ING Groep (NYSE: ING) outlines 2025 risks, ESG and cyber focus
Filing Impact
Filing Sentiment
Form Type
20-F
ING Groep N.V. files its 2025 Form 20-F, describing its global banking operations, capital markets listings and detailed risk profile. The group serves 40 million clients in 38 countries, with 2,902,437,688 ordinary shares outstanding as of year-end.
Financial information for SEC reporting is prepared under IFRS-IASB, with statutory accounts under IFRS‑EU, and the report explains differences due to the IAS 39 hedge accounting carve‑out. Extensive risk factors cover macroeconomic volatility, interest-rate and benchmark shifts, regulation and supervision, litigation and tax exposure, ESG and climate risks, cyber and IT threats, deposit guarantee and resolution regimes, and intense competition. ING also notes its wholesale activities in Russia and Ukraine and its previously announced intention to sell its Russian business, highlighting uncertainty around required approvals and timing.
Positive
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
FORM 20-F
(Mark One)
REGISTRATION STATEMENT PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934 |
OR
ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934 |
For the fiscal year ended 31 December 2025
OR
TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934 |
OR
SHELL COMPANY REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934 |
Commission File Number: 001-14642
(Exact name of Registrant as specified in its charter)
ING GROUP
(Translation of Registrant’s name into English)
The Netherlands
(Jurisdiction of incorporation or organization)
The Netherlands
(Address of principal executive offices)
Telephone: + 31 20 564 7705
E-mail: Erwin.Olijslager@ing.com
The Netherlands
(Name, Telephone, E-mail and/or Facsimile number and Address of Company Contact Person)
Securities registered or to be registered pursuant to Section 12(b) of the Act.
Title of each class | Trading symbols | Name of each exchange on which registered | ||
1.726% Callable Fixed-to-Floating Rate Senior Notes due 2027 | ||||
2.727% Callable Fixed-to-Floating Rate Senior Notes due 2032 | ||||
4.017% Callable Fixed-to-Floating Rate Senior Notes due 2028 | ||||
4.252% Callable Fixed-to-Floating Rate Senior Notes due 2033 | ||||
6.083% Callable Fixed-to-Floating Rate Senior Notes due 2027 | ||||
$500,000,000 Callable Floating Rate Senior Notes due 2027 | ||||
5.335% Callable Fixed-to-Floating Rate Senior Notes due 2030 | ||||
5.550% Callable Fixed-to-Floating Rate Senior Notes due 2035 | ||||
4.858% Callable Fixed-to-Floating Rate Senior Notes due 2029 | ||||
5.066% Callable Fixed-to-Floating Rate Senior Notes due 2031 | ||||
5.525% Callable Fixed-to-Floating Rate Senior Notes due 2036 | ||||
(i)Not for trading, but only in connection with the registration of American Depositary Shares representing
such ordinary shares, pursuant to the requirements of the Securities and Exchange Commission.
Securities registered or to be registered pursuant to Section 12(g) of the Act.None
Securities for which there is a reporting obligation pursuant to Section 15(d) of the Act. None
Indicate the number of outstanding shares of each of the issuer’s classes of capital or common stock as of the
close of the period covered by the annual report.
Ordinary Shares, nominal value EUR 0.01 per Ordinary Share 2,902,437,688
Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities
Act. ☒ Yes ☐ No
If this report is an annual or transition report, indicate by check mark if the registrant is not required to file reports
pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934. ☐ Yes ☒ No
Note — Checking the box above will not relieve any registrant required to file reports pursuant to Section 13 or
15(d) of the Securities Exchange Act of 1934 from their obligations under those Sections.
Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of
the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant
was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days.
☒ Yes ☐ No
Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to
be submitted pursuant to Rule 405 of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or
for such shorter period that the registrant was required to submit and post such files). ☒ Yes ☐ No
Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated
filer, or an emerging growth company. See definition of “large accelerated filer,” accelerated filer,” and “emerging
growth company” in Rule 12b-2 of the Exchange Act.
If an emerging growth company that prepares its financial statements in accordance with U.S. GAAP, indicate by
check mark if the registrant has elected not to use the extended transition period for complying with any new or
revised financial accounting standards† provided pursuant to Section 13(a) of the Exchange Act. ☐
† | The term “new or revised financial accounting standard” refers to any update issued by the Financial Accounting Standards Board to its Accounting Standards Codification after April 5, 2012. |
Indicate by check mark whether the registrant has filed a report on and attestation to its management’s
assessment of the effectiveness of its internal control over financial reporting under Section 404(b) of the
Sarbanes-Oxley Act (15 U.S.C.7262(b)) by the registered public accounting firm that prepared or issued its audit
report. ☒
If securities are registered pursuant to Section 12(b) of the Act, indicate by check mark whether the financial
statements of the registrant included in the filing reflect the correction of an error to previously issued financial
statements. ☐
Indicate by check mark whether any of those error corrections are restatements that required a recovery analysis
of incentive based compensation received by any of the registrant’s executive officers during the relevant recovery
period pursuant to §240.10D-1(b). ☐
Indicate by check mark which basis of accounting the registrant has used to prepare the financial statements
included in this filing:
U.S. GAAP ☐ | by the International Accounting Standards Board ☒ | Other ☐ |
If “Other” has been checked in response to the previous question, indicate by check mark which financial
statement item the registrant has elected to follow.
☐ Item 17 ☐ Item 18
If this is an annual report, indicate by check mark whether the registrant is a shell company (as defined in Rule
12b-2 of the Exchange Act). ☐ Yes ☒ No
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 5 |
Contents
Part I
Presentation of information | 6 | |
Cautionary Statement with respect to Forward- looking Statements | 7 | |
1 | Identity of Directors, Senior Management and Advisors | 10 |
2 | Offer Statistics and Expected Timetable | 10 |
3 | Key Information | 11 |
4 | Information on the Company | 28 |
4A | Unresolved Staff comments | 58 |
5 | Operating and Financial Review and Prospects | 59 |
6 | Directors, Senior Management and Employees | 75 |
7 | Major Shareholders and Related Party Transactions | 108 |
8 | Financial Information | 110 |
9 | The Offer and Listing | 111 |
10 | Additional Information | 112 |
11 | Quantitative and Qualitative Disclosure about Market Risk | 117 |
12 | Description of Securities other than Equity Securities | 118 |
Part II
13 | Defaults, Dividend Arrearages and Delinquencies | 121 |
14 | Material Modifications to the Rights of Security Holders and Use of Proceeds | 121 |
15 | Controls and Procedures | 122 |
16A | Audit Committee Financial Expert | 124 |
16B | Code of Ethics | 125 |
16C | Principal Accountant Fees and Services | 126 |
16D | Exemptions from the Listing Standards for Audit Committees | 127 |
16E | Purchases of Equity Securities s by the Issuer and Affiliated Purchasers | 128 |
16F | Change in Registrant's Certifying Accountant | 130 |
16G | Corporate Governance | 131 |
16H | Mine Safety Disclosure | 133 |
16I | Disclosure Regarding Foreign Jurisdictions that Prevent Inspections | 134 |
16J | Insider Trading Policies | 135 |
16K | Cybersecurity | 136 |
Part III
17 | Consolidated Financial Statements | 139 | |
18 | Consolidated Financial Statements | 140 | |
19 | Exhibits | 141 |
Additional information
Capital management | 146 | |
Risk management | 149 | |
Selected Statistical Information on Banking Operations | 212 |
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 6 |
Presentation of information
In this Annual Report, and unless otherwise stated or the context
otherwise dictates, references to "ING Groep N.V.", "ING Groep NV", "ING
Groep" and "ING Group" refer to ING Groep NV and references to "ING", the
"Company", the "Group", "we" and "us" refer to ING Groep NV and its
consolidated subsidiaries. ING Groep N.V.'s primary banking subsidiary is
ING Bank N.V. (together with its consolidated subsidiaries, "ING Bank").
References to "Executive Board or EB" and "Supervisory Board or SB" refer
to the Executive Board or Supervisory Board of ING Groep N.V.,
respectively.
ING presents its consolidated financial statements in euros, the currency of
the European Economic and Monetary Union. Unless otherwise specified or
the context otherwise requires, references to “$”, “US$” and “Dollars” are
to the United States dollars and references to "€" and “EUR” are to euros.
ING prepares financial information in accordance with International
Financial Reporting Standards as issued by the International Accounting
Standards Board (“IFRS-IASB”) for purposes of reporting with the U.S.
Securities and Exchange Commission (“SEC”), including financial
information contained in this Annual Report on Form 20-F. ING Group’s
accounting policies and its use of various options under IFRS-IASB are
described under Note '1.2 Basis of preparation of the Consolidated
financial statements’ in the consolidated financial statements. In this
document the term “IFRS-IASB” is used to refer to IFRS-IASB as applied by
ING Group.
The published 2025 Financial Statements of ING Group, however, are
prepared in accordance with IFRS-EU. IFRS-EU refers to International
Financial Reporting Standards (“IFRS”) as adopted by the European Union
(“EU”), including the decisions ING Group made with regard to the options
available under IFRS as adopted by the EU (IFRS-EU).
IFRS-EU differs from IFRS-IASB, in respect of certain paragraphs in IAS 39
‘Financial Instruments: Recognition and Measurement’ regarding hedge
accounting for portfolio hedges of interest rate risk. Under IFRS-EU, ING
Group applies fair value hedge accounting for portfolio hedges of interest
rate risk (fair value macro hedges) in accordance with the EU “carve-out”
version of IAS 39. Under the EU “IAS 39 carve-out”, hedge accounting may
be applied, in respect of fair value macro hedges, to core deposits and
hedge ineffectiveness is only recognised when the revised estimate of the
amount of cash flows in scheduled time buckets falls below the original
designated amount of that bucket, and is not recognised when the revised
amount of cash flows in scheduled time buckets is more than the original
designated amount. Under IFRS-IASB, hedge accounting for fair value
macro hedges cannot be applied to core deposits and hedge
ineffectiveness arises whenever the revised estimate of the amount of
cash flows in scheduled time buckets is either more or less than the
original designated amount of that bucket. IFRS-IASB financial information
is prepared by reversing the hedge accounting impacts that are applied
under the EU “carve-out” version of IAS 39. Financial information under
IFRS-IASB accordingly does not take into account the possibility that, had
ING Group applied IFRS-IASB as its primary accounting framework, it might
have applied alternative hedge strategies where those alternative hedge
strategies could have qualified for IFRS-IASB compliant hedge accounting.
These decisions could have resulted in different shareholders’ equity and
net result amounts compared to those indicated in this Annual Report on
Form 20-F.
Other than for the purpose of SEC reporting, ING Group intends to continue
to prepare its Financial Statements under IFRS-EU. A reconciliation
between IFRS-EU and IFRS-IASB for shareholders’ equity and net result is
included in Note 1 ‘Basis of preparation and material accounting policy
information’ to the consolidated financial statements.
In the discussion of ING’s financial performance, ING uses a number of
alternative performance measures, including resilient net profit,
commercial net interest income and net core lending and net core
deposits growth. Resilient net profit is defined as net profit adjusted for
significant items not linked to the normal course of business. ING considers
commercial net interest income, and the derived commercial net interest
margin, to be useful information because the scope is restricted to those
products that are mainly interest driven and excludes the interest on
products where performance measurement is primarily done based on fee
income or at the total income level (including Financial Markets and
Treasury). Commercial net interest income also excludes significant
volatile items in lending and liability net interest income, thus removing
items that distort period-on-period comparisons. Net core lending and net
core deposits growth measures the development of ING’s customer
lending and deposits adjusted for currency impacts and changes in the
Treasury and run-off portfolios. ING considers net core lending and net
core deposits growth as useful information to track ING’s real commercial
growth in customer balances.
For reconciliation of these alternative performance measures to the
nearest IFRS-IASB measures, please refer to Capital Management and Item
5. Operating and Financial Review and Prospects – A. Operating results -
Alternative performance measures.
Certain amounts set forth herein, such as percentages, may not sum due
to rounding.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 7 |
Cautionary Statement with respect to Forward-looking
Statements
Certain of the statements contained herein are not historical facts,
including, without limitation, certain statements made of future
expectations and other forward-looking statements that are based on
management’s current views and assumptions and involve known and
unknown risks and uncertainties that could cause actual results,
performance or events to differ materially from those expressed or implied
in such statements. Actual results, performance or events may differ
materially from those in such statements due to a number of factors,
including, without limitation:
§changes in general economic conditions and customer behaviour, in
particular economic conditions in ING’s core markets, including changes
affecting currency exchange rates and the regional and global economic
impact of the invasion of Russia into Ukraine and related international
response measures
§changes affecting interest rate levels
§any default of a major market participant and related market disruption
§changes in performance of financial markets, including in Europe and
developing markets
§fiscal uncertainty in Europe and the United States
§discontinuation of or changes in ‘benchmark’ indices
§inflation and deflation in our principal markets
§changes in conditions in the credit and capital markets generally, including
changes in borrower and counterparty creditworthiness
§failures of banks falling under the scope of state compensation schemes
§non-compliance with or changes in laws and regulations, including those
concerning financial services, financial economic crimes and tax laws, and
the interpretation and application thereof
§geopolitical risks, political instabilities and policies and actions of
governmental and regulatory authorities, including in connection with the
invasion of Russia into Ukraine, other existing or emerging military conflicts,
the risk of further military escalation, geopolitical tensions, trade restrictions
and the related international response measures
§legal and regulatory risks in certain countries with less developed legal and
regulatory frameworks
§prudential supervision and regulations, including in relation to stress tests
and regulatory restrictions on dividends and distributions, (also among
members of the group)
§ING’s ability to meet minimum capital and other prudential regulatory
requirements
§changes in regulation of US commodities and derivatives businesses of ING
and its customers
§application of bank recovery and resolution regimes, including write-down
and conversion powers in relation to our securities
§outcome of current and future litigation, enforcement proceedings,
investigations or other regulatory actions, including claims by customers or
stakeholders who feel misled or treated unfairly, and other conduct issues
§changes in tax laws and regulations and risks of non-compliance or
investigation in connection with tax laws, including FATCA
§operational and IT risks, such as system disruptions or failures, breaches of
security, cyber-attacks, human error, changes in operational practices or
inadequate controls including in respect of third parties with which we do
business and including any risks as a result of incomplete, inaccurate, or
otherwise flawed outputs from the algorithms and data sets utilized in
artificial intelligence
§risks and challenges related to cybercrime including the effects of cyber-
attacks and changes in legislation and regulation related to cybersecurity
and data privacy, including such risks and challenges as a consequence of
the use of emerging technologies, such as advanced forms of artificial
intelligence and quantum computing
§changes in general competitive factors, including ability to increase or
maintain market share
§inability to protect our intellectual property and infringement claims by third
parties
§inability of counterparties to meet financial obligations or ability to enforce
rights against such counterparties
§changes in credit ratings
§business, operational, regulatory, reputation, transition and other risks and
challenges in connection with climate change, diversity, equity and
inclusion and other ESG-related matters, including data gathering and
reporting and also including managing the conflicting laws and
requirements of governments, regulators and authorities with respect to
these topics
§inability to attract and retain key personnel
§future liabilities under defined benefit retirement plans
§failure to manage business risks, including in connection with use of models,
use of derivatives, or maintaining appropriate policies and guidelines
§changes in capital and credit markets, including interbank funding, as well
as customer deposits, which provide the liquidity and capital required to
fund our operations, and
§the other risks and uncertainties detailed in the most recent annual report
of ING Groep N.V. (including the Risk Factors contained therein) and ING’s
more recent disclosures, including press releases, which are available on
www.ing.com.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 8 |
This document may contain ESG-related material that has been prepared
by ING on the basis of publicly available information, internally developed
data and other third-party sources believed to be reliable. ING has not
sought to independently verify information obtained from public and
third-party sources and makes no representations or warranties as to
accuracy, completeness, reasonableness or reliability of such information.
This document may also discuss one or more specific transactions and/or
contain general statements about ING’s ESG approach. The approach and
criteria referred to in this document are intended to be applied in
accordance with applicable law. Due to the fact that there may be
different or even conflicting laws, the approach, criteria or the application
thereof, could be different.
Materiality, as used in the context of ESG, is distinct from, and should not
be confused with, such term as defined in the Market Abuse Regulation or
as defined for Securities and Exchange Commission (‘SEC’) reporting
purposes. Any issues identified as material for purposes of ESG in this
annual report are therefore not necessarily material as defined in the
Market Abuse Regulation or for SEC reporting purposes. In addition, there
is currently no single, globally recognized set of accepted definitions in
assessing whether activities are “green” or “sustainable.” Without limiting
any of the statements contained herein, we make no representation or
warranty as to whether any of our securities constitutes a green or
sustainable security or conforms to present or future investor expectations
or objectives for green or sustainable investing. For information on
characteristics of a security, use of proceeds, a description of applicable
project(s) and/or any other relevant information, please reference the
offering documents for such security.
This annual report contains inactive textual addresses to internet websites
operated by us and third parties. Reference to such websites is made for
information purposes only, and information found at such websites is not
incorporated by reference into this annual report. ING does not make any
representation or warranty with respect to the accuracy or completeness
of, or take any responsibility for, any information found at any websites
operated by third parties. ING specifically disclaims any liability with
respect to any information found at websites operated by third parties.
ING cannot guarantee that websites operated by third parties remain
available following the filing of this annual report or that any information
found at such websites will not change following the filing of this annual
report. Many of those factors are beyond ING’s control.
Any forward-looking statements made by or on behalf of ING speak only
as of the date they are made, and ING assumes no obligation to publicly
update or revise any forward-looking statements, whether as a result of
new information or for any other reason.
This document does not constitute an offer to sell, or a solicitation of an
offer to purchase, any securities in the United States or any other
jurisdiction.
Part I
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 10 |
Item 1. Identity of Directors, Senior Management and
Advisors
Not applicable.
Item 2. Offer Statistics and Expected Timetable
Not applicable.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 11 |
Item 3. Key Information
A. [Reserved]
B. Capitalization and indebtedness
This item does not apply to annual reports on Form 20-F.
C.Reasons for the offer and use of proceeds
This item does not apply to annual reports on Form 20-F.
D. Risk Factors
Summary of Risk factors
The following is a summary of the principal risk factors that could have a
material adverse effect on the reputation, business activities, financial
condition, results and prospects of ING. Please carefully consider all of the
information discussed in this section “Risk Factors” for a detailed
description of these risks.
Risks related to financial conditions, market environment and
general economic trends
§Our revenues and earnings are affected by volatility, regime shifts and
cross-market contagion of the economic, business, liquidity, funding
and capital markets environments of the various geographic regions in
which we conduct business, as well as by changes in customer
behaviour in these regions, and an adverse change in any one region
could have an impact on our business, results and financial condition.
§Inflation and deflation scenarios, as well as interest rate volatility and
changes may adversely affect our business, results and financial
condition.
§The default of a major market participant could disrupt the markets
and may have an adverse effect on our business, results and financial
condition.
§Continued risk of political instability and fiscal uncertainty around the
globe, as well as ongoing volatility in the financial markets and the
economy generally have adversely affected, and may continue to
adversely affect, our business, results and financial condition.
§Market conditions, including those observed over the past few years,
may increase the risk of loans being impaired and have a negative
effect on our results and financial condition.
§Discontinuation of interest rate benchmarks may negatively affect our
business, results and financial condition.
§We may incur losses due to failures of banks falling under the scope of
resolution funding or deposit schemes.
Risks related to the regulation and supervision of the Group
§Non-compliance with laws and/or regulations could result in fines and
other liabilities, penalties or consequences for us, which could
materially affect our business and reputation and reduce our
profitability.
§Changes in laws and/or regulations governing financial services or
financial institutions or the application of such laws and/or regulations
may increase our operating costs and limit our business activities.
§We are subject to additional legal and regulatory risk in certain
countries with less developed or less predictable legal and regulatory
frameworks or the supervision thereof.
§We are subject to the regulatory supervision of the ECB and other
regulators and public bodies with extensive supervisory and
investigatory powers.
§Failure to meet minimum capital and other prudential regulatory
requirements as applicable to us from time to time may have a
material adverse effect on our business, results and financial condition
and on our ability to make payments on certain of our securities.
§Our US commodities and derivatives business is subject to CFTC and SEC
regulation under the Dodd-Frank Act.
§We are subject to the EU recovery and resolution regime and several
other bank recovery and resolution regimes that include statutory
write-down and conversion as well as other powers, which remain
subject to significant uncertainties as to the scope and impact on us.
Risks related to litigation, enforcement proceedings and
investigations and to changes in tax laws
§We may be subject to litigation, enforcement proceedings,
investigations or other regulatory actions, and adverse publicity.
§We are subject to different tax regulations in each of the jurisdictions
where we conduct business, and are exposed to changes in tax laws
and risks of non-compliance resulting in proceedings or investigations
with respect to tax laws.
§Our reputation could be harmed and we could be subject to
enforcement actions, fines and penalties if we fail to comply with our
obligations under tax laws and regulations.
§ING is exposed to the risk of claims from customers or stakeholders
who feel misled or treated unfairly because of advice or information
received.
Risks related to the Group’s business and operations
§ING may be unable to meet evolving expectations or requirements with
respect to ESG-related matters.
§ING may be unable to adapt its products and services to meet
changing customer behaviour and demand, including as a result of
ESG-related matters.
§ING’s business and operations are exposed to transition risks related to
climate change.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 12 |
§ING’s business and operations are exposed to physical risks, including
as a direct result of climate change.
§Operational and IT risks, such as systems disruptions or failures,
breaches of security, human error, changes in operational practices,
inadequate controls including in respect of third parties with which we
do business or outbreaks of communicable diseases may adversely
impact our reputation, business and results.
§We are subject to increasing risks related to cybercrime and
compliance with cybersecurity regulation.
§Because we operate in highly competitive markets, including our home
market, we may not be able to increase or maintain our market share,
which may have an adverse effect on our results.
§We may not always be able to protect our intellectual property
developed in our products and services and may be subject to
infringement claims, which could adversely impact our core business,
inhibit efforts to monetise our internal innovations and restrict our
ability to capitalise on future opportunities.
§The inability of counterparties to meet their financial obligations or our
inability to fully enforce our rights against counterparties could have a
material adverse effect on our results.
§Ratings are important to our business for a number of reasons, and a
downgrade or a potential downgrade in our credit ratings could have
an adverse impact on our results and net results.
§An inability to retain or attract key personnel may affect our business
and results.
§We may incur further liabilities in respect of our defined benefit
retirement plans if the value of plan assets is not sufficient to cover
potential obligations, including as a result of differences between
actual results and underlying actuarial assumptions and models.
Risks related to the Group’s risk management practices
§Risks relating to our use of quantitative models to model client
behaviour for the purposes of our calculations may adversely impact
our results and reputation.
§We may be unable to manage our risks successfully through
derivatives.
Risks related to the Group’s liquidity and financing activities
§We depend on the capital and credit markets, as well as customer
deposits, to provide the liquidity and capital required to fund our
operations, and adverse conditions in the capital and credit markets, or
significant withdrawals of customer deposits, may negatively impact
our liquidity, borrowing and capital positions, as well as increase the
cost of liquidity, borrowings and capital.
§As a holding company, ING Groep N.V. is dependent for liquidity on
payments from its subsidiaries, many of which are subject to
regulatory and other restrictions on their ability to transact with
affiliates.
Additional risks relating to ownership of ING shares
§Holders of ING shares may experience dilution of their holdings and
may be impacted by any share buyback programme.
§Because we are incorporated under the laws of the Netherlands and
many of the members of our Supervisory and Executive Boards and our
officers reside outside of the United States, it may be difficult to
enforce judgements of US courts against ING or the members of our
Supervisory Board and Executive Board or our officers.
Risk factors
Any of the risks described below could have a material adverse effect on
the business activities, financial condition, results and prospects of ING as
well as ING’s reputation. ING may face a number of the risks described
below simultaneously and some risks described below may be
interdependent. While the risk factors below have been divided into
categories, some risk factors could belong in more than one category and
investors should carefully consider all of the risk factors set out in this
section. Additional risks of which the Company is not presently aware, or
that are currently viewed as immaterial, could also affect the business
operations of ING and have a material adverse effect on ING’s business
activities, financial condition, results and prospects. The market price of
ING shares or other securities could decline due to any of those risks
including the risks described below, and investors could lose all or part of
their investments.
Although the risk factors that ING currently believes to be most material
have been presented first within each category, the order in which the risk
factors are presented is not necessarily an indication of the likelihood of
the risks actually materialising, of the potential significance of the risks or
of the scope of any potential negative impact to our business, results,
financial condition and prospects.
Risks related to financial conditions, market environment and
general economic trends
Our revenues and earnings are affected by volatility, regime shifts and
cross-market contagion of the economic, business, liquidity, funding and
capital markets environments of the various geographic regions in which
we conduct business, as well as by changes in customer behaviour in
these regions, and an adverse change in any one region could have an
impact on our business, results and financial condition.
Because ING is a multinational banking and financial services corporation,
with a global presence and serving 40 million customers, corporate clients
and financial institutions in 38 countries, ING’s business, results and
financial condition may be significantly impacted by turmoil and volatility
in the worldwide financial markets or in the particular geographic areas in
which we operate. In Retail Banking, our products include savings,
payments, investments, loans and mortgages. In Wholesale Banking, we
provide specialised lending, tailored corporate finance, debt and equity
market solutions, payments & cash management, trade and treasury
services. Negative developments in relevant financial markets and/or
countries or regions have in the past had and may in the future have a
material adverse impact on our business, results and financial condition,
including as a result of the potential consequences listed below.
Factors such as inflation or deflation, interest rates, government spending,
geopolitical events and trends, supply chain disruptions, shortages,
terrorism, pandemics and epidemics (such as Covid-19 pandemic) or other
widespread health emergencies, securities prices, the volatility and
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 13 |
strength of the capital markets, exchange rates, credit spreads, liquidity
spreads, real estate values and private equity valuations, consumer
spending, business investment, changes in customer behaviour and
climate change, all impact the business and economic environment and,
ultimately, our solvency, liquidity and the amount and profitability of
business we conduct in a specific geographic region. Some of these risks
are often experienced globally as well as in specific geographic regions and
are described in greater detail below under the headings: ‘Inflation and
deflation scenarios, as well as interest rate volatility and changes may
adversely affect our business, results and financial condition'; 'Market
conditions, including those observed over the past few years may increase
the risk of loans being impaired and have a negative effect on our results
and financial condition'; and 'Continued risk of political instability and fiscal
uncertainty, as well as ongoing volatility in the financial markets and the
economy generally have affected, and may adversely affect, our business,
results and financial condition'. All of these are factors in local and regional
economies as well as in the global economy, and we may be affected by
changes in any one of these factors in any one country or region, and
more if more of these factors occur simultaneously and/or in multiple
countries or regions or on a global scale.
In case one or more of the factors mentioned above adversely affects the
profitability of our business, this might also result, among other things, in
the following:
§Inadequate reserves or provisions, in relation to which losses could
ultimately be realised through profit and loss and shareholders’ equity;
§The write-down of tax assets impacting net results and/or equity;
§Impairment expenses related to goodwill and other intangible assets,
impacting our net result and equity; and/or
§Movements in risk-weighted assets for the determination of required
capital.
In particular, we are exposed to financial, economic, market and political
conditions in the Benelux countries and Germany, from which we derive a
significant portion of our revenues in both Retail Banking and Wholesale
Banking, and which could present risks of economic downturn. Though less
material, we also derive substantial revenues in the following geographic
regions: United States, Türkiye, Poland and the remainder of Eastern
Europe, Southern Europe, East Asia and Australia. In an economic
downturn affecting some or all of these jurisdictions, we expect that higher
unemployment, lower family income, lower corporate earnings, higher
corporate and private debt defaults, lower business investments and lower
consumer spending would adversely affect the demand for banking
products, and that ING may need to increase its reserves and provisions,
each of which may result in overall lower earnings. Securities prices, real
estate values and private equity valuations may also be adversely
impacted, and any such losses would be realised through profit and loss
and shareholders’ equity. We also offer a number of financial products
that expose us to risks associated with fluctuations in interest rates,
securities prices, corporate and private default rates, the value of real
estate assets, exchange rates and credit spreads. As a result, their impact
may continue to affect our business. We also have wholesale banking
activities in both Russia and Ukraine, as well as investments in Russia,
some of which are denominated in local currency. In response to Russia’s
invasion of Ukraine, the international community imposed various punitive
measures, including sanctions, capital controls, restrictions on SWIFT
access and restrictions on central bank activity. These measures and
Russia’s response thereto have significantly impacted, and may continue
to significantly impact, Russia’s economy, our activities in Russia and our
activities involving Russian-owned parties. They have contributed to
heightened instability in global markets and increased inflation due in part
to supply chain constraints, as well as continued volatile and periodic
elevation of energy and commodity prices. Should prices remain elevated
for an extended period, most businesses and households would be
negatively impacted, and our business in Russia and Ukraine, as well as
our broader business, may be adversely affected, including through spill-
over risk to the entire wholesale banking portfolio (e.g. commodities
financing, energy and utilities and energy-consuming clients).
On 28 January 2025, ING announced its intention to sell its business in
Russia to a third party. As the buyer has not received all necessary
approvals, ING has been unable to complete the deal within the expected
timeframe. There is no guarantee that any such approvals will be received,
or any certainty as to the timing or occurrence of closing of the proposed
transaction, or the ultimate divestment of ING’s business in Russia.
Environmental and/or climate risks have also directly and indirectly
impacted ING without significant financial impact, for example through,
among other things, losses suffered as a result of extreme weather events,
the impact of climate-related transition risk on the risk and return profile
or value of security or operations of certain categories of customer to
which ING has exposure. In addition, these risks may also increase ING’s
reputational and litigation risk if the economic activity that ING supports is
not in line with community expectations or ING’s external commitments or
legal or regulatory requirements (this includes, but is not limited to,
greenwashing risk).
For more information on ING’s exposure to particular geographic areas,
see Note 31 ‘Information on geographical areas’ to the consolidated
financial statements.
Inflation and deflation scenarios, as well as interest rate volatility and
changes may adversely affect our business, results and financial
condition.
In general, both inflation and deflation may influence consumers’
spending habits, affecting the economic activity and consequently our
core revenue stream (e.g. in terms of overall financial health of borrowers
and loan demand, and collateral management, among other things).
Furthermore, inflation and deflation may have repercussions on interest
rate spreads, and therefore on the profitability of traditional banking
activities. Overall, both inflation and deflation can pose significant
challenges, impacting our ability to generate revenue, manage risk, and
maintain a stable financial position.
Furthermore, a significant and sustained increase in inflation has
historically also been associated with decreased prices for equity securities
and sluggish performance of equity markets generally. A sustained decline
in equity markets may:
§result in impairment charges to equity securities that we hold in our
investment portfolios and reduced levels of unrealised capital gains
available to us which would reduce our net income; and
§lower the value of our equity investments impacting our capital
position.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 14 |
Central banks continue to adopt a cautious stance in response to
persistent inflationary pressures, moderate economic growth, and
elevated geopolitical risks. With EU inflation converging toward the 2%
target and expected to remain near this level over the medium term,
markets anticipate stable interest rates through 2026.
Changes in interest rates may impact our business. In case of increased
interest rates, we may:
§experience a decrease of the estimated fair value of certain fixed
income securities that we hold in our investment portfolios, resulting in:
–reduced levels of unrealised capital gains available to us, which
could negatively impact our solvency position and net income, and/
or
–a decrease in collateral values;
§face an increased withdrawal of certain savings products, particularly
those with fixed rates below market rates;
§be required, as an issuer of securities, to pay higher interest rates on
debt securities that we issue in the financial markets from time to time
to finance our operations, which would increase our interest expenses
and reduce our results;
§experience further customer defaults as interest rate rises flow through
into payment stress for lower credit quality customers.
On the other hand, a decrease in prevailing interest rates may lead to
lower interest income from loans and investments, reduced profitability of
traditional banking activities, and potential declines in the value of certain
fixed income securities we hold in our investment portfolio, as well as
negatively affecting our business in other ways, including leading to:
§compress in the net interest income margins because of a potential
reduction in the interest income earned from loans;
§lower earnings over time on investments, as reinvestments will earn
lower rates;
§increased prepayment or redemption of mortgages and fixed maturity
securities in our investment portfolios, as well as increased
prepayments of corporate loans. This as borrowers seek to borrow at
lower interest rates potentially combined with lower credit spreads.
Consequently, we may be required to reinvest the proceeds into assets
at lower interest rates;
§lower profitability as the result of a decrease in the spread between
client rates earned on assets and client rates paid on savings, current
account and other liabilities;
§higher costs for certain derivative instruments that may be used to
hedge certain of our product risks;
§lower profitability since we may not be able to fully track the decline in
interest rates in our savings rates;
§lower profitability since we may not always be entitled to impose
surcharges to customers to compensate for the decline in interest
rates;
§lower profitability since we may have to pay a higher premium for the
defined contribution scheme in the Netherlands for which the premium
paid is dependent on interest rate developments and the Dutch Central
Bank’s (DNB) methodology for determining the ultimate forward rate;
§lower interest rates that may cause asset margins to decrease, thereby
lowering our results. This may, for example, be the consequence of
increased competition for investments as result of the low rates,
thereby driving margins down; and/or
§(depending on the position) a significant collateral posting requirement
associated with our interest rate hedge programs, which could
materially and adversely affect liquidity and our profitability.
In addition, given the volatility in inflation and related volatility in interest
rates, a failure to accurately anticipate inflation on an ongoing basis and
factor it into our product pricing assumptions may result in the mispricing
of our products, which could materially and adversely impact our results.
Each of the preceding risks, should they materialise, may adversely affect
our business, results and financial condition.
The default of a major market participant could disrupt the markets and
may have an adverse effect on our business, results and financial
condition.
Within the financial services industry, the severe distress or default of any
one institution (including sovereigns and central counterparties (CCPs))
could lead to defaults by, or the severe distress of, other market
participants. While prudential regulation may reduce the probability of a
default by a major financial institution, the actual occurrence of such a
default could have a material adverse impact on ING. Such distress of, or
default by, a major financial institution could disrupt markets or clearance
and settlement systems and lead to a chain of defaults by other financial
institutions, since the commercial and financial soundness of many
financial institutions may be closely related as a result of credit, trading,
clearing or other relationships. Also, the perceived lack of creditworthiness
of a sovereign or a major financial institution (or a default by any such
entity) may lead to market-wide liquidity problems and losses or defaults
by us or by other institutions. This risk is also referred to as ‘systemic risk’
and may adversely affect financial intermediaries, such as clearing
agencies, clearing houses, banks, securities firms and exchanges with
whom we interact on a daily basis, and financial instruments of sovereigns
in which we invest. Systemic risk could impact ING directly, by exposing it
to material credit losses on transactions with defaulting counterparties or
indirectly by significantly reducing the available market liquidity on which
ING and its lending customers depend to fund their operations and/or
leading to a write-down of loans or securities held by ING. In addition, ING
may also be faced with additional open market risk for which hedging or
mitigation strategies may not be available or effective (either by hedges
eliminated by defaulting counterparties, or reduced market liquidity).
Systemic risk could have a material adverse effect on our ability to raise
new funding and on our business, results and financial condition. In
addition, such distress or failure could impact future product sales as a
potential result of reduced confidence in the financial services industry.
Continued risk of political instability and fiscal uncertainty around the
globe, as well as ongoing volatility in the financial markets and the
economy generally have adversely affected, and may continue to
adversely affect, our business, results and financial condition.
Our global business and results are materially affected by conditions in the
global capital markets and the economy generally. In Europe, there are
continuing concerns over weaker economic conditions, levels of
unemployment in certain countries, as well as geopolitical developments,
including tariffs or other trade barriers introduced by the United States and
responses to those trade barriers, the availability and cost of credit, as well
as credit spreads. In addition, geopolitical issues, including military
conflicts, the risk of further military escalation, trade tensions between
major economies, increasing protectionism between key countries, and
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 15 |
issues with respect to North Korea and the Middle East, may all contribute
to adverse developments in the global capital markets and the economy
generally. Sustained uncertainty about, or worsening of, current global
economic conditions and further escalation of trade tensions between the
US and its trading partners, especially China, could result in a global
economic slowdown and long-term changes to global trade. In particular,
Russia’s invasion of Ukraine, the conflict in the Middle East and other
existing or emerging military conflicts, as well as the risk that such
conflicts could escalate or widen, and related international response
measures have had, and are expected to continue to have, a negative
impact on regional and global economic conditions, including heightened
instability in global markets and increased inflation due in part to supply
chain constraints, as well as higher energy and commodity prices. Should
prices remain elevated for an extended period, most businesses and
households would be negatively impacted, and our business in Russia and
Ukraine, as well as our broader business, may be adversely affected,
including through spill-over risk to our entire Wholesale Banking portfolio,
in areas such as commodities financing, energy and utilities and energy-
consuming clients
Moreover, there is a risk that an adverse credit event at one or more
European sovereign debtors (including a credit rating downgrade, such as
that experienced by France in 2025, or a default) could trigger a broader
economic downturn in Europe and elsewhere. In addition, the confluence
of these and other factors has resulted in volatile foreign exchange
markets. International equity markets have also continued to experience
heightened volatility and turmoil. These events, market upheavals and
continuing risks, including high levels of volatility, may have an adverse
effect on our results, in part because we have a large investment portfolio.
There is also continued uncertainty over the long-term outlook for the tax,
spending and borrowing policies of the US, the future economic
performance of the US within the global economy and any potential future
budgetary restrictions in the US, with a potential impact on a future
sovereign credit ratings downgrade of the US government, including the
rating of US Treasury securities. A downgrade of US Treasury securities
could also impact the ratings and perceived creditworthiness of
instruments issued, insured or guaranteed by institutions, agencies or
instrumentalities directly linked to the US government. US Treasury
securities and other US government-linked securities are key assets on the
balance sheets of many financial institutions and are widely used as
collateral by financial institutions to meet their day-to-day cash flows in
the short-term debt market. The impact of any further downgrades to the
sovereign credit rating of the US government or a default by the US
government on its debt obligations would create broader financial turmoil
and uncertainty, which would weigh heavily on the global financial system
and could consequently result in a significant adverse impact to the
Group’s business and operations.
In many cases, the markets for investments and instruments have been
and remain illiquid, and issues relating to counterparty credit ratings and
other factors have exacerbated pricing and valuation uncertainties.
Valuation of such investments and instruments is a complex process
involving the consideration of market transactions, pricing models,
management judgement and other factors, and is also impacted by
external factors, such as underlying mortgage default rates, interest rates,
rating agency actions and property valuations. Historically these factors
have resulted in, among other things, valuation and impairment issues in
connection with our exposures to European sovereign debt and other
investments.
Any of these general developments in global financial and political
conditions could negatively impact our business, results and financial
condition in future periods.
Discontinuation of interest rate benchmarks may negatively affect our
business, results and financial condition.
Changes to major interest rate benchmarks may adversely affect our
business, including net interest revenue. Historically, financial markets
relied on Interbank Offered Rates (IBORs) such as LIBOR, EONIA, CDOR, and
EURIBOR. While some benchmarks like EURIBOR have been reformed and
remain in use, others such as EONIA, CDOR, and LIBOR have been
discontinued and replaced by alternative rates.
