a division without units ...

[KeefM]

It comes to pass from time to time in BE games (ie it is not that rare), that a divisional commander remains on-table even after all their units are destroyed or have left the table; most often this occurs with smaller divisions.

So, does this division with no units activate in the divisional command phase ?

It would be my view that they don't activate, but the rules are silent on this point. Actually, the rules seem to indicate that the division would activate as activation is not contingent on being able to move/use any units (and which also happens from time to time due to prior game circumstances).

Indeed, I would even be tempted to go one step further than not allowing a lonely commander to activate but also count that Divisional Commander as lost (in effect giving a victory point bonus for wiping out the division by awarding VPs for the "lost" divisional commander).

[Adrian Steer]

The usual practice when this sort of thing happens is that the commander is removed from play but doesn't count lost( probably sacked though!)and the division is discounted from performing any further actions but you're right can't see it mentioned in the rules but that's how I'd play it