wrote is correct; if $\Sigma$ is part of the grammar and is always non-empty, again what I wrote is correct; but if $\Sigma$ could be empty, then $\Sigma^* = \emptyset$, so what I wrote is wrong.