In Poland, the National Working Group has established a roadmap to
replace WIBOR with POLSTR (Polish Short-Term Rate), a risk-free overnight
benchmark based on actual transactions. POLSTR was selected in
December 2024 and began publication in June 2025, including
compounded 1-, 3-, and 6-month versions. Treasury bonds referencing
POLSTR were launched in late 2025, with broader adoption in loans and
mortgages expected in 2026. Full transition and WIBOR phase-out are
anticipated by the end of 2027
The discontinuation of benchmarks and adoption of new rates may create
legal, operational, and financial risks, including documentation changes,
conduct risks, and potential earnings volatility from contract modifications
and hedge accounting adjustments.
ING continues to monitor market developments and reform plans for other
rates to anticipate the impact on our customers and any related risks.
Market conditions, including those observed over the past few years,
may increase the risk of loans being impaired and have a negative effect
on our results and financial condition.
We are exposed to the risk that our borrowers (including sovereigns) may
not repay their loans according to their contractual terms and that the
collateral securing the payment of these loans may be insufficient. We
may see adverse changes in the credit quality of our borrowers and
counterparties, for example, as a result of their inability to refinance their
indebtedness or in the case of a decline in financial performance. Adverse
changes in the credit quality of our borrowers and/or decreasing collateral
values would result in increased capital requirements and provisions, and
any deterioration of market conditions may lead to increasing
delinquencies, defaults and insolvencies across a range of sectors. This
may lead to impairment charges on loans and other assets, higher costs
and additions to loan loss provisions. A significant increase in the size of
our provision for loan losses could have a material adverse effect on our
business, results and financial condition.
ING manages concentration risk through a comprehensive framework of
limits on single names, countries, and sectors, supported by regular
monitoring and portfolio steering to ensure exposures remain within its
risk appetite. If we are significantly exposed to a concentrated set of
customers or counterparties, an adverse event affecting these parties
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 16 |
could lead to increased losses for the Group, and adversely affect our
business, results and financial condition.
We may incur losses due to failures of banks falling under the scope of
resolution funding or deposit schemes.
While prudential regulation is intended to minimise the risk of bank
failures, in the event such a failure occurs, given our size, we may incur
significant compensation payments to be made under the Dutch Deposit
Guarantee Scheme (DGS), which we may be unable to recover from the
bankrupt estate, and therefore the consequences of any future failure of
such a bank could be significant to ING. Such costs and the associated
costs to be borne by us may have a material adverse effect on our results
and financial condition. On the basis of the EU Directive on deposit
guarantee schemes, ING pays quarterly risk-weighted contributions into a
DGS-fund. The Dutch DGS-fund reached its intended target size of 0.8
percent of all deposits guaranteed under the DGS, in July 2024. Further,
quarterly risk-weighted contributions are only required when individual
and / or collective covered deposits show an increase in a quarter. In case
of failure of a Dutch bank, depositor compensation is paid from the DGS-
fund. If the available financial means of the fund are insufficient, Dutch
banks, including ING, may be required to pay extraordinary ex-post
contributions not exceeding 0.5 percent of their covered deposits per
calendar year. In exceptional circumstances, and with the consent of the
competent authority, higher contributions may be required. However,
extraordinary ex-post contributions may be temporarily deferred if, and
for so long as, they would jeopardise the solvency or liquidity of a bank.
Depending on the size of the failed bank, the available financial means in
the DGS-fund, and the required additional financial means, the impact of
the extraordinary ex-post contributions on ING may be material.
Since 2015, the EU has been discussing the introduction of a pan-European
deposit guarantee scheme (EDIS), which would (partly) replace or
complement national compensation schemes. As of the date of this
report, negotiations regarding EDIS have stalled and no such scheme has
been introduced.
On 18 April 2023, the European Commission published its proposals for the
revision of the common framework for bank crisis management and
deposit insurance (CMDI) that focuses on small and medium-sized banks,
but will affect banks in the EU. The CMDI framework consists of the Bank
Recovery and Resolution Directive (BRRD), the Single Resolution
Mechanism Regulation (SRMR) and the Deposit Guarantee Schemes
Directive (DGSD). The European Parliament adopted its first-reading reports
on the proposals in April 2024. The Council agreed on a negotiating
mandate for the revision of the CMDI on 19 June 2024. With this
agreement, the Council is ready to negotiate with the European
Parliament on the final form of this legislative proposal. On 25 June 2025,
the Council and the European Parliament reached a political agreement on
the reformed CMDI framework. The co-legislators are now expected to
finalise the legal text, after which the revised framework is expected to be
formally adopted and enter into force. The revision of the CMDI framework
is part of the debate on the completion of the Banking Union and in
particular its third and missing pillar EDIS.
Risks related to the regulation and supervision of the Group
Non-compliance with laws and/or regulations could result in fines and
other liabilities, penalties or consequences for us, which could materially
affect our business and reputation and reduce our profitability.
ING has faced, and in the future may continue to face, the consequences
of non-compliance with applicable laws and regulations, including the
potential initiation of regulatory investigations or legal proceedings. For
additional information on legal proceedings, see Note 42 ‘Legal
proceedings’ in the consolidated financial statements. There are potential
risks in areas where applicable regulations may be unclear, subject to
multiple interpretations or under development; where regulations may
conflict with one another; or where regulators revise their previous
guidance or courts overturn previous rulings. These could result in our
failure to comply with applicable standards. Regulators and other
authorities have the power to initiate investigations and/or administrative
or judicial proceedings against us, which may result, among other things,
in suspension or revocation of our licences, cease and desist orders, fines,
civil penalties, criminal penalties or other disciplinary measures, which
could materially harm our results and financial condition as well as ING’s
reputation. If we fail, or appear to fail to properly address, any of these
matters, our reputation may be harmed and we may be exposed to
additional legal risk, which in turn may increase the size and number of
claims and damages brought against us or subject us to enforcement
actions, fines and penalties.
Furthermore, as a financial institution, we are exposed to the risk of
unintentional involvement in criminal activity in connection with financial
economic crimes, including the circumvention of sanctions, money
laundering and the funding of terrorist and other criminal activities. The
failure or perceived failure by us to comply with legal and regulatory
requirements with respect to financial economic crimes may result in
adverse publicity, claims and allegations, litigation and regulatory
investigations and sanctions, which may have a material adverse effect on
our business, results, financial condition and/or prospects in any given
period. For further information on the impact of litigation, enforcement
proceedings, investigations or other regulatory actions with respect to
financial economic crimes, see 'We may be subject to litigation,
enforcement proceedings, investigations or other regulatory actions, and
adverse publicity' below.
Changes in laws and/or regulations governing financial services or
financial institutions or the application of such laws and/or regulations
may increase our operating costs and limit our business activities.
We are subject to detailed banking laws and financial regulations in the
jurisdictions in which we conduct business. The regulations governing the
industries in which we operate have become more extensive and complex,
while also attracting supervisory scrutiny. Compliance with current and
new laws and regulations is resource-intensive and may materially
increase our operating costs. Moreover, these regulations are designed to
protect our customers, markets and society as a whole and can limit or
redirect our activities, among others, through stricter net capital, market
conduct and transparency requirements and restrictions on the businesses
in which we can operate or invest.
Our revenues and profitability and those of our industry have been and
continue to be affected by requirements relating to capital, additional loss-
absorbing capacity, leverage, minimum liquidity and long-term funding
levels, resolution and recovery planning requirements, derivatives clearing
and margin rules and levels of regulatory oversight, as well as restrictions
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 17 |
on which and, if permitted, how certain business activities may be carried
out by financial institutions.
We are subject to additional legal and regulatory risk in certain
countries with less developed or less predictable legal and regulatory
frameworks or the supervision thereof.
In certain countries where we operate or where our clients reside, judicial
and dispute resolution systems may be less effective. As a result, in the
event of a breach of contract, we have experienced in the past and may
continue to have difficulties in making and enforcing claims against
contractual counterparties and, if claims are made against us, we have
experienced in the past and may continue to encounter difficulties in
mounting a defence against such allegations. If we become party to legal
proceedings in a market with an insufficiently developed judicial system, it
could have an adverse effect on our operations and net results. For
additional information on legal proceedings, see Note 42 ‘Legal
proceedings’ in the consolidated financial statements.
In addition, as a result of our operations in certain countries, we are
subject to risks of possible nationalisation, expropriation, price controls,
exchange controls and other restrictive government actions, as well as the
outbreak of hostilities and/or war, in these markets. In particular, we have
wholesale banking activities in both Russia and Ukraine, as well as
investments in Russia, some of which are denominated in local currency.
Furthermore, the current economic environment in certain countries in
which we operate may increase the likelihood for regulatory initiatives to
enhance consumer protection or to protect homeowners from
foreclosures. Any such regulatory initiative could have an adverse impact
on our ability to protect our economic interest, for instance in the event of
defaults on residential mortgages.
We are subject to the regulatory supervision of the ECB and other
regulators and public bodies with extensive supervisory and
investigatory powers.
In its capacity as the principal prudential supervisor in the EU, the ECB has
extensive supervisory and investigatory powers, including the ability to
issue requests for information, to conduct regulatory investigations and
on-site inspections, and impose monetary and other sanctions. For
example, under the Single Supervisory Mechanism (SSM), the relevant
(national) competent authorities, including the ECB, can conduct stress
tests and have the discretionary power to impose capital surcharges on
financial institutions for risks not otherwise recognised in risk-weighted
assets or other surcharges depending on the individual situation of the
bank, and take or require other measures, such as restrictions on or
changes to the Group’s business. Competent authorities may also prohibit
the Group from making dividend payments to shareholders or distributions
to holders of its regulatory capital instruments if the Group fails to comply
with regulatory requirements, in particular with regard to supervisory
measures, minimum capital requirements (including buffer requirements)
or with liquidity requirements, or if there are deficiencies in its governance
and risk management processes. A perceived failure to comply with
prudential or conduct regulations may have a material adverse effect on
the Group’s business, results and financial condition.
Failure to meet minimum capital and other prudential regulatory
requirements as applicable to us from time to time may have a material
adverse effect on our business, results and financial condition and on
our ability to make payments on certain of our securities.
ING is subject to a variety of regulations that require us to comply with
minimum requirements for capital (own funds) and additional loss-
absorbing capacity, as well as for liquidity, and to comply with leverage
restrictions. In addition, such capital, liquidity and leverage requirements
and their application and interpretation may change. Any changes may
require us to maintain more capital or to raise a different type of capital by
disqualifying existing capital instruments from continued inclusion in
regulatory capital, requiring replacement with new capital instruments
that meet the new criteria. Sometimes changes are introduced subject to
a transitional period during which the new requirements are being phased
in, gradually progressing to a fully phased-in, or fully-loaded, application of
the requirements.
Any failure to comply with these requirements, or to adapt to changes in
such requirements, may have a material adverse effect on our business,
results and financial condition, and may require us to seek additional
capital. Failures to meet minimum capital or other prudential
requirements may also result in ING being prohibited from making
payments on certain of our securities. Because implementation phases
and transposition into EU or national regulation where required may often
involve a lengthy period, the impact of changes in capital, liquidity and
leverage regulations on our business, results and financial condition, and
on our ability to make payments on certain of our securities, is often
unclear.
Our US commodities and derivatives business is subject to CFTC and SEC
regulation under the Dodd-Frank Act.
Our affiliate ING Capital Markets LLC is registered with the Commodity
Futures Trading Commission (CFTC) as a swap dealer and is subject to CFTC
regulation pursuant to Title VII of the US Dodd-Frank Wall Street Reform
and Consumer Protection Act (Dodd-Frank). Operating as a swap dealer
requires compliance with CFTC regulatory requirements, which may be
burdensome, impose additional compliance costs and could adversely
affect the profitability of this business, as well as exposing ING to the risk of
non-compliance with these regulations.
ING Capital Markets LLC is also registered with the SEC as a security-based
swap dealer. Operating as a security-based swap dealer requires
compliance with SEC regulatory requirements, which may be burdensome,
impose additional compliance costs and could adversely affect the
profitability of this business, as well as exposing ING to the risk of non-
compliance with these regulations. While most of these SEC requirements
apply to ING Capital Markets LLC, in addition to its CFTC swap dealer
requirements, SEC rules have permitted an Alternative Compliance
Mechanism that allows for compliance, subject to eligibility requirements,
with CFTC capital and margin rules applying to swap dealers in lieu of SEC
capital and margin rules applying to security-based swap dealers. ING
Capital Markets LLC has elected to use the Alternative Compliance
Mechanism. However, should ING Capital Markets LLC in the future be
ineligible for the Alternative Compliance Mechanism, it would be subject to
SEC security-based swap dealer rules for margin, capital, and related
financial reporting instead of the CFTC swap dealer rules which could be
more capital- intensive.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 18 |
Any of the foregoing factors, and any further regulatory developments
with respect to commodities and derivatives, could have a material impact
on our business, results and financial condition.
We are subject to the EU recovery and resolution regime and several
other bank recovery and resolution regimes that include statutory write-
down and conversion as well as other powers, which remains subject to
significant uncertainties as to scope and impact on us.
We are subject to several recovery and resolution regimes, including the
Single Resolution Mechanism (SRM) and the Bank Recovery and Resolution
Directive (BRRD) as implemented in national legislation such as the Dutch
Financial Supervision Act. The SRM applies to banks that are supervised by
the ECB under the SSM, with the aim of ensuring an orderly resolution of
failing banks at minimum cost for taxpayers and the real economy. The
BRRD establishes a common framework for the recovery and resolution of
banks within the European Union, with the aim of providing supervisory
authorities and resolution authorities with common tools and powers to
address banking crises pre-emptively to safeguard financial stability and
minimise taxpayers’ exposure to losses. Any application of statutory write-
down and conversion or other powers would not be expected to constitute
an event of default under our securities entitling holders to seek
repayment. If any of these powers were to be exercised in respect of ING,
there could be a material adverse effect on both ING and on holders of ING
securities, including through a material adverse effect on credit ratings
and/or the price of our securities. Investors in our securities may lose their
investment if resolution measures are taken under current or future
regimes.
Risks related to litigation, enforcement proceedings and
investigations and to changes in tax laws
We may be subject to litigation, enforcement proceedings,
investigations or other regulatory actions, and adverse publicity.
We are involved in governmental, regulatory, arbitration and legal
proceedings and investigations involving claims by and against us which
arise in the ordinary course of our businesses, including in connection with
our activities as financial services provider, employer, investor and
taxpayer. As a financial institution, we are subject to specific laws and
regulations governing financial services and/or financial institutions. See
'Changes in laws and/or regulations governing financial services or
financial institutions or the application of such laws and/or regulations
may increase our operating costs and limit our activities' and 'Our US
commodities and derivatives business is subject to CFTC and SEC
regulation under the Dodd-Frank Act' above. Financial reporting
irregularities involving other large and well-known companies, possible
findings of government authorities in various jurisdictions which are
investigating several processes, notifications made by whistleblowers,
increasing regulatory and law enforcement scrutiny of ‘know your
customer’ anti-money laundering regulations, tax evasion, prohibited
transactions with countries or persons subject to sanctions, and bribery or
other anti-corruption measures and anti-terrorist-financing procedures
and their effectiveness, regulatory investigations of the banking industry,
and litigation that arises from the failure or perceived failure by us to
comply with legal, regulatory, tax and compliance requirements could
result in adverse publicity and reputational harm. Such developments
could lead to increased regulatory supervision, affect our ability to attract
and retain customers and employees and maintain access to the capital
markets, result in cease and desist orders, claims, enforcement actions,
fines and civil and criminal penalties, other disciplinary action or have
other material adverse effects on us in ways that are not predictable. With
respect to sanctions, Russia’s continued occupation of Ukraine and the
associated conflict has seen successive significant sanctions packages
imposed and continued focus of the EU, US, and other governments on the
potential circumvention of sanctions against Russia, and the roles of third
countries and companies in facilitating the circumvention or undermining
of such sanctions' measures. The EU’s additional measures combating
sanctions circumvention has led to focus on several locations as potential
diversion hubs. While various sanctions include grace periods before full
compliance is required, there is no guarantee that ING will be able to
implement all required procedures within the applicable grace periods. In
addition, some claims and allegations may be brought by or on behalf of a
class and claimants may seek large or indeterminate amounts of
damages, including compensatory, liquidated, treble and punitive
damages. Our reserves for litigation liabilities may prove to be inadequate.
Claims and allegations, should they become public, need not be well
founded, true or successful to have a negative impact on our reputation. In
addition, press reports and other public statements that assert some form
of wrongdoing could result in inquiries or investigations by regulators,
legislators and law enforcement officials, and responding to these inquiries
and investigations, regardless of their ultimate outcome, is time
consuming and expensive. Adverse publicity claims and allegations,
litigation and regulatory investigations and sanctions have had in the past
and may continue to have in the future a material adverse effect on our
business, results, financial condition and/or prospects.
We are subject to different tax regulations in each of the jurisdictions
where we conduct business, and are exposed to changes in tax laws and
risks of non-compliance resulting in proceedings or investigations with
respect to tax laws.
Changes in tax laws (including case law) and tax treaties (including the
termination thereof) could increase our taxes and our effective tax rates
and could materially impact our tax receivables and liabilities as well as
deferred tax assets and deferred tax liabilities, which could have a material
adverse effect on our business, results and financial condition. Changes in
tax laws could also make certain ING products less attractive, which could
have adverse consequences for our businesses and results.
Because of the geographic spread of its business, ING may be subject to
tax audits, investigations and procedures in numerous jurisdictions at any
point in time. Although we believe that we have adequately provided for
all our tax positions, the ultimate resolution of these audits, investigations
and procedures may result in liabilities which are different from the
amounts recognised. In addition, increased bank taxes in countries where
the Group is active result in increased taxes on ING’s banking operations,
which could negatively impact our operations, financial condition and
liquidity.
Our reputation could be harmed and we could be subject to enforcement
actions, fines and penalties if we fail to comply with our obligations
under tax laws and regulations.
Due to the nature of its business, ING is subject to various provisions of EU,
US, and other local tax laws in relation to its customers. These include,
amongst others, the Foreign Account Tax Compliance Act (FATCA), which
requires ING to provide certain information for the US Internal Revenue
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 19 |
Service (IRS); the Qualified Intermediary (QI) requirements, which require
withholding tax on certain US-source payments; and the Common
Reporting Standards (CRS) which requires ING to provide certain
information to local tax authorities. Failure to comply with these
requirements and regulations could harm our reputation and could subject
the Group to enforcement actions, fines and penalties, which could have a
material adverse effect on our business, reputation, revenues, results,
financial condition and prospects.
ING is exposed to the risk of claims from customers or stakeholders who
feel misled or treated unfairly because of advice or information
received.
Our products and services, including banking products and advice services
for third-party products are exposed to claims from customers who might
allege that they have received insufficient advice or misleading
information from advisers (both internal and external) as to which
products were most appropriate for them, or that the terms and
conditions of the products, the nature of the products or the
circumstances under which the products were sold, were misrepresented
to them. When new financial products are brought to the market, it is
ING’s policy to engage in a multidisciplinary product approval process in
connection with the development and distribution of such products,
including production of appropriate marketing and communication
materials. Notwithstanding these processes, customers have made in the
past and may continue to make in the future claims against ING if the
products do not meet their expectations, either at the purchase/execution
of the product and/or through the life of the product. Customer protection
regulations, as well as changes in interpretation and perception by both
the public at large and governmental authorities of acceptable market
practices, influence customer expectations.
Products distributed through person-to-person sales forces have a higher
exposure to such claims as the sales forces may provide face-to-face
financial planning and advisory services. Complaints may also arise if
customers feel that they have not been treated reasonably or fairly, or
that the duty of care has not been complied with. While a considerable
amount of time and resources have been invested in reviewing and
assessing historical sales practices and products that were sold in the past,
and in the maintenance of risk management, legal and compliance
procedures to monitor current sales practices, there can be no assurance
that all of the issues associated with current and historical sales practices
have been or will be identified, nor that any issues already identified will
not be more widespread than presently estimated.
The negative publicity associated with any sales practices, any
compensation payable in respect of any such issues and regulatory
changes resulting from such issues, have had and could have a material
adverse effect on our reputation, business, results, financial condition and
prospects. For additional information regarding legal proceedings or
claims, see Note 42 ‘Legal proceedings’ to the consolidated financial
statements.
Risks related to the Group’s business and operations
ING may be unable to meet evolving expectations or requirements with
respect to ESG-related matters.
Environmental, Social and Governance (ESG) is an area of significant and
increased public dialogue and focus for governments and regulators,
investors, ING’s customers and employees, and other stakeholders or third
parties (e.g. non-governmental organisations or NGOs). As a result, an
increasing number of laws, regulations and legislative actions have been
introduced to address ESG-related matters, including in relation to the
financial sector’s operations and strategy. Such ESG-related matters may
relate to climate change, sustainability, diversity, equity and inclusion (DEI)
or other ESG-related matters. Such recent regulations include the EU
Sustainable Finance Disclosure Regulation (SFDR), EU Taxonomy regulation
and EU Green Bond Standards, which broadly focus on disclosure
obligations, standardised definitions and classification frameworks for
environmentally sustainable activities, and the EU Corporate Sustainability
Reporting Directive (CSRD), which requires certain companies, including
ING, to disclose information on what they see as the risks and
opportunities arising from environmental, social and governance issues,
and on the impact of their activities on people and the environment.
Similarly, the State of California’s legislation requires broad disclosure of
greenhouse gas emissions and other climate-related information.
National or international regulatory actions or developments may also
result in financial institutions coming under increased pressure from
internal and external stakeholders regarding the management and
disclosure of their ESG risks and related lending and investment activities.
ING may regularly adopt or update ESG-related policies, frameworks or
disclosures in connection with the conduct of its business and operations.
However, these approaches may change regularly and, ultimately, there is
no guarantee that ING will be able to fully comply with all applicable
requirements within anticipated timeframes, or at all. Our ability to satisfy
evolving ESG-related laws, regulations, initiatives, targets, ambitions, aims
or expectations and to accurately report performance or developments
with respect to such matters is subject to numerous risks, many of which
are outside of our control, including the evolving legal environment,
regulatory requirements for the tracking and reporting of standards or
disclosures, the actions of suppliers, partners, and other third parties, and
data that is outside of ING’s control.
Our stakeholders may hold differing views on ESG-related matters,
including DEI, which may result in negative attention in traditional and
social media or a negative perception of our response to concerns
regarding these matters. In addition, we may also face potentially
conflicting supervisory directives as certain US regulatory and non-US
authorities have prioritized ESG-related issues while Congress and certain
US state governments have signaled pursuing potentially conflicting
priorities. These circumstances, among others, may result in pressure from
investors, unfavourable reputational impacts, including inaccurate
perceptions or a misrepresentation of our actual ESG-related practices and
diversion of management’s attention and resources. Any failure, or
perceived failure, by us to adhere to our public statements, comply fully
with developing interpretations of ESG-related laws and regulations,
including with respect to DEI-related matters, or meet evolving and varied
stakeholder expectations and standards could negatively impact our
reputation or result in legal and enforcement proceedings against ING. For
instance, Friends of the Earth Netherlands (Milieudefensie) has alleged that
ING has contributed to climate change and has initiated legal proceedings
against ING. For additional information on legal proceedings, including
climate related litigation, see Note 42 ‘Legal proceedings’ in the
consolidated financial statements.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 20 |
Any of these factors may have an adverse impact on ING’s reputation and
brand value, or on ING’s business, financial condition and operating results.
ING may be unable to adapt its products and services to meet changing
customer behaviour and demand, including as a result of ESG-related
matters.
Customers or other counterparties may increasingly assess sustainability
or other ESG-related matters in their economic decisions. For instance,
customers may choose investment products or services based on
sustainability or other ESG criteria or may look at a financial institution’s
ESG-related lending strategy when choosing to make deposits. At the
same time, market and stakeholder views, including those of regulatory or
governmental authorities, on ESG-related matters may vary across
jurisdictions and over time, and we have faced scrutiny, reputational risk,
product boycotts, lawsuits or market access restrictions from these parties
regarding our ESG-related policies, including with respect to DEI matters.
To remain competitive and to safeguard its reputation, ING is required to
continuously adapt its business strategy, products and services to respond
to emerging, increasing or changing sustainability and other ESG-related
demands from customers, investors and other stakeholders. However,
there is no guarantee that ING’s current or future products or services will
meet applicable ESG-related regulatory requirements, customer
preferences or investor expectations.
ING’s business and operations are exposed to transition risks related to
climate change.
The transition to a low-carbon or net-zero economy gives rise to risks and
uncertainties associated with climate change-related laws, regulations
and oversight, changing or new technologies, and shifting customer
sentiment. For instance, ING may be required to change its lending
portfolio to comply with new climate change-related regulations and other
ESG-related demands from customers, investors and other stakeholders.
Such changes could affect ING’s ability to continue or expand certain
customer relationships. This could result in claims or legal challenges
against ING. At the same time, market and stakeholder views, including
those of regulatory or governmental authorities, on ESG-related matters
may vary across jurisdictions and over time, and we may face scrutiny,
reputational risk, product boycotts, lawsuits or market access restrictions
from these parties regarding our ESG-related policies. This transition may
also adversely impact the business and operations of ING’s customers and
other counterparties. Further, there is a risk that changing community
standards and market expectations could lead to a reduction in demand
and a decline in valuations for certain assets, which may affect the value
of collateral we hold or the financial strength of certain of our portfolios. If
ING fails to adequately factor in such risks in its lending or other business
decisions, ING could be exposed to losses.
The low-carbon or net-zero transition may also require ING to modify or
implement new compliance systems, internal controls and procedures or
governance frameworks. The integration and automation of internal
governance, compliance, and disclosure and reporting frameworks across
ING could lead to increased operational costs for ING and other execution
and operational risks. The implementation cost of these systems may
especially be higher in the near term as ING seeks to adapt its business, or
address overlapping, duplicative or conflicting regulatory or other
requirements in this fast-developing area. Furthermore, ING’s ongoing aim
to implement appropriate systems, controls and frameworks increasingly
requires ING to develop adequate climate change-related risk assessment
and modelling capabilities (as there is currently no standard approach or
methodology available), and to collect customer, third-party or other data.
There are significant risks and uncertainties inherent in the development of
new risk modelling methodologies and the collection of data, potentially
resulting in systems or frameworks that could be inadequate, inaccurate,
incomplete or susceptible to incorrect customer, third-party or other data.
Any delay, change or failure in developing, implementing or meeting ING’s
climate change-related policies and complying with applicable regulatory
requirements may have a material adverse impact on our business,
financial condition, operating results and reputation, and lead to climate
change or ESG-related investigations, enforcement proceedings or
litigation.
ING’s business and operations are exposed to physical risks, including as
a direct result of climate change.
ING’s business and operations are exposed to the impacts of physical risks
arising from climate and weather-related events, including heatwaves,
droughts, flooding, storms, rising sea levels, other extreme weather events
or natural disasters, and to the impacts of physical risks arising from
environmental degradation, including the loss of biodiversity, water or
resource scarcity, pollution or waste management. Such physical risks
have disrupted in the past and could continue in the future to disrupt ING’s
business continuity and operations or impact ING’s premises or property
portfolio, as well as its customers’ property, business or other financial
interests. These risks could potentially result in impairing asset values,
financial losses, declining creditworthiness of customers and increased
defaults, delinquencies, write-offs and impairment charges in ING’s
portfolio, etc. In particular, changing climate patterns resulting in more
frequent and extreme weather events, such as the severe flooding that
occurred in Spain in October 2024 or the severe flooding in Germany in
mid-2024, could lead to unexpected business interruptions or losses for
ING or its customers.
Furthermore, ING’s ongoing aim to implement appropriate systems,
controls and frameworks increasingly requires ING to develop adequate
physical risk assessment and modelling capabilities (as there is currently
no standard approach or methodology available), and to collect customer,
third-party or other data. There are significant risks and uncertainties
inherent in the development of new risk modelling methodologies and the
collection of data, potentially resulting in systems or frameworks that
could be inadequate, inaccurate, incomplete or susceptible to incorrect
customer, third-party or other data.
For a description of physical risks to our operations and business other
than resulting from natural disasters as a result of climate change, see
'Operational and IT risks, such as system disruptions or failures, breaches
of security, cyber attacks, human error, changes in operational practices,
inadequate controls including in respect of third parties with which we do
business or outbreaks of communicable diseases may adversely impact
our reputation, business and results' below.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 21 |
Operational and IT risks, such as systems disruptions or failures,
breaches of security, human error, changes in operational practices,
inadequate controls including in respect of third parties with which we
do business or outbreaks of communicable diseases may adversely
impact our reputation, business and results.
Operational and IT risks are inherent to our business. Our clients depend on
our ability to process and report a large number of transactions efficiently
and accurately. In addition, we routinely transmit, receive and store
personal, confidential and proprietary information electronically. Losses
can result from inadequately trained or skilled personnel, IT failures
(including due to a cyber attack), inadequate or failed internal control
processes and systems, regulatory breaches, human errors, employee
misconduct, (including fraud), or from natural disasters or other external
events that interrupt normal business operations. As the role of artificial
intelligence in the finance industry and in our business increases, losses
may also result from incomplete, inaccurate or otherwise flawed outputs
from the algorithms and data sets utilised. Such losses may adversely
affect our reputation, business and results.
We depend on the secure processing, storage and transmission of
confidential and other information in our IT systems and networks. The
equipment and software used in our computer systems and networks may
not always be capable of processing, storing or transmitting information
as expected. Despite our business continuity plans and procedures, certain
of our computer systems and networks may have insufficient recovery
capabilities in the event of a malfunction or loss of data. We are
consistently managing and monitoring our IT risk profile globally. ING is
subject to increasing regulatory requirements including EU General Data
Protection Regulation (GDPR) and EU Payment Services Directive (PSD2)
and the new Digital Operational Resilience Act (DORA) which applies from
17 January 2025. Failure to appropriately manage and monitor our IT risk
profile could affect our ability to comply with these regulatory
requirements, to securely and efficiently serve our clients or to timely,
completely and accurately process, store and transmit information, and
may adversely affect our reputation, business and results. For further
description of the particular risks associated with cybercrime, which is a
specific risk to ING as a result of its strategic focus on technology and
innovation, see 'We are subject to increasing risks related to cybercrime
and compliance with cybersecurity regulation' below.
In addition, as the use of artificial intelligence in the financial services
industry increases, data protection and information security risks may also
increase. Our or our customers’ sensitive, proprietary, or confidential
information could be leaked, disclosed, or revealed as a result of or in
connection with our or our third-party providers’ use of generative or other
artificial intelligence technologies. Any such information input into a third-
party generative or other artificial intelligence or machine learning
platform could be revealed to others, including if information is used to
train the third party's artificial intelligence models. Additionally, where an
artificial intelligence model ingests personal information and makes
connections using such data, those technologies may reveal other
sensitive, proprietary, or confidential information generated by the model.
The EU AI Act entered into force in 2024. Certain prohibitions and AI-
literacy requirements apply from February 2025, governance and GPAI
model provisions from August 2025, and obligations for high-risk system
are expected to phase in during 2026 and 2027. We are implementing AI
governance and model risk controls to comply with these requirements.
Widespread of communicable diseases (including pandemics or other
large-scale public health emergencies) may impact the health of our
employees, increasing absenteeism, or may cause a significant increase in
the utilisation of health benefits offered to our employees, and may also
disrupt broader economic activity and cross-border operations, either or
both of which could adversely impact our business. Further, a significant
portion of our staff continue to work from home on a full- or part-time
basis, which may raise operational risks, including with respect to
information security, data protection, availability of key systems and
infrastructure integrity. In addition, other events including unforeseeable
and/or catastrophic events can lead to an abrupt interruption of activities
and cause operational losses. Losses can result from destruction or
impairment of property, financial assets, trading positions, and the loss of
key personnel.
If our business continuity plans are implemented effectively or do not
sufficiently take such events into account, losses may increase further.
We are subject to increasing risks related to cybercrime and compliance
with cybersecurity regulation.
Like other financial institutions and global companies, we are regularly the
target of cyber attacks, which are a specific risk to ING as a result of its
strategic focus on technology and innovation. In particular, threats from
Distributed Denial of Service (DDoS), targeted attacks (also called
Advanced Persistent Threats) and ransomware have intensified worldwide,
and attempts to gain unauthorised access and the sophistication of
techniques used for such attacks is increasing. Cyber threats are
constantly evolving and the techniques used in these attacks change,
develop and evolve rapidly, including the use of emerging technologies,
such as advanced forms of artificial intelligence and quantum computing.
The new cyber risks introduced by these changes in technology require us
to devote significant attention to the identification, assessment and
analysis of the risks and the implementation of corresponding
preventative measures. We have faced, and expect to continue to face, an
increasing number of cyber attacks (both successful and unsuccessful) as
we have further digitalised. This includes the continuing expansion of our
mobile- and other internet-based products and services, as well as our
usage and reliance on cloud technology.
A substantial majority of our customers interact with us primarily through
digital channels. This increased reliance on digital banking and remote
working may increase the risk of cybersecurity breaches, loss of personal
data and related reputational risk. If any of these risks were to materialise
that may adversely affect our business, results and financial condition.
Cybersecurity, the use and safeguarding of customer data and data
privacy have become the subject of increasing legislative and regulatory
focus. The EU’s second Payment Services Directive (PSD2), GDPR, DORA,
NIS2 and the Cyber Resilience Act are examples of such regulations. The
EU Cyber Resilience Act entered into force on 10 December 2024. Certain
vulnerability and incident reporting obligations apply from 11 September
2026, with full obligations applicable from 11 December 2027. In 2024, the
ECB conducted its first cyber resilience stress test to assess banks’ ability
to respond to and recover from a severe cyber incident. The results,
reflected in the 2024 SREP, identified areas for improvement in our
response and recovery capabilities, leading to enhancements in our cyber
resilience measures. In certain locations where ING is active, there are
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 22 |
additional local regulatory requirements and legislation on top of EU
regulations that must be followed for business conducted in that
jurisdiction. Some of these legislations and regulations may be conflicting
due to local regulatory interpretations. We may become subject to new
legislation or regulation concerning cybersecurity, security of customer
data in general or the privacy of information we may store or maintain.
Compliance with such new legislation or regulation could increase the
Group’s compliance cost. Failure to comply with applicable laws or
regulation could harm our reputation and could subject the Group to
enforcement actions, fines and penalties.
ING may be exposed to the risks of misappropriation, unauthorised access,
including through malware (such as ransomware), other malicious code,
cyber attacks and internal breaches, for purposes of misappropriating
assets or sensitive information, corrupting data, or impairing operational
performance, each of which could have a security impact. These events
could also jeopardise our confidential information or that of our clients or
our counterparties. These events can potentially result in financial loss and
harm to our reputation, hinder our operational effectiveness, result in
regulatory censure, compensation costs or fines resulting from regulatory
investigations and could have a material adverse effect on our business,
reputation, revenues, results, financial condition and prospects. Even when
we are successful in defending against cyber attacks, such defence may
consume significant resources or impose significant additional costs on
ING.
Because we operate in highly competitive markets, including our home
market, we may not be able to increase or maintain our market share,
which may have an adverse effect on our results.
There is substantial competition in the Netherlands and the other
countries in which we do business for the types of wholesale banking,
retail banking, investment banking and other products and services we
provide. Customer loyalty and retention can be influenced by several
factors, including brand recognition, reputation, relative service levels, the
prices and attributes of products and services, scope of distribution, credit
ratings and actions taken by existing or new competitors (including non-
bank or financial technology competitors). A decline in our competitive
position as to one or more of these factors could adversely impact our
ability to maintain or further increase our market share, which would
adversely affect our results. Such competition is most pronounced in our
more mature markets of the Netherlands, Belgium, the rest of Western
Europe and Australia. In recent years, however, competition in emerging
markets, such as Asia and Central and Eastern Europe, has also increased
as large financial services companies from more developed countries have
sought to establish themselves in markets which are perceived to offer
higher growth potential, and as local institutions have become more
sophisticated and competitive and proceeded to form alliances, mergers
or strategic relationships with some of our competitors. The Netherlands is
our largest market. Our main competitors in the banking sector in the
Netherlands are ABN AMRO Bank and Rabobank.
Competition could also increase due to new entrants (including non-bank
and financial technology competitors) in the markets that may have new
operating models that are not burdened by potentially costly legacy
operations and that are subject to reduced regulation. Competitive
dynamics continue to evolve as a result of platform-based players and
fintechs, regulatory changes affecting payments and data access, and
accelerated cloud-native operating models, which may intensify price and
service-level pressure across retail and wholesale. New entrants may rely
on new technologies, advanced data and analytic tools, lower cost to
serve, less extensive oversight from regulators compared to the
frameworks established in respect of traditional banks and/or faster
processes to challenge traditional banks. Developments in technology
have also accelerated the use of new business models, and ING may not
be successful in adapting to this pace of change or may incur significant
costs in adapting its business and operations to meet such changes. For
example, new business models have been observed in retail payments,
consumer and commercial lending (such as peer-to-peer lending), foreign
exchange and low-cost investment advisory services. In particular, the
emergence of disintermediation in the financial sector resulting from new
banking, lending and payment solutions offered by rapidly evolving
incumbents, challengers and new entrants, in particular with respect to
payment services and products, and the introduction of disruptive
technology may impede our ability to grow or retain our market share and
impact our revenues and profitability.
Increasing competition in the markets in which we operate (including from
non-banks and financial technology competitors) may significantly impact
our results if we are unable to match the products and services offered by
our competitors. Future economic turmoil may accelerate additional
consolidation activity. Over time, certain sectors of the financial services
industry have become more concentrated, as institutions involved in a
broad range of financial services have been acquired by or merged into
other firms or have declared bankruptcy. These developments could result
in our competitors gaining greater access to capital and liquidity,
expanding their ranges of products and services, or gaining geographic
diversity. We may experience pricing pressures as a result of these factors
in the event that some of our competitors seek to increase market share
by reducing prices, which may have a material adverse impact on our
business, results and financial condition.
We may not always be able to protect our intellectual property
developed in our products and services and may be subject to
infringement claims, which could adversely impact our core business,
inhibit efforts to monetise our internal innovations and restrict our
ability to capitalise on future opportunities.
In the conduct of our business, we rely on a combination of contractual
rights with third parties and copyright, trademark, trade name, patent and
trade secret laws to establish and protect our intellectual property, which
we develop in connection with our products and services. Third parties
may infringe or misappropriate our intellectual property. We may have to
litigate to enforce and protect our copyrights, trademarks, trade names,
patents, trade secrets and know-how or to determine their scope, validity
or enforceability. In that event, we may be required to incur significant
costs, and our efforts may not prove successful. The inability to secure or
protect our intellectual property assets could have an adverse effect on
our core business and our ability to compete, including through the
monetisation of our internal innovations.
We may also be subject to claims made by third parties for (i) patent,
trademark or copyright infringement, (ii) breach of copyright, trademark or
licence usage rights, or (iii) misappropriation of trade secrets. Any such
claims and any resulting litigation could result in significant expense and
liability for damages. If we were found to have infringed or
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 23 |
misappropriated a third-party patent or other intellectual property right
(including where we or a third party have used generative artificial
intelligence outputs based on data for which the generative model may
not have had consent), we could in some circumstances be enjoined from
providing certain products or services to our customers or from utilising
and benefiting from certain methods, processes, copyrights, trademarks,
trade secrets or licences. Alternatively, we could be required to enter into
costly licensing arrangements with third parties or to implement a costly
workaround. Any of these scenarios could have a material adverse effect
on our business and results and could restrict our ability to pursue future
business opportunities.
