Coding does not count towards the word count.
For Ren’Py VN’s, if someone accuses you of being under 2,000 words or circumventing the requirement, we can easily use a function to count how many words of dialogue there are along with adding up the number of times characters’ names are being displayed.
For other engines, if someone accuses you of being under 2,000 words or circumventing the requirement, an Administrator will play the VN and manually count the number of words.
Remember that you are innocent until proven guilty in these scenarios.