The phase-in is staged by index membership rather than by market capitalisation alone, so the first question is simply whether you are in scope this year.
One thing is already mandatory for everyone: Scope 1 and Scope 2 greenhouse-gas emissions have been required of every Main Board and GEM issuer for financial years beginning on or after 1 January 2025. What is still phasing in is the broader climate disclosure, and that is where the governance questions sit.
Why the governance parts matter more than the metrics
Emissions figures are the visible part. The requirements that cause difficulty are the ones about board oversight, risk management process, targets and how the numbers were assured. Those are governance questions, and they are the ones an auditor or an investor will test.
What this means for you
If the sustainability report is produced by a consultant in isolation from the risk register and the board papers, the disclosure will not hold together. The remedy is procedural, not editorial — connect the reporting cycle to the governance cycle.