The inability of counterparties to meet their financial obligations or our
inability to fully enforce our rights against counterparties could have a
material adverse effect on our results.
Third parties that have payment obligations to ING, or obligations to return
money, securities or other assets, may not pay or perform under their
obligations. These parties include the issuers and guarantors (including
sovereigns) of securities we hold, borrowers under loans originated,
reinsurers, customers, trading counterparties, securities lending and
repurchase counterparties, counterparties under swaps, credit default and
other derivative contracts, clearing agents, exchanges, clearing houses
and other financial intermediaries. Defaults by one or more of these
parties on their obligations to us due to bankruptcy, lack of liquidity,
downturns in the economy or real estate values, volatile oil or other
commodity prices, operational failure or other factors, or even rumours
about potential defaults by one or more of these parties or regarding a
severe distress of the financial services industry generally, could have a
material adverse effect on our results, financial condition and liquidity.
Given the high level of interdependence between financial institutions, we
are and will continue to be subject to the risk of deterioration of the
commercial and financial soundness, or perceived soundness, of
sovereigns and other financial services institutions. This is particularly
relevant to our franchise as an important and large counterparty in equity,
fixed income and foreign exchange markets, including related derivatives.
We routinely execute a high volume of transactions, such as unsecured
debt instruments, derivative transactions and equity investments with
counterparties and customers in the financial services industry, including
brokers and dealers, commercial and investment banks, mutual and hedge
funds, insurance companies, institutional clients, futures clearing
merchants, swap dealers, and other institutions, resulting in large periodic
settlement amounts, which may result in us having significant credit
exposure to one or more of such counterparties or customers. As a result,
we could face concentration risk with respect to liabilities or amounts we
expect to collect from specific counterparties and customers. We are
exposed to increased counterparty risk as a result of past financial
institution failures and weakness and will continue to be exposed to the
risk of loss if counterparty financial institutions fail or are otherwise unable
to meet their obligations. As a result of the Russian invasion of Ukraine and
related international response measures, including sanctions and capital
controls, we may be exposed to an increased risk of default of
counterparties located in Russia and Ukraine, counterparties of which the
ultimate parent is located in Russia or may be considered effectively
controlled or influenced through Russian involvement, and other
counterparties in sectors affected by the response measures. Also,
liquidity or currency controls enforced by the Russian central bank may
impact Russian companies’ ability to pay. In addition, we have
counterparty exposure to Russian entities in connection with foreign
exchange derivatives for future receipt of foreign currencies against the
Russian rouble (RUB). Remaining at risk for ING at year-end 2025 is €600
million of credit exposures booked outside of Russia and €550 million with
clients in Ukraine. A default by, or even concerns about the
creditworthiness of, one or more of these counterparties or customers or
other financial services institutions could therefore have an adverse effect
on our results or liquidity.
With respect to secured transactions, our credit risk may be exacerbated
when the collateral held by us cannot be liquidated or is liquidated at
prices not sufficient to recover the full amount of the loan or derivative
exposure due to us. We also have exposure to a number of financial
institutions in the form of unsecured debt instruments, derivative
transactions and equity investments. For example, we hold certain hybrid
regulatory capital instruments issued by financial institutions which permit
the issuer to cancel coupon payments on the occurrence of certain events
or at their option. Pursuant to regulatory powers and resolution
frameworks, the ECB has indicated that, in certain circumstances, it may
require these financial institutions to cancel payment. If this were to
happen, we expect that such instruments may experience ratings
downgrades and/or a drop in value and we may have to treat them as
impaired, which could result in significant losses. There is no assurance
that losses on these assets would not materially and adversely affect our
business, results or financial condition.
In addition, we are subject to the risk that our rights against third parties
may not be enforceable in all circumstances, including sanction risk. The
deterioration or perceived deterioration in the credit quality of third parties
whose securities or obligations we hold could result in losses and/or
adversely affect our ability to rehypothecate or otherwise use those
securities or obligations for liquidity purposes. A significant downgrade in
the credit ratings of our counterparties could also have a negative impact
on our income and risk weighting, leading to increased capital
requirements. While in many cases we are permitted to require additional
collateral from counterparties that experience financial difficulty, disputes
may arise as to the amount of collateral we are entitled to receive and the
value of pledged assets. Collateral valuation is performed in accordance
with internal policies aligned with market data hierarchies; however,
disputes may still occur under stress. Also in this case, our credit risk may
also be exacerbated when the collateral we hold cannot be liquidated at
prices sufficient to recover the full amount of the loan or derivative
exposure due to us, which is most likely to occur during periods of
illiquidity and depressed asset valuations, such as those experienced
during the financial crisis of 2008. The termination of contracts and the
foreclosure on collateral may subject us to claims. Bankruptcies,
downgrades and disputes with counterparties as to the valuation of
collateral tend to increase in times of market stress and illiquidity. Any of
these developments or losses could materially and adversely affect our
business, results, financial condition, and/or prospects.
Ratings are important to our business for a number of reasons, and a
downgrade or a potential downgrade in our credit ratings could have an
adverse impact on our results and net results.
Credit ratings represent the opinions of rating agencies regarding an
entity’s ability to repay its indebtedness. Our credit ratings are important
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 24 |
to our ability to raise capital and funding through the issuance of debt and
to the cost of such financing. In the event of a downgrade, the cost of
issuing debt will increase, having an adverse effect on our net results.
Certain institutional investors may also be obliged to withdraw their
deposits from ING following a downgrade, which could have an adverse
effect on our liquidity. They can also have lower risk appetite for our debt
notes, leading to lower purchases of (newly issued) debt notes. We have
credit ratings from S&P, Moody’s, Fitch and Scope. Each of the rating
agencies reviews its ratings and rating methodologies on a recurring basis
and may decide on a downgrade at any time.
As rating agencies continue to evaluate the financial services industry, it is
possible that rating agencies will heighten the level of scrutiny that they
apply to financial institutions, increase the frequency and scope of their
credit reviews, request additional information from the companies that
they rate and potentially adjust upward the capital and other
requirements employed in the rating agency models for maintenance of
certain ratings levels. It is possible that the outcome of any such review of
us would have additional adverse ratings consequences, which could have
a material adverse effect on our results and financial condition. We may
need to take actions in response to changing standards or capital
requirements set by any of the rating agencies, which could cause our
business and operations to suffer. We cannot predict what additional
actions rating agencies may take, or what actions we may take in
response to the actions of rating agencies.
Furthermore, ING’s assets are risk-weighted. Downgrades of these assets
could result in a higher risk-weighting, which may result in higher capital
requirements. This may impact net earnings and the return on capital, and
may have an adverse impact on our competitive position.
An inability to retain or attract key personnel may affect our business
and results.
ING Group relies to a considerable extent on the quality of its senior
management, such as members of the executive committee, and
management in the jurisdictions which are material to ING’s business and
operations. The success of ING Group’s operations is dependent, among
other things, on its ability to attract and retain highly qualified personnel.
Competition for key personnel in most countries in which ING Group
operates, and globally for senior management, is intense. ING Group’s
ability to attract and retain key personnel, in senior management and in
particular areas such as technology and operational management, client
relationship management, finance, risk and product development, is
dependent on a number of factors, including prevailing market conditions
and compensation packages offered by companies competing for the
same talent.
The increasing restrictions on, and public and political scrutiny of,
remuneration (especially in the Netherlands), may continue to have an
impact on existing ING Group remuneration policies and individual
remuneration packages for personnel. For example, under the EU’s
amended Shareholder Rights Directive, known as SRD II, which came into
effect on 10 June 2019, ING is required to hold a shareholder binding vote
on ING’s Executive Board remuneration policy and Supervisory Board
remuneration policy at least every four years. Furthermore, the
shareholders have an advisory vote on ING’s remuneration report
annually. This may restrict our ability to offer competitive compensation
compared with companies (financial and/or non-financial) that are not
subject to such restrictions and it could adversely affect ING Group’s ability
to retain or attract key personnel, which, in turn, may affect our business
and results.
We may incur further liabilities in respect of our defined benefit
retirement plans if the value of plan assets is not sufficient to cover
potential obligations, including as a result of differences between actual
results and underlying actuarial assumptions and models.
ING Group companies operate various defined benefit retirement plans
covering the post-employment benefits of a number of our employees.
The liability recognised in our consolidated balance sheet in respect of our
defined benefit plans is the present value of the defined benefit obligations
at the balance sheet date, less the fair value of each plan’s assets,
together with adjustments for unrecognised actuarial gains and losses and
unrecognised past service costs. We determine our defined benefit plan
obligations based on internal and external actuarial models and
calculations using the projected unit credit method. Inherent in these
actuarial models are assumptions, including discount rates, rates of
increase in future salary and benefit levels, mortality rates and the
consumer price index. These assumptions are based on available market
data and are updated annually. Nevertheless, the actuarial assumptions
may differ significantly from actual results due to changes in market
conditions, economic and mortality trends and other assumptions. Any
changes in these assumptions could have a significant impact on our
present and future liabilities and costs associated with our defined benefit
plans.
Risks related to the Group’s risk management practices
Risks relating to our use of quantitative models to model client
behaviour for the purposes of our calculations may adversely impact our
results and reputation.
We use quantitative methods, systems or approaches that apply
statistical, economic, financial, or mathematical theories, techniques and
assumptions to process input data into quantitative estimates. Errors in
the development, implementation, use or interpretation of such models, or
from incomplete or incorrect data, can lead to inaccurate, noncompliant or
misinterpreted model outputs, which may adversely impact our results
and reputation. In addition, we use assumptions to model client behaviour
for risk calculations in our banking books. Assumptions are used to
determine the interest rate risk profile of savings and current accounts and
to estimate the embedded option risk in loans and investment portfolios.
Assumptions based on past client behaviour may not always be a reliable
indicator of future behaviour. The use of different assumptions to
determine client behaviour could have a material adverse effect on the
calculated risk figures and, ultimately, our future results or reputation.
Furthermore, we may be subject to risks related to changes in laws and
regulations (e.g. with reference to client rates, prepayment compensation,
etc.) governing the risk management practices of financial institutions. For
more information, see 'Risks related to the regulation and supervision of
the Group – Changes in laws and/or regulations governing financial
services or financial institutions or the application of such laws and/or
regulations may increase our operating costs and limit our activities'
above. As noted there, regulation of the industries in which we operate is
becoming increasingly more extensive and complex, while also attracting
supervisory scrutiny. Compliance failures may lead to changes in the laws
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 25 |
and regulations governing the risk management practices and materially
increase our operating costs.
We may be unable to manage our risks successfully through derivatives.
We employ various economic hedging strategies with the objective of
mitigating the market risks that are inherent in our business and
operations. These risks include currency fluctuations, changes in the fair
value of our investments, the impact of interest rates, equity markets and
credit spread changes, the occurrence of credit defaults and changes in
client behaviour. We seek to control these risks by, among other things,
entering into a number of derivative instruments, such as swaps (e.g. CCY,
IR, etc.), options, futures and forward contracts, including, from time to
time, macro hedges for parts of our business, either directly as a
counterparty or as a credit support provider to affiliate counterparties.
Developing an effective strategy for dealing with these risks is complex,
and no strategy can completely insulate us from risks associated with
those fluctuations. Our hedging strategies also rely on assumptions and
projections regarding our assets, liabilities, general market factors and the
creditworthiness of our counterparties that may prove to be incorrect or
prove to be inadequate. Accordingly, our hedging activities may not have
the desired beneficial impact on our results or financial condition. Poorly
designed strategies or improperly executed transactions could actually
increase our risks and losses. Hedging strategies involve transaction costs
and other costs, and if we terminate a hedging arrangement, we may also
be required to pay additional costs, such as transaction fees or breakage
costs. There have been periods in the past, and it is likely that there will be
periods in the future, during which we have incurred or may incur losses
on transactions, possibly significant, after taking into account our hedging
strategies. Further, the nature and timing of our hedging transactions
could actually increase our risk and losses. Hedging instruments we use to
manage product and other risks might not perform as intended or
expected, which could result in higher realised or unrealised losses, such as
credit value adjustment risks or unexpected P&L effects, and unanticipated
cash needs to collateralise or settle such transactions. Adverse market
conditions can limit the availability and increase the costs of hedging
instruments, and such costs may not be recovered in the pricing of the
underlying products being hedged. In addition, hedging counterparties
may fail to perform their obligations, resulting in unhedged exposures and
losses on positions that are not collateralised. As such, our hedging
strategies and the derivatives that we use or may use may not adequately
mitigate or offset the risks they intend to cover, and our hedging
transactions may result in losses.
Our hedging strategy additionally relies on the assumption that hedging
counterparties remain able and willing to provide the hedges required by
our strategy. Increased regulation, market shocks, worsening market
conditions, and/or other factors that affect or are perceived to affect the
financial condition, liquidity and creditworthiness of ING may reduce the
ability and/or willingness of such counterparties to engage in hedging
contracts with us and/or other parties, affecting our overall ability to
hedge our risks and adversely affecting our business, results and financial
condition.
Risks related to the Group’s liquidity and financing activities
We depend on the capital and credit markets, as well as customer
deposits, to provide the liquidity and capital required to fund our
operations, and adverse conditions in the capital and credit markets, or
significant withdrawals of customer deposits, may negatively impact
our liquidity, borrowing and capital positions, as well as increase the
cost of liquidity, borrowings and capital.
Adverse capital market conditions may negatively impact our cost of
borrowed funds and our ability to borrow on a secured and unsecured
basis, thereby impacting our ability to support and/or grow our businesses.
From a liquidity perspective, central banks have continued its path of
quantitative tightening by decreasing its balance sheet, which may reduce
the liquidity provided to the financial system. Consequently, banks have
significantly increased debt issuance and heightened competition for
client deposits is observed.
We require liquidity to fund new and ongoing business, to pay our
operating expenses and interest on our debt as well as dividends on our
capital stock, maintain our securities lending activities and replace
maturing liabilities. Without sufficient liquidity, we will be forced to curtail
our operations and our business will suffer. The principal sources of our
funding include a variety of short- and long-term instruments, including
deposit funds, repurchase agreements, commercial paper, medium- and
long-term debt, subordinated debt securities, capital securities and
shareholders’ equity.
In addition, as we rely on customer deposits to fund our business and
operations, the confidence of customers in financial institutions may be
tested in a manner that may adversely impact our liquidity and capital
position. Consumer confidence in financial institutions may, for example,
decrease due to ING’s or our competitors’ failure to communicate to
customers the terms of, and the benefits and risks to customers of,
complex or high-fee financial products. Reduced customer confidence
could have an adverse effect on our liquidity and capital position through
the withdrawal of deposits, as well as on our revenues and total financial
results. As a significant percentage of our customer deposit base is
originated via internet banking, a loss of customer confidence may result
in a rapid withdrawal of deposits over the internet.
In the event that our current resources do not satisfy our liquidity
requirements, we may need to seek additional financing. The availability of
additional financing will depend on a variety of factors, such as market
conditions, the general availability of credit, the volume of trading
activities, the overall availability of credit to the financial services industry,
our credit rating and credit capacity, as well as the possibility that
customers or lenders could develop a negative perception of our long- or
short-term financial prospects. See also under the heading 'Ratings are
important to our business for a number of reasons, and a downgrade or a
potential downgrade in our credit ratings could have an adverse impact on
our results and net results'. Similarly, our access to funding may be limited
if regulatory authorities or rating agencies take negative actions against
us. If our internal sources of liquidity prove to be insufficient, there is a risk
that we may not be able to successfully obtain additional financing on
favourable terms, or at all. Any actions we might take to access financing
may, in turn, cause rating agencies to re-evaluate our ratings.
Disruptions, uncertainty or volatility in the capital and credit markets may
also limit our access to capital. Such market conditions may in the future
limit our ability to raise additional capital to support business growth, to
counterbalance the consequences of losses, or to meet increased
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 26 |
regulatory capital and rating agency capital requirements. This could force
us to (i) delay raising capital, (ii) reduce, cancel or postpone payment of
dividends on our shares, (iii) reduce, cancel or postpone interest payments
on our other securities, (iv) issue capital of different types or under
different terms than we would otherwise, or (v) incur a higher cost of
capital than in a more stable market environment. This would have the
potential to decrease both our profitability and our financial flexibility. Our
results, financial condition, cash flows, regulatory capital and rating
agency capital positions could be materially adversely affected by
disruptions in the financial markets.
Furthermore, regulatory liquidity requirements in certain jurisdictions in
which we operate remain stringent, undermining our efforts to maintain
centralised management of our liquidity. This may continue to cause
trapped pools of liquidity and capital, resulting in inefficiencies in the cost
of managing our liquidity and solvency, and hinder our efforts to integrate
our balance sheet. An example of such trapped liquidity includes our
operations in Germany where German regulations impose separate
liquidity requirements that restrict ING’s ability to move a liquidity surplus
out of the German subsidiary.
As a holding company, ING Groep N.V. is dependent for liquidity on
payments from its subsidiaries, many of which are subject to regulatory
and other restrictions on their ability to transact with affiliates.
ING Groep N.V. is a holding company and, therefore, depends on dividends,
distributions and other payments from its subsidiaries to fund dividend
payments to its shareholders and to fund all payments on its obligations,
including debt service obligations.
ING Groep N.V.’s ability to obtain funds to meet its obligations depends on
legal and regulatory restrictions applicable to ING Groep N.V.’s subsidiaries.
Many of ING Groep N.V.’s direct and indirect subsidiaries, including certain
subsidiaries of ING Bank N.V., may be subject to laws that restrict dividend
payments, as well as requirements with respect to capital and liquidity
levels. For example, certain local governments and regulators have taken
steps and may take further steps to 'ring fence' or impose minimum
internal total loss-absorbing capacity on the local affiliates of a foreign
financial institution to protect clients and creditors of such affiliates in the
event of financial difficulties involving such affiliates or the broader
banking group. Increased local regulation and supervision have therefore
limited and may in the future further limit the ability to move capital and
liquidity among affiliated entities and between ING Groep N.V. and its
direct and indirect subsidiaries; limit the flexibility to structure
intercompany and external activities of ING as otherwise deemed most
operationally efficient, and increase in the overall level of capital and
liquidity required by ING on a consolidated basis.
Lower earnings of a local entity may also reduce the ability of such local
entity to make dividends and distributions to ING Groep N.V. Other
restrictions, such as restrictions on payments from subsidiaries or
limitations on the use of funds in client accounts, may also apply to
distributions to ING Groep N.V. from its subsidiaries.
ING Groep N.V. has also in the past guaranteed and may in the future
continue to guarantee the payment obligations of some of its subsidiaries,
including ING Bank N.V.. Any such guarantees may require ING Groep N.V.
to provide substantial funds or assets to its subsidiaries or the creditors or
counterparties of these subsidiaries at a time when the guaranteed
subsidiary is in need of liquidity to fund its own obligations.
Finally, ING Groep N.V., as the resolution entity of ING, has an obligation to
remove impediments to resolution and to improve resolvability.
Regulatory authorities have required and may continue to require ING to
increase capital or liquidity levels at the level of the resolution entity or at
particular subsidiaries. This may result in, among other things, the
issuance of additional long-term debt issuance at the level of ING Groep
N.V. or particular subsidiaries.
Additional risks relating to ownership of ING shares
Holders of ING shares may experience dilution of their holdings and may
be impacted by any share buyback programme.
ING’s AT1 securities may, under certain circumstances, convert into equity
securities. Such conversion would dilute the ownership interests of existing
holders of ING shares and such dilution could be substantial. Additionally,
any conversion, or the anticipation of the possibility of a conversion, could
depress the market price of ING shares. Furthermore, we may undertake
future equity offerings with or without subscription rights. In case of equity
offerings without subscription rights, holders of ING shares may suffer
dilution. In case of equity offerings with subscription rights, holders of ING
shares in certain jurisdictions, however, may not be entitled to exercise
such rights unless the rights and the related shares are registered or
qualified for sale under the relevant legislation or regulatory framework.
Holders of ING shares in these jurisdictions may suffer dilution of their
shareholding should they not be permitted to, or otherwise choose not to,
participate in future equity offerings with subscription rights.
Any share repurchases could affect the price of our ordinary shares, ADRs
or other securities and increase trading price volatility. The existence of a
share buyback programme could also cause the price of our ordinary
shares, ADRs or other securities to be higher than it would be in the
absence of such a share buyback programme, and could potentially
reduce the market liquidity of our ordinary shares, ADRs or other
securities. There can be no assurance that any share buybacks will
enhance shareholder value because the market price of our ordinary
shares or ADRs may decline below the levels at which we repurchase any
ordinary shares or ADRs.
In addition, ING cannot guarantee that any future share buyback
programme will be fully consummated. The timing and amount of share
repurchases pursuant to a share buyback programme will depend upon a
number of factors, including market, business conditions, and the trading
price of our ordinary shares or ADRs. A share buyback programme may
also be suspended or terminated at any time, and any such suspension or
termination could negatively affect the trading price of, increase trading
price volatility of or reduce the market liquidity of our ordinary shares,
ADRs or other securities. Additionally, a share buyback programme could
diminish our cash reserves, which may impact our ability to finance future
growth and to pursue possible future strategic opportunities.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 27 |
Because we are incorporated under the laws of the Netherlands and
many of the members of our Supervisory and Executive Boards and our
officers reside outside of the United States, it may be difficult to enforce
judgments of US courts against ING or the members of our Supervisory
Board and Executive Board or our officers.
Most of our Supervisory Board members, our Executive Board members
and some of the experts named in this Annual Report, as well as many of
our officers are persons who are not residents of the United States, and
most of our and their assets are located outside the United States. As a
result, investors may not be able to serve process on those persons within
the United States or to enforce in the United States judgments obtained in
US courts against us or those persons based on the civil liability provisions
of the US securities laws.
Investors also may not be able to enforce judgments of US courts under
the US federal securities laws in courts outside the United States, including
the Netherlands. The United States and the Netherlands do not currently
have a treaty providing for the reciprocal recognition and enforcement of
judgments (other than arbitration awards) in civil and commercial matters.
Therefore, a final judgment for the payment of money rendered by any
federal or state court in the United States based on civil liability, whether
or not predicated solely upon the US federal securities laws, would not be
enforceable in the Netherlands unless the underlying claim is re-litigated
before a Dutch court. However, under current practice, the courts of the
Netherlands may be expected to render a judgment in accordance with
the judgment of the relevant US court, provided that such judgment (i) is a
final judgment and has been rendered by a court which has established its
jurisdiction on the basis of internationally accepted grounds of jurisdiction,
(ii) has not been rendered in violation of elementary principles of fair trial,
(iii) is not contrary to the public policy of the Netherlands, and (iv) is not
incompatible with (a) a prior judgment of a Netherlands court rendered in
a dispute between the same parties, or (b) a prior judgment of a foreign
court rendered in a dispute between the same parties, concerning the
same subject matter and based on the same cause of action, provided
that such prior judgment is not capable of being recognised in the
Netherlands. It is uncertain whether this practice extends to default
judgments as well.
Based on the foregoing, there can be no assurance that US investors will
be able to enforce against us or members of our board of directors, officers
or certain experts named herein who are residents of the Netherlands or
countries other than the United States any judgments obtained in US
courts in civil and commercial matters, including judgments under the US
federal securities laws.
In addition, there is doubt as to whether a Dutch court would impose civil
liability on us, the members of our board of directors, our officers or certain
experts named herein in an original action predicated solely upon the US
federal securities laws brought in a court of competent jurisdiction in the
Netherlands against us or such members, officers or experts, respectively.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 28 |
Item 4. Information on the Company
A.History and development of the company
General
ING Groep N.V. was established as a Naamloze Vennootschap (a Dutch
public limited liability company) on March 4, 1991. ING Groep N.V. is
incorporated under the laws of the Netherlands.
The corporate site of ING, www.ing.com, provides news, investor relations
and general information about the company.
ING is required to file certain documents and information with the United
States Securities and Exchange Commission (SEC). These filings relate
primarily to periodic reporting requirements applicable to issuers of
securities, as well as to beneficial ownership reporting requirements as a
holder of securities. The most common filings we submit to the SEC are
Forms 6-K and 20-F (periodic reporting requirements). The SEC maintains
an internet site that contains reports, proxy and information statements,
and other information regarding issuers that file electronically with the SEC
at http://www.sec.gov. ING’s electronic filings are available on the SEC’s
internet site under CIK ID 0001039765 (ING Groep NV).
The official address of ING Group is:
ING Groep N.V.
Bijlmerdreef 106
1102 CT Amsterdam
P.O. Box 1800,
1000 BV Amsterdam
The Netherlands
Telephone +31 20 563 9111
The name and address of ING Group’s agent for service of process in the
United States in connection with ING’s registration statement on Form F-3
is:
ING Financial Holdings Corporation
1133 Avenue of the Americas
New York, NY 10036
United States of America
Telephone +1 646 424 6000
Changes in the composition of the Group
There were no significant acquisitions and divestments in 2025, 2024 or
2023.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 29 |
B.Business Overview
Our strategy
As part of our 'Growing the difference' strategy
our ambition is to accelerate growth, increase
impact, and deliver value to become the best
European bank.
Growing the difference means expanding our scale and impact across
more markets and segments to become the most loved, most impactful
and most valued bank. We aim to increase our relevance by deepening
customer relationships, broadening services, and continuing to make
banking easier and more seamless. Our two main priorities are providing
superior customer value and putting sustainability at the heart of what we
do, supported by four key enablers.
This strategy translates into specific business goals: in Retail, we focus on
Private Individuals, including Gen Z and affluent customers, as well as
small and medium-sized enterprises through Business Banking, and high-
net-worth and investment clients via Private Banking & Wealth
Management. Each segment has a dedicated approach aligned with our
priorities: enhancing digital engagement for younger customers, offering
personalised solutions for affluent clients, and delivering superior value
across all relationships. In Wholesale Banking, we aim to create greater
value by reinforcing our role as a strategic partner and core bank for large
corporates, multinationals, and institutional clients. Guided by our purpose
to empower people to stay a step ahead, we help individuals and
businesses realise their vision for a better future.
Providing superior value for customers
Banking relies on strong relationships, and the strongest relationships are
those where people feel valued, confident, empowered and in control. This
is how we want our customers to feel throughout their journey with us.
Growing the difference means sharpening our focus on customer value,
moving beyond one-size-fits-all services towards more tailored solutions
for each customer segment. In Retail Banking, this is about offering the
right services, at the right time, in the right way. In Wholesale Banking, this
means leveraging our network, expertise and sustainability leadership.
Putting sustainability at the heart of what we do
Our sustainability strategy spans climate, nature and social agendas,
recognising their interdependencies and how they affect each other, both
positively and negatively, and taking into account the legal and regulatory
frameworks in the jurisdictions in which we operate. Each of these is a
complex and dynamic issue, so our response needs to be dynamic as well.
As scientific understanding is continually advancing, our approach will also
keep evolving. Therefore, our climate action has evolved to encompass
both mitigation and a growing emphasis on adaptation. Increasingly, we
are also exploring how we can play a role in halting and reversing nature
degradation and regenerating natural systems, while respecting human
rights and working to advance financial health and inclusion for customers
and communities.
Four enabling priorities
Providing seamless digital services
We can serve our customers better if we use ‘always-on’ channels,
providing data-enabled personalised experiences and end-to-end digital
processes, with human intervention only where needed or desired.
Using scalable technology and operations
A technology and operations foundation that is modular and scalable
brings many benefits, including superior customer experience and safety.
Staying safe and secure
Trust is fundamental for all stakeholders, especially at a digital-first bank
like ING. Customers rely on us to safeguard their money and data, and
maintaining this trust is essential.
Unlocking our people’s full potential
We aim to attract, develop, and retain future-ready talent and foster an
environment that enables employees to thrive, maximising their growth
and impact.
1 Operative customers
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 30 |
Superior value for customers
Providing superior value for customers is one of
our two overarching priorities, as we strive to
make banking easy, instant, personal and
relevant. For Retail Banking, delivering superior
customer value means making banking simple
and expertise accessible, offering the right
services, at the right time, in the right way.
For Wholesale Banking, delivering superior value
for customers means building on our network
strength, sector expertise, and sustainability
leadership.
Retail Banking
In Retail Banking, we service customers across three pillars: Private
Individuals, Business Banking, and Private Banking & Wealth Management.
Equipped with leading digital capabilities, we strive to provide a mobile-
first digital, frictionless, and relevant banking experience, shaped to
specific customer needs for all of these pillars.
Private Individuals
We serve nearly 41 million Private Individual customers1 across 10
markets: the Netherlands, Belgium, Luxembourg, Germany, Spain, Italy,
Türkiye, Poland, Romania and Australia.
ING offers a broad range of banking products and services for private
individuals, including savings accounts, payments, credit cards,
mortgages, unsecured lending, investment solutions and insurance
products. We seek to deliver banking that is easy, instant, personal and
relevant. We focus on simplifying our services, improving our digital
capabilities, and anticipating customer needs to help people manage their
financial lives. Our progress is reflected in customers choosing us as their
primary bank and in their willingness to recommend us, as indicated by
our leading NPS score in five out of ten retail markets.
ING aims to build primary relationships with customers. In Retail Banking,
we define this as customers holding an active payment account with
recurrent income, plus at least one other active product with us. Earning
primary relationships is a key driver of sustainable, profitable growth. It
leads to deeper loyalty, significantly higher engagement, greater
customer satisfaction and ultimately higher value, as customers choose
ING for a broader set of their financial needs.
Growing the difference means focusing even more on growing value for
customers. We continue to expand our offering by developing relevant
propositions for our various customer groups and applying a personalised
approach enabled by our digital banking capabilities. Our priorities include
becoming the bank of choice for Gen Z and affluent customers, expanding
subscription-based services that provide superior customer value,
diversifying our Private Individuals lending portfolio, and partnering to offer
full-service solutions that help homeowners make their homes more
sustainable. We are also broadening our investment and savings offering
to help customers protect and grow their wealth and manage their
financial health more effectively.
We strive to provide a seamless, mobile-first digital experience, engaging
customers across their daily banking activities and offering personalised
products and services supported by advanced technology and data-driven
insights. As mobile adoption continues to grow, customer expectations for
digital services are rising. In 2025, 87 percent of customers chose mobile
as their primary channel, up from 84 percent in 2024.
This growth has led to an increase in mobile primary customers – defined
as customers with at least one mobile interaction through our app or
mobile website per quarter. In 2025, in line with our mobile-first ambition,
we expanded our mobile primary customer base by over 1 million to 15.4
million.
In 2025, customers visited our digital platforms 8.8 billion times, an
increase of 6 percent compared to 2024.
Business Banking
For Business Banking clients, growing the difference means making banking
simple, frictionless, and tailored to their needs. Our ambition is to be the first
choice for entrepreneurs and businesses to manage and grow their
operations. We define success by delivering superior customer value
through digital innovation, expert advice, and sector-specific solutions.
Business Banking serves clients in nine markets: the Netherlands, Belgium,
Luxembourg, Germany, Türkiye, Poland, Romania, Australia, and most
recently Italy, where we began offering Business Banking services to a select
group of customers at the end of 2025 ahead of the wider commercial
launch in January 2026.
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Our service model addresses both basic and complex needs, offering
solutions through a mix of self-service digital platforms and remote or in-
person advisory. Through this approach, we aim to strengthen client
engagement and incorporate sector-specific expertise to support informed
decision-making.
Across all three segments – Self-Employed & Micro, SME, and Mid-Corps –
we focus on making banking effortless and accessible. As of 2025, we offer
digital onboarding journeys, and instant and fast-track lending across six
markets: the Netherlands, Belgium, Poland, Romania, Türkiye and Germany.
We aim to combine digital convenience with human expertise, making
sure every client, regardless of size, receives the support they need.
Private Banking & Wealth Management
Private Banking, Wealth Management & Investments combines our Private
Banking & Wealth Management activities with our total Retail investments
business across Private Individuals, Private Banking and Business Banking
clients. We do this through a scalable investments platform that we are
implementing across our Retail markets, designed to meet diverse client
needs.
Our Private Banking & Wealth Management offering provides tailored
banking solutions to ultra-high-net worth individuals and high-net-worth
individuals and their entities in the Netherlands, Belgium, Luxembourg,
and Poland. We provide clients with investment solutions focused on
managing, preserving, and growing their wealth. Beyond investments, we
offer solutions to meet specific client needs, including financial planning,
estate planning, real estate financing, and securities-based lending.
Our strategy builds on our strong Business Banking position to serve
entrepreneurs and their wealth needs. We continue to invest in digital
capabilities to enhance client engagement and provide actionable insights
through advanced analytics, while maintaining human expertise through
relationship managers supported by product specialists and portfolio
managers.
Our investments offering spans all Retail Banking countries, serving mass,
affluent, high-net-worth individuals and ultra-high-net worth individuals
through a differentiated approach. For Private Individual clients, we aim to
provide a fully digital experience with simple onboarding, intuitive tools,
and innovative features for first-time investors. For affluent clients, we
offer a hybrid model that combines digital convenience with personalised
support.
In line with our ambition to make investing personal and accessible
throughout Europe, total assets under management and e-brokerage
reached €278 billion in 2025, representing a 16 percent increase from
2024.
Wholesale Banking
Growing the difference for our customers means we strive to be the best –
and in this case, the best European wholesale bank. We define ‘best’ as
achieving a high net promoter score (NPS), ranking in the industry’s top
quartile, leading in sustainability, digital services and employer
attractiveness, while delivering sustainable returns. Our work starts with
providing corporate clients and financial institutions with the financial
solutions they need across their value chains.
In 2025, our Wholesale Banking team was recognised by Global Finance as
Best Bank for Payments in Western and Central & Eastern Europe, and the
Most Innovative Bank for Trade Finance globally. Treasury Management
International named ING as the 2025 Best Bank for Trade & Supply Chain
Finance in Europe, and Global Capital recognised ING as the 2025 Most
Impressive Investment Bank for Corporate ESG Capital Markets and Advice.
Global Reach
ING’s Wholesale Banking network serves clients around the world and
operates from 37 countries across three regions: EMEA, APAC and the
Americas.
Sector Expertise
Clients benefit from our sector knowledge of eight sectors and 29 sub-
sectors, including: commodities, food and agriculture; corporate sector
coverage; energy; financial institutions; infrastructure and real estate;
sustainable value chains; technology, media, telecom and healthcare; and
transport and logistics. By making use of our target sector research
capabilities and our client segmentation model, we aim to help clients
navigate the highs and lows of economic cycles. We provide them with
relevant advice, data-driven insights and customised, integrated solutions
that support their business ambitions.
How we aim to become the best European wholesale bank
We have identified several ‘must-win’ priorities for us to become the best
European wholesale bank and to drive impact for our clients. In
Transaction Services, we are expanding our product foundations to offer
more efficient cash management, trade finance, and payment solutions,
while diversifying our product mix to support clients’ global operations. In
Financial Markets, we are harmonising our product suite and increasing
access to green and conventional instruments, enabling clients to manage
risk and fund sustainable growth. And within Capital Markets & Advisory
(CMA), we are broadening our capabilities to deliver tailored financing and
advisory solutions, with more teams positioned close to clients for faster,
more relevant support.
In 2025 we took another step in strengthening our client offer with the
launch of a private markets unit. This will help clients access alternative
capital and diversify funding sources.
Alongside our focus on our three core differentiators, this year we also
worked towards achieving a fourth: digital. As such, we have advanced our
digitalisation efforts to enhance client experience. We expanded self-
service journeys on our InsideBusiness platform, streamlined processes,
and introduced new tools to make interactions simpler and faster. At the
same time, we equipped our front-office teams with integrated CRM and
GenAI capabilities, combining data, insights, and automation to deliver
proactive advice and deepen engagement.
We progressed our capital velocity strategy in 2025, and completed two
significant risk transfer (SRT) transactions, enabling us to deploy capital
more efficiently and expand our lending capacity. As a result, we are
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better positioned to serve a wider range of clients and pursue new
business opportunities, while continuing to manage risks prudently.
Our NPS performance
One of the ways we measure our ability to deliver superior customer value
is through the net promoter score (NPS). The NPS indicates whether
customers would recommend ING to others. We compare our NPS to
selected peers in each market.
The net promoter score is a measure for customer satisfaction and loyalty.
The measure is derived from the survey question on the scale from 0 (not
at all) to 10 (extremely likely): 'How likely is it that you would recommend
a product or brand to a friend, family member or colleague?' (RB) and 'how
likely are you to recommend ING to a colleague or business partner?' (WB).
The score is calculated as the difference between the percentage of
promoters (who rate ING as 9 or 10), and detractors (rating ING with a
score of 6 or below).
Our ambition is to achieve a number one NPS ranking in all our Retail
markets. In 2025, ING ranked number one in 5 of our Retail markets:
Australia, Poland, Germany, Romania and Spain.
We ran an NPS programme in 32 Wholesale Banking (WB) markets
throughout 2025, to ensure a broad coverage of our client base, and
achieved a 69 percent response rate. ING’s WB NPS score rose to 77 (on a
scale of -100 to +100), compared to a score of 74 in 2024. The insights
from the survey showed how our sector expertise, global reach and local
experts are highly appreciated by clients and important reasons for why
they chose ING. We also asked clients how satisfied they were with our
product areas, people, processes and digital offering, with the highest
scores going to our product offering, relationship management and client
support. Off the back of these results, we will continue to prioritise building
strong relationships with excellent execution, simplifying and automating
our KYC processes and optimising our digital offering.
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How we are growing the difference
We focus and continue to work on our four key
enablers that will help us grow the difference:
providing seamless digital services, using scalable
technology and operations, staying safe and
secure, and unlocking our people’s full potential.
Providing seamless digital services
Through our ‘Growing the difference’ strategy, we continue to build on our
success of making banking easy. One of the ways we aim to do this is by
making banking as frictionless and relevant as possible. We can serve our
customers better through our ‘always-on’ channels, data-enabled
personalised experiences, and end-to-end digital processes, with human
intervention where needed or desired. For Private Individuals, our ING
Banking App enables customers to open accounts in minutes, manage
investments, and receive real-time spending insights. In Business Banking,
our Mijn ING Zakelijk platform helps SMEs manage payments and link
accounting packages seamlessly, while larger corporates benefit from the
InsideBusiness portal, providing self-service access to trade finance and
cash management globally. For Private Banking & Wealth Management,
clients enjoy secure digital portfolio management and personalised
advisory services through our app, which offers tailored dashboards and
seamless access to expert support.
We use data analytics and machine learning to personalise digital services,
delivering relevant, data-driven insights that help customers make
informed financial decisions. As data becomes increasingly central to
delivering personal and relevant services, privacy and data security are
more important than ever.
Scalable technology and operations
ING uses scalable technology and operations that enable us to reach the
market faster, achieve volume more quickly, maintain consistent and
higher quality, and enhance productivity. This also helps us attract and
retain talent by offering employees the opportunity to not only work with
technology but also collaborate across countries and make an impact
globally. Scalable technology enables ING to create specific, local
propositions that serve our customers, while leveraging ING’s scale in
engineering, security, and data expertise.
Scalable technology
ING's technology vision is anchored in the 'Scalable Tech Platform', a
unified, integrated foundation. The platform hosts the IT modular
components we (re)use across countries and business lines to build and
operate customer propositions. It allows ING countries and business lines
to introduce propositions quickly, easily, and safely.
To fully unlock the potential of this platform and advance our ambition of
'Banking with Impact', the ING Tech strategy sets out three goals under the
leadership of the chief technology officer: increase productivity, excel in
customer experience, and be a top employer for engineering talent.
In 2025, we translated these longer-term goals into clear priorities for the
years ahead:
§Operational excellence: Enhancing reliability, reinforcing cybersecurity,
and investing in our workforce to ensure resilient and secure
operations.
§Digital product governance: Advancing our digital product capabilities,
which contributes further to control, transparency, and strategic
alignment.
§Engineering: Driving an engineering way of working and innovation,
including AI-enabled coding.
§Transformation: Continuing the development and expansion of our
scalable technology platform.
§Data and AI development: Accelerating the responsible and effective
use of data and artificial intelligence to unlock new opportunities and
efficiencies.
Our scalable technology consists of three core components: ING’s private
cloud infrastructure (IPC), our engineering pipeline (OnePipeline), and our
banking technology platform.
IPC is where we store and manage applications and data such as channel
applications, core banking systems, and other banking applications. We
measure IPC adoption by the percentage of physical cores – also known as
processing cores or CPU cores – in IPC compared to the total number of
physical cores in ING data centres globally. By the end of 2025, 68 percent
(2024: 67 percent) of all physical cores in ING were on IPC. This is in line
with our objective to evolve towards a structural hybrid cloud set up, which
allows us to optimise our infrastructure landscape by using both private
and public cloud to run our applications.
OnePipeline, our continuous integration and delivery pipeline, provides
engineers with a consistent and secure global capability to develop, test,
and deploy software. At the end of 2025, 90 percent of applications were
onboarded to this pipeline (2024: 85 percent) out of the total number of
applications registered in our IT management platform across all ING
entities.
Touchpoint is part of our banking technology platform. It provides reusable
shared services that help engineers build products – like Instant Payments
and Open Banking – more quickly and easily. At the end of 2025,
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approximately 81 percent of customer logins used Touchpoint (2024:
approximately 75 percent)
Digital access
In a digital society, customers expect to have round-the-clock access to
digital channels, including their banking services. To live up to their
expectations, we strive to provide uninterrupted access to our banking
services, while allowing for scheduled maintenance and downtime. For
2025, our Retail scope includes Belgium, Germany, and the Netherlands.
The combined digital channel availability for these three countries was
99.89 percent (2024: 99.86 percent).
For Wholesale Banking clients worldwide, the availability for our Inside
Business Payments channel was 99.97 percent (2024: 99.82 percent) and
for our Inside Business Connect channel (file transfer), 99.99 percent
(2024: 100 percent.
Scalable operations
Our scalable operations are driven by digitalisation and capability hubs,
focusing on becoming fully straight-through processing (STP), removing
friction towards a seamless experience for our customers in a safe and
secure way. In all we do, our customers are our point of departure. Our
processes, both digital and non-digital, are designed and executed to
embed excellent customer experience. We apply the same mindset to all
our employee journeys.
Digitalising key customer journeys allows us to enable superior customer
value at a reduced cost-to-serve, while measuring impact through NPS and
cost efficiency. In 2025, our digi index score was 81.8 percent (2024:78.1
percent). The digi index score reflects the average of STP rates of key
customer journeys that are handled without manual intervention.
Capability hubs provide shared services and solutions across ING
worldwide, leveraging expertise and using scale, and sharing productive,
quality services across the ING network. The hubs are located in the
Netherlands, Poland, Romania, Slovakia, the Philippines and Türkiye.
In November 2025, ING opened a new hub in Madrid, Spain.
Through expanded and improved digital services we have reduced friction
and increased self service options, including GenAI chatbots. In 2025, we
reduced inbound contacts to contact centres by 43 percent (2024: 26
percent).
Data analytics
In 2025, ING Analytics continued to drive our strategy forward by
embedding AI and GenAI into our products, process, and interaction in
Retail, Wholesale, and the associated operations. Building on the targeted
approach in five priority domains – contact centres, Know Your Customer
(KYC), hyper-personalisation, Wholesale Banking Lending, and software
engineering – we scaled solutions and explored new opportunities.
Key milestones include the first large language model (LLM) voicebot
experiment and the introduction of machine learning-based client due
diligence assessments in Retail Banking. In Wholesale Banking, we
prioritised front-office productivity by embedding AI tools, including
enhancing liquidity management through machine learning and providing
near real-time visibility into client data to support faster, more informed
decision‑making.
We continued to advance our platform capabilities in line with ING’s
broader transformation objectives. The introduction of a unified data,
analytics, AI and agentic environment marked an important milestone in
strengthening our data infrastructure. The platform delivers analytics
initiatives with greater consistency and efficiency, while simplifying risk
assessments and strengthening data governance.
As AI adoption accelerated across 2025, moving from pilots to day‑to‑day
use in areas such as analytics, software development and customer
service, we strengthened our governance to ensure we scale AI responsibly
by establishing a dedicated central AI Risk Committee to oversee emerging
risks in new domains such as voicebots and agentic AI capabilities.
We continue to empower our workforce by shifting from AI education to
hands-on enablement across three key groups: employees, specialists,
and leaders. This year’s data fluency training reached more than 8,700
individual participants across 18 functions in 14 countries. These initiatives
aim to ensure ING talent remains at the forefront of responsible and
innovative AI adoption.
In Retail Banking, we have introduced GenAI-powered campaigns to
improve customer engagement and support sales. These tools are
currently live in Belgium, Germany, Spain, Romania, and Poland. In Spain,
early results show positive campaign uplifts. We are also assessing the use
of GenAI for educational and awareness content, including illustrated
messaging.
In consumer lending, we use AI to assess applicants and process loan
applications automatically. We enhanced the mortgage credit decision
process in Australia by introducing machine learning-based scorecards.
This improvement enables a more digitised application experience and
ensures reliable assessments aligned with our risk appetite.
Our contact centres underwent a GenAI transformation, with chatbots
now live in seven countries (the Netherlands, Belgium, Germany, Spain,
Italy, Romania, and Australia).
We integrated analytics and AI into KYC processes across Retail and
Wholesale Banking. Our Secondary Analytics Transaction Monitoring
solution distinguishes between high- and low-risk activity, improving
investigations and supporting compliance. The model is live in Belgium,
the Netherlands, Romania, and Australia.
We introduced STP 2.0 and a new Risk Assessment Model for customer due
diligence, shifting from manual checks to AI-driven risk management.
These solutions are designed to streamline processes, support compliance,
and enable dynamic risk scoring and smarter decisions globally.
In engineering, we have implemented GenAI to accelerate software
development, improve code quality, and reduce communication overhead.
Staying safe and secure
At ING, trust is the foundation of everything we do. As a digital-first bank,
we are entrusted with our customers’ money and personal data.
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Safeguarding these assets is essential to maintaining the confidence of our
stakeholders.
We operate within a robust risk management framework designed to
identify, assess and manage material risks to our business. Our Risk
Appetite Framework (RAF) supports the execution of our ‘Growing the
difference’ strategy in a secure, compliant, and responsible manner,
ensuring we meet all regulatory obligations.
As we expand our customer base, we remain vigilant in protecting our
organisation, our clients and the broader financial system. Our anti-money
laundering (AML) activities include customer screening, due diligence and
transaction monitoring to detect and prevent suspicious activity. We also
continue to strengthen our fraud prevention capabilities, using innovative
technologies to reduce fraud-related harm to individuals and society.
Cybersecurity remains a top priority. We continuously monitor the threat
landscape and invest in capabilities across all cyber domains – prediction,
prevention, detection, response and recovery. In 2025, two Distributed
Denial of Service (DDoS) incidents were reported to the supervisors: one
impacted availability for individuals in Belgium, Italy, and the Netherlands,
and another caused temporary interruptions in third-party service
availability within the Polish mobile payment system. Our Chief
Information Security Office (CISO) organisation maintains 24/7 vigilance,
actively monitoring our environment, investigating emerging threats, and
taking timely action to protect our customers and essential services.
As a global financial institution, we process personal data from customers,
employees, suppliers, and partners. Protecting this data is critical. We
continuously evaluate our compliance with evolving data ethics standards
and regulatory requirements. We also foster a culture of integrity by
encouraging employees to report unethical or unlawful behaviour through
secure and anonymous channels.
For more information on ING’s policies and processes to stay safe and
secure, see.
Unlocking our people’s full potential
Unlocking our people’s full potential is a key enabler of our strategy as we
believe we have an abundance of talent and potential at ING. We attract,
develop, retain, and reward the right fit-for-future talents and skills. We
strive to deliver a superior employee experience to unlock our people’s
time and energy to grow the difference. We are dedicated to fostering a
safe and inclusive environment for our 60,000+ employees, as we aim to
create a friendly and collaborative workplace that mirrors the diverse
world we operate in. This is reinforced by our Orange Culture and Orange
Behaviours. We ask our people to act with honesty, prudence, and
responsibility, and that they strive to ‘take it on and make it happen’, ‘help
others be successful’, and are ‘always a step ahead’.
In 2025, we continued to focus on unlocking our people’s potential through
three strategic pillars: ‘talent & leadership’, ‘culture & organisation’ and
‘employee experience’.
Talent & leadership
To grow the difference and keep ING fit for the future, we need the right
people with the right skills and a readiness to learn and develop. In 2025,
we launched ING University, our new global learning platform. This brings
learning into one place for all ING employees worldwide, making
development more accessible, personal, and relevant – so everyone has
the skills to thrive today and tomorrow. Alongside this, we have continued
to empower employees to take ownership of their growth through tools
like the Individual Development Plan (IDP), available globally to help map
personal learning journeys. We also offer high-quality learning content
tailored to different roles and ambitions. Employee feedback on learning
content is positive, with colleagues actively exploring topics beyond
mandatory training – showing appetite for self-driven learning.
Our focused attention on training complements our efforts to build strong,
diverse talent pipelines. Through our annual strategic global talent reviews,
conducted for approximately 5,000 senior employees, each domain
evaluated their contributions to growing the difference and identified the
talent, leadership, and capability needs to advance our ING goals and help
future-proof our talent pipelines. In 2025, we enhanced this review cycle
by integrating near-term and forward-looking assessments of
organisational and people requirements, including future workforce needs,
skills, and capacity, as well as future leadership requirements.
One example of how we are building future-ready leaders is our Global
Leadership Accelerator, run in partnership with the IMD Business School,
where, following completion, participants are demonstrating increased
readiness for senior roles. As we strengthen the talent of today, we can
also look ahead with confidence: the International Talent Programme
continues to welcome new trainees to ING to develop their banking skills,
cultivate professional expertise and support their personal growth. This
rigorous, global two-year programme is just one of our investments in
strengthening our leadership pipeline.
Our commitment to a fair and transparent performance and rewards
process supports our talent and leadership goals. We retained the same
focus in 2025 of providing our employees with clarity and consistency.
ING follows a Pay for Performance approach, supported by a five-point
performance rating scale in our performance evaluation scheme,
introduced in 2024. Remuneration decisions are clearly linked to
performance outcomes.
ING began using a structured variable remuneration framework based on
our job architecture in 2025. This means all employees eligible for variable
remuneration have a variable remuneration target. This provides
managers with a decision framework for determining variable
remuneration rewards equitably, while having enough flexibility to
differentiate outcomes for individual performance. Employees see
increased transparency and can better understand how their personal
performance influences their variable remuneration.
Culture & organisation
At ING we aim to unlock our people's full potential through our inclusive
culture where everyone has the opportunity to develop and have impact
for our customers and society.
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Strong mental, social and physical wellbeing is essential for an inclusive
environment and a healthy, high-performing and engaged workforce.
We promote flexibility through hybrid working and have introduced
healthy 'Working Habits', for which we provide training and resources.
We have also included a Wellbeing Index in our Organisational Health
Index (OHI) survey to track how our people are doing, identify
improvement areas, and monitor the link between wellbeing and
performance. By prioritising wellbeing and leveraging these insights,
we aim to build a resilient workforce and drive a sustainable high-
performance culture.
Equally important is the role feedback plays in sustaining our Orange
Culture. We maintain a continuous listening framework, which gives our
people formal channels to provide feedback on our strategy, working
conditions, behaviours, and experiences. Our Organisational Health Index is
the most comprehensive of these listening tools. In 2025, we held two OHI
surveys and received feedback from 80 percent of our workforce. We saw
sustained strong organisational engagement among our employees
showing that it is desirable to continue with our Orange Culture. The
feedback showed that our people continue to value and appreciate their
colleagues, the ability to work hybrid, and the opportunities that support
their wellbeing.
Employee experience
Employee experience remains a top priority at ING. We believe that
delivering a great employee experience is essential to providing excellent
customer experience and to attract and retain talent. In 2025, ING
continued the collective efforts of the Employee Experience Design Board,
which brings together representatives from Human Resources, Facilities
Services, Operations, Information Technology, and Global Communications
to enhance the employee experience globally.
Throughout the year, this group focused on operational excellence and
service quality, enabling productivity from anywhere, and using data to
prioritise work that matters most. Initiatives included improving the office
environment, streamlining facility management ticketing, creating a
unified portal for employee support, and empowering employees to
be more self-sufficient by simplifying access to information. ING will
continue to focus on the moments that matter to deliver a superior
employee experience.
Competition
ING is a leading European universal bank with global activities. Our more
than 60,000 colleagues based in 40 countries serve nearly 41 million
individuals, corporates and financial institutions in 10 Retail Banking and
over 100 Wholesale Banking markets. ING’s purpose is to empower people
to stay a step ahead in life and in business.
Our Retail Banking business, which consists of Private Individuals, Business
Banking, and Private Banking & Wealth Management, offers individuals,
small to medium-sized businesses (SMEs) and mid-corporates a full range
of products and services covering payments, savings, insurance,
investments, mortgages, trade finance, structured finance and financial
markets solutions, among others. In Wholesale Banking we provide
corporate clients and financial institutions with specialised lending, tailored
corporate finance, debt & equity market solutions and sustainable finance
solutions. We also offer daily banking services such as payments & cash
management and trade & treasury services.
There is substantial competition in the countries in which we do business
for the types of Wholesale Banking, Retail Banking, Business Banking and
other products and services we provide. In recent years, competition has
further increased in both developed and emerging markets. Our largest
market is the Netherlands, where our main competitors are ABN AMRO
Bank and Rabobank.
Traditional banks are no longer the sole providers of financial services.
Digital innovation and AI-driven low-cost models are driving competition
from fintechs, non-bank lenders, and technology companies. Digital banks
are competing for retail customers with user-friendly platforms and low
fees, while private lenders – including big tech companies – are taking a
growing share of business lending. At the same time, innovations such as
digital tokens and stablecoins are reshaping payment systems, moving
them beyond traditional banking channels.
In this competitive landscape, where banking products and services have
mostly become commodified, the main differentiator is being able to
provide superior value for customers. For Retail Banking, delivering superior
customer value means making banking simple and expertise accessible,
offering the right products, at the right time, in the right way. Businesses
too want to benefit from gains in speed, transparency, security and
efficiency created by technologies such as blockchain and artificial
intelligence. Winners will be those with a strong trusted brand and a
superior digital experience, taking the effort out of managing finances and
offering personalised, real-time advice, products and services for all
financial needs.
Statements regarding ING’s competitive position reflect the assessment of
ING’s management about the general competitive landscape in which ING
operates.
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Sustainability
ING aims to leverage our role as a global bank to
support clients in addressing environmental
challenges, including climate-related and nature-
related risks, because it matters to our company,
our customers, society, and the environment.
For ING, ensuring the resilience and commercial success of our business
includes managing climate-related risks while also seizing the
opportunities that come with financing the transition.
Climate change mitigation
Climate change mitigation means reducing GHG emissions to limit global
warming to 1.5 °C above pre-industrial levels, in line with the Paris
Agreement. For ING, this involves managing the emissions linked to our
financing activities.
Climate change adaptation
Climate change adaptation refers to the process of adjusting to current
and anticipated climate change and its impacts. It is intrinsically linked to
physical risk, as it involves implementing strategies to manage and
mitigate the effects of climate-related physical events.
These physical risks can increase the likelihood of defaults and non-
performing loans, exposing ING to financial vulnerabilities through various
channels:
§Wholesale and Business Banking: Damage to infrastructure, operational
disruptions, rising costs, and reduced customer demand can lead to
lower borrower income and higher insurance premiums, increasing the
risk of default.
§Residential real estate: More frequent and severe climate events may
reduce property values, limit insurance availability in high-risk areas,
and impair borrowers’ ability to repay mortgages or access renovation
financing.
Policies, actions and performance
This section includes the relevant policies and guidelines to address the
material impacts, risks and opportunities and the related actions to
execute those policies and guidelines.
The Environmental, Social, and Governance (ESG) Risk Policy
The ESG Risk Framework, described in the 'ESG risk’ section, sets out ING’s
approach to managing ESG risks as drivers of existing risk types. It is
supported by the double materiality assessment (DMA) and the ESG Risk
Policy, which are designed to ensure the implementation of obligations,
processes, and control requirements from the framework.
The ESG Risk Policy explains how ING identifies, assesses, mitigates,
monitors, and reports ESG-related risks in line with our risk appetite, by
considering applicable and material risks and negative impacts across the
value chain. It applies to ING Groep N.V. and all majority-owned entities,
unless local laws require deviations. The policy considers relevant
legislation and guidance, including EBA guidelines on ESG risk
management, EBA ITS on Pillar 3 ESG disclosures, CSRD, EU Taxonomy, and
SFDR. It sets objectives, references applicable regulations, and outlines
high-level obligations and control objectives for managing ESG risks across
the value chain. The ESG Risk Department oversees implementation and
compliance.
ESG risks influence financial and non-financial risk types. Therefore, ESG
risk management is embedded in existing processes such as credit
granting, risk appetite steering, and credit risk management. Local entities
adapt global requirements to local regulations and practices, mainly
through lending criteria, loan-management systems, and sales
procedures.
Actions related to ESG Risk Policy
As part of our risk management cycle (see ‘ESG risk section’), ING
proactively mitigates identified risks and negative impacts within its risk
appetite. We apply strategies such as reducing, avoiding, accepting, or
transferring risk, embedding these measures into policy and procedure
updates across risk categories. It is ING’s policy to act in compliance with
applicable laws and regulations. The following paragraphs outline key
initiatives in business lines where climate change is a material risk.
Retail Banking: Residential mortgages
ING integrates transition and physical climate risks into its mortgage
portfolio strategy, risk appetite, lending criteria, and collateral valuation.
Local entities apply the ESG Risk Policy using global guidance, adapting to
local regulations and practices.
Key actions include:
§Customer engagement: Advisory services and duty-of-care procedures
promote interest in low-emission buildings.
§Data collection: ING implemented controls to ensure the mandatory
collection of EPC data for new loans and enhancement of existing
portfolios through proxy models.
§Risk appetite: Aligned with business strategy and metrics for managing
low-quality EPCs at origination are monitored under the Risk Appetite
Framework, with escalation to the ESG Risk Committee when needed.
Retail Banking: Business Banking lending
ING identifies sectors with higher climate-related risk exposure and
supports these through dedicated lending criteria, data controls (e.g., EPC
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data for real estate), and regular monitoring. We engage with clients to
understand their business plans and transition-related risk considerations.
In line with our risk appetite, we accept certain transition risks but monitor
and manage them through client-specific assessments, exposure limits,
and key risk indicators (KRIs). Risks outside our appetite must be mitigated
or may not be accepted. Mitigation measures include insurance for
physical risks, covenants addressing risk mitigation measures, and
incorporating climate risks into collateral valuation. Sector-specific lending
policies and data collection enable accurate portfolio assessment and
active management.
Wholesale Banking lending
While climate transition-related risks may be more pronounced in certain
carbon-intensive sectors, we manage climate-related risks across the
entire Wholesale Banking portfolio through the ESG Risk Framework,
lending policies, and due-diligence processes. These efforts are supported
by quantification methodologies and advanced tools, ensuring that risks
are identified, assessed, and managed throughout the full origination-to-
monitoring cycle. Key actions include:
§Climate Risk Appetite: We assess transition risks at the client level,
considering emissions, financial capacity, and transition plans. High-risk
clients are managed through risk appetite limits and growth
constraints.
§Lending policies and steering: Sector lending policies reference the ESG
Risk Policy and apply its minimum requirements. They include ESG
factors and transmission channels relevant to each sector, detailing
acceptable mitigants to address potential financial risks from ESG
factors. Relevant sector considerations may inform lending decisions.
§ESG risk assessment tool: In 2025, we launched an enhanced ESG risk
assessment platform that integrates environmental, social, and
governance factors, replacing the previous ESR framework. The tool
improves efficiency and consistency in credit granting by enabling
users to input supplementary ESG data and automating integration
into the assessment process. Further automation and data
enhancements are planned for 2026. The assessment process includes:
–Materiality check: Determines if a client or transaction is likely to
have significant ESG impacts or dependencies based on sector data.
–Initial assessment: Evaluates ESG and reputational risks for material
factors.
–Qualitative review: Front office identifies mitigants and checks
compliance with sector standards and restricted activities.
–High-risk escalation: ESR desk performs due diligence and provides
binding advice, which may include additional conditions or a go/no-
go decision.
–Credit risk review: Experts validate ESG factor assessments and
mitigants relevant to credit risk.
§Client engagement and data infrastructure: We engage clients to
understand and manage climate-related risks and continuously
enhance ESG data infrastructure by integrating internal and external
sources. This provides granular insights for portfolio management and
supports data-driven solutions.
§Collateral valuation: Climate risks affecting property values are
embedded in valuation, monitoring, and revaluation processes for
commercial real estate.
Guidelines and actions addressing our opportunities
Our approach to sustainability-related opportunities is integrated into
ING’s business strategy. This strategic approach ensures that our actions
align with our long-term ambitions. Sustainable lending represents a key
opportunity for us to grow and differentiate in the market. It enables us to
increase sustainable volumes mobilised, expand our renewable energy
financing portfolio, and support clients in purchasing energy-efficient
homes. In addition, our green funding framework supports eligible
financing activities and funding diversification.
To help guide these opportunities and safeguard against greenwashing
risks, we have sustainable finance guidelines and implement mandatory
instructions that set clear criteria and provide practical guidance tailored
to each business line. These instructions ensure reliable and transparent
reporting. Where they are still being embedded, we apply additional
controls to maintain accuracy and prevent greenwashing.
Wholesale Banking
The Sustainable Finance Guidelines provide ING colleagues with a clear
framework for engaging with clients and offering sustainable finance
products and solutions. These guidelines are to be followed by all relevant
business units when advising clients and structuring products.
All products included in our Sustainable Finance Guidelines must comply
with the criteria set out in the mandatory instructions, which define the
conditions under which a product can be classified as sustainable. While
we are still in the process of fully embedding these instructions, the
guidelines are continuously being updated to reflect new product
developments and evolving regulatory requirements.
Wholesale Banking offers financing and advisory services tailored to client
needs in areas where sustainability-related risk considerations are
relevant.
In 2025 we recorded €166 billion of volumes mobilised (2024: €130 billion).
We also see opportunities in financing our clients meeting their energy
transition objectives, by financing renewable power generation. Volumes
mobilised refer to the total amount of financing, investment and related
financial activity that we enable for clients through our products and
services, where we plays a role in originating, structuring, coordinating or
participating in the transaction. Volumes are measured based on ING’s role
in each transaction, with full or pro‑rata recognition when acting as ESG
lead to reflect its contribution to mobilising sustainable finance, and
recognition of the bank’s own share when participating without a lead role.
Retail Banking
Retail Banking has significant opportunities related to green mortgages
and energy-efficient housing. For private individuals, by offering
preferential pricing and mortgage extensions or top-ups for properties with
better EPC ratings, we can attract customers seeking energy-efficient
homes and differentiate our offering in a growing market segment.
Moreover, we can create opportunities by financing renovations that
improve energy performance, such as insulation upgrades or installing
solar panels, enabling customers to enhance property value and reduce
emissions. This not only supports environmental goals but also
strengthens borrowers’ financial resilience, as energy-efficient homes
typically have lower energy bills contributing to a more robust credit
profile.
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Similarly, Business Banking lending presents financing products that may
support client investments in energy efficiency or renewable energy.
Treasury
Our Global Green Funding Framework promotes opportunities for ING, its
investors, and clients on both sides of the balance sheet. On the asset side,
we finance eligible green buildings and renewable energy portfolios. On
the liability side, we issue green bonds and other funding instruments to
diversify funding sources.
The framework aligns with the EU Taxonomy and includes a sustainable
asset classification system. As of 31 December 2025, ING Group has € 14.9
billion in green bonds outstanding (2024: € 15.3 billion).
1Own workforce refers to our employees and non-employees (contractors and individuals engaged via employment agencies), also referred to as our 'employees'.
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Own workforce
As an employer, we aim to provide a safe and
inclusive workplace. We believe financially healthy
people contribute to a healthy economy and drive
social progress, which is why we aim to support
customers in meeting their financial commitments
now, while building their financial security for
tomorrow. We believe every person deserves to be
treated with dignity and have their interests
considered equally, whether it concerns people in
our own workforce or our consumers and end-
users.
Our own workforce1 is our greatest asset. Unlocking our people’s full
potential is a key enabler of our ‘Growing the difference’ strategy as we
believe we have an abundance of talent and potential at ING. We succeed
when we equip our workforce with the skills and capabilities they need to
make significant contributions to the continued and sustainable growth of
our business. We seek to create a safe, non-discriminatory and inclusive
environment that reflects the world we operate in, and where our
employees feel they can belong and thrive.
Own workforce strategy – Unlocking our people’s full
potential
ING strives to provide a safe, non-discriminatory and inclusive workplace
where everyone has the potential to grow and develop. This is supported
by internal policies, controls and workforce processes, taking into account
applicable legal and regulatory frameworks in the jurisdictions in which we
operate. We consider both external and internal factors, such as
geopolitical forces, evolving technology, and changing employee
expectations, as these trends shape our business needs and,
consequently, our strategy. For more on ‘unlocking our people’s full
potential’, see our ‘How we are growing the difference'’ section.
The governance of our policies regarding harassment and violence, and of
our initiatives supporting wellbeing, employment, and the inclusion of
persons with disabilities, is structured in such a way that ING can address
its material risks and impacts in a timely and effective manner. These risks,
such as harassment and violence, can result in lower employee morale,
reduced productivity and harm to ING’s overall reputation and operational
instability, as well as potential legal claims with financial consequences. To
strengthen our adaptability and resilience, tools and the Organizational
Health Index provide valuable insights that guide the refinement of our
policies, inform strategic direction, and support the implementation of
regulatory changes. Through ongoing policy reviews, residual risk
assessments, and the alignment of processes with evolving regulations,
we continuously enhance our capacity to manage both current and
emerging risks effectively.
ING maintains policies and procedures intended to address accessibility
requirements where applicable.
Policies, actions and performance
As a globally operating bank, we are continuously navigating the
complexities of global and local regulations. In some instances, we set
general, globally applicable policies to help address the material risks and
material negative impacts our workforce may face, with consideration for
local laws and regulations which may necessitate tailored local policies to
ensure full compliance. ING maintains workforce-related policies designed
to mitigate discrimination, misconduct and other workforce-related risks. It
is ING’s policy to act in compliance with applicable laws and regulations.
At ING, we denounce all forms of discrimination. Any distinction, exclusion,
or preference not based on the inherent requirements of the job is deemed
as discrimination.
ING’s workforce policies are aligned with local labour laws and regulations
in all countries where we have operations. In countries where local
legislation goes further than the principles set out by the Universal
Declaration of Human Rights and ILO Core Conventions, we also apply
additional and stricter requirements. In addition, we seek alignment with
international standards on human rights (such as the UNGPs) through the
implementation of EU directives and the development of internal policies.
We take various actions to further understand the impacts coming from
outside ING, and we continuously inform our workforce and leaders on
best practices related to developments and learnings. This is exemplified in
our collaboration with external organisations to understand the impact of
global events, socio-economic movements, and changes in legislation.
Where appropriate, we participate in external assessments to understand
our maturity on specific areas and our need for focus and improvement in
others. In 2025, ING continued its ‘Advocate’ status in the annual
Workplace Pride global benchmark, the highest ranking possible for an
organisation.
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Actions on training and skill development
Through our engagement with our workforce, we understand that to drive
meaningful change, we must attract, develop, and retain fit-for-future
talents. That is why we offer both scalable and curated learning and
development opportunities tailored to our employees’ roles and growth,
helping us meet our current and future skills and capability needs. In 2025,
we launched our internal ING University - a global learning platform
powered by a newly introduced learning technology. It brings learning into
one place for all employees, including domain-level academies,
mandatory and non-mandatory learnings (online and in-person) and both
formal and informal development opportunities. In 2025, we continued our
focus on talent development. This year, we performed strategic talent
reviews across the bank for more than 5,000 senior roles in order to better
identify and understand the leadership, skill, and capability needs of our
domains to grow the difference.
Workforce characteristics
ING has no employees with non-guaranteed working hours, as employees
with on-call agreements have agreed fixed hours and are treated as full-
time or part-time employees. We also examine other contextual
information and methodologies for data compilation to aid in
understanding our workforce characteristics. For example, we measure
turnover on a monthly basis as it has the potential to impact operational
effectiveness. In 2025 total turnover was 9 percent, no change compared
to 2024. Additional disclosures include breakdowns by region for full-time
and part-time employees, in order to obtain a comprehensive insight into
our employment practices and impacts. The related staff expenses and
the number of own employees are disclosed in note Note 25 'Staff
expenses' to the consolidated statement of profit or loss.
Actions on privacy
With regard to safeguarding our employees' wellbeing against the risk of
unauthorised access, misuse, or exposure of personal data like address,
remuneration, review assessment scores, outside interests or concerns
raised, we have a Global Personal Data Protection Internal Policy in place.
See the 'Consumers and End Users' section for more details on our policy
and actions regarding privacy.
Whistleblower Policy
Regarding the risks and negative impacts related to ‘measures against
violence and harassment’, our Whistleblower Policy provides instructions
on treating concerns in a careful and proportionate manner, aimed at
ensuring that ING takes appropriate, lawful, and timely action in case of
concerns related to human rights by or within ING. Read more about our
Whistleblower Policy in the ‘Business conduct’ section.
Our actions against violence and harassment in the workplace
We are committed to upholding both the requirements set by human
rights, laws, and regulations, as well as the exacting standards of our
Orange Code and Global Code of Conduct, through which we can fulfil our
purpose of empowering people while countering potential negative
impacts and risks related to, for example, violence and harassment. Read
more about our Global Code of Conduct in the 'Business conduct' section.
In line with our Whistleblower Policy and related control standards, we
categorise and monitor all reported concerns. This overview reflects issues
raised through our dedicated whistleblower channel concerning our own
workforce. All whistleblower reports received and addressed are reported
quarterly by the ING Group Chief Compliance Officer to the Supervisory
Board Risk Committee.
Whistleblower concerns are grouped into categories that link to
internationally recognised human rights:
§Discrimination;
§Aggression, violence, and bullying;
§Breach of confidentiality and data privacy related to an employee;
§(Sexual) Harassment;
§Work-pressure/unrealistic targets; and
§Retaliation
To understand if any of the whistleblower cases concern a severe human
rights incident, we apply three elements of severity: scale, scope, and the
remediability of the impact to the whistleblower categories mentioned
above. Based on our assessment, no severe human rights incidents
connected to our own workforce were identified in the reporting period
(2024: nil).
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Consumers and end-users
Consumers and end-users of ING’s services include companies and private
individuals who we provide our services to. We focus in this section on
private individual customers within our Retail Banking domain, also
referred to as our ‘customers’. At ING, we strive to make access to our
products fair and our communication transparent, and to respect the
rights of our customers when providing our services. This includes
mitigating impacts and risks related to access to quality information, social
inclusion, and privacy.
We are committed to ensure fair access, transparent communication, and
respect for customer rights, while mitigating risks related to information
access, social inclusion, and privacy. These topics are especially relevant
for customers in vulnerable positions, such as elderly individuals or those
with temporary or permanent disabilities, chronic illness, or reading
difficulties, who may be more susceptible to harm or exclusion without
appropriate care.
Customer strategy: Superior customer value
We strive to make banking easy, instant, personal, and relevant so
customers can stay up to date with all that ING offers. We aim to clearly
price products and services, avoid complicated jargon, and always be
accessible. And as part of our accessibility strategy of ‘Leave no one behind’,
we strive for the inclusion of all our customers, with and without disabilities.
Access to quality information and social inclusion is important in
promoting financial health and accessibility. Enhancing financial literacy is
also essential to empower customers to make informed decisions. These
topics, along with related issues such as non-discrimination, access to
products and services, and responsible marketing, are validated through
our customer-centric compliance risk assessment.
Additionally, safeguarding customer privacy and data security is a key
compliance and reputational priority, reflecting our responsibility to
protect personal information. We manage related risks by continuously
assessing the regulatory environment for updates and implementing
these in line with our governance measures. This ensures we remain
compliant while safeguarding our strategy to provide superior customer
value. The processes for managing our risks and impacts, as laid out in this
section, are integrated into existing risk management and compliance
processes.
Policies, actions and performance
Customer Centricity Policy
ING offers customers a large variety of financial products and services, so
we face different risks and are subject to a multitude of regulations. Our
Customer Centricity Policy (CCP) helps in preventing and mitigating
impacts and risks regarding the topics of social inclusion and access to
quality information, including mis-selling and unfair customer treatment.
For instance, we want all our customers to have equitable access to our
products and services, including persons with disabilities, which is why we
strive to comply with the procedures of our policies and apply controls.
After rolling out the first version of the CCP in 2024, we updated the policy
this year to bring elements such as discrimination and access to banking
into the Compliance Risk Framework. In practice, this means we apply
global minimum standards for these issues, which aim to support us in
identifying severe human-rights incidents in the future. Our governance
framework, supported by continuous policy reviews, risk assessments, and
regulatory change implementation, enables us to address material risks
related to discrimination, inclusivity, and access to information in a timely
and effective manner.
The CCP defines high-level obligations to ensure ING handles risks
appropriately and in line with regulations. We want to offer products and
services suitable for our customers throughout the whole relationship
lifecycle at a fair price, considering the market, costs, and risks. We
monitor internal controls and processes, such as our Product Review and
Approval Process (PARP), in which relevant elements of customer centricity
are considered and challenged. The CCP requires us to communicate
information on products and services in a clear and non-misleading
manner, and provide services and trusted advice through professionals
with the necessary knowledge and expertise. In doing so, we also consider
the ESG risks and impact of our products and services on customers.
Having a global CCP enables us to align and assess whether customer
centricity is applied to all products and customers across ING. Norms we
formalised into minimum standards include the need to only create and
sell products that are in the interests of customers and society, an aligned
standard on complaints processes, the provision of clear and accessible
information that is at all times fair and not misleading, and the
assessment of the needs of individual customers – both when we sell a
product and when the customer uses a product. With these, we aim to
mitigate potential and actual financial distress for individual customers,
resulting from not having access to products, services and/or quality
information.
Complaints and remediation process
In addition to our general engagement activities, we use our complaints
channels to gain a clearer picture of the impacts we have on our
customers. The insights we gain from complaints help us implement
structural improvements in our products and processes. The CCP sets out
the minimum requirements for complaints procedures across all ING
entities, including the need for transparency about the process and
keeping customers informed of the progress in handling their complaint.
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All complaints must be assessed regularly, and root cause analyses must
be carried out to mitigate the risks of customer harm. The CCP also aims
to ensure that customers can raise complaints about ING’s financial
products through third parties, including distributors, brokers, and
manufacturers. There are several ways our customers can file a
complaint. Within nearly all our Retail markets there is at least one
assisted channel available (e.g. call centre, branch, human chat, social
media), and at least one self-service channel (e.g. mail, e-mail, online
channels app and web) where customers can file a complaint, which will
then be handled by a human agent.
Customers are made aware of these channels via publicly available
information e.g. ING websites (FAQs and search engine) and via the Terms
& Conditions provided to customers during onboarding. Furthermore, a call
centre, branch and/or a chat agent can provide further information
regarding the complaints processes when a customer contacts ING. We
value our customers and take their concerns seriously. While this is not
embedded in our customer-focused policies, we do not tolerate retaliation
by any employee. For our anti-retaliation measures included in our
Whistleblower Policy, see the ‘Business conduct’ section.
We manage complaints primarily through contact centres and when
possible complaints are solved on initial contact. If unresolved, they
escalate to specialised teams. We evaluate the complaints handling
process, for instance, through an assessment of the time it takes to resolve
complaints and how frequently we do so. A change in products, financial
compensation, and/or apologies can help to address any negative impacts
on customers. We analyse complaints to implement structural changes in
products, processes, policies, procedures, and communication, and involve
relevant risk parties and internal stakeholders as needed. We have
established channels and procedures to ensure that customers are aware
of and have confidence in our complaints procedures. However, we do not
assess this confidence separately. Instead, if concerns about our
complaints procedures are raised, we consider these within our broader
evaluation of customer concerns.
Over the course of 2025, ING implemented a minimum set of
standardised labels on human rights (like discrimination, accessibility,
privacy), customer centricity and ESG. These labels are applied to
complaints, further enabling us to perform root-cause analyses and to
rectify service breakdowns, improve the customer journey, address
potential human rights issues and provide appropriate remedy, help
senior management better understand customer protection and further
strengthen customer trust.
An assessment for severe incidents was conducted using our internal issue
management system. Through this process no severe human rights
incidents were identified in 2025.
Actions on access to quality information and social inclusion
ING has implemented the requirements of the European Accessibility Act
and remains committed to further optimising and improving accessibility
across all customer‑facing services in our EU Retail Banking countries. This
implementation is supported by a dedicated accessibility team, whose
main objectives are to safeguard accessibility within ING, raise awareness
of this topic, and provide advice and coordination across countries.
We strive to make ING more accessible and inclusive for our customers. For
example, we have introduced voice-activated ATMs in certain countries to
help people with visual impairments to withdraw money. We also issue
bank cards with a physical notch that allows customers with visual
impairments to quickly identify the correct card by touch. In certain
countries, customers with visual impairments can also use screen readers
– software applications that read aloud on-screen information.
To further mitigate potential material negative impacts and risks related to
social inclusion, we are collaborating with the United Nations Environment
Programme Finance Initiative (UNEP FI) under the Principles for Responsible
Banking to contribute to setting a measurement standard for financial
health impact for our industry. As a founding signatory of the
Commitment to Financial Health and Inclusion, we aim to reduce
financially vulnerable or unhealthy households. We use technology to
create innovative digital tools that encourage customers to build savings
and manage their expenses, which have been implemented in multiple
European locations. For more information on financial health, see ing.com.
Compliance policies, such as the CCP, are implemented in the locations we
operate in. Outcomes of our monitoring, complaints analyses, event
analysis or regulatory interactions, are recorded as an issue in our global
database. We monitor and address issues on a local and global level. In
addition, CCP standards and compliance risks are subject to continuous
monitoring and, in line with our risk-based approach, undergo periodic
assessment and measurement. In relation to products and services, we
perform periodic reviews in the context of the Product Approval and
Review Process, which may lead to the remediation of a product if, for
example, it is considered unfit for our customers.
Global Personal Data Protection Policy
Just as we strive to enable customers to engage with ING without issue or
interruption, we aim to protect the personal data they provide to us
throughout their ING journey. In line with the EU's General Data Protection
Regulation (GDPR) and other applicable data protection requirements, ING
aims to only process personal data for a specific business purpose in a fair
and lawful manner, observing the rights and liberties of data subjects in
scope of our activities. To fulfil this ambition, ING has implemented a
Global Personal Data Protection Policy (GPDP), which reflects the
requirements based on laws and regulations, industry standards, and ING’s
internal risk appetite. This GPDP contains specific requirements and
controls, which ensure the necessity and accuracy of the personal data
ING is processing. The GPDP helps in preventing and mitigating impacts
and risks regarding the topic of (data) privacy.
It is our policy to have operational flows in place regarding data subject
rights (such as the right to access personal data, right to erase personal
data that no longer needs to be retained, right to object to data processing
etc.), and to ensure that these rights are adequately provided to all
individuals whose personal data is subject to processing. This means ING
has implemented operational flows to handle requests – such as access to
personal data, amendments/corrections, or objections to data processing –
promptly and in line with regulatory requirements.
In accordance with our policies, we strive to be transparent about what we
do with the personal data of customers, employees, suppliers and business
partners, as well as who we share personal data with and why. We want
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our business entities, support functions, and the third parties we engage
with, to grant a level of protection to the data subject equivalent to that
guaranteed by the GDPR, especially if personal data is transferred outside
of the European Economic Area. Part of the data protection scope is that
personal data is managed in a safe and secure manner, in line with current
information security standards. For more information, see the Privacy
Statement on ing.com.
Actions regarding Privacy
ING manages personal data protection and retention risks and impacts via
the Global Data Protection and Global Record Retention and Deletion
frameworks and control standards. Potential material impacts are
identified and addressed by relevant data protection risk assessments
such as:
§The Data Protection Impact Assessment – performed at processing
activity level and allows for an in-depth scrutiny of personal data
processing activities in line with applicable regulations and data
protection principles;
§The Legitimate Interest Assessment – performed to assess whether ING
can rely on legitimate interest as a lawful basis in case of certain
personal data processing activities. In the case of this assessment the
legitimate interests of ING are considered and balanced against the
interests and rights of individuals in scope of the processing; and
§The Transfer Impact Assessment – performed in case personal data is
transferred to a non-EEA country. In this case the soundness of
contractual and technical protective measures and controls is
assessed.
All assessments mentioned lead to concrete risk identification and impact
mitigation measures, which are implemented on a granular level (business
process- or IT asset-level). This enables ING to continuously identify,
manage and limit relevant data protection risks, as data protection risk
assessments represent an integral part of defining new business processes
or introducing changes to existing ones.
Equally, personal data protection considerations are assessed and
documented at product level, within the PARP process. The data protection
framework includes policies and control standards that are continuously
monitored and, in line with our risk-based approach, periodically assessed
and measured.
In the case of security incidents impacting personal data (e.g. data
breaches) it is our policy to take the necessary containment and
mitigation measures as soon as possible after identifying such an
occurrence. As part of this policy we assess related data protection risks
and impacts, and determine whether external reporting to supervisors is
required, ensuring compliance with regulatory requirements. Based on the
incident’s impact and risk, we conduct ‘lessons learned’ sessions to
improve workflows and prevent similar future occurrences, strengthening
the protection of customer personal data. These lessons learned take into
account, first and foremost, the potential or actual impact of a data
breach occurrence on affected customers.
The effectiveness of our data protection and retention controls is
monitored and tested periodically as part of the ING Key Control Testing
framework. Data protection and retention controls are managed in line
with implemented data protection governance. Dedicated first- and
second-line teams, along with the Data Protection Executive Office and
Data Protection Compliance, support relevant business process, asset and
contract owners in identifying and managing data protection and
retention risks, including implementing appropriate mitigation measures.
For 2025, we delivered relevant improvements of the personal data
protection framework, focusing on implementing controls for data
retention and deletion, and enhancing the Data Protection Policy. We
continuously optimise data protection processes to ensure data protection
requirements are embedded in relevant business processes in full
compliance.
Metrics and targets
We aim to limit the number of complaints and/or breaches related to
access to quality information, social inclusion, data privacy, and associated
reputational risks. If these occur, we take actions to remediate risks and
impacts, as described in the previous paragraph. For our reputational risks,
we have a Compliance Risk Framework, which contains risk appetite
indicators used for internal monitoring.
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Business conduct
Our culture drives the way we do business and
impacts all our stakeholders. We are guided by
ING’s Orange Code, which sets our values and
behaviours and ensures we work with integrity,
transparency, and high standards of business
ethics. Our employees are encouraged to speak up
and report concerns, and have a zero-tolerance
approach to any form of bribery and corruption.
Business conduct refers to the way we do business. Our Global Code of
Conduct reflects the standards we must adhere to, and includes our
values, principles, and ethical standards. Business conduct includes
matters such as business ethics and corporate culture, including anti-
corruption and anti-bribery, and the protection of whistleblowers – and
these are the specific sustainability matters we have identified.
Policies, actions and performance
Corporate culture – integrity above all
Our operations touch many lives: customers, employees, shareholders,
and society at large. Everyone within these groups has a reasonable
expectation that we act with integrity. At ING, we all have a duty to put
integrity above all we do and to live up to the values we hold. We will not
ignore, tolerate or excuse behaviour that breaches our values. To do so
would break the trust of society and the thousands of great colleagues
who do the right thing to take this company forward every day.
Our corporate culture starts with the Orange Code – it is a declaration of
who we are, with the overarching principle of ‘integrity above all’. While
the Orange Code sets out general values and behaviours, the ING policies
and guidelines are much more specific and state the rules in more detail.
The ING Global Code of Conduct is the link between the Orange Code and
the main ING policies and guidelines.
Our values and behaviours | Main ING policies and procedures | |||
Business Conduct Framework | ||||
The Orange Code is a manifesto that describes our way of working. It comprises our values and behaviours | Orange Code | ING Global Code of Conduct | Whistleblower Policy | |
Global Investigations Charter | ||||
Zero tolerance on corruption and bribery | Anti-bribery and Corruption Policy | ABC High-Risk Roles Guidance | Global Event Management Procedure | |
The table above outlines the main policies and procedures within ING's
Business Conduct Framework, with key policies highlighted in bold. All
policies are subject to Internal Control Binding Principles (ICBP), which set
the standard for the entire lifecycle of the policy and apply to all ING
Business Units (i.e. all branches and majority-owned subsidiaries of ING
Groep N.V.). In accordance with ICBP, policies are reviewed in full at a
minimum every three years (unless otherwise approved), and checked, at
least annually, for alignment with relevant laws and regulations and
current practice. Policies, procedures and guidelines are available and
easily accessible for all staff on the ING intranet. The Orange Code and
Global Code of Conduct are available for external stakeholders on ing.com.
In addition to the abovementioned policies, ING has several internal
processes and guidelines in place to provide guidance towards the actions
and monitoring of the risks and policies.
The following processes and guidelines are linked to the global policies:
§The Global Investigations Charter specifies which incidents are to be
investigated under the local or global responsibility of Corporate Special
Investigations (CSI), and how the investigation is to be initiated,
conducted, and resolved. It defines the governing principles for
organising, managing, and conducting the investigations function
within ING.
§The Global Event Management Procedure outlines the processes for the
management of operational risk events, as well as the roles and
responsibilities for mitigating the impact of such identified events and
their related reporting.
§The AB&C High-Risk Role Guidance defines job activities considered to
be at risk or vulnerable from the bribery and corruption risk perspective,
and provides the basis for enrolment to the AB&C HRR training.
Training and awareness are of great importance for policies to be effective.
To this end, we have developed global mandatory training for business
conduct-related policies.
The Orange Code
The Orange Code describes what we can expect from each other when we
turn up to work each day. It is a set of standards that we collectively value,
strive to live up to, and invite others to measure us by. The Orange Code
comprises the ING values and the ING behaviours:
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Values | Behaviours |
We are honest | You take it on and make it happen. |
We are prudent | You help others to be successful. |
We are responsible | You are always a step ahead. |
The Orange Behaviours are embedded in commitments we make to each
other and the standards by which we measure each other’s performance.
ING’s Global Code of Conduct
Building on the values and behaviours of our Orange Code, the ING Global
Code of Conduct outlines the 10 conduct principles expected from
employees. The Global Code of Conduct aims to prevent and protect our
employees from making unethical and/or illegal decisions within ING’s
day-to-day business. Prevention of bribery & corruption (AB&C), and
whistleblowing (speaking up), are among those 10 core principles. Conduct
principles are further governed via their respective policy frameworks.
ING launched a new global mandatory training on the Global Code of
Conduct in 2025, and new joiners are expected to undertake the training
upon joining ING. At the conclusion of the e‑learning module, employees
are required to acknowledge their understanding of and commitment to
complying with the Global Code of Conduct, which is actively monitored.
Risk culture
At ING, we attach great importance to a sound risk culture, which is
essential for performing our role in society responsibly and for keeping the
bank safe and secure. We determine our risk culture as: the way in which
employees identify, understand, discuss, and act on many financial and
non-financial risks we are confronted with every day. On an annual basis,
we monitor the progress of our risk culture maturity and furthermore, risk
culture is actively discussed by the Management Board Banking and the
Supervisory Board on a bi-annual basis. In 2025, ING further strengthened
its risk culture by promoting organisational learning as a bank-wide
priority with a key focus on enhancing lessons learned practices.
Behavioural risk
Behavioural risk is an increasingly important area for ING and across the
financial industry. It arises when behavioural patterns are at the root of
financial and non-financial risks in the organisation. The complexity of this
type of risk is that it is less tangible compared to other risk areas because it
focuses on behavioural patterns and their drivers. There are patterns in how
decisions are made, how people communicate, and whether they can and
are willing to take ownership. Behaviour is driven by formal and informal
mechanisms. Examples of formal drivers are the processes ING applies and
how its governance is structured. Informal drivers are less tangible, such as
group dynamics or underlying beliefs that influence behaviour.
Behavioural risk assessments
Behavioural risk assessments identify and analyse undesired behaviours
within ING and provide management with specific direction on how to
change these behaviours. They focus on the effectiveness of groups rather
than individuals, the role of leadership, and on less visible aspects such as
team dynamics and unwritten social norms. The goal is to understand and
systematically assess what drives undesired habits at ING. The behavioural
risk management framework is used as a guide across ING to identify
behavioural risks in the organisation that require deeper investigation.
Behavioural risk interventions
Based on the results of the executed behavioural risk assessments,
interventions are taken to mitigate the behavioural risks in a focused
manner. Effective mitigation requires a deep understanding of what drives
undesirable behaviours. Behavioural and organisational science theories
and evidence-based techniques and tools play an important role in
designing and facilitating interventions.
Whistleblower Policy
At ING we systematically look for ways to enhance and harmonise our
‘speak up’ channels. Speak-up concerns can be reported via a variety of
channels, in particular to managers, HR, confidential advisers,
Whistleblower Reporting Officers or via our (anonymous) whistleblower
reporting platform. We want our employees to feel safe to raise concerns
and to be confident that we will adequately address reported concerns.
We encourage and support employees in raising whistleblower concerns
through any reporting channel. All reports are handled with the highest
level of confidentiality, and we clearly communicate reporters’ rights and
responsibilities. Concerns reported via a whistleblowing channel are, when
in scope of the Whistleblower policy, reviewed by an ING Whistleblower
Reporting Officer to assess if there is sufficient ground for an investigation.
The global Whistleblower Policy and procedure, together with the Global
Investigations Charter, set out the minimum requirements to ensure
concerns are handled fairly, timely, proportionately, and with care.
Robust anti-retaliation measures are in place to protect whistleblowers.
ING does not tolerate any form of retaliation by any employee, including
(senior) management. It is strictly prohibited to retaliate against a reporter
or anyone providing information or assisting in an investigation.
External parties can report suspicions and complaints on misconduct or
behaviour via the pages ‘Whistleblower policy’ (shareholders and suppliers)
and 'Complaints about our conduct' (customers and other stakeholders)
on ing.com.
There is a global mandatory training for employees to educate them on
the whistleblower channel, anonymity and confidentiality, their rights and
responsibilities as reporters, the importance of awareness on retaliation,
and how the follow-up on concerns is handled. We actively monitor the
timely completion of the e-learning. Alongside the global support
community, a specialist learning journey provides Whistleblower Reporting
Officers with a one‑stop resource for mandatory obligations, investigative
interviewing, guidance, and templates.
ING entities have created local policy annexes where necessary in case of
specific local legal requirements based on the transposition of the EU
Directive 2019/1937 on the protection of persons who report breaches of
Union law/Whistleblowing into national law.
Anti-bribery and Corruption Policy
We are committed to doing business in an honest, prudent and
responsible manner and aim to ensure compliance with applicable AB&C
laws and regulations. ING’s AB&C Policy outlines the obligations, key risks,
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and control objectives that are necessary to ensure that bribery and
corruption risks are identified, assessed, managed, and monitored
accordingly.
ING has a zero-tolerance approach to bribery and corruption in all its
relationships and business dealings. ING does not permit accepting or
paying bribes or offering improper inducements or anything that could be
perceived as such. ING expects the same from its business partners and
third parties that perform services or deliver business on its behalf.
Investigations into possible breaches of anti-bribery regulations are the
responsibility of CSI, as we want to ensure independence, objectivity,
impartiality, and confidentiality. ING entities are required to report
instances of bribery and/or corruption, in accordance with the Global Event
Management Procedure. This includes reporting to the Management Board
Banking and chairperson of the Supervisory Board.
ING has a key risk indicator in place to monitor its zero-tolerance policy on
bribery and corruption by ING employees or third parties on a monthly
basis. Reporting is based on event data from ING’s Non-Financial Risk (NFR)
Management tool, iRisk, which captures NFR-related events and provides
standard reports for risk monitoring.
During 2025, there were no instances of convictions and fines related to
violations of AB&C laws (2024: nil).
ING published an updated AB&C Policy, effective 1 July 2025, on our
intranet and on ing.com. The policy is aligned with relevant local and
international laws, including the US Foreign Corrupt Practices Act and the
UK Bribery Act.
Global mandatory training on AB&C has been designed to provide all
employees, including contingent workers, with an understanding of the
bribery and corruption risks faced by ING, the risks they may be exposed
to, and how ING manages these risks. New joiners are expected to
undertake the training on joining ING. The goal of the training is to enable
the learners to:
§recognise the importance of our role in fighting bribery and corruption;
§understand the consequences of bribery and corruption on society and
the organisation;
§recognise how we identify, manage, and mitigate potential bribery and
corruption risks; and
§escalate any suspicious behaviour or suspicions of potential bribery or
corruption risks through appropriate channels.
ING has an approach to identify the roles with an increased exposure to
bribery and corruption risks, known as High-Risk Roles (HRR's). The HRR
Guidance defines, in detail, the job activities considered to be at risk or
vulnerable from a bribery and corruption risk perspective. For more
information on the criteria, see ‘Definitions of our environment, social and
governance metrics’ in the Appendix to the Executive Board report.
Employees in a High Risk Role (HRR) are enrolled in a targeted e-learning
(updated November 2025). It covers the following key areas of activity:
§AB&C regulatory requirements relating to anti-bribery and corruption,
the risks for the financial industry, and the impact of a regulatory
breach;
§ING gifts & entertainment rules;
§enhanced risks associated with public officials; and
§bribery and corruption risks in the hiring process; and when engaging
with third parties.
Both the global mandatory and HRR training completion by employees is
monitored. In 2025 97 percentof employees completed the global
mandatory training on AB&C (2024: 98 percent and 89 percentof eligible
employees completed the HRR training (2024: 89 percent).
In 2025 the management boards and Supervisory B were offered a training
session that:
§provided an overview of global AB&C laws along with business activities
vulnerable to bribery and corruption risks;
§reinforced the critical role of leadership in upholding ING’s zero-
tolerance stance on bribery and corruption; and
§fostered interactive group discussions that highlighted bribery and
corruption risks.
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Regulation and Supervision
The banking and broker-dealer businesses of ING are subject to detailed
and comprehensive supervision in all of the jurisdictions in which ING
conducts business.
Regulatory agencies and supervisors have broad administrative power and
enforcement capabilities over many aspects of our business, which may
include liquidity, capital adequacy, permitted investments, ethical issues,
money laundering, anti-terrorism measures, privacy, recordkeeping,
product and sale suitability, marketing and sales practices, ESG,
remuneration policies, personal conduct and our own internal governance
practices. Also, regulators and other supervisory authorities in the EU, the
US and elsewhere continue to scrutinise payment processing and other
transactions and activities of the financial services industry through laws
and regulations governing such matters as money laundering, anti-
terrorism financing, tax evasion, prohibited transactions with countries or
persons subject to sanctions, and bribery or other anti-corruption
measures.
As discussed under “Item 3. Key Information - Risk Factors”, as a large
multinational financial institution we are subject to reputational and other
risks in connection with regulatory and compliance matters involving these
countries.
European Regulatory framework
The Single Supervisory Mechanism (“SSM”) is the first pillar of the Banking
Union and has been operational since 4 November 2014. The SSM consists
of the European Central Bank (“ECB”) and the national competent
authorities of the participating EU member states. The main objective of
European banking supervision is to ensure the safety and soundness of the
European banking system, enhance financial integration and stability and
ensure consistent supervision. Under the SSM, the ECB is the main
prudential supervisor of ING Group and ING Bank. The ECB's responsibilities
include tasks such as market access, compliance with capital and liquidity
requirements and governance arrangements. National competent
authorities, including the Dutch Central Bank (De Nederlandsche Bank or
“DNB”) for ING Group and ING Bank, remain responsible for supervising
tasks not transferred to the ECB such as financial crime and payment
supervision.
The SSM is complemented by the second pillar of the Banking Union, the
Single Resolution Mechanism (“SRM”), which consists of the Single
Resolution Board (“SRB”) and the national resolution authorities. The SRM
has been fully responsible for the resolution of banks within the Eurozone
since 1 January 2016.
As the third pillar of the Banking Union, the EU wants to further harmonise
the regulation for Deposit Guarantee Schemes (DGS). One of the key
elements is the creation of ex-ante funded DGS funds, financed by risk-
weighted contributions from banks. Since 2015, the EU has been
discussing a pan-European (or pan-banking union) DGS (the European
Deposit Insurance Scheme (EDIS)), which would (partly) replace or
complement national compensation schemes, but there is no EDIS yet as
political negotiations have stalled. On 18 April 2023, the European
Commission published the proposals for the revision of the common
framework for bank crisis management and deposit insurance (CMDI) that
focuses on small and medium-sized banks, but will affect all banks in the
EU. The CMDI framework consists of the Bank Recovery and Resolution
Directive (BRRD), the Single Resolution Mechanism Regulation (SRMR) and
the Deposit Guarantee Schemes Directive (DGSD). On 25 June 2025, the
Council and the European Parliament reached political agreement on the
reformed CMDI framework. The co-legislators are now expected to finalise
the legal text, after which the revised framework will be formally adopted
and enter into force.
Dutch Regulatory Framework
The Dutch regulatory system for financial supervision consists of
prudential supervision – monitoring the soundness of financial institutions
and the financial sector, and conduct-of-business supervision – regulating
institutions’ conduct in the financial markets. To the extent that prudential
supervision is not transferred to the ECB, it is carried out by the Dutch
Central Bank (De Nederlandsche Bank or “DNB”), while conduct-of-business
supervision is carried out by the Dutch Authority for the Financial Markets
(Autoriteit Financiële Markten or “AFM”).
Global Regulatory Environment
There are several legislative and regulatory proposals that could impact
ING globally, in particular the proposals of the Financial Stability Board and
the Basel Committee on Banking Supervision at the transnational level and
a growing set of supranational directives and national legislation in the
European Union (see “Item 3. Key Information - Risk Factors - We operate
in highly regulated industries. Changes in laws and/or regulations
governing financial services or financial institutions or the application of
such laws and/or regulations governing our business may reduce our
profitability"). The aggregated impact and possible interaction of all these
proposals is difficult to determine, and it may be difficult to reconcile them
if they are not aligned. The financial industry has also taken initiatives
through guidelines and self-regulatory initiatives.
Dodd-Frank Act and other US Regulations
ING Bank has a limited direct presence in the United States through the
ING Bank Representative Offices in New York, Dallas, Houston, and Los
Angeles. Although the offices’ activities are strictly limited to essentially
that of a marketing agent of lending and other similar products (i.e. the
offices may not take deposits or execute any transactions), the offices are
subject to the regulation of the State of New York Department of Financial
Services, the State of Texas Department of Banking, the California
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Department of Financial Protection and Innovation, respectively, as well as
the Federal Reserve. ING Bank also has a subsidiary in the United States,
ING Financial Holdings Corporation, which through several operating
subsidiaries offers various financial products, including lending, and
financial markets products. These entities do not accept deposits in the
United States on their own behalf or on behalf of ING Bank N.V.
The ING subsidiary, ING Capital Markets LLC, is registered as a U.S. swap
dealer and subject to a statutory regulatory regime and CFTC rules and
oversight. As a result, it is subject to, among others, business conduct,
record-keeping and reporting requirements, as well as margin
requirements and capital requirements. In addition to the obligations
imposed on registrants (such as swap dealers), other requirements relating
to reporting, clearing, and on-facility trading have been imposed for much
of the off-exchange derivatives market and new risk management
requirements have been proposed focused on business continuity
generally. The proposed new risk management requirements could impose
significant compliance costs to the extent inconsistent with the existing
group-wide framework.
ING Capital Markets LLC is also registered as a security-based swap dealer
and is subject to a statutory regulatory regime and SEC rules and
oversight. The SEC has adopted regulations, among others, establishing
registration, reporting, risk management, business conduct, and margin
and capital requirements for security-based swaps. While ING Capital
Markets LLC, as a security-based swap dealer, is required to comply with
SEC rules with respect to most of these requirements, SEC rules have
permitted an “Alternative Compliance Mechanism” that allows for
compliance, subject to eligibility requirements, with CFTC capital and
margin rules applying to swap dealers in lieu of SEC capital and margin
rules applying to security-based swap dealers. ING Capital Markets LLC has
elected to use the Alternative Compliance Mechanism. However, should
ING Capital Markets LLC in the future be ineligible for the “Alternative
Compliance Mechanism”, it would be subject to SEC security-based swap
dealer rules for margin, capital, and related financial reporting instead of
the CFTC swap dealer rules applied to security-based swaps with respect to
margin, capital, and related financial reporting.
The Dodd-Frank Act also created an agency, the Financial Stability
Oversight Council (FSOC), an interagency body that is responsible for
monitoring the activities of the U.S. financial system, designating
systemically significant financial services firms and recommending a
framework for substantially increased regulation of such firms, including
systemically important non-bank financial companies that could consist of
securities firms, insurance companies and other providers of financial
services, including non-U.S. companies. ING has not been designated a
systemically significant non-bank financial company by FSOC and FSOC
initiating such a designation currently is deemed unlikely.
Dodd-Frank continues to impose significant requirements on us, some of
which may have a material impact on our operations and results, as
discussed further under “Item 3. Key Information - Risk Factors - We
operate in highly regulated industries. Changes in laws and/or regulations
governing financial services or financial institutions or the application of
such laws and/or regulations governing our business may reduce our
profitability”.
Basel III has been implemented in the EU and is currently applied
by ING
In all jurisdictions where the bank operates through a separate legal entity
that is a credit institution, ING must meet the local implementation of
Basel requirements. ING uses the Advanced and Foundation IRB Approach
for credit risk, the Internal Model Approach for its trading book exposures
and the Standardised Measurement Approach for operational risk. A small
number of portfolios including certain sovereign exposures are reported
under the Standardized Approach for credit risk.
In December 2010, the Basel Committee on Banking Supervision
announced higher global minimum capital standards for banks, and
introduced a new global liquidity standard and a new leverage ratio (LR).
The Basel Committee's package of reforms, collectively referred to as the
“Basel III” rules, among other requirements, increased the amount of
common equity required to be held by subject banking institutions,
prescribed the amount of liquid assets and the long term funding a subject
banking institution must hold at any given moment, and limited leverage.
Banks are required to hold a “capital conservation buffer” to withstand
future periods of stress. Basel III also introduced a “countercyclical buffer”
as an extension of the capital conservation buffer, which permits national
regulators to require banks to hold more capital during periods of high
credit growth (to strengthen capital reserves and moderate the debt
markets). Further, Basel III strengthened the definition of capital that had
the effect of disqualifying many hybrid securities, as well as increased
capital requirements associated with certain business conditions (for
example, for credit value adjustments (CVAs) and illiquid collateral) as part
of a number of reforms to the Basel II framework. In addition, the Basel
Committee and Financial Stability Board (“FSB”) published measures that
have had the effect of requiring higher loss absorbency capacity, liquidity
surcharges, exposure limits and special resolution regimes for, and
instituting more intensive and effective supervision of, “systemically
important financial institutions” (SIFIs), in addition to the Basel III
requirements otherwise applicable to most financial institutions. One such
measure, published by the FSB in November 2015, is the Final Total-Loss
Absorbing Capacity (TLAC) standard for G-SIFIs, which aims for G-SIFIs to
have sufficient loss-absorbing and recapitalisation capacity available in
resolution. Since 2011, ING has been designated by the Basel Committee
and FSB as a so-called “Global Systemically Important Bank” (G-SIB, or
Global Systemically Important Institution - G-SII in the European
legislation), and by DNB and the Dutch Ministry of Finance as a “other
SII” (O-SII) . Since December 2020 DNB has required ING Group to hold O-SII
Buffer in addition to the capital conservation buffer and the countercyclical
buffer described above. ING Group is subject to O-SII Buffer of 2.0% (from
31 May 2024 when DNB lowered it from 2.5% that applied previously). In
December 2025 DNB announced that it reviewed the identification and
buffer requirements for systemically important banks, and maintained
2.0% O-SII Buffer requirement for ING. The higher of G-SIB or O-SII buffers
applies, hence ING Group's risk-based capital requirements are not
affected by G-SII Buffer of 1%. However 50% of G-SII buffer increases ING's
Leverage Ratio requirement from a regular 3.0% (3.1% with 0.1% Pillar 2
requirement from 1 January 2026) that applies to non G-SII banks to 3.5%
(3.6 % including 0.1% Pillar 2 requirement from 1 January 2026).
For European banks the Basel III requirements have been implemented
through the Capital Requirement Regulation (CRR) and the Capital
Requirement Directive (CRD). The CRD IV regime entered into effect in
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August 2014 in the Netherlands, but not all requirements were
implemented all at once. Having started in 2014, the requirements have
been gradually tightened, mostly before 2019, until the Basel III migration
process was completed.
CRD IV has not only resulted in new quantitative requirements but has also
led to the setting of new standards and evolving regulatory and
supervisory expectations in the area of governance, including with regard
to topics like conduct and culture, strategy and business models,
outsourcing and reporting accuracy.
CRR II / CRD V and BRRD II
On 27 June 2019, a series of measures referred to as the Banking Reform
Package (including certain amendments to CRR and CRDIV commonly
referred to as ‘CRR II’ and CRD V’) came into force, subject to various
transitional and staged timetables. The adoption of the Banking Reform
Package concluded a process that began in November 2016 and marked
an important step toward the completion of the European post-crisis
regulatory reforms, drawing on a number of international standards
agreed by the Basel Committee, the Financial Stability Board and the G20.
CRDV was implemented in Dutch law in 2020. The Banking Reform Package
introduced changes to the CRR, CRD IV, the Bank Recovery and Resolution
Directive (BRRD) and the Single Resolution Mechanism Regulation (SRMR).
The Banking Reform Package covered multiple areas, including the Pillar 2
framework, the introduction of a leverage ratio requirement of 3% and a
leverage ratio buffer requirement of 50% of the G-SIB buffer requirement
(applicable per 1 January 2023), a binding Net Stable Funding (NSFR) ratio
based on the Basel NSFR standard (including adjustments with regard to
e.g. pass-through models and covered bonds issuance), mandatory
restrictions on distributions, permission for reducing own funds and eligible
liabilities, macroprudential tools, a new category of ‘non-preferred’ senior
debt, the minimum requirement for own funds and eligible liabilities
(MREL) and the integration of the TLAC standard into EU legislation.
Further, the EBA obtained a mandate to investigate how to incorporate
environmental, social, and governance (ESG) risks into the supervisory
process and what the prudential treatment of assets associated with
environmental or social objectives should look like.
Whilst the Banking Reform Package was being developed, the ECB
introduced the Targeted Review of Internal Models (TRIM) in June 2017 to
assess reliability and comparability between banks’ models for calculating
each bank’s risk-weighted assets (‘RWA’) used for determining certain of
such bank’s capital requirements. In July 2019, the ECB published the final
chapters of the guide to internal models, covering credit risk, market risk
and counterparty credit risk. These risk type-specific chapters are intended
to ensure a common and consistent approach to the most relevant
aspects of the regulations on internal models for banks directly supervised
by the ECB. Additionally, they provided transparency on how the ECB
understands the regulations on the use of internal models to calculate
own funds requirements for the three risk types. Impact on ING is through
more stringent regulation on the end-to-end process and governance
around internal models as well as an increase of risk weighted assets
(RWA).
In 2020, the last TRIM ECB inspection ended. Most of the remedial actions
triggered by the TRIM assessments resulted in the redevelopment of the
credit risk models and were addressed. Most remedial actions have been
implemented, with limited remaining.
CRR “quick fix” in response to the Covid‐19 pandemic
On 26 June 2020 Regulation (EU) 2020/873 of the European Parliament
and of the Council of 24 June 2020 amending Regulations CRR as regards
certain adjustments in response to the COVID-19 pandemic (commonly
referred to as CRR ”quick fix”) was published.
The CRR ‘quick fix’ introduced certain adjustments to the CRR, including
temporary measures and measures that early adopt changes in the
regulations that were intended to become effective at a future date. This
notably included reduced capital requirement for certain exposures to
small- and medium sized enterprises (SMEs), a more favourable prudential
treatment for certain software assets, one year delay in the application of
the leverage ratio buffer requirement of 50% of the G-SIB buffer (to 1
January 2023). Also, the ‘quick fix’ extended by 2 years transitional
arrangements for mitigating the impact on own funds of the introduction
of IFRS 9 (Article 473a (8) of CRR).
CRR III / CRD VI
On 27 October 2021, the European Commission published a legislative
proposal to review the EU’s CRD/CRR framework. The review consisted of
the following legislative elements: a proposal to amend CRD V ("CRD VI"), a
proposal to amend CRR II ("CRR III"), and a separate, targeted proposal to
amend CRR II in the area of resolution.
This proposed legislative review was to implement the final Basel III
framework – agreed at the end of 2017 - in the EU. The revisions mainly
related to the prudential standards for credit, market, operational and
credit valuation adjustment (CVA) risk as well as the introduction of an
output floor. Key changes comprise the reduced use of internal models
and more risk-sensitive and granular standardised approaches. It aimed to
increase consistency in risk-weighted asset calculations and improve
comparability of bank capital ratios. The Commission’s proposal remained
close to the 2017 Basel agreement, but in some areas included targeted
measures to account for specificities of the EU banking sector. These
measures mitigate until 2030-2032 the impact of the Output Floor for
lending to unrated corporates, low risk mortgages, and some other
categories.
While most CRR III amendments entered into force on 1 January 2025,
some provisions will be phased-in over subsequent year. Specifically, the
output floor will be generally phased in over 5 years with some of the
output floor and general phase-in provisions lasting until 2032. CRR III also
requires secondary legislation, much of which has yet to be finalized.
CRD VI requires EU Member States to transpose its provisions into national
law by 10 January 2026, with most measures applying from 11 January
2026. In the Netherlands, a draft legislation was published in April 2025,
followed by a revised version in October 2025. However, legislation has not
yet been finalised or enacted.
Capital requirements applicable to ING Group at a consolidated level
In accordance with the CRR the minimum Pillar 1 capital requirements
applicable to ING Group are:
§in terms of the Risk Weighted Assets (RWA): 4.5% of Common Equity
Tier 1 (CET1), 6% of Tier 1 and 8% of Total capital.
§in terms of the Leverage Exposure: 3% of Tier 1.
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For the Leverage Exposure, the overall Pillar I requirement is 3.5% of Tier 1
(including 0.50% G-SIII buffer).
In terms of the risk weighted capital requirements, ING Group is also
subject to the Combined Buffer Requirement that consists of the Capital
Conservation Buffer of 2.5%, the O-SII buffer (buffer for Other Systemically
Important Institutions) of 2.0%, the Countercyclical Buffer (CCyB) of 0.93%
and Systemic Risk Buffer (SyRB) of 0.16%. ING Group is subject to SyRB
because: 1) ING Group has exposures in Germany, Belgium and Norway
that are in scope of SyRB set in those countries, and 2) De Nederlandsche
Bank (DNB) recognised SyRB set in those countries (while initially the
recognition did not apply at the consolidated level, DNB adjusted it so that
it applies at consolidated level from December 2025).
These buffers rates may fluctuate. Specifically, the following authorities
adjusted the CCyB recently: De Nederlandsche Bank (DNB; for exposures in
the Netherlands), Narodowy Bank Polski (NBP; for exposures in Poland)
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin; for exposures in
Germany) and National Bank of Belgium (NBB; for exposures in Belgium).
DNB increased the CCyB to 2% from May 2024. NBP increased the CCyB to
1% from September 2025 (planned increase to 2% from September 2026).
DNB and NBP intend to apply a 2% CcyB in a standard risk environment.
BaFin decided to set the CCyB at 0.75% from February 2023. NBB increased
the CCyB to 1% from October 2024 (planned increase to 1.25% from July
2026). Other authorities announced increases too.
For more information reference is made to Note 46 ‘Capital management’
and ‘Capital management’ in Additional Information.
In accordance with the CRD IV, ING Group is also subject to Pillar 2 capital
requirements that supplement Pillar I capital requirements. Pillar 2
requirements are bank specific and for ING Group they are determined by
the ECB. As of 31 December 2025, Pillar II capital requirement for ING
Group are in terms of the Risk Weighted Assets (RWA) is 0.93% of Common
Equity Tier 1 (CET1), 1.24% of Tier 1, 1.65% of Total capital. As of 1 January
2026, these will increase to 0.96%, 1.28%, 1.70%, respectively.
Additionally, from 1 January 2026, ING group will be subject to Pillar II
requirement in terms of the Leverage Exposure of 0.1% of Tier 1. The ECB
reviews Pillar II requirements every year.
Bank recovery and resolution directive
The BRRD aims to safeguard financial stability and minimise the use of
public funds in case banks face financial distress or fail to comply with the
BRRD. Since 2014 banks across the EU need to have recovery plans in place
and need to cooperate with resolution authorities to determine, and make
feasible, the preferred resolution strategy. The banking reform which came
into force on 27 June 2019 includes changes to the minimum requirement
for own funds and eligible liabilities (MREL) to ensure an effective bail in
process. It also includes new competences for resolution authorities and
requires G-SIBs and other banks to build up loss-absorbing and
recapitalization capacity.
In April 2023 the European Commission published a legislative proposal to
review the EU’s existing bank crisis management and deposit insurance
(CMDI) framework, with a focus on medium-sized and smaller banks. Based
on the political agreement of co-legislators from June 2025: 1) DGS or
resolution funds could be used to finance the resolution as a last resort, 2)
criteria for assessment whether the resolution can be initiated would be
broadened, 3) assessment to determine whether a bank should be able to
use the resources of the DGS will be harmonised, 4) current preference of
DGS protected deposits is maintained with a second tier of deposits of
households and SME depositors not covered by the DGS. Based on the
initial draft proposal, majority of the changes would apply from 18 months
from the date of entry into force. Final legislation is yet to be published.
ING has had a recovery plan in place since 2012. The plan includes
information on crisis governance, recovery indicators, recovery options,
and operational stability and communication measures. The plan
enhances the bank’s readiness and decisiveness in case of a financial crisis.
The plan is updated annually to make sure it stays fit for purpose. The
completeness, quality and credibility of the updated plan is assessed each
year by ING’s regulators.
The Single Resolution Board (SRB) confirmed to ING in 2017 that a single-
point-of-entry (SPE) strategy is ING’s preferred resolution strategy, with
ING Groep N.V. as the resolution entity.
In July 2025, ING Group received an updated formal notification from De
Nederlandsche Bank (DNB) of its MREL requirements. The MREL
requirement has been established to ensure that banks in the European
Union have sufficient own funds and eligible liabilities to absorb losses and
to recapitalize bank in the case of a resolution. The MREL requirement is
set for ING Group at a consolidated level, as determined each year by the
Single Resolution Board (SRB). The following MREL requirements for ING
Group were applicable on 31 December 2025: 22.62% of RWA, and 7.24%
of LR exposure. MREL requirements are updated every year.
CRR II implements the Financial Stability Board’s total loss absorbing (TLAC)
requirement for Global Systemically Important Institutions (G-SII), which is
the EU equivalent of a G-SIB. The transitional requirement - the higher of
16% of the resolution group’s RWA or 6% of the leverage ratio exposure
measure - applied immediately. The higher requirement - 18% and 6.75%,
respectively - came into effect as of 1 January 2022. ING is required to
meet both the TLAC and requirement.
On top of MREL and TLAC RWA requirements, ING Group is required to
meet the Combined Buffer Requirement (CBR) of 5.60% of CET1 (as of 31
December 2025). Fully loaded CBR (that reflects measures already known
on 31 December 2025 but not yet applicable) would amount to 5.63%. ING
Group meets these requirements. If ING Group breaches the CBR on top of
MREL/TLAC (M-MDA), ING may face restrictions on dividend payments, AT1
instruments coupons and payment of variable remuneration.
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In addition to the requirements for the Group on a consolidated level,
internal MREL requirements are also set for individual ING subsidiaries in
the EU.
Regulatory liquidity ratios
In line with the CRR, ING Group is required to comply with:
§the Liquidity Coverage Requirement (LCR) that is designed to ensure
that banks hold enough liquidity assets to cover for net liquidity
outflows under stressed conditions over 30 days. The required LCR ratio
is 100%.
§The Net Stable Funding Requirement (NSFR) that is designed to ensure
that banks hold sufficient stable funding to meet their funding needs
over a one-year horizon under both normal and stressed conditions.
The required NSFR ratio is 100%.
For more information reference is made to "Funding and liquidity risk"
section in Additional Information.
Simplification of EU banking rules
In December 2025 the European Central Bank published recommendations
on how to simplify the EU banking rules: 1) to reduce the numbers of
elements in the framework, 2) to introduce a simpler regime for smaller
banks, 3) to introduce a new European governance with holistic view of the
capital requirements, and 4) to finalise the saving and investment union,
including completion of the banking union. These recommendations are
not binding, but might be considered by legislators. The European
Commission is expected to publish a Report on possible simplification
measures in 2026.
Stress testing
Stress testing is an important risk management tool that provides input for
strategic decisions and capital planning. The purpose of stress testing is to
assess the impact of plausible but severe stress scenarios on ING’s capital
and liquidity position. Stress tests provide complementary and forward-
looking insights into the vulnerabilities of certain portfolios, with regards to
adverse macroeconomic circumstances, stressed financial markets, and
changes in the (geo)political climate. In addition to assessing P&L, capital
and liquidity positions of ING for a range of different scenarios,
idiosyncratic risks are also included. The outcome of these stress tests help
management get insight into the potential impact and define actions to
mitigate this potential impact.
In addition to running internal stress test scenarios to reflect the outcomes
of the annual risk assessment, ING also participates in regulatory stress
test exercises. ING participated in the 2025 EU-wide stress test. The
exercise has been coordinated by the European Banking Authority (EBA)
and carried out in cooperation with the European Central Bank (ECB), the
European Systemic Risk Board (ESRB), the European Commission (EC) and
the Competent Authorities (CAs) from all relevant national jurisdictions.
The baseline macro-financial scenario is based on the projections from the
EU national central banks, IMF and OECD. The adverse stress test scenario
was developed by the ESRB. Both the scenario covers the three years from
2025 to 2027 in line with the EBA methodology.
The 2025 EU-wide stress test exercise was carried out applying a static
balance sheet assumption as of December 2024, and therefore does not
take into account current or future business strategies and mitigating
actions. The results of the EBA stress test shows that even under the
severe but hypothetical scenario ING’s is able to withstand these
circumstances even when no mitigating actions have been taken into
account. Under the hypothetical baseline scenario and EBA’s
methodological instructions, ING Group would have a transitional common
equity Tier 1 capital ratio (CET1) of 12.90% in 2027 and a fully loaded CET1
ratio of 11.85% in 2027. Under the hypothetical adverse scenario and
EBA’s methodological instructions, ING Group would have a transitional
CET1 ratio of 10.63% in 2027 and a fully loaded CET1 ratio of 10.41% in
2027. Our commitment to maintain a robust, fully loaded Group common
equity Tier 1 (CET1) ratio in excess of prevailing requirements remains. ING
Group published an actual CET1 ratio of 13.56% per 31 December 2024
(the reference date for the stress test), and 13.08% per 31 December 2025.
The next EBA EU-wide stress test will be held in 2027.
Deposit Schemes
In the Netherlands and other jurisdictions, deposit guarantee schemes and
similar funds (‘Compensation Schemes’) have been implemented to ensure
depositor pay-out to customers if a deposit taking institution is unable, or
unlikely to pay, claims against it. These Compensation Schemes are
funded, directly or indirectly, by financial services firms operating and/or
licensed in the relevant jurisdiction.
Dutch Deposit Guarantee Scheme (‘DGS’):, ING Bank participates in the
Dutch Deposit Guarantee Scheme (DGS) which guarantees an amount of
EUR 100,000 per person per bank, regardless of the number of accounts
held. Based on the EU Directive on deposit guarantee schemes, ING pays
quarterly risk-based contributions into a DGS-fund. The Dutch DGS fund
reached its target size of 0.8% of all deposits guaranteed under the DGS in
July 2024.
In the event of a Dutch bank's failure, depositor compensation is paid from
the DGS-fund. If the available financial means of the fund are insufficient,
Dutch banks, including ING, may be required to pay extraordinary ex-post
contributions not exceeding 0.5% of their covered deposits per calendar
year. In exceptional circumstances and with the consent of the competent
authority, higher contributions may be required. However, extraordinary
ex-post contributions may be temporarily deferred if they would
jeopardise the solvency or liquidity of a bank.
Since 2015, the EU has been discussing the introduction of a pan-European
Deposit Guarantee Scheme (EDIS), but no political agreement has been
reached on its creation.
Instant Payments and the Payment Services Regulation/PSD3
In January and October 2025, key provisions of the EU instant payments
regulation entered into force. The regulation aims to ensure that instant
payments in euro are affordable, secure and without hindrance across the
European Union. Instant Payments are to be credited to the account of the
beneficiary within 10 seconds after receipt of the payment order by the
payer’s payment service provider and shall be available 24 hours a day all
year round. The regulation has introduced a service to be provided by
payment service providers to payers to verify the match between the bank
account number and the name of the beneficiary provided by the payer to
prevent mistakes or fraud.
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In June 2023 the European Commission launched its proposal for the
Payment Services Regulation (PSR) and Payment Services Directive 3,
which together will succeed the current directive for payment services
(PSD2). The main proposed changes relate to fraud, further development
of open banking, the granting of access to payment systems by non-bank
payment service providers, and further improving consumer rights and
obligations.
The PSR is in the final stages of negotiation among the European
Parliament and EU member states. The combat of fraud stands out and
addresses new fraud types, such as impersonation fraud. To that end
priorities emerging from PSR negotiation include: an obligation for
electronic communications services providers to contribute to the
collective fight against fraud, the IBAN/name check, a legal basis for
payment service providers to share fraud related data, and intensified
transaction monitoring. Political consensus is emerging that all actors in
the ecosystem must contribute to the combat of fraud. PSR may grant
certain refund rights to consumers that suffered damages from the failure
of the IBAN/name verification or that are a victim of specific types of fraud.
Agreement on final texts has not yet been reached.
The single currency package: the digital euro and access to cash
In October 2025 the ECB’s governing council concluded its preparation
phase for the digital euro, and announced further preparations, in
anticipation of a political agreement on the digital euro. In June 2023 the
European Commission launched its legislative proposal establishing the
legal framework for such euro. It will ensure that people and business
when paying with central bank money also have the possibility to pay
digitally, online and/or offline, in addition to coins and banknotes. The
legislative proposal on the legal tender status of euro cash safeguards the
role of cash, it shall continue to be a means of payment and should
continue to be easily accessible. If enacted, the digital euro could have an
impact on ING’s deposit funding, as a portion of our clients may transfer
part of their deposits held at ING, to digital euros. In addition, depending
on the set-up of the digital euro, which is still being negotiated by
European co-legislators, it could have an impact on the competitive
landscape between banks and non-bank financial services providers, as
well as on private sector-provided payment solutions.
Benchmarks Regulation
The EU Benchmarks Regulation (BMR), adopted in 2016 and effective since
January 2018, was amended in May 2025, effective as per 01.01.2026, to
streamline its scope and strengthen governance. Under the revised
framework, only critical and significant benchmarks, EU Climate Transition
and Paris-Aligned benchmarks, and certain commodity benchmarks
remain subject to the regulation, while non-significant benchmarks have
largely been removed, reducing compliance complexity. The ESMA
Benchmarks Register will serve as the single authoritative source for
benchmark and administrator information.
Benchmarks based on contributor input must have a code of conduct in
place to safeguard data integrity, address key areas such as conflicts of
interest management, internal controls, and benchmark methodologies.
Financial contracts and instruments referencing benchmarks are required
to include clear fallback provisions to ensure continuity in case of
benchmark cessation.
ING has established a Global Benchmarks Transition Office to oversee
benchmark transitions with global impact (e.g. WIBOR), ensuring controlled
execution of all transition elements. For qualitative and quantitative
disclosures on IBOR transition refer to “Additional information – ING Group
Risk Management – Market Risk”.
KYC Requirements
Financial institutions continue to face new and increasingly complex
regulatory requirements, contributing to increasing costs of compliance, in
the context of heightened regulatory scrutiny. Generally, we expect the
scope and extent of regulations in the jurisdictions in which we operate to
continue to increase.
The evolving regulatory landscape drives the need for continuous change
in the various processes, procedures and systems of the bank. Where the
timeline for implementation of new or revised requirements is sometimes
quite short, this presents challenges to financial institutions in general. In
addition, in some instances, the complexity of the regulatory landscape
gives rise to potential tension between applicable laws and regulations at a
local and/or global level. For example, there is the potential tension
between data privacy (GDPR) and AML/CFT and anti-corruption laws and
regulations; including the requirement to share information relating to
financial crime concerns to manage risk exposure across the group, while
complying with the legislative requirements relating to data, which can
differ significantly depending on the jurisdiction. In contrast, the European
Union’s proposed Anti-Money Laundering Regulation (AMLR) seeks to
create a harmonized framework across EU member states, enhancing
consistency in anti-money laundering and counter-terrorist financing
efforts when it is implemented in 2027.
ING is focused on continuing to embed applicable requirements in our
processes and procedures, including in our IT systems and data sources, in
a robust and sustainable way; driving a business environment which is
compliant by desire and design. The bank also executes ongoing training
and awareness to develop its people to have the right knowledge and
skills.
In addition, ING aims to continuously monitor regulatory developments, as
well as considering emerging and evolving risks. This supports assessment
of the risks that ING may be exposed to and of the associated controls and
processes ING has in place, so we can appropriately manage these risks in
accordance with our risk appetite.
AML/CTF-related developments
The Authority for Anti-Money Laundering and Countering the Financing of
Terrorism (AMLA) is the newly established EU agency tasked with
transforming AML/CFT supervision across the European Union. Following its
formal adoption in mid-2024, AMLA officially commenced operations on 1
July 2025, headquartered in Frankfurt. Its mandate includes harmonising
enforcement, coordinating national authorities, and enhancing
collaboration among financial intelligence units (FIUs).
AMLA’s 2025 Work Programme outlines its phased operational rollout, with
full supervisory powers expected by 1 January 2028. The agency will
directly supervise up to 40 high-risk financial institutions operating across
multiple EU member states, with selection criteria to be finalised by the
end of 2025. ING continues to monitor developments closely, as its cross-
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border footprint and risk profile suggest a strong likelihood of being
designated for direct supervision.
Policy with respect to certain countries
As a result of frequent evaluation of all businesses from economic,
strategic and risk perspective ING continues to believe that for business
reasons doing business involving certain specified countries should be
discontinued. In that respect, ING has a policy not to enter into new
relationships with clients from these countries and processes remain in
place to discontinue existing relationships involving these countries. At
present these countries are Cuba, Iran, North Korea, Sudan and Syria, as
well as the Crimea region.
ING Group maintains a limited legacy portfolio of guarantees, accounts,
and loans that involve various entities with a connection to Iran. These
positions remain on the books but certain accounts related thereto are
‘frozen’ where prescribed by applicable laws and procedures and in all
cases subject to increased scrutiny within ING Group. ING Group may
receive loan repayments, duly authorised by the relevant competent
authorities where prescribed by applicable laws. For the calendar year
2025, ING Group had limited revenues and no net profit is made as there
were no repayments made in 2025.
Sanctions related developments
With respect to sanctions, as a result of Russia’s continued occupation of
parts of Ukraine and the associated conflict there has been a continued
focus of the EU, US, and other governments to impose additional sanctions
and combat the potential circumvention of sanctions against Russia. In
addition to several new sanctions packages there has been an increased
focus on the roles of third countries and companies in facilitating the
circumvention or undermining of such sanction’s measures.
Accordingly, as part of ING’s Know Your Customer and compliance risk
governance and procedures, ING is continuously monitoring the situation
to stay abreast on all relevant updates to implement effective and
appropriate additional control measures and to manage the increased risk
and financial impacts of these developments.
Operationally, the impact of these enhancements has resulted in the need
for additional staff members to review and apply greater scrutiny of
transactions alerted for heightened risk of non-compliance with applicable
sanctions.
For additional information regarding regulatory developments, see also
this Form 20-F 2025, under “Additional Information – ING Group Risk
Management- Compliance Risk”.
ESG Reporting Regulations
Environmental, Social and Governance (ESG) metrics and disclosures are
an increasing focus for businesses as they respond to a wave of scrutiny
from all manner of stakeholders, from investors and regulators to
employees and customers. There’s an expectation that ESG disclosures will
comply with mandatory and voluntary reporting requirements and be
reliable, verifiable and comparable to allow those stakeholders to make
decisions that matter to them.
There is currently a legislative initiative ongoing at the European
Commission level (i.e the EU Omnibus Regulation) which aims to
streamline and simplify certain sustainability regulations, such as the
CSDDD, CSRD and EU Taxonomy. The outcome of this initiative may impact
the interpretation and implementation of these regulations in the future.
Non-Financial Reporting Directive (NFRD)
Since 2018, companies like ING within the scope of the NFRD (Directive
2014/95/EU) have been required to disclose information on non-financial
matters (environmental, social and employee matters, human rights,
bribery and corruption). The objective of the NFRD is to improve the quality
and quantity of corporate non-financial information reporting.
Under the NFRD, large, listed companies, banks and insurance companies
('public interest entities') with more than 500 employees are required to
publish reports on the policies they implement in relation to social
responsibility and treatment of employees; respect for human rights; anti-
corruption and bribery; and diversity on company boards (in terms of age,
gender, educational and professional background). In particular, the NFRD
requires companies to disclose information about their business models,
policies (including implemented due diligence processes), outcomes, risks
and risk management, and Key Performance Indicators relevant to the
business.
Corporate Sustainability Reporting Directive (CSRD)
The CSRD (directive (EU) 2022/2464) was published in December 2022 in
the Official Journal of the European Union and should have been
transposed into national law by 6 July 2024. Currently several European
Union Member States, including the Netherlands, have not yet notified the
European Commission on the full transposition of the CSRD into national
law and missed the deadline of July 6, 2024. This situation creates an
ambiguity in terms of legal enforcement of the CSRD in local context(s). On
26 September, 2024, the European Commission has opened infringement
procedures for those countries by sending a letter of formal notice due to
the absence of measures taken to transpose EU directives into national
law. Legislative initiatives are currently underway in the Netherlands, as
well as in other jurisdictions that have yet to adopt the regulation;
however, the implementation timelines remain uncertain at this stage.
CSRD profoundly revises the ESG reporting requirements, and it is designed
to bring sustainability reporting on par with financial reporting over time
and monitor the progress of companies’ activities in relation to
sustainability matters. With the CSRD, the existing sustainability matters of
ESG reporting will be expanded and standardized. Its aims are to:
§harmonize and improve the quality of information published by
undertakings, particularly information on ESG (sustainability-related
information);
§provide financial undertakings, investors, relevant stakeholders and the
general public with relevant, comparable and reliable sustainability
information;
§encourage investment that supports the transition to a sustainable
economy in line with the European Green Deal.
Undertakings falling within its scope are required to report detailed
disclosure requirements that are specified under the European
Sustainability Reporting Standards (ESRS).
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CSRD introduced a phased-in approach for the application, where
undertakings that are subject to the NFRD were required to provide
sustainability related information for financial years beginning on or after
1 January 2024. These companies would be later joined by large non-listed
companies (2025), listed SMEs (2026) and certain European subsidiaries of
non-EU groups. ING Group, as well as some of its subsidiaries in scope,
have disclosed their sustainability related information in their 2024
Management Board report for the first time in 2025.
Subsequently, the European Commission introduced an Omnibus
Simplification Package which includes simplification measures on the
CSRD. The first component, known as the Stop-the-Clock Directive
(Directive (EU) 2025/794), published in the Official Journal on 16 April 2025,
postpones CSRD reporting by two years for companies scheduled to start
in 2026 and 2027. This measure prevents reporting obligations from taking
effect while simplification efforts are ongoing. The second component
introduces major amendments to CSRD which includes amongst other
narrowing the scope of undertakings required to report (incl. removing in
scope subsidiaries from reporting obligations), removing sector-specific
standards and removing the future move to reasonable assurance from
limited assurance. On 9 December 2025, a political agreement was
reached between the European Parliament and Council on the legislative
package introducing these amendments, which is currently awaiting its
publication in the Official Journal of the EU. Besides these, the Commission
has also adopted a quick-fix regulation (Delegated Regulation (EU)
2025/1416) to extend transitional provisions of specific disclosures
requirements to avoid additional burden during regulatory change. ING is
closely monitoring regulatory developments.
European Sustainability Reporting Standards (ESRS)
In July 2023, the European Commission has adopted the final delegated
act of the European Sustainability Reporting Standards (ESRS). Companies
subject to the CSRD shall report according to the ESRS, starting from 2025,
over financial year 2024, based on a phased-in approach.
The ESRS specify the sector-agnostic sustainability reporting requirements
based on the CSRD, covering the full range of sustainability matters
(Environment, Social and Governance). The overall architecture of the ESRS
is designed to ensure that sustainability information is reported in the
companies’ management report based on a double materiality
assessment (i.e. impact and financial materiality) and is based on the
following reporting structure:
1.Governance: the governance processes, controls and procedures used
to monitor and manage impacts, risks and opportunities
2.Strategy: how the undertaking’s strategy and business model(s)
interact with its material impacts, risks and opportunities, including the
strategy for addressing them
3.Impact, risk and opportunity management: the process(es) by which
impacts, risks and opportunities are identified, assessed and managed
through policies and actions
4.Metrics and targets: how the undertaking measures its performance,
including progress toward the targets it has set.
The cross-cutting standards consist of:
§ESRS 1 which prescribes the mandatory concepts and principles to be
applied when preparing sustainability statements under the CSRD.
§ESRS 2 is on general, strategy, governance, and materiality assessment
disclosure requirements.
The topical standards consist of:
§Environment topical standards (ESRS E1–E5) outline disclosure
requirements for companies to report on matters related to climate
change, pollution, water and marine resources, biodiversity and
ecosystems, and resource use and circular economy.
§Social topical standards (ESRS S1–S4) provide a framework for entities
to report on topics related to their own workforce, the workers in their
value chains, the communities impacted by their operations and the
consumers and end-users of their products or services.
§Governance topical standards (ESRS G1) set out disclosure
requirements that seek to enhance users’ understanding of a
company’s governance structure, its internal control and risk
management system, the company’s strategy and approach, and the
processes, procedures and performance in relation to their business
conduct.
As part of the Omnibus initiative, the European Commission aims to revise
the ESRS to reduce the reporting burden while maintaining consistency
with the EU sustainability objectives and ensuring interoperability with
global frameworks. The European Commission has mandated the EFRAG to
provide a technical advice on this initiative. EFRAG has consulted the public
and submitted its work to the Commission by the end of November 2025.
The key changes include the reduction of mandatory data points, removal
of majority of voluntary data points, simplification of the double
materiality assessment and enhanced alignment with the ISSB. Adoption
of the revised ESRS by the Commission is expected by the of the first half
of 2026 with mandatory application for the reporting year 2027.
EU Taxonomy
The EU Taxonomy Regulation (EU Taxonomy), published in the Official
Journal of the EU in 2020, is a classification system, establishing a list of
‘environmentally sustainable’ economic activities and introducing
reporting requirements. The EU Taxonomy provides companies, investors
and policymakers with appropriate definitions for which economic
activities can be considered ‘environmentally sustainable’ and can be
reported accordingly. In this way, it creates security for investors and
protects private investors from greenwashing. For economic activities to be
recognized as ‘environmentally sustainable”, they should meet the
following criteria:
§Substantially contributing to one of the six EU environmental
objectives:
–Climate change mitigation
–Climate change adaptation
–Sustainable use and protection of water and marine resources
–Transition to a circular economy
–Pollution prevention and control
–Protection and restoration of biodiversity and ecosystems
§Do not significantly harm to any of the other 5 objectives
§Meeting minimum safeguards, including OECD Guidelines for
Multinational Enterprises and the UN Guiding Principles on Business, ILO
standards and Human Rights.
For disclosure requirements under the EU Taxonomy, a delegated act
supplementing Article 8 of the Taxonomy is applicable since January 2022.
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Article 8 of the EU Taxonomy aims to increase transparency in the market
and help prevent greenwashing by providing information to investors
about the environmental performance of assets and economic activities of
financial and non-financial undertakings in scope. This delegated act
specifies the content, methodology and presentation of information to be
disclosed concerning the proportion of environmentally sustainable
economic activities in their businesses, depending on the type of the
company (i.e. non-financial/financial). Within the scope of Article 8
delegated act, in-scope credit institutions are required disclose the Green
Asset Ratio (GAR) which measures the share of a credit institution's
taxonomy-aligned exposure against total covered assets, amongst other
detailed disclosures.
As part of the Omnibus Simplification Package, the European Commission
has adopted a delegated act introducing amendments to improve the
effectiveness of EU Taxonomy disclosures by reducing complexity and
burden. The amendment introduces key changes such as recalibrating the
GAR to ensure symmetry within the numerator and denominator,
introducing materiality thresholds and removing or simplifying certain
templates to ease administrative burden. Revised rules have entered into
force and can already be applied from 1 January 2026 per the delegated
act.
Pillar 3 ESG Disclosures
Article 449a of Regulation (EU) No 575/2013 (CRR) requires institutions to
disclose prudential information on environmental, social and governance
risks, including physical risks and transition risks, as defined in Article 4 of
the same regulation. Under CRR III, the scope of application has been
extended beyond large and listed institutions to cover all institutions,
including large subsidiaries of parent institutions. Article 434a CRR
mandates the EBA to develop draft implementing technical standards (ITS)
specifying uniform formats and associated instructions for these
disclosures.
The current ITS on Pillar III disclosures on Environmental, Social and
Governance (ESG) risks, which is applicable to large and listed institutions,
was adopted by the European Commission in November 2022, published in
the Official Journal of the EU in December 2022 with a first reporting date
in 2023 (reference date: 31 December 2022). The ESG Pillar 3 requires
credit institutions such as ING to disclose the following information:
§Climate risks: how climate change may exacerbate other risks within
banks' balance sheets.
§Mitigating actions: what mitigating actions banks have in place to
address those risks, including financing activities that reduce carbon
emissions.
§Green Asset ratio and Banking Book Taxonomy Alignment ratio: to
understand how banks are financing activities that will meet the
publicly agreed Paris agreement objectives of climate change
mitigation and adaptation based on the EU taxonomy of green
activities.
The EBA ESG Pillar 3 requirements features (i) a set of 10 quantitative
templates that request banks to disclose climate-related risks and actions
to mitigate them, together with exposure to assets that support the
climate change mitigation and adaptation and (ii) qualitative information
on their ESG strategies, governance and risk management arrangements
with regard to ESG risk.
As the CRR III extends the scope of application to all institutions, including
large subsidiaries on an individual, or where applicable on a sub-
consolidated basis, the EBA launched a consultation on 22 May 2025
proposing amendments to the current ITS as mandated by the CRR III in
order to lay down proportionate requirements for new in-scope entities, as
well as modifying certain requirements for already in-scope entities.
Proposed amendments include, amongst others, reduced templates and
frequency for newly in-scope entities, certain modifications and
simplifications on current templates, allowing annual reporting for certain
templates subject to materiality assessment and the full alignment with
the EU Taxonomy Regulation. In addition, amendments include
transitional provisions that suspend disclosures of certain templates until
31 December 2026 and defer disclosures by newly in-scope entities to the
same date. EBA has published a no-action letter advising supervisors not
to enforce these suspended requirements to provide regulatory certainty
during the transition.
Sustainable Finance Disclosure Regulation
The Sustainable Finance Disclosure Regulation (SFDR) is a European
regulation intended to improve financial sector transparency for certain
sustainable investment products, via website and pre-contractual
disclosures. It also aims to prevent greenwashing and to increase
transparency around sustainability claims made by financial sector
participants. The SFDR imposes sustainability disclosure requirements on
certain financial actors who are offering certain type of financial products
or investment advice in the EU covering a broad range of environmental,
social and governance (ESG) metrics at both entity- and product-level.
Subsidiaries of ING Groep N.V. in the European Union are, or may be,
subject to the SFDR through certain products or services they provide. The
SFDR came into effect on 10 March 2021, with certain disclosure
requirements being in effect at a later stage.
In 2025, the European Commission launched a review of the SFDR aimed at
simplifying the framework and improving legal clarity. The initiative seeks
to reduce complexity, address overlaps with other EU sustainable finance
regulations, and introduce clearer product categories to enhance
comparability and mitigate greenwashing risks. A legislative proposal for
these revisions is published in November 2025, which will be followed by
the standard EU legislative process.
California Climate Disclosure Bills
California has enacted climate disclosure laws (SB 253 & SB 261) which
require companies that has business activities in California and meet
certain revenue thresholds to provide; (1) annual greenhouse gas (GHG)
emissions reporting in accordance with the GHG Protocol in 2026 for fiscal
year 2025; and (2) biennial climate-related financial risk reporting in line
with the recommendations of the Task Force on Climate-Related
Disclosures (TCFD) or with another framework that is consistent with the
recommendations by the beginning of 2026. There are phased in
requirements in relation to GHG emissions reporting where scope 3
emissions are only to be disclosed in 2027. In addition, scope 1 and scope
2 emissions are subject to limited assurance in 2026 and to reasonable
assurance in 2030; whereas scope 3 emissions are subject to limited
assurance only in 2030. Authorities issued further guidance in relation to
implementation of disclosure laws during the second half of 2025.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 57 |
Subsequently, on 18 November 2025, the U.S. Court of Appeals for the
Ninth Circuit temporarily suspended enforcement of SB 261 pending
appeal, while SB 253 remains in effect for the time being. This suspension
introduces a degree of regulatory uncertainty and ING will continue to
monitor legal developments closely.
Additional information regarding regulatory developments
For additional information regarding regulatory developments, see also
this Form 20-F 2025, under “Additional Information – ING Group Risk
Management - Environmental, social and governance Risk”.
For a description of our segments including a breakdown of total revenues
by category for the last three financial years, refer to "Item 5. Operating
and financial review and prospects - Segment reporting”.
C. Organisational structure
ING Groep N.V., a publicly listed company, is the parent of one main legal
entity: ING Bank N.V. (ING Bank). ING Bank is the parent company of
various Dutch and foreign banking and other subsidiaries.
Reference is made to Exhibit 8 “List of subsidiaries of ING Groep N.V.” for a
list of principal subsidiaries of ING Groep. N.V. For the majority of ING’s
principal subsidiaries, ING Groep N.V. has control because it either directly
or indirectly owns more than half of the voting power. For subsidiaries in
which the interest held is below 50%, control exists based on the
combination of ING’s financial interest and its rights from other contractual
arrangements which result in control over the operating and financial
policies of the entity.
D.Property, plants and equipment
ING predominantly leases the land and buildings used in the normal
course of its business. In addition, ING has invested in land and buildings.
Management believes that ING’s facilities are adequate for its present
needs in all material respects.
For information on property, plants and equipment, reference is made to
Note 9 'Property and equipment', for information on lease liabilities
reference is made to Note 16 'Other liabilities' and for information on
investment properties reference is made to Note 11 'Other assets' in the
consolidated financial statements.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 58 |
Item 4A. Unresolved Staff comments
Not applicable.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 59 |
Item 5. Operating and Financial Review and Prospects
The following operating and financial review and
prospects should be read in conjunction with the
consolidated financial statements and the related
Notes thereto included elsewhere herein. The
consolidated financial statements have been
prepared in accordance with IFRS-IASB. Unless
otherwise indicated, financial information for ING
Group included herein is presented on a
consolidated basis under IFRS-IASB.
A.Operating results
In a fast-changing world, it is essential for our business to adapt, evolve
and remain resilient. We need to stay ahead of changing consumer
preferences, technological advances, shifts in the banking sector, evolving
views on sustainability, talent shortages, and economic and geopolitical
uncertainty. Change is constant, so we stay agile and ready for what’s
next.
As a global bank, we constantly anticipate and adapt to change so we can
continue to grow our scale, impact and relevance across the markets and
segments we serve. By responding proactively to shifts around us, we not
only manage risks more effectively but also turn challenges into
opportunities, with the aim of delivering superior value for our customers.
Technological change reshapes consumer experience
In recent years, rapid advances in generative AI have transformed how
people use technology in their daily lives – from searching for information
to receiving personalised products, services, and experiences in real time.
The impact on banking is profound, as AI and scalable technology
platforms redefine consumer expectations for speed, personalisation, and
reliability.
Among other applications, AI tools enable faster customer support,
improve customer protection and compliance, and help assess and
process mortgage applications. Our digital-first approach positions us
strongly to adapt to this landscape. We continue to invest in AI and digital
infrastructure to ensure we can scale our technology to reach the market
faster, enhance productivity, and keep our customers safe. As AI moves
from the pilot stage to large-scale deployment, its dependability and
reliability faces real-world testing. Only AI tools that solve specific business
challenges and clear consumer needs will prove their value at scale.
Banking landscape is fragmenting, competition intensifying
The banking world is changing fast. Traditional banks are no longer the
sole providers of financial services. Digital innovation and AI-driven low-
cost models are driving competition from fintechs, non-bank lenders, and
technology companies. Digital banks are competing for retail customers
with user-friendly platforms and low fees, while private lenders – including
big tech companies – are taking a growing share of business lending. At
the same time, innovations such as digital tokens and stablecoins are
reshaping payment systems, moving them beyond traditional banking
channels. In this transformed competitive environment, we strive to make
banking easier and seamless. Continuous innovation and adaptation help
us broaden our services, increase our relevance, and deepen our customer
relationships.
Keeping course in a shifting sustainability landscape
We see shifts in the global sustainability agenda, with economic pressure,
geopolitical uncertainty and energy security concerns changing some
areas of sustainability regulation. National policies and attitudes to
sustainability priorities are increasingly dispersed. We continue to monitor
these developments as part of our strategic and risk management
processes.
Complex and changing regulatory environment
The regulatory landscape we operate in is becoming increasingly complex,
driven by inconsistent rules, rapid technological change, and rising
expectations in data privacy, cybersecurity and ESG. In particular, the
banking and financial landscape in Europe is marked by a fragmented
regulatory landscape. Diverging global and European standards require
stronger controls, clearer disclosures, and significant investment in
compliance. Fintech innovation and geopolitical volatility further
accelerate regulatory shifts, while the complexity of navigating both EU-
level and individual country requirements places additional demands on
governance and risk management. To stay resilient, we adapt quickly to
evolving requirements, strengthening our governance and risk
management capabilities to remain competitive and compliant.
Battle for talent in specialist roles
International companies face an intensifying global battle for talent,
particularly in technology and AI. To attract, develop and retain the talent
we need, we invest in skills development, flexible work models, and
continuous learning.
Dynamic geopolitical environment
In 2025 the international business climate was marked by rising
geopolitical tensions and economic uncertainty. Political changes,
unpredictable policy shifts, tariffs, trade disputes, changing international
alliances and supply-chain restrictions all combined disrupt global business
and trade. This heightened uncertainty contributed to increased volatility
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 60 |
in the financial markets. Global conflicts continue to shape the geopolitical
landscape, with the war in Ukraine ongoing, persistent tensions in the
Middle East, and new areas of instability emerging in other regions. These
developments contribute to an environment of heightened uncertainty
and potential risk for international businesses.
For further information on other factors that can impact ING Group’s
results of operations, reference is made to “Item 3. Key information - Risk
Factors”.
For further information on regulatory changes reference is made to “Item
4. Information on the Company – Regulation and Supervision”.
Fluctuations in markets
Fluctuations in equity markets
Our banking operations are exposed to fluctuations in equity markets. ING
maintains an internationally diversified and mainly client-related trading
portfolio. Accordingly, market downturns are likely to lead to declines in
securities trading and brokerage activities which we execute for customers
and therefore to a decline in related commissions and trading results. In
addition to this, ING also maintains equity investments in its own non-
trading books. Fluctuations in equity markets may affect the value of
these investments.
Fluctuations in interest rates
Our banking operations are exposed to fluctuations in interest rates.
Mismatches in the interest re-pricing and maturity profile of assets and
liabilities in our balance sheet can affect the future interest earnings and
economic value of the bank's underlying banking operations. In addition,
changing interest rates may impact the (assumed) behavior of our
customers, impacting the interest rate exposure, interest hedge positions
and future interest earnings, solvency and economic value of the bank’s
underlying banking operations. The stability of future interest earnings and
margin also depends on the ability to actively manage pricing of customer
assets and liabilities. Especially, the pricing of customer savings portfolios
in relation to re-pricing customer assets and other investments in our
balance sheet is a key factor in the management of the bank’s interest
earnings.
Fluctuations in exchange rates
ING Group is exposed to fluctuations in exchange rates. Our management
of exchange rate sensitivity affects the results of our operations through
the trading activities (which includes local country versus international
transactions) and because we prepare and publish our consolidated
financial statements in Euros. Because a substantial portion of our income,
expenses and foreign investments is denominated in currencies other than
Euros, fluctuations in the exchange rates can impact our reported results
of operations, cash flows and reserves from year to year. Fluctuations in
exchange rates will also impact the value (denominated in Euro) of our
investments in our non-Euro reporting subsidiaries. The impact of these
fluctuations in exchange rates is mitigated to some extent by the fact that
income and related expenses, as well as assets and liabilities, of each of
our non-Euro reporting subsidiaries are generally denominated in the
same currencies. FX translation risk is managed by taking into account the
effect of translation results on the Common Equity Tier 1 ratio (CET1).
Consolidated result of operations
ING Group monitors and evaluates the performance of ING Group at a
consolidated level and by segment using results based on figures
according to IFRS as adopted by the European Union (IFRS-EU). The
Executive Board and the Management Board Banking consider this
measure to be relevant to an understanding of the Group’s financial
performance, because it allows investors to understand the primary
method used by management to evaluate the Group’s operating
performance and make decisions about allocating resources. In addition,
ING Group believes that the presentation of results in accordance with
IFRS-EU helps investors compare its segment performance on a
meaningful basis by highlighting result before tax attributable to ongoing
operations and the profitability of the segment businesses. IFRS-EU result
is derived by including the impact of the IFRS-EU ‘IAS 39 carve out’
adjustment compared to IFRS-IASB.
The IFRS-EU ‘IAS 39 carve-out’ adjustment relates to fair value portfolio
hedge accounting strategies for the mortgage and savings portfolios in the
Benelux, Germany and Other Challengers that are not eligible under IFRS-
IASB. As no hedge accounting is applied to these mortgage and savings
portfolios under IFRS-IASB, the fair value changes of the derivatives are not
offset by fair value changes of the hedge items (mortgages and savings).
For a reconciliation to IFRS-IASB of non-GAAP measures 'Net core lending
growth', 'Net core deposits growth' and 'Commercial net interest income',
please refer to Alternative performance measures at the end of this
section.
Our financial performance
The published 2025 financial statements of ING Group includes financial
information in accordance with International Financial Reporting
Standards as adopted by the European Union (IFRS-EU). The segment
reporting in the annual report on Form 20-F has been reconciled with
International Financial Reporting Standards as issued by the International
Accounting Standards Board (IFRS-IASB) for consistency with the other
financial information contained in this report. The difference between the
accounting standards is reflected in the Wholesale Banking segment, and
in the geographical split of the segments in the Netherlands, Belgium,
Germany, Other Challengers, Growth Markets and Wholesale Banking Rest
of World. Reference is made to Note 1 ‘Basis of preparation and material
accounting policy information’ for a reconciliation between IFRS-EU and
IFRS-IASB.
For further information on the segments by line of business and the main
sources of income of each of the segments, reference is made to Note 30
‘Segments’.
Total Operations
The following table sets forth the contribution of ING’s business lines and
the corporate line to the net result for each of the years 2025, 2024 and
2023.
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Total operations | |||||||
1 January to 31 December 2025 in EUR million | Retail Banking Netherlands | Retail Banking Belgium | Retail Banking Germany | Retail Other | Wholesale Banking | Corporate Line | Total |
Income: | |||||||
Net interest income | 3,115 | 1,786 | 2,457 | 3,892 | 2,997 | 434 | 14,681 |
Net fee and commission income | 1,128 | 692 | 632 | 717 | 1,433 | 1 | 4,602 |
Total investment and other income | 726 | 197 | -98 | 299 | 2,579 | 49 | 3,752 |
Total income | 4,968 | 2,674 | 2,991 | 4,908 | 7,009 | 484 | 23,035 |
Expenditure: | |||||||
Operating expenses | 2,089 | 1,878 | 1,362 | 2,905 | 3,837 | 512 | 12,583 |
Additions to loan loss provision | 107 | 153 | 171 | 323 | 549 | 1 | 1,304 |
Total expenditure | 2,196 | 2,031 | 1,533 | 3,228 | 4,386 | 513 | 13,887 |
Result before taxation | 2,773 | 644 | 1,457 | 1,680 | 2,624 | -30 | 9,148 |
Taxation | 733 | 178 | 472 | 398 | 673 | 92 | 2,545 |
Non-controlling interests | 2 | 225 | 48 | 275 | |||
Net result IFRS-EU | 2,040 | 466 | 983 | 1,058 | 1,902 | -121 | 6,327 |
Adjustment of the EU 'IAS 39 carve- out' | 1,996 | 1,996 | |||||
Net result IFRS-IASB | 2,040 | 466 | 983 | 1,058 | 3,899 | -121 | 8,324 |
Total operations | |||||||
1 January to 31 December 2024 in EUR million | Retail Banking Netherlands | Retail Banking Belgium | Retail Banking Germany | Retail Other | Wholesale Banking | Corporate Line | Total |
Income: | |||||||
Net interest income | 3,027 | 1,959 | 2,647 | 3,817 | 3,259 | 315 | 15,023 |
Net fee and commission income | 1,049 | 603 | 433 | 609 | 1,317 | -3 | 4,008 |
Total investment and other income | 835 | 189 | -173 | 263 | 2,405 | 66 | 3,584 |
Total income | 4,910 | 2,751 | 2,906 | 4,688 | 6,981 | 378 | 22,615 |
Expenditure: | |||||||
Operating expenses | 2,124 | 1,811 | 1,303 | 2,792 | 3,558 | 533 | 12,121 |
Additions to loan loss provision | -8 | 134 | 149 | 291 | 627 | 1 | 1,194 |
Total expenditure | 2,117 | 1,944 | 1,452 | 3,083 | 4,185 | 534 | 13,315 |
Result before taxation | 2,793 | 807 | 1,455 | 1,605 | 2,796 | -156 | 9,300 |
Taxation | 723 | 210 | 505 | 381 | 693 | 138 | 2,650 |
Non-controlling interests | 1 | 221 | 35 | 258 | |||
Net result IFRS-EU | 2,070 | 597 | 949 | 1,002 | 2,068 | -294 | 6,392 |
Adjustment of the EU 'IAS 39 carve- out' | -1,058 | -1,058 | |||||
Net result IFRS-IASB | 2,070 | 597 | 949 | 1,002 | 1,010 | -294 | 5,334 |
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 62 |
Total operations | |||||||
1 January to 31 December 2023 in EUR million | Retail Banking Netherlands | Retail Banking Belgium | Retail Banking Germany | Retail Other | Wholesale Banking | Corporate Line | Total |
Income: | |||||||
Net interest income | 3,096 | 2,063 | 2,862 | 3,437 | 4,028 | 489 | 15,976 |
Net fee and commission income | 959 | 502 | 357 | 519 | 1,259 | -1 | 3,595 |
Total investment and other income | 945 | 117 | -67 | 277 | 1,771 | -38 | 3,005 |
Total income | 5,001 | 2,683 | 3,152 | 4,233 | 7,057 | 450 | 22,575 |
Expenditure: | |||||||
Operating expenses | 2,135 | 1,852 | 1,243 | 2,479 | 3,313 | 542 | 11,564 |
Additions to loan loss provision | 5 | 169 | 119 | 313 | -92 | 5 | 520 |
Total expenditure | 2,140 | 2,022 | 1,362 | 2,792 | 3,222 | 547 | 12,084 |
Result before taxation | 2,861 | 661 | 1,790 | 1,441 | 3,836 | -97 | 10,492 |
Taxation | 740 | 182 | 631 | 359 | 900 | 158 | 2,970 |
Non-controlling interests | 174 | 61 | 235 | ||||
Net result IFRS-EU | 2,121 | 479 | 1,159 | 908 | 2,875 | -255 | 7,287 |
Adjustment of the EU 'IAS 39 carve- out' | -3,147 | -3,147 | |||||
Net result IFRS-IASB | 2,121 | 479 | 1,159 | 908 | -272 | -255 | 4,140 |
Year ended 31 December 2025 compared to year ended 31 December
2024
Without application of the EU ‘IAS 39 carve-out’, ING’s net result rose by
EUR 2,990 million, or 56%, to EUR 8,324 million compared with EUR 5,334
million in 2024. The net result was affected by a EUR 1,996 million positive
contribution of fair value changes on derivatives related to asset-liability-
management activities for the mortgage and savings portfolios in the
Benelux, Germany, France, Spain, Italy and Romania, versus a EUR 1,058
million negative contribution in 2024. These fair value changes were
mainly caused by changes in market interest rates. No hedge accounting
is applied to these derivatives under IFRS-IASB.
ING’s IFRS-EU net result (when applying the EU ‘IAS 39 carve-out’) declined
to EUR 6,327 million from EUR 6,392 million in 2024.
In 2025, we again achieved higher revenues. Total income rose 1.9% to
EUR 23,035 million, supported by growth in our customer base and a 15%
increase in fee income. Customer lending increased by EUR 41.5 billion.
Adjusted for currency impacts and excluding Treasury and run-off
portfolios, the net core lending growth was EUR 56.9 billion (more than
double the amount recorded in the previous year).
Total net interest income decreased 2.3% to EUR 14,681 million.
Commercial net interest income remained resilient at EUR 15,316 million.
Net interest income from lending rose by €134 million, as volume growth
more than offset a reduction in the average lending margin. This margin
decline was partly attributable to the ongoing expansion of our residential
mortgage portfolio, which delivers higher returns on equity but carries
lower average margins than other lending products. Liability net interest
income decreased by €277 million, as strong deposit growth could not
fully offset the impact of lower average margins on retail deposits and for
Payments & Cash Management in Wholesale Banking. Other net interest
income primarily comprises interest income from Financial Markets and
Treasury.
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Net fee and commission income totalled EUR 4,602 million, an increase of
15%, in line with our ambition to further diversify our income mix. In Retail
Banking, fee income from investment products rose significantly, driven by
growth in the number of investment accounts and higher customer
trading activity. Daily banking fees also increased, supported by strong
growth in primary customers and updated pricing for payment packages,
while Retail Banking also achieved solid growth in lending-related and
insurance fees. Fee income in Wholesale Banking rose 8.8%, primarily
reflecting higher deal flow in its Lending business and an increase in daily
banking fees.
Total investment and other income rose 4.7% to EUR 3,752 million. The
majority of this amount relates to Financial Markets and Treasury. The
2025 figure included a positive revaluation of the derivative for a the
forward purchase of a stake in Van Lanschot Kempen, a EUR 44 million
gain from the sale of an associate in Belgium, and higher income from
Corporate Investments. The previous year had included EUR 77 million as
our share in the one-off profit of an associate in Belgium and a EUR 53
million receivable related to the prior insolvency of a financial institution in
the Netherlands.
Operating expenses increased 3.8% to EUR 12,583 million, including EUR
866 million in regulatory costs — a slight decrease compared with the
previous year. Expenses in 2025 also included EUR 297 million of incidental
items, primarily related to restructuring, versus EUR 178 million of
incidental items in 2024.
Expenses excluding regulatory costs and incidental items rose 3.2%,
reflecting inflationary pressure on salaries and other costs, as well as
continued investments to support business growth. These impacts were
partially mitigated by further increasing scalability and efficiency in our
operations, including enhanced client interactions in our contact centres,
and ongoing optimisation of our footprint across several retail countries.
Net additions to loan loss provisions amounted to EUR 1,304 million
compared with EUR 1,194 million in 2024. Risk costs for 2025 were
equivalent to 19 basis points of average customer lending, remaining
below our through-the-cycle average of 20 basis points.
Net additions to Stage 3 provisions declined sharply to EUR 1,186 million,
down from EUR 1,583 million in 2024. This reflects a limited inflow of new
Stage 3 files, as well as several repayments and recoveries on existing files
during 2025.
Total Stage 1 and 2 risk costs were EUR 118 million (including EUR 8 million
of modification losses). In 2024, these had amounted to EUR -389 million,
primarily due to a partial release of management overlays.
The net result (attributable to shareholders of the parent) for 2025
amounted to EUR 6,327 million, slightly below the net profit of EUR 6,392
million achieved in 2024. The effective tax rate for 2025 was 27.8%
compared with 28.5% in the previous year.
Year ended 31 December 2024 compared to year ended 31 December
2023
Without application of the EU ‘IAS 39 carve-out’, ING’s net result rose by
EUR 1,195 million, or 29%, to EUR 5,334 million compared with EUR 4,140
million in 2023. The net result was affected by a EUR 1,058 million negative
contribution of fair value changes on derivatives related to asset-liability-
management activities for the mortgage and savings portfolios in the
Benelux, Germany, France, Spain, and Italy, versus a EUR 3,147 million
negative contribution in 2023. These fair value changes were mainly
caused by changes in market interest rates. No hedge accounting is
applied to these derivatives under IFRS-IASB.
ING’s IFRS-EU net result (when applying the EU ‘IAS 39 carve-out’) declined
to EUR 6,392 million from EUR 7,287 million in 2023. The total income in
2024 was supported by double-digit growth in fee income and strongly
increased customer lending and customer deposit volumes. Higher
expenses show the continued investments in the growth of our business,
as well as inflationary effects on staff expenses. Risk costs remained below
our through-the-cycle average.
Total income rose to EUR 22,615 million. This was supported by continued
growth of our customer base, double-digit growth in fee income and
sharply increased lending and deposit volumes.
We recorded outstanding commercial growth in 2024. Customer lending
rose by EUR 38.0 billion. The net core lending growth - which is the
increase in customer lending adjusted for currency impacts and excluding
Treasury and the run-off portfolios - was EUR 27.7 billion. We were
particularly successful in increasing our residential mortgages portfolio, by
EUR 18.9 billion, spread across all our retail countries. In addition, we also
grew our consumer lending and business lending books (by EUR 6.9 billion
in total). And we recorded a net growth in Wholesale Banking of EUR 1.8
billion, while we continued to optimise our capital usage.
Customer deposits increased by EUR 41.4 billion in 2024. Net core deposits
growth (which excludes FX impacts and movements in Treasury deposits)
was EUR 47.4 billion in 2024, with strong contributions from both Retail
Banking and Wholesale Banking. At the end of 2024, 68% of our balance
sheet was funded by customer deposits.
Net interest income (NII) from lending and liabilities held up well; however,
total NII declined 6.0% to EUR 15,023 million due to lower NII in Financial
Markets and Treasury. Lending NII rose by EUR 139 million, reflecting
volume growth at a stabilising margin. Liability NII declined by EUR 318
million as deposit growth could not entirely offset the impact of
normalising margins. Financial Markets NII was EUR 494 million more
negative than in 2023 as higher interest rates led to an increase in funding
costs. This impacted NII while the income from related positions is
reflected in other income due to accounting asymmetry. NII in Treasury
dropped by EUR 335 million, primarily impacted by the ECB’s adjustment in
September 2023 of the remuneration on the minimum reserve
requirements to zero basis points as well as by less favourable conditions
in the money markets. Other NII included a one-off income of EUR 70
million in Wholesale Banking and a EUR -39 million impact from the Polish
mortgage moratorium. The net interest margin was 1.45% in 2024, which
is 11 basis points lower than in 2023, mainly due to a lower NII in Financial
Markets and Treasury.
Net fee and commission income strongly increased in line with our
ambition to diversify our income and was up 11% to over EUR 4 billion. Fee
income from retail investment products was significantly up, reflecting an
increase in accounts, in assets under management and customer trading
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 64 |
activity. Daily banking fees rose on the back of strong growth in the
number of customers and an updated pricing for payment packages. The
increase in fee income for Wholesale Banking was mainly attributable to a
higher income from Capital Markets issuance.
Total investment and other income increased 19% to EUR 3,584 million.
This was mainly due to the positive effect of accounting asymmetry in
Financial Markets, as well as to a smaller IAS 29 impact (reflecting lower
inflation in Türkiye). Furthermore, in 2024 we recorded EUR 77 million as
our share in the one-off profit of an associate in Belgium and a EUR 53
million receivable (recorded in the Corporate Line) related to a prior
insolvency of a financial institution in the Netherlands.
Operating expenses increased 4.8% to EUR 12,121 million. Expenses in
2024 included EUR 882 million of regulatory costs, a decline of EUR 160
million year-on-year, mainly because no contribution to the eurozone’s
Single Resolution Fund was required in 2024 and because the Dutch
deposit guarantee fund reached its target level in 2024. Furthermore,
expenses in 2024 included EUR 178 million of incidental items (largely
related to restructuring provisions) compared with EUR 247 million of
incidental items in 2023.
Expenses excluding regulatory costs and incidental items rose 7.6%,
mainly attributable to the impact of inflation on staff expenses and the
implementation of the ‘Danske Bank’ ruling on VAT in the Netherlands. In
Retail Banking, this was coupled with investments in digitalisation and in
client acquisition to support growth. Wholesale Banking expenses also
reflect front office growth in Capital Markets & Advisory and Transaction
Services, as well as investments to enhance the digital experience and the
scalability of our systems. The cost/income ratio came out at 53.6% in
2024 compared with 51.2% a year earlier.
Net additions to loan loss provisions increased to EUR 1,194 million
compared with EUR 520 million in 2023. This is equivalent to 18 basis
points of average customer lending, and below our through-the-cycle
average of 20 basis points.
The increase year-on-year was largely due to additions for a number of
Stage 3 files in Wholesale Banking. This was partly compensated by a net
release from loan loss provisions in Stage 1 and 2, mainly reflecting a
partial release of management overlays.
The net result (attributable to shareholders of the parent) in 2024 was EUR
6,392 million compared with EUR 7,287 million in 2023. The effective tax
rate in 2024 was 28.5% compared with 28.3% in 2023.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 65 |
Retail Netherlands
Retail Netherlands | |||
in EUR million | 2025 | 2024 | 2023 |
Income: | |||
Net interest income | 3,115 | 3,027 | 3,096 |
Net fee and commission income | 1,128 | 1,049 | 959 |
Investment income and other income | 726 | 835 | 945 |
Total income | 4,968 | 4,910 | 5,001 |
Expenditure: | |||
Operating expenses | 2,089 | 2,124 | 2,135 |
Additions to the provision for loan losses | 107 | -8 | 5 |
Total expenditure | 2,196 | 2,117 | 2,140 |
Result before tax | 2,773 | 2,793 | 2,861 |
Taxation | 733 | 723 | 740 |
Non-controlling interests | 0 | 0 | 0 |
Net result IFRS-IASB | 2,040 | 2,070 | 2,121 |
Year ended 31 December 2025 compared to year ended 31 December
2024
The net result of Retail Netherlands decreased by EUR 30 million, or 1.4%,
to EUR 2,040 million in 2025 from EUR 2,070 million in 2024. Retail
Netherlands posted a result before tax of EUR 2,773 million compared with
EUR 2,793 million in 2024, a year in which risk costs benefited from a
modest net release. Income increased slightly year-on-year, while
operating expenses showed a small decline.
Results in 2025 were supported by a further increase in both our customer
base and customer balances. Customer lending rose by EUR 14.9 billion in
2025. Net core lending growth (which is the increase in customer lending,
excluding movements in Treasury and in the WestlandUtrecht Bank run-
off portfolio) was EUR 16.2 billion. This was fuelled by sustained strong
mortgage production (EUR 11.1 billion) and further expansion across both
business and consumer lending portfolios. Customer deposits increased by
EUR 8.5 billion. Excluding Treasury, customer deposits grew by EUR 11.5
billion, primarily driven by a solid net inflow from private individuals.
Net interest income rose 2.9% to EUR 3,115 million. This mainly reflected
higher Treasury-related interest income, which was partly offset within
‘total investment and other income’. Interest income from lending
products also increased, with the expansion of the lending portfolio more
than offsetting margin compression. Net fee and commission income rose
7.5%, with growth across all product categories — most notably in
investment products, supported by an increase in assets under
management. Investment and other income totalled EUR 726 million
(compared with EUR 835 million in 2024) and included lower Treasury-
related income.
Operating expenses decreased slightly to EUR 2,089 million. Regulatory
costs declined by EUR 47 million, as no contribution to the Dutch deposit
guarantee fund was required in 2025, and we benefited from an
adjustment to our DGS contribution related to previous years. Expenses
excluding regulatory costs remained broadly stable year-on-year, as
salary increases under the collective labour agreement and higher
restructuring costs were almost fully offset by operational efficiencies and
savings on external staffing.
Net additions to loan loss provisions were modest at EUR 107 million, the
equivalent of six basis points of average customer lending. In the previous
year, there had been a net release of EUR 8 million, mainly related to
mortgages.
Year ended 31 December 2024 compared to year ended 31 December
2023
The net result of Retail Netherlands decreased by EUR 51 million, or 2.4%,
to EUR 2,070 million in 2024 from EUR 2,121 million in 2023. Retail
Netherlands posted a result before tax of EUR 2,793 million compared with
EUR 2,861 million in 2023. The 2.4% decline was due to lower Treasury-
related income, while expenses were broadly flat and risk costs showed a
small net release.
Net interest income was EUR 3,027 million, or 2.2% lower than a year
earlier. The decline was attributable to lower Treasury-related interest
income, reflecting the impact of the ECB’s adjustment of the remuneration
on the minimum reserve requirement to zero basis points in September
2023 as well as less favourable money market conditions. Net interest
income from lending increased, supported by significant growth in the
mortgage portfolio. Net fee and commission income was strong and rose
9.4% to EUR 1,049 million. This was driven by growth in the number of
customers, higher fees for payment packages and a double-digit increase
in assets under management. Other income decreased due to lower other
income from specific money market and FX transactions in Treasury.
Customer lending rose by EUR 11.4 billion. The net core lending growth
(which excludes movements in Treasury and in the WestlandUtrecht Bank
run-off portfolio) was EUR 9.6 billion, driven by strong growth of the
mortgage portfolio. Customer deposits were EUR 1.0 billion higher but
excluding Treasury grew by EUR 5.0 billion.
Operating expenses slightly decreased to EUR 2,124 million. Regulatory
costs declined by EUR 98 million because no contribution to the Single
Resolution Fund was required in 2024 and because the Dutch deposit
guarantee fund in the Netherlands reached its target level in 2024. This
more than compensated for a higher bank tax in the Netherlands.
Expenses excluding regulatory costs rose 4.6% to EUR 2,011 million. This
included higher internal staff expenses due to collective labour agreement
(CLA) increases, partly offset by savings on external staff.
In 2024, a net release from loan loss provisions was recorded of EUR -8
million. This was attributable to a net release for mortgages, driven by a
strong improvement in the housing market and a partial release of
management overlays.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 66 |
Retail Belgium
Retail Belgium | |||
in EUR million | 2025 | 2024 | 2023 |
Income: | |||
Net interest income | 1,786 | 1,959 | 2,063 |
Net fee and commission income | 692 | 603 | 502 |
Investment income and other income | 197 | 189 | 117 |
Total income | 2,674 | 2,751 | 2,683 |
Expenditure: | |||
Operating expenses | 1,878 | 1,811 | 1,852 |
Additions to the provision for loan losses | 153 | 134 | 169 |
Total expenditure | 2,031 | 1,944 | 2,022 |
Result before tax | 644 | 807 | 661 |
Taxation | 178 | 210 | 182 |
Net result IFRS-IASB | 466 | 597 | 479 |
Year ended 31 December 2025 compared to year ended 31 December
2024
The net result of Retail Belgium (including ING in Luxembourg) decreased
by EUR 131 million, or 22%, to EUR 466 million in 2025 from EUR 597
million in 2024. The result before tax for Retail Belgium (which includes our
retail activities in Luxembourg) declined to EUR 644 million (from EUR 807
million in the prior year), mainly due to a lower margin on liabilities and
higher regulatory costs. However, fee income increased significantly, and
expenses excluding regulatory costs remained well-contained.
Customer lending rose by EUR 1.8 billion year-on-year. Net core lending
growth (which is the increase in customer lending excluding Treasury) was
EUR 2.0 billion, with growth in both mortgages and other lending.
Customer deposits declined by EUR 0.6 billion, following the conclusion of a
successful promotional campaign originated in the third quarter of 2024.
The campaign was highly effective, enabling the retention of the vast
majority of term deposits and facilitating their conversion into investment
products, thereby enhancing long-term customer value.
Net interest income declined 8.8% to EUR 1,786 million, primarily due to
reduced liability margins. Treasury-related net interest income also
decreased year-on-year, although this was fully offset by higher
investment and other income within Treasury. Investment and other
income included a EUR 44 million gain from the sale of an associate in
2025, while 2024 had included EUR 77 million relating to our share in the
one-off profit of another associate. Net fee and commission income was
strong, rising 15% to EUR 692 million. This growth was primarily driven by
higher fees from investment products, reflecting the success of campaigns
to attract new customers for investment solutions, as well as from daily
banking services.
Operating expenses amounted to EUR 1,878 million, including EUR 261
million in regulatory costs (up from EUR 206 million in 2024 due to a higher
DGS contribution) and EUR 79 million in incidental restructuring costs
(compared with EUR 59 million for this in 2024). These restructuring costs
are part of broader multi-year transformation programmes across
Belgium and Luxembourg, aimed at simplifying operations, increasing
commercial focus and improving long-term profitability, though they
temporarily impact reported returns. Expenses excluding regulatory costs
and incidental items declined 0.5%, as the impact of automatic salary
indexation was offset by lower accommodation and IT expenses.
The net addition to the provision for loan losses amounted to EUR 153
million, or 15 basis points of average customer lending, up from EUR 134
million in 2024. Risk costs were mainly related to business lending.
Year ended 31 December 2024 compared to year ended 31 December
2023
The net result of Retail Belgium (including ING in Luxembourg) increased
by EUR 118 million, or 25%, to EUR 597 million in 2024 from EUR 479
million in 2023. The result before tax for Retail Belgium rose 22% to EUR
807 million. The increase was attributable to higher income, coupled with
lower operating expenses and a decline in risk costs.
Net interest income decreased by EUR 104 million or 5.0%, mainly due to
lower Treasury-related interest income. In addition, net interest income
was impacted by higher funding costs for mortgages. Net fee and
commission income rose by EUR 101 million or 20%, supported by an
increase in assets under management and lower commissions paid.
Investment and other income was strongly up because 2024 included EUR
77 million for our share in the one-off profit of an associate.
Customer lending was up by EUR 4.0 billion. Net core lending (which
excludes Treasury) rose by EUR 3.7 billion, reflecting a EUR 2.7 billion
increase in business lending and EUR 1.0 billion of growth in the mortgage
portfolio. Customer deposits grew by EUR 5.9 billion. Net core deposits
(which excludes Treasury) increased by EUR 6.4 billion, driven by a EUR 5.5
billion inflow from our successful term deposit campaigns (exceeding the
EUR 2.6 billion outflow we saw in 2023 when customers bought bonds
issued by the Belgian government).
Operating expenses amounted to EUR 1,811 million, including EUR 206
million of regulatory costs (versus EUR 211 million in 2023) and EUR 59
million of incidental item costs related to restructuring and a further
optimisation of the branch network (compared with EUR 76 million for this
in 2023). Expenses excluding regulatory costs and incidental items
declined 1.3%, as the impact of automatic salary indexation was offset by
FTE reductions.
The net addition to the provision for loan losses amounted to EUR 134
million, or 14 basis points of average customer lending, down from EUR
169 million in 2023. Risk costs for mortgages and consumer lending
declined while risk costs for business lending were stable.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 67 |
Retail Germany
Retail Germany | |||
in EUR million | 2025 | 2024 | 2023 |
Income: | |||
Net interest income | 2,457 | 2,647 | 2,862 |
Net fee and commission income | 632 | 433 | 357 |
Investment income and other income | -98 | -173 | -67 |
Total income | 2,991 | 2,906 | 3,152 |
Expenditure: | |||
Operating expenses | 1,362 | 1,303 | 1,243 |
Additions to the provision for loan losses | 171 | 149 | 119 |
Total expenditure | 1,533 | 1,452 | 1,362 |
Result before tax | 1,457 | 1,455 | 1,790 |
Taxation | 472 | 505 | 631 |
Non-controlling interests | 2 | 1 | 0 |
Net result IFRS-IASB | 983 | 949 | 1,159 |
Year ended 31 December 2025 compared to year ended 31 December
2024
The net result of Retail Germany increased by EUR 35 million, or 3.6%, to
EUR 983 million in 2025 from EUR 949 million in 2024. Retail Germany
recorded a result before tax of EUR 1,457 million, stable year-on-year
despite higher risk costs.
The business continued to demonstrate strong commercial momentum,
including a double-digit increase in the number of mobile primary
customers. Customer lending showed a EUR 6.4 billion increase. Net core
lending growth (which is the increase in customer lending excluding the
Treasury portfolio) was EUR 6.9 billion, with mortgages remaining the
principal driver of growth. Customer deposits increased by EUR 6.6 billion,
reflecting the success of a promotional savings campaign, with a portion of
these funds subsequently channelled into investment products during the
second half of the year.
Net interest income declined 7.2% to EUR 2,457 million, as the positive
impact of volume growth was outweighed by narrower margins on
liabilities and mortgages, and by lower Treasury-related interest income,
the latter largely offset by an increase in investment and other income.
Net fee and commission income surged 46% to EUR 632 million. This was
driven by a growing customer base, a higher number of investment
product accounts, increased trading activity, and a rise in fees from daily
banking services.
Operating expenses in 2025 totalled EUR 1,362 million. This comprised EUR
32 million in regulatory costs, down from EUR 88 million a year earlier,
reflecting a lower contribution to the deposit guarantee scheme. Expenses
excluding regulatory costs in both years, as well as EUR 14 million of
incidental restructuring costs recorded in 2025, rose 8.3%. This was
predominantly due to higher internal staff expenses (related to annual
salary increases) and investments in business growth and scalability.
Net additions to loan loss provisions amounted to EUR 171 million (15 basis
points of average customer lending) and were primarily related to
consumer lending and portfolio sales.
Year ended 31 December 2024 compared to year ended 31 December
2023
The net result of Retail Germany decreased by EUR 210 million, or 18%, to
EUR 949 million in 2024 from EUR 1,159 million in 2023. The result before
tax for Retail Germany was EUR 1,455 million, a decline of 19% year-on-
year, which was mainly due to lower income from liabilities.
Net interest income decreased 7.5% to EUR 2,647 million, as higher client
rates on savings led to a narrowing of the liability margin in comparison to
the elevated levels we had seen in 2023. This was partly offset by volume
growth in both lending and deposits. Net fee and commission income
increased 21% to EUR 433 million, mainly fuelled by investment products,
where we recorded a higher number of trades and exceeded the milestone
of EUR 100 billion in assets under management in 2024. The increase in fee
income was also attributable to higher fees from daily banking and
mortgage brokerage. Total investment and other income declined,
reflecting lower Treasury-related income.
Customer lending was up by EUR 7.3 billion year-on-year. Net core lending
growth (which excludes Treasury) was EUR 4.4 billion. Next to EUR 3.6
billion in mortgages we grew our other lending portfolio by EUR 0.8 billion,
with an increase in both our consumer lending and business lending
portfolio.
Customer deposits increased by EUR 7.5 billion following a successful
campaign to attract new savings and private customers, as well as a net
inflow of EUR 0.8 billion in Business Banking.
Operating expenses rose 4.8% to EUR 1,303 million. Excluding EUR 88
million of regulatory costs (down from EUR 96 million in 2023) and EUR 20
million of incidental items for restructuring costs and staff allowances
recorded in 2023, cost growth was 7.8%. This was due to higher staff
expenses and investments in business growth.
Net additions to loan loss provisions amounted to EUR 149 million (14 basis
points of average customer lending) and were primarily related to
consumer lending.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 68 |
Retail Other
Retail Other | |||
in EUR million | 2025 | 2024 | 2023 |
Income: | |||
Net interest income | 3,892 | 3,817 | 3,437 |
Net fee and commission income | 717 | 609 | 519 |
Investment income and other income | 299 | 263 | 277 |
Total income | 4,908 | 4,688 | 4,233 |
Expenditure: | |||
Operating expenses | 2,905 | 2,792 | 2,479 |
Additions to the provision for loan losses | 323 | 291 | 313 |
Total expenditure | 3,228 | 3,083 | 2,792 |
Result before tax | 1,680 | 1,605 | 1,441 |
Taxation | 398 | 381 | 359 |
Non-controlling interests | 225 | 221 | 174 |
Net result IFRS-IASB | 1,058 | 1,002 | 908 |
Year ended 31 December 2025 compared to year ended 31 December
2024
Retail Other comprises the six retail markets in Spain, Italy, Australia,
Poland, Romania and Türkiye. The net result of Retail Other increased to
EUR 1,058 million in 2025 from EUR 1,002 million in 2024. The result before
tax for Retail Other was EUR 1,680 million compared with EUR 1,605 million
in 2024, with income growth more than offsetting a modest increase in
expenses and higher risk costs.
Customer lending rose by EUR 11.2 billion. Net core lending growth (which
reflects the increase in customer lending, adjusted for currency impacts
and Treasury) reached EUR 13.4 billion. This was led by an EUR 11.1 billion
expansion in the mortgage portfolio — most notably in Australia, Italy,
Spain, and Poland — alongside continued growth in business and
consumer lending. Customer deposits grew by EUR 10.2 billion. Net core
deposits growth (which is the increase in customer deposits excluding
currency impacts and Treasury) amounted to EUR 12.6 billion, reflecting
substantial net inflows, particularly in Spain, Italy, and Poland.
Net interest income rose 2.0% to EUR 3,892 million, as the favourable
impact of higher lending and deposit volumes more than compensated for
lower liability margins and negative FX impacts. In addition, net interest
income in the prior year had included a EUR -39 million impact from the
Polish mortgage moratorium. Net fee and commission income increased
significantly to EUR 717 million, representing an 18% year-on-year rise.
Fee income from investment products grew substantially, driven by net
inflows and a higher number of trades. This was complemented by
markedly higher fee income from daily banking services and insurance,
reflecting both customer growth and successful cross-selling initiatives.
Investment and other income also rose year-on-year, thanks to an
increase in Treasury-related income.
Operating expenses in 2025 amounted to EUR 2,905 million. This included
EUR 287 million of regulatory costs, a 10% increase, primarily due to a
higher contribution to the deposit guarantee scheme and increased bank
taxes in Poland. The previous year’s expenses had included EUR 17 million
in incidental restructuring costs (versus EUR 6 million in 2025) and a EUR
35 million legal provision. Excluding regulatory costs and these one-off
items, expenses rose 5.3%, mainly as a result of inflationary pressures and
ongoing investments in future business growth.
The net addition to loan loss provisions was EUR 323 million, or 26 basis
points of average customer lending, with additions mainly in Poland.
Year ended 31 December 2024 compared to year ended 31 December
2023
Retail Other comprises the six retail markets in Spain, Italy, Australia,
Poland, Romania and Türkiye. The net result of Retail Other increased to
EUR 1,002 million in 2024 from EUR 908 million in 2023. For Retail Other,
result before tax increased 11% to EUR 1,605 million, mainly thanks to
higher income.
Total income rose 11% to EUR 4,688 million. Net interest income was up
11% to EUR 3,817 million, supported by growth in both lending and deposit
volumes in all countries, coupled with higher margins on liabilities outside
the eurozone. Net interest income in 2024 included a EUR -39 million
impact from the Polish mortgage moratorium, following amendments to
the regulation that offers some customers the right to suspend up to four
instalment payments on their mortgage loan. Net fee and commission
income increased 17% to EUR 609 million. This was driven by higher fees in
daily banking, reflecting an increase in the number of customers and an
updated pricing for payment packages, combined with higher fee income
from investment products. Other income decreased due to lower
Treasury-related income.
Customer lending rose by EUR 7.4 billion. Net customer lending growth
(which is the change in customer lending adjusted for currency effects and
Treasury) was EUR 8.2 billion in 2024, with growth in all countries, but
particularly in Australia, Poland, Spain and Italy. Customer deposits were
up by EUR 12.1 billion. Net core deposits growth (excluding currency
impacts and movements in Treasury deposits) was EUR 12.7 billion,
primarily driven by net inflows in Poland, Spain and Australia.
Operating expenses in 2024 amounted to EUR 2,792 million. Excluding
regulatory costs (which were slightly up on 2023) and restructuring costs
and impairments (EUR 17 million in 2024 versus EUR 36 million in 2023),
expenses increased by 15%. This was due to inflationary pressure
(particularly in Türkiye), higher client acquisition expenses and
investments in further business growth.
The net addition to loan loss provisions was EUR 291 million, or 26 basis
points of average customer lending, compared with EUR 313 million in
2023. Risk costs in 2024 were primarily attributable to net additions in
Poland and Spain.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 69 |
Wholesale Banking
Wholesale Banking | |||
in EUR million | 2025 | 2024 | 2023 |
Income: | |||
Net interest income | 2,997 | 3,259 | 4,028 |
Net fee and commission income | 1,433 | 1,317 | 1,259 |
Investment income and other income | 2,579 | 2,405 | 1,771 |
Total income | 7,009 | 6,981 | 7,057 |
Expenditure: | |||
Operating expenses | 3,837 | 3,558 | 3,313 |
Additions to the provision for loan losses | 549 | 627 | -92 |
Total expenditure | 4,386 | 4,185 | 3,222 |
Result before tax | 2,624 | 2,796 | 3,836 |
Taxation | 673 | 693 | 900 |
Non-controlling interests | 48 | 35 | 61 |
Net result IFRS-EU | 1,902 | 2,068 | 2,875 |
Adjustment of the EU 'IAS 39 carve-out' | 1,996 | -1,058 | -3,147 |
Net result IFRS-IASB | 3,899 | 1,010 | -272 |
Year ended 31 December 2025 compared to year ended 31 December
2024
Without application of the EU ‘IAS 39 carve-out’, ING’s net result of
Wholesale Banking was EUR 3,899 million in 2025, compared with EUR 1,010
million in 2024. The adjustment of the EU ‘IAS 39 carve-out’, included in the
net result, was EUR 1,996 million in 2025, compared with EUR -1,058 million
in 2024, due to fair value changes on derivatives related to asset-liability-
management activities for the mortgage and savings portfolios in the
Benelux, Germany, France, Spain, Italy, and Romania. These fair value
changes were mainly a result of changes in market interest rates. No hedge
accounting is applied to these derivatives under IFRS-IASB.
The IFRS-EU net result (when applying the EU ‘IAS 39 carve-out’) decreased
to EUR 1,902 million from EUR 2,068 million in 2024. Wholesale Banking
delivered a robust performance in 2025, with a result before tax of EUR
2,624 million, compared with EUR 2,796 million in the previous year. Total
income grew slightly amid ongoing geopolitical uncertainties, and was
supported by a 9% rise in fee income, reflecting our strategic focus on
diversifying income streams. This growth helped to mitigate the impact of
margin compression in Payments & Cash Management and EUR -200
million in negative currency impacts. Earnings were also impacted by
elevated investment costs aimed at supporting future growth and EUR 90
million in restructuring provisions.
Customer lending IFRS-EU increased by EUR 7.3 billion. Net core lending
growth (which is the change in customer lending IFRS-EU, excluding
currency impacts and movements in the Treasury and run-off portfolios)
was significant at EUR 18.3 billion. This was driven by higher volumes in
Working Capital Solutions and short-term trade-related financing,
alongside a recovery in long-term loan demand in the second half of the
year. Customer deposits were up by EUR 5.0 billion. Net core deposits
growth (which excludes currency impacts and movements in the Treasury
portfolio) was EUR 8.0 billion, reflecting net inflows in Payments & Cash
Management and Financial Markets.
Total income from Lending increased slightly, supported by higher
volumes and an increase in fee income. This was partly offset by negative
currency movements. The rise in deal flow and fee income highlights the
strength of our client relationships and advisory capabilities. Through
disciplined capital management, we reduced risk-weighted assets within
Lending by 5.3%, with capital-velocity measures offsetting lending growth
and currency movements also contributing.
Income from Daily Banking & Trade Finance declined 3.4% year-on-year.
Higher revenues from increased client demand in Working Capital
Solutions and Trade Finance Services, as well as a strong performance in
our cash pooling business, were more than offset by margin compression
in Payments & Cash Management.
Financial Markets income increased 6.7% to EUR 1,512 million. This reflects
strong results in Interest Rate Derivatives, FX, Equity Derivatives, and
Capital Markets issuance, all benefiting from healthy client flows and
favourable market conditions.
Income from Treasury & Other declined by EUR 9 million year-on-year, as
higher income from Corporate Investments almost fully offset a EUR 70
million one-off income recorded in 2024.
Operating expenses for 2025 included EUR 90 million in restructuring costs
(versus EUR 10 million in 2024), of which EUR 85 million related to
workforce redundancies — part of our efforts to ensure our teams are well
positioned for the future. Excluding these incidental costs as well as
regulatory costs (which increased slightly to EUR 219 million), expenses
rose 5.8% year-on-year, driven by targeted, multi-year investment
initiatives — focused on digital foundations, platforms, and product
capabilities — that are required to structurally improve long-term
profitability.
Net additions to loan loss provisions declined to EUR 549 million
(equivalent to 28 basis points of average customer lending), down from
EUR 627 million in 2024. Individual Stage 3 risk costs fell sharply due to
lower inflows, repayments and recoveries. Risk costs in Stage 1 and 2 were
higher, as 2024 had included releases from collective provisions, including
a partial release of management overlays.
Year ended 31 December 2024 compared to year ended 31 December
2023
Without application of the EU ‘IAS 39 carve-out’, ING’s net result of
Wholesale Banking turned to EUR 1,010 million in 2024, compared with a
loss of EUR -272 million in 2023. The adjustment of the EU ‘IAS 39 carve-out’,
included in the net result, was EUR -1,058 million in 2024, compared with
EUR -3,147 million in 2023, due to fair value changes on derivatives related
to asset-liability-management activities for the mortgage and savings
portfolios in the Benelux, Germany, France, Spain, and Italy. These fair value
changes were mainly a result of changes in market interest rates. No hedge
accounting is applied to these derivatives under IFRS-IASB.
The IFRS-EU net result (when applying the EU ‘IAS 39 carve-out’) decreased
to EUR 2,068 million from EUR 2,875 million in 2023. Total income was
resilient, supported by increased lending and deposit volumes and strong
results in Financial Markets, which compensated for margin compression in
Payments & Cash Management. Expenses rose, primarily due to the
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 70 |
impact of collective labour agreements, inflation and investments in
business growth and in our product foundations. We remained disciplined
in capital management, with a modest increase of EUR 1.9 billion in risk-
weighted assets, fully due to the strengthening of the US dollar, and
income over average risk-weighted assets was resilient at 458 basis points.
The net result declined 28% to EUR 2,068 million, mainly due to higher risk
costs versus a net release in 2023. The return on equity came out at 11.0%
in 2024.
Customer lending IFRS-EU rose by EUR 7.8 billion. Net core lending growth
(which is the increase in customer lending IFRS-EU, adjusted for currency
impacts and changes in the Treasury and run-off portfolios) was EUR 1.8
billion in 2024, with the increase being softened by loan sales and other
ongoing efforts to optimise our capital usage. Customer deposits were EUR
14.9 billion higher year-on-year. Net core deposits growth (which excludes
currency impacts and movements in Treasury deposits) was EUR 15.8
billion in 2024, mainly attributable to strategic initiatives in Payments &
Cash Management and Money Markets.
Total income in 2024 amounted to EUR 6,981 million and was almost
stable year-on-year. Our focus on income diversification yielded positive
results, as evidenced by higher income from Financial Markets and an
increase in fee income. Our Capital Markets & Advisory business continued
to grow, following investments to further build on our expertise. Income
from Payments & Cash Management declined, reflecting lower margins.
Total income in Lending rose 1.7% to EUR 3,278 million, with an increase in
both net interest income and in fee income. We further optimised our
capital efficiency and kept our risk-weighted assets flat despite the
strengthening of the US dollar, leading to an improvement in income over
average risk-weighted assets.
In Daily Banking & Trade Finance we were successful in attracting deposit
balances. Income declined year-on-year, reflecting lower margins for
Payments & Cash Management. This was partly offset by income growth
for Trade Finance Services, on the back of higher margins and increased
fee income.
Financial Markets had a strong year, with income increasing 11% to EUR
1,417 million. This was primarily driven by increased Capital Markets
issuance income and an enhanced performance in Global Securities
Finance products.
Income from Treasury & Other declined, largely due to a lower
remuneration on the ECB minimum reserve requirement, while Treasury
had also benefited from the rapid increase in interest rates in 2023. This
was coupled with lower results from Corporate Investments, and partly
offset by a EUR 70 million one-off income.
Total operating expenses increased 7.4% to EUR 3,558 million. Regulatory
costs were lower, mainly because no contribution to the eurozone’s Single
Resolution Fund was required in 2024. Excluding regulatory costs and
incidental item costs (EUR 10 million in 2024 versus EUR 17 million in the
year before), expenses increased 10%. This was due to the impact of
collective labour agreements, inflation and front office growth in Capital
Markets & Advisory and Transaction Services, as well as investments to
enhance the digital customer experience and the scalability of our
systems.
The net addition to loan loss provision amounted to EUR 627 million in
2024 (33 basis points of average customer lending). This compares to a net
release of EUR 92 million in 2023, when EUR 218 million of provisions for
our Russia-related portfolio could be released, mainly due to a reduction of
our exposure. Risk costs in 2024 were primarily related to individual Stage
3 provisioning. Additions for a number of unrelated files in Stage 3 were
partly offset by releases from collective provisions in Stage 1 and 2
(including a partial release of management overlays).
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 71 |
Alternative performance measures
Our financial information is prepared in accordance with IFRS as detailed out in the financial statements of our Annual Report. In addition, in the discussion of our financial performance, we use a number of alternative performance
measures, including resilient net profit, commercial net interest income and net core lending and net core deposits growth. Resilient net profit is defined as net profit adjusted for significant items not linked to the normal course of
business, reference is made to 'Capital Management' for a reconciliation. We consider commercial net interest income, and the derived commercial net interest margin, to be useful information because the scope is restricted to those
products that are mainly interest driven and excludes the interest on products where performance measurement is primarily done based on fee income or at the total income level (including Financial Markets and Treasury).
Commercial net interest income also excludes significant volatile items in lending and liability net interest income, thus removing items that distort period-on-period comparisons. We consider net core lending and net core deposits
growth as useful information to track our real commercial growth in customer balances. It measures the development of our customer lending and deposits adjusted for currency impacts and changes in the Treasury and run-off
portfolios.
The tables below show how net core lending growth and net core deposits growth can be reconciled to the nearest IFRS-IASB measure.
Reconciliation commercial net interest income (NII) | |||||||||||||||||||||
Retail Netherlands | Retail Belgium | Retail Germany | Retail Other | Wholesale Banking | Corporate Line | Total | |||||||||||||||
in EUR million | 2025 | 2024 | 2023 | 2025 | 2024 | 2023 | 2025 | 2024 | 2023 | 2025 | 2024 | 2023 | 2025 | 2024 | 2023 | 2025 | 2024 | 2023 | 2025 | 2024 | 2023 |
Net interest income IFRS-IASB | 3,115 | 3,027 | 3,096 | 1,786 | 1,959 | 2,063 | 2,457 | 2,647 | 2,862 | 3,892 | 3,817 | 3,437 | 3,273 | 3,524 | 4,214 | 434 | 315 | 489 | 14,957 | 15,288 | 16,162 |
IFRS-EU 'IAS 39 carve-out' impact | -276 | -265 | -187 | -276 | -265 | -187 | |||||||||||||||
Net interest income IFRS-EU | 3,115 | 3,027 | 3,096 | 1,786 | 1,959 | 2,063 | 2,457 | 2,647 | 2,862 | 3,892 | 3,817 | 3,437 | 2,997 | 3,259 | 4,028 | 434 | 315 | 489 | 14,681 | 15,023 | 15,976 |
Exclude: Other NII (excl. significant volatile items)1 | -572 | -621 | -535 | 93 | 142 | 198 | 205 | 298 | 151 | 195 | 213 | 207 | -972 | -693 | -171 | 434 | 315 | 489 | -618 | -346 | 338 |
Exclude: Significant volatile items2 | -18 | -51 | -39 | 70 | -18 | -20 | |||||||||||||||
Commercial net interest income | 3,687 | 3,647 | 3,631 | 1,692 | 1,816 | 1,866 | 2,270 | 2,400 | 2,711 | 3,698 | 3,643 | 3,231 | 3,969 | 3,882 | 4,199 | 0 | 0 | 0 | 15,316 | 15,389 | 15,638 |
1Other NII mainly includes NII for Financial Markets and Treasury. In Financial Markets this primarily reflects the funding costs of positions for which associated revenue is reported in 'other income'. For Treasury, it includes the funding costs of specific money market and FX transactions where an offsetting revenue is
recorded in 'other income', as well as interest income from other Treasury activities (such as foreign currency ratio hedging) that are not allocated to Retail or Wholesale. Furthermore, other NII includes the funding costs for our equity stakes, the NII related to investment portfolios, as well as the effect of indexation
of NII required by IAS 29 due to hyperinflation in Türkiye.
2Significant volatile items in lending and liability NII are lending- and liability-related interest items that management would consider as outside the normal course of business and large enough to distort a proper period-on-period comparison. For the years 2025 and 2024, it includes EUR -18 million (2025) and
EUR -51 million (2024) for incentives to attract new customers (Retail Germany), EUR -39 million for the Polish mortgage moratorium (2024), and a EUR +70 million one-off in Wholesale Banking (2024).
Customer lending IFRS-IASB versus Customer lending IFRS-EU and Net core lending growth by business line | |||||||||||||||||||||
Retail Netherlands | Retail Belgium | Retail Germany | Retail Other | Wholesale Banking | Corporate Line | Total | |||||||||||||||
in EUR billion | 2025 | 2024 | change | 2025 | 2024 | change | 2025 | 2024 | change | 2025 | 2024 | change | 2025 | 2024 | change | 2025 | 2024 | change | 2025 | 2024 | change |
Customer lending IFRS-IASB 1 | 179.2 | 164.3 | 14.9 | 100.1 | 98.3 | 1.8 | 116.6 | 110.2 | 6.4 | 128.4 | 117.2 | 11.2 | 209.1 | 199.2 | 10.0 | 0.3 | 0.3 | 0.0 | 733.6 | 689.4 | 44.2 |
IFRS-EU 'IAS 39 carve out' impact | -6.0 | -3.4 | -2.6 | -6.0 | -3.4 | -2.6 | |||||||||||||||
Customer lending IFRS-EU | 179.2 | 164.3 | 14.9 | 100.1 | 98.3 | 1.8 | 116.6 | 110.2 | 6.4 | 128.4 | 117.2 | 11.2 | 203.1 | 195.8 | 7.3 | 0.3 | 0.3 | 0.0 | 727.6 | 686.1 | 41.5 |
Exclude: FX impact | 0.0 | 0.0 | 0.0 | 2.3 | 8.9 | 11.2 | |||||||||||||||
Exclude: Change in fair value macro hedged loans | 2.6 | 2.6 | |||||||||||||||||||
Exclude: Treasury, run-off portfolios and other | 1.3 | 0.3 | 0.5 | -0.1 | -0.5 | 0.0 | 1.5 | ||||||||||||||
Net core lending growth | 16.2 | 2.0 | 6.9 | 13.4 | 18.3 | 0.0 | 56.9 | ||||||||||||||
1Loans and advances to customers excluding loan loss provision.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 72 |
Customer deposits IFRS-IASB versus Customer deposits IFRS-EU and Net core deposits growth by business line | |||||||||||||||||||||
Retail Netherlands | Retail Belgium | Retail Germany | Retail Other | Wholesale Banking | Corporate Line | Total | |||||||||||||||
in EUR billion | 2025 | 2024 | change | 2025 | 2024 | change | 2025 | 2024 | change | 2025 | 2024 | change | 2025 | 2024 | change | 2025 | 2024 | change | 2025 | 2024 | change |
Customer deposits IFRS-IASB | 209.1 | 200.7 | 8.5 | 96.5 | 97.1 | -0.6 | 157.7 | 151.1 | 6.6 | 173.4 | 163.2 | 10.2 | 84.6 | 79.6 | 5.0 | 0.0 | 0.0 | 0.0 | 721.4 | 691.7 | 29.7 |
IFRS-EU 'IAS 39 carve out' impact | 0.0 | 0.0 | 0.0 | 0.0 | 0.0 | 0.0 | |||||||||||||||
Customer deposits IFRS-EU | 209.1 | 200.7 | 8.5 | 96.5 | 97.1 | -0.6 | 157.7 | 151.1 | 6.6 | 173.4 | 163.2 | 10.2 | 84.6 | 79.6 | 5.0 | 0.0 | 0.0 | 0.0 | 721.4 | 691.7 | 29.7 |
Exclude: FX impact | 0.0 | 0.0 | 0.0 | 2.3 | 1.4 | 3.7 | |||||||||||||||
Exclude: Change in fair value macro hedged deposits | 0.0 | 0.0 | |||||||||||||||||||
Exclude: Treasury, run-off portfolios and other | 3.1 | -0.1 | 0.0 | 0.1 | 1.6 | 0.0 | 4.7 | ||||||||||||||
Net core deposits growth | 11.5 | -0.6 | 6.6 | 12.6 | 8.0 | 0.0 | 38.1 | ||||||||||||||
Customer lending IFRS-IASB versus Customer lending IFRS-EU and Net core lending growth by business line | |||||||||||||||||||||
Retail Netherlands | Retail Belgium | Retail Germany | Retail Other | Wholesale Banking | Corporate Line | Total | |||||||||||||||
in EUR billion | 2024 | 2023 | change | 2024 | 2023 | change | 2024 | 2023 | change | 2024 | 2023 | change | 2024 | 2023 | change | 2024 | 2023 | change | 2024 | 2023 | change |
Customer lending IFRS-IASB 1 | 164.3 | 152.8 | 11.4 | 98.3 | 94.3 | 4.0 | 110.2 | 102.9 | 7.3 | 117.2 | 109.8 | 7.4 | 199.2 | 192.9 | 6.3 | 0.3 | 0.3 | 0.0 | 689.4 | 652.9 | 36.5 |
IFRS-EU 'IAS 39 carve out' impact | -3.4 | -4.9 | 1.5 | -3.4 | -4.9 | 1.5 | |||||||||||||||
Customer lending IFRS-EU | 164.3 | 152.8 | 11.4 | 98.3 | 94.3 | 4.0 | 110.2 | 102.9 | 7.3 | 117.2 | 109.8 | 7.4 | 195.8 | 188.0 | 7.8 | 0.3 | 0.3 | 0.0 | 686.1 | 648.0 | 38.0 |
Exclude: FX impact | 0.0 | 0.0 | 0.0 | 0.9 | -4.7 | -3.8 | |||||||||||||||
Exclude: Change in fair value macro hedged loans | -1.5 | -1.5 | |||||||||||||||||||
Exclude: Treasury, run-off portfolios and other | -1.9 | -0.4 | -2.9 | -0.2 | 0.2 | 0.0 | -5.1 | ||||||||||||||
Net core lending growth | 9.6 | 3.7 | 4.4 | 8.2 | 1.8 | 0.0 | 27.7 | ||||||||||||||
1Loans and advances to customers excluding loan loss provision.
Customer deposits IFRS-IASB versus Customer deposits IFRS-EU and Net core deposits growth by business line | |||||||||||||||||||||
Retail Netherlands | Retail Belgium | Retail Germany | Retail Other | Wholesale Banking | Corporate Line | Total | |||||||||||||||
in EUR billion | 2024 | 2023 | change | 2024 | 2023 | change | 2024 | 2023 | change | 2024 | 2023 | change | 2024 | 2023 | change | 2024 | 2023 | change | 2024 | 2023 | change |
Customer deposits IFRS-IASB | 200.7 | 199.7 | 1.0 | 97.1 | 91.2 | 5.9 | 151.1 | 143.6 | 7.5 | 163.2 | 151.0 | 12.1 | 79.6 | 64.8 | 14.9 | 0.0 | 0.0 | 0.0 | 691.7 | 650.3 | 41.4 |
IFRS-EU 'IAS 39 carve out' impact | 0.0 | 0.0 | 0.0 | 0.0 | 0.0 | 0.0 | |||||||||||||||
Customer deposits IFRS-EU | 200.7 | 199.7 | 1.0 | 97.1 | 91.2 | 5.9 | 151.1 | 143.6 | 7.5 | 163.2 | 151.0 | 12.1 | 79.6 | 64.8 | 14.9 | 0.0 | 0.0 | 0.0 | 691.7 | 650.3 | 41.4 |
Exclude: FX impact | 0.0 | 0.0 | 0.0 | 0.6 | -0.4 | 0.3 | |||||||||||||||
Exclude: Change in fair value macro hedged deposits | 0.0 | 0.0 | |||||||||||||||||||
Exclude: Treasury, run-off portfolios and other | 4.0 | 0.5 | 0.0 | -0.1 | 1.3 | 0.0 | 5.8 | ||||||||||||||
Net core deposits growth | 5.0 | 6.4 | 7.5 | 12.7 | 15.8 | 0.0 | 47.4 | ||||||||||||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 73 |
B.Liquidity and capital resources
ING believes that its working capital is sufficient for its present
requirements.
For information regarding our material short and long- term cash
requirements from known contractual and other obligations, see
“Additional information – ING Group Risk Management section Funding and
liquidity risk”, "Additional information - ING Capital management" and
Note 46 'Capital management' in the consolidated financial statements.
For information on legal or economic restrictions on the ability of
subsidiaries to transfer funds to the company in the form of cash
dividends, loans or advances, see Note 19 'Equity' in the consolidated
financial statements.
For information on the maturity profile of borrowings and a further
description of the borrowings, please see Note 17 'Debt securities in issue',
Note 18 'Subordinated loans' and Note 38 'Liabilities and off-balance sheet
commitments by maturity' in the consolidated financial statements.
For information on currency and interest rate structure, see “Additional
information – ING Group Risk Management section Market risk” and
“Additional information – ING Group Risk Management section Funding and
liquidity risk”.
For information on the use of financial instruments for hedging purposes,
please see Note 36 'Derivatives and hedge accounting' in the consolidated
financial statements.
ING Group Consolidated Cash Flows | |||
cash and cash equivalents | |||
in EUR million | 2025 | 2024 | 2023 |
Treasury bills and other eligible bills included in securities at AC | |||
Deposits from banks | - | - | - |
Loans and advances to banks | |||
Cash and balances with central banks | |||
Cash and cash equivalents at end of year |
Year ended 31 December 2025 compared to year ended 31 December
2024
Net cash flow from operating activities amounts to EUR -6,380 million for
the year-end 2025, compared to EUR -22,544 million for the year-end
2024. The increase in cash flow from operating activities of EUR 16,164
million in 2025 is explained by higher cash inflows for trading assets and
liabilities (EUR 20,009 million), Loans and deposits from banks (EUR 20,192
million) and higher result before tax, after adjustment for non-cash items
(EUR 2,605 million) and is partly offset by higher cash outflows from loans
and deposits to/from customers (EUR -28,845 million).
Net cash flow from investing activities amounts to EUR -15,697 million for
the year-end 2025 compared to EUR -6,033 million in 2024. The net cash
flow from investing activities decreased by EUR -9,663 million and is
explained by a net decrease from Financial assets at fair value through OCI
of EUR -6,057 million and net decrease from Securities at amortised costs
of EUR -3,673 million.
Net cash flow from financing activities amounts to EUR 8,245 million in
2025, compared to EUR 5,374 million in 2024. The increase of EUR 2,871
million is explained by a net increase of EUR 3,502 million of debt securities
and is partly offset by a net decrease of EUR -746 million of Subordinated
loans.
The operating, investing and financing activities described above result in a
decrease of EUR -14,921 million in cash and cash equivalents to EUR
on cash and cash equivalents of EUR -1,089 million.
Year ended 31 December 2024 compared to year ended
31 December 2023
Net cash flow from operating activities amounts to EUR -22,544 million for
the year-end 2024, compared to EUR -11,340 million for the year-end
2023. The decrease in cash flow from operating activities of EUR -11,204
million in 2024 is explained by higher cash outflows for trading assets and
liabilities (EUR -9,400 million), assets and liabilities mandatorily and
designated at fair value through profit or loss (EUR -4,515 million), other
assets and liabilities (EUR -4,326 million), non-trading derivatives (EUR
-2,463 million) and is partly offset by higher cash inflows from loans and
deposits to/from customers (EUR 3,992 million), loans and deposits to/from
banks (EUR 3,558 million) and higher result before tax, after adjustment for
non-cash items (EUR 2,224 million).
Net cash flow from investing activities amounts to EUR -6,033 million for
the year-end 2024 compared to EUR -8,545 million in 2023. The net cash
flow from investing activities increased by EUR 2,511 million and is
explained by a net increase from Financial assets at fair value through OCI
of EUR 3,939 million and net decrease from Securities at amortised costs
of EUR -1,231 million.
Net cash flow from financing activities amounts to EUR 5,374 million in
2024, compared to EUR 18,404 million in 2023. The decrease of EUR
-13,030 million is explained by a net decrease of EUR -14,175 million of
debt securities and higher dividend paid of EUR -911 million partly offset
by a net increase of EUR 2,341 million of Subordinated loans.
The operating, investing and financing activities described above result in a
decrease of EUR -23,944 million in cash and cash equivalents to EUR
and cash equivalents of EUR -740 million.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 74 |
C. Research and development, patents and
licenses, etc.
Not applicable.
D. Trend information
For information regarding trend information, see Item 5.A of this Form 20-
F.
E. Critical Accounting Estimates
Reference is made to Note 1 'Basis of preparation and material accounting
policy information' to the consolidated financial statements for detailed
information on Critical Accounting Estimates.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 75 |
Item 6. Directors, Senior Management and Employees
A.Directors and senior management
Executive Board
Roles and responsibilities
The Executive Board (EB) is entrusted with the management of ING Group
and its subsidiaries and is responsible for the continuity and long-term
value creation of ING. This includes the day-to-day management of the
business and setting ING’s strategy, the responsibility of which is vested in
the members of the EB collectively. The organisation, main roles and
responsibilities of the EB are set out in the Management Board Charter,
which is available on ing.com.
The EB performs its activities under the supervision of the Supervisory
Board (SB). The Articles of Association, the Management Board Charter and
the Supervisory Board Charter, which are available on ing.com, outline
which resolutions of the EB are subject to approval by the SB.
ING Group indemnifies the members of the EB to the extent permitted by
law against direct financial losses in connection with claims from third
parties. This applies to claims filed, or threatened to be filed, against them
in connection with their service as a member of the EB in accordance with
the Articles of Association and their commission contract. ING Group has
taken out liability insurance for the members of the EB.
Appointment and reappointment
The SB is responsible for selecting and nominating candidates to be
appointed or reappointed to the EB by the General Meeting, based on,
among other factors, the EB profile, which is available on ing.com. The SB
regularly assesses the composition and functioning of the EB.
The following two topics form part of this process:
1.Bench strength and succession planning for EB positions are continuous
attention points. Potential internal candidates for such roles may be
complemented with potential talent from outside ING.
2.A long-term view is taken on the composition of the EB in line with
strategic priorities.
Members of the EB are appointed, suspended and dismissed by the
General Meeting. The SB may draw up a binding list of candidates for
appointment and may propose the dismissal and suspension of EB
members. Candidates for appointment to the EB are assessed by the DNB
and the ECB for suitability and integrity and must continue to meet these
criteria while in function.
A resolution of the General Meeting to render this list non-binding, or to
suspend or dismiss EB members without this being proposed by the SB,
requires an absolute majority of the votes cast. Additionally, this majority
must represent more than half of the issued share capital. In a second
general meeting, such a resolution also requires an absolute majority of
the votes cast, and this majority must represent more than half of the
issued share capital. This ensures that such significant resolutions can only
be adopted with substantial support of ING Group’s shareholders.
Composition of the Executive Board
On 24 July 2025, it was announced that Tanate Phutrakul will step down
from his position as chief financial officer, member of the Management
Board Banking and member of the Executive Board as of the 2026 General
Meeting. On 29 October 2025, it was announced that Ida Lerner will be
appointed as chief financial officer and member of the Management Board
Banking effective 1 April 2026. The Supervisory Board will propose to
shareholders to appoint her as member of the Executive Board and as CFO
of ING Group at the 2026 General Meeting.
Furthermore, on 23 October 2025, it was announced that Ljiljana Čortan
will step down as CRO and will succeed Andrew Bester as head of
Wholesale Banking. It has since been announced that Ljiljana will start as
head of Wholesale Banking and leave her position as CRO on 24 February
2026. She will remain a member of the EB until a successor is appointed as
CRO.
Remuneration and share ownership
Details of the remuneration of members of the EB, including shares
granted to them, are set out in the ‘Remuneration report’.
Members of the EB are permitted to hold shares in the share capital of ING
Group for long-term investment purposes. Transactions by members of
the Executive Board in these shares need to comply with the ING
regulations for insiders, which are available on ing.com.
Relevant positions pursuant to CRD IV/conflicting interests
Members of the EB may hold other positions outside ING. No member of
the EB had corporate directorships relevant under CRD IV outside ING
throughout 2025.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 76 |
Members of the EB are to report any conflict of interest (including potential
conflicts of interest) to the chairperson of the EB and the other EB
members, and shall provide all relevant information. The EB, excluding the
member concerned, decides whether a conflict of interest exists.
In the case of a conflict of interest, the relevant member of the EB abstains
from discussions and decision-making on the topic or the transaction in
relation to which they have a conflict of interest with ING Group.
Transactions involving actual or potential conflicts of interest
There were no transactions reported in 2025 in which there were conflicts
of interest with EB members that are of material significance to ING Group
and/or to the relevant board members.
If a member of the EB obtains financial products and services, other than
loans, which are provided by subsidiaries of ING Group in the ordinary
course of business on terms that apply to employees, this is not
considered a significant conflict of interest and is therefore not reported.
Banking and financial products in which the granting of credit is of a
secondary nature (e.g. credit cards and overdrafts in current accounts) are
not considered a loan for this purpose and are therefore not disclosed in
the ‘Remuneration report’. For an overview of loans granted to members of
the Executive Board, see the ‘Remuneration report’.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 77 |
Members of the Executive Board and Management Board Banking
 |  |  |  | |||||||||||||||
Steven van Rijswijk (CEO) Born 1970 Nationality Dutch | Tanate Phutrakul (CFO) Born 1965 Nationality Thai | Ljiljana Čortan (CRO) Born 1971 Nationality Croatian | Pinar Abay Born 1977 Nationality Turkish | |||||||||||||||
Steven has been a member of the EB since May 2017. He has been CEO and chairperson of this board since July 2020. Prior to his appointment as CEO and chairperson of this board, he was the chief risk officer. Steven is responsible for ING's strategy, including ESG and sustainability, leading governance including the decision- making process, results, culture, branding, reputation and people. | Tanate was appointed as chief financial officer and a member of the MBB in February 2019. Subsequently, Tanate was appointed a member of the EB at the Annual General Meeting in April 2019. Tanate is responsible for ING's financial strategy, budgeting, cost control, and the financing of the company. | Ljiljana was appointed as chief risk officer and a member of the MBB effective January 2021. Ljiljana was appointed a member of the EB at the Annual General Meeting in April 2021. Ljiljana is responsible for ING's risk activities, including formulating our risk management framework and risk appetite, risk culture and awareness, risk governance and policies and compliance. | Pinar was appointed a member of the MBB in January 2020. She is also head of Retail, Market Leaders and Challengers & Growth Markets. Pinar is responsible for ING's retail banking activities globally. | |||||||||||||||
Relevant CRD IV position(s) §CEO and chairperson of the EB and MBB Other ancillary positions §Member of the management board of the Nederlandse Vereniging van Banken (NVB) §Member of the Cyber Security Council (CSR) | Relevant CRD IV position(s) §CFO and member of the EB and the MBB Other ancillary positions §None | Relevant CRD IV position(s) §CRO and member of the EB and the MBB Other ancillary positions §None | Relevant CRD IV position(s) §Member of the MBB §Non-executive member of the board of ING Belgium N.V./ S.A. §Member of the supervisory board of ING-DiBa A.G. §Member of the board of EPI Company SE Other ancillary positions §None | |||||||||||||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 78 |
 |  |  | |||||||||||
Andrew Bester Born 1965 Nationality British/South African | Marnix van Stiphout (COO) Born 1970 Nationality Dutch | Daniele Tonella (CTO) Born 1971 Nationality Swiss | |||||||||||
Andrew was appointed a member of the MBB and head of Wholesale Banking in April 2021. Andrew is responsible for ING's wholesale banking activities globally. | Marnix was appointed a member of the MBB and chief operations officer in September 2021. Marnix is responsible for translating, overseeing, and embedding ING's strategies into a strategy for the operations function. | Daniele was appointed a member of the MBB and chief technology officer in August 2024. Daniele is responsible for overseeing and managing the total IT landscape and advising on technology-driven business opportunities. | |||||||||||
Relevant CRD IV position(s) §Member of the MBB Other ancillary positions §None | Relevant CRD IV position(s) §Member of the MBB Other ancillary positions §None | Relevant CRD IV position(s) §Member of the MBB Other ancillary positions §Member of the Tech Advisory Board of The Hg Foundation | |||||||||||
Executive Board in numbers | ||||||
 | Board members 3 | |||||
 | Average age 56 | |||||
 | Nationalities 3 | |||||
 | Average board tenure (years) 6 | |||||
 | Female 33% | |||||
Management Board Banking in numbers | ||||||
| Board members 7 | |||||
| Average age 55 | |||||
| Nationalities 6 | |||||
| Average board tenure (years) 4.5 | |||||
| Female 29% | |||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 79 |
Supervisory Board
Roles and responsibilities
The SB members are collectively responsible for supervising and advising
the EB and for overseeing the activities of ING and the business connected
with it. The organisation, powers and modus operandi of the SB are set out
in the Charter of the Supervisory Board, available on ing.com.
In performing their duties, members of the SB are required to:
§be guided by the interests of ING and the business connected with it,
thereby carefully balancing the interests of all stakeholders of ING and
in this consideration give paramount importance to customers'
interests, as set out in the Dutch Banker’s Oath;
§foster a culture focused on sustainable long-term value creation,
financial and non-financial risk awareness, compliance with ING’s risk
appetite, and responsible and ethical behaviour;
§stimulate openness and accountability within ING and its subsidiaries;
§act without mandate from third parties and independent of any
interest in the business of ING; and
§ensure that the Supervisory Board functions effectively.
The articles of association of ING Group (Articles of Association), the
Management Board Charter and the Supervisory Board Charter outline
which resolutions of the EB are subject to approval by the SB.
ING Group indemnifies the members of the SB as far as legally permitted
against direct financial losses in connection with claims from third parties
filed, or threatened to be filed, against them by virtue of their service as a
member of the SB in accordance with the Articles of Association.
Composition
ING Group aims to have an adequate and balanced composition of its SB,
with a mix of persons with knowledge, skills and executive experience,
preferably gained in the banking sector, experience in corporate
governance of large stock-listed companies, and experience in the political
and social environment in which such companies operate. In the selection
of the members of the SB, consideration is given to a range of professional
qualifications and backgrounds, including experience, skills, education and
business judgment. In addition, there should be a balance of experience
and affinity with the nature and culture of the business of ING. ING believes
that a range of professional background and experience at the level of the
SB fosters a diversity of views and experiences and facilitates independent
opinions and sound decision-making, which has a positive impact on ING’s
business and stakeholders. According to the Dutch Gender Diversity Act,
ING is required to comply with a gender-diversity quota of at least one
third male and at least one third female for its SB. ING meets this criterion.
As from 1 July 2025, the SB consisted of seven male members and four
female members.
The SB is responsible for selecting and nominating candidates for
appointment or reappointment to the SB, based on, among other factors,
the SB profile, which is available on ing.com. The SB regularly assesses its
composition.
On 20 January 2026, it was announced that Herna Verhagen will resign
from the Supervisory Board as of the 2026 General Meeting. As of this
date, Herna will also step down as chairperson of the Remuneration
Committee and as member of the Nomination and Corporate Governance
Committee and the Risk Committee.
Appointment, suspension and dismissal
Members of the SB are appointed, suspended and dismissed by the
General Meeting. The SB may draw up a binding list of candidates for
appointment and may propose the dismissal and suspension of SB
members. Candidates for appointment to the SB are assessed by the DNB
and ECB for suitability and reliability, and must continue to meet these
criteria while in function.
A resolution of the General Meeting to render this list non-binding, or to
suspend or dismiss SB members without this being proposed by the SB,
requires an absolute majority of the votes cast. In addition, this majority
must represent more than half of the issued share capital. In a second
general meeting, such a resolution also requires an absolute majority of
the votes cast, and this majority must represent more than half of the
issued share capital. This ensures that such significant resolutions can only
be adopted with substantial support of ING Group’s shareholders.
Term of appointment of the Supervisory Board members
As a general rule, SB members step down from the SB after the fourth
anniversary of their last appointment or reappointment term. SB members
are appointed for four years and may be reappointed once for another
four-year term. Thereafter, they may be reappointed for an additional
two-year term, which may be extended by no more than two years. The
SB may deviate from this general rule under special circumstances and
with explanation, for instance to maintain a balanced composition of the
SB and/or to preserve valuable expertise and experience. The retirement
schedule is available on ing.com.
Relevant positions pursuant to CRD IV / conflicting interests
Members of the SB may hold other positions outside ING, including
directorships, either paid or unpaid. CRD IV restricts the total number of SB
positions or non-executive directorships with predominantly commercial
organisations that may be held by an SB member to four. If an SB member
also has an executive position, the number of positions is restricted to two.
The ECB may, under special circumstances, permit an SB member to fulfil
an additional SB position or non-executive directorship. Positions with, inter
alia, subsidiaries or qualified holdings are not taken into account in the
application of these restrictions. Such positions may not conflict with the
interests of ING Group. It is the responsibility of the individual member of
the SB and the SB collectively to ensure that the directorship duties are
performed properly and are not affected by any other positions that the
individual may hold outside ING Group.
Members of the SB are to report any conflict of interest (including potential
conflicts of interest) to the chairperson of the SB (or, in the case of the
chairperson, to the vice-chairperson) and to the other SB members, and
shall provide all relevant information. The SB, excluding the member
concerned, decides whether a conflict of interest exists.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 80 |
In the case of a conflict of interest, the relevant member of the SB abstains
from discussions and decision-making on the topic or the transaction in
relation to which they have a conflict of interest with ING Group.
Transactions involving actual or potential conflicts of interest
There were no transactions reported in 2025 in which there were conflicts
of interest with SB members that are of material significance to ING Group
and/or to the relevant board members.
If a member of the SB obtains financial products and services, other than
loans, which are provided by ING Group subsidiaries in the ordinary course
of business on terms that apply to employees, this is not considered to be
a material conflicting interest. Banking and financial products in which the
granting of credit is of a secondary nature, e.g. credit cards and overdrafts
in a current account, are not considered a loan for this purpose and are
therefore not disclosed in the ‘Remuneration report’. For an overview of
loans granted to members of the SB, see the ‘Remuneration report’.
Independence
All SB members, with the exception of no more than one person, should
qualify as independent as defined in the best practice provision 2.1.8 of the
Dutch Corporate Governance Code. The members of the SB are therefore
requested to assess annually whether or not they are independent as set
out in the Code and to confirm this in writing. On this basis, the SB confirms
that all members of the SB are to be regarded as independent on 31
December 2025. On this date all members of the SB were also to be
regarded as independent within the meaning of the NYSE listing standards.
Committees of the Supervisory Board
On 31 December 2025, the SB had six committees: the Risk Committee, the
Audit Committee, the Nomination and Corporate Governance Committee,
the Remuneration Committee, the ESG Committee and the Technology &
Operations Committee.
Separate charters have been drawn up for these committees, which are
available on ing.com.
Remuneration and share ownership
Remuneration of the members of the SB is determined by the General
Meeting and does not depend on the results of ING Group. Members of the
SB are permitted to hold shares in the share capital of ING Group for long-
term investment purposes. Details are given in the ‘Remuneration report’.
Transactions by members of the SB in these shares need to comply with
the ING insider regulations, which are available on ing.com.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 81 |
Members of the Supervisory Board
 |  |  |  | |||||||||||||||
Karl Guha (chairperson) Born 1964 Nationality Dutch Term expires 2027 | Mike Rees (vice-chairperson) Born 1956 Nationality British Term expires 2027 | Juan Colombás Born 1962 Nationality Spanish Term expires 2028 | Stuart Graham Born 1967 Nationality British/German Term expires 2029 | |||||||||||||||
Karl was appointed chairperson of the SB at the General Meeting in April 2023. Karl is chairperson of the Nomination and Corporate Governance Committee and a member of the Remuneration Committee, the Risk Committee, the Audit Committee, the ESG Committee and the Technology & Operations Committee. | Mike was appointed a member of the SB at the General Meeting in April 2019. Mike is vice-chairperson of the SB, chairperson of the Risk Committee and a member of the Nomination and Corporate Governance Committee and the Audit Committee. | Juan was appointed a member of the SB at the General Meeting in April 2020. Juan is chairperson of the Technology & Operations Committee and a member of the Risk Committee, the Audit Committee and the ESG Committee. | Stuart was appointed a member of the SB at the General Meeting in April 2025. Stuart is a member of the Risk Committee, the ESG Committee, the Technology & Operations Committee and the Audit Committee. | |||||||||||||||
Former position CEO of Van Lanschot Kempen N.V. Relevant CRD IV position(s) §Chairperson of the SB §Member of the supervisory board of SHV Holdings N.V. §Non-executive board member of Exor N.V. Other ancillary positions §Member of the supervisory board of Rijksmuseum Fonds | Former position Deputy CEO of Standard Chartered Bank PLC Relevant CRD IV position(s) §Vice-chairperson of the SB §Non-executive chairperson of the board of directors of Midlands Mindforge Other ancillary positions §Non-executive chairperson of the board of directors of Mauritius Africa FinTech Hub | Former position Chief operations officer and executive board member of the board of directors of Lloyds Banking Group PLC Relevant CRD IV position(s) §Member of the SB §Non-executive member of the board of directors of Azora Capital S.L., Azora Investment Management S.L. and Azora Gestion SGIIC §Non-executive chairperson of the board of directors of Bluserena Spa Unipersonale Other ancillary positions §Member of the global alumni advisory board of the Institute de Empresa (IE) Business School | Former position Co-founder and CEO of Autonomous Research Relevant CRD IV position(s) §Member of the SB Other ancillary positions §None | |||||||||||||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 82 |
 |  |  |  | |||||||||||||||
Margarete Haase Born 1953 Nationality Austrian Term expires 2027 | Lodewijk Hijmans van den Bergh Born 1963 Nationality Dutch Term expires 2029 | Petri Hofsté Born 1961 Nationality Dutch Term expires 2029 | Herman Hulst Born 1955 Nationality Dutch Term expires 2028 | |||||||||||||||
Margarete was appointed a member of the SB at the General Meeting in May 2017. Margarete is chairperson of the Audit Committee and a member of the Risk Committee and the Remuneration Committee. | Lodewijk was appointed a member of the SB at the General Meeting in April 2021. Lodewijk is chairperson of the ESG Committee and a member of the Risk Committee. | Petri was appointed a member of the SB at the General Meeting in April 2025. Petri is a member of the Risk Committee and the Audit Committee. | Herman was appointed a member of the SB at the General Meeting in April 2020. Herman is a member of the Audit Committee, the Risk Committee and the ESG Committee. | |||||||||||||||
Former position CFO of Deutz AG Relevant CRD IV position(s) §Member of the SB §Chairperson of the supervisory board of ams-OSRAM AG §Member of the supervisory board of Fraport AG Other ancillary positions §Chairperson of the employers association of Kölnmetall §Member of the German Corporate Governance Commission | Former position Partner/member of the management committee of De Brauw Blackstone Westbroek N.V. Relevant CRD IV position(s) §Member of the SB §Member of the supervisory board of HAL Holding N.V. §Member of the supervisory board of Heineken N.V. Other ancillary positions §Chairperson of the executive committee of Vereniging Aegon | Former position Member of the supervisory board of Coöperatieve Rabobank U.A. Relevant CRD IV position(s) §Member of the SB §Member of the supervisory board of Royal Friesland Campina N.V. §Member of the supervisory board of Pon Holdings B.V. Other ancillary positions §Chair of the foundation board of the Nyenrode Foundation §Member of the board of Oranje Fonds §Member of the NBA Stakeholders Forum §Member of the committee of reporting & accountancy (Commissie Verslaggeving & Accountancy) of AFM | Former position Global vice-chairperson EY Japan Relevant CRD IV position(s) §Member of the SB Other ancillary positions §None | |||||||||||||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 83 |
 |  |  | |||||||||||
Harold Naus Born 1969 Nationality Dutch Term expires 2028 | Alexandra Reich Born 1963 Nationality Austrian Term expires 2027 | Herna Verhagen Born 1966 Nationality Dutch Term expires 2027 | |||||||||||
Harold was appointed a member of the SB at the General Meeting in April 2020. Harold is a member of the Remuneration Committee, the Risk Committee and the Technology & Operations Committee. | Alexandra was appointed a member of the SB at the General Meeting in April 2023. Alexandra is a member of the Risk Committee, the Technology & Operations Committee and the ESG Committee. | Herna was appointed a member of the SB at the General Meeting in April 2019. Herna is chairperson of the Remuneration Committee and a member of the Nomination and Corporate Governance Committee and the Risk Committee. | |||||||||||
Former position Global head of Trading Risk Management and general manager Market Risk of ING Bank and CEO of various Cardano entities. Relevant CRD IV position(s) §Member of the SB §Chairman of the advisory board of Cardano Nederland B.V. §Member of the supervisory board and chair of the Audit Committee and the Appointment & Remuneration Committee of N.V. Eneco Other ancillary positions §None | Former position CEO of Telenor Thailand Relevant CRD IV position(s) §Member of the SB §Member of the non-executive board of directors of Cellnex Telecom S.A. §Member of the non-executive board of directors of DELTA Fiber §Non-executive director on the board of the Connecting Europe Broadband Fund Other ancillary positions §None | Former position CEO of PostNL N.V. Relevant CRD IV position(s) §Member of the SB §Member of the supervisory board of Koninklijke Philips N.V. Other ancillary positions §None | |||||||||||
Supervisory Board in numbers | ||||||
 | Board members 11 | |||||
 | Average age 62 | |||||
 | Nationalities 5 | |||||
 | Average board tenure (years) 4 | |||||
 | Female 36% | |||||
 | Independent board members* 100% | |||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 84 |
B. Compensation
Remuneration report
FOR ADVISORY VOTE AT 2026 ING GROEP N.V. ANNUAL GENERAL
MEETING (AGM)
This Remuneration report is based on the
remuneration policies for the Executive Board (EB)
and Supervisory Board (SB). This section of the
report is the Remuneration report as referred to in
the Dutch Act implementing the EU Shareholder
Rights Directive II (SRD II). It will be presented to
shareholders at the 2026 AGM for an advisory
vote. An explanation of how the results of this vote
are taken into account will be included in the 2026
Remuneration report.
This Remuneration report includes, under section 2025 Executive Board
performance and remuneration, further alignment with prescribed tables
from the draft (non-binding) ‘Guidelines on the standardised presentation
of the remuneration report’ from the European Commission. In addition,
we comply with the European Sustainability Reporting Standards (ESRS)
related to the GOV-3 requirements, which are incorporated by reference.
The services of the following external consultants were used with regards
to remuneration: Stibbe, Willis Towers Watson, Aon, Korn Ferry Hay Group,
and PricewaterhouseCoopers. These are independent consultants who, at
the request of ING, provide advice.
2025 AGM
The 2024 Remuneration report was presented for an advisory vote at the
AGM held on 22 April 2025 (2025 AGM). The outcome was an advisory vote
of 95.25 percent in favour, reflecting strong shareholder support for our
remuneration practices. During the 2025 AGM, shareholders raised
questions regarding the integration of climate-related targets and their
linkage to variable remuneration. These targets are embedded in the non-
financial performance metrics, which are used to determine variable
remuneration outcome. In addition, our SB RemCo Chair emphasised the
importance of market-competitive pay to attract and retain high-calibre
talent and noted that a remuneration review would be conducted in 2025,
with stakeholder engagement. This review has been carried out
extensively, including broad stakeholder involvement.
Board changes in 2025
Steven van Rijswijk and Ljiljana Čortan were reappointed as members of the EB
at the 2025 AGM for another four-year term, lasting until the end of the 2029
AGM. On 23 October 2025, it was announced that Ljiljana Čortan would step
down from her role as CRO and succeed Andrew Bester as head of Wholesale
Banking. Ljiljana Čortan will leave her position as CRO on 24 February 2026 but
remain a member of the EB until a successor is appointed. On 24 July 2025, it
was announced that Tanate Phutrakul would step down from his role as CFO
as of the 2026 AGM. In accordance with the Executive Board Remuneration
Policy and with due observance of applicable legal requirements, a severance
payment equal to one year's base salary has been granted and his previous
deferred variable remuneration awards will continue to vest over time
according to the schedule. On 29 October 2025, we announced that Ida Lerner
will be appointed as a member of the Management Board Banking as of 1 April
2026. Subsequently, she will be proposed to be appointed as a member of the
EB and as CFO at the AGM in April 2026. Her remuneration package will be in
line with the current Executive Board Remuneration Policy and the proposed
new Executive Board Remuneration Policy, and is similar to the remuneration
package of the previous CFO. The main elements of Ida Lerner’s contract will be
published on ING’s website.
Shareholders at the 2025 AGM approved the appointment of Petri Hofsté
and Stuart Graham as new members of the SB for a four-year term. In
addition, shareholders approved the reappointment of Margarete Haase
for a two-year term and of Lodewijk Hijmans van den Bergh for another
four-year term on the SB.
Main decisions on the remuneration of the Executive
Board and Supervisory Board for 2026
The following decisions were taken in relation to remuneration for 2026:
§Updates to the Executive Board and Supervisory Board remuneration
policies will be proposed;
§From 1 January 2026, the base salary of the EB members is proposed
to be increased by 5 percent for the CEO, 7 percent for both the CFO
and CRO, see '2026 Executive Board remuneration'. 50 percent of the
increase will be delivered in fixed shares, subject to a five-year
retention period. The proposed increase for the CEO is broadly in line
with the Dutch CLA and wider workforce increases.
§The SB fees will be increased in line with the proposed updated
Supervisory Board Remuneration Policy, subject to a positive binding
vote by the AGM on 14 April 2026, see '2026 Supervisory Board
remuneration'.
1For more, see table '2025 remuneration outcomes' and table 'Breakdown of benefits paid in 2025'.
2This amount is excluding the severance payment granted, see '2025 remuneration outcomes'.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 85 |
2025 Executive Board remuneration at a glance
For more on the EB members' performance and variable remuneration outcomes, see '2025 Executive Board performance and remuneration' 1 2
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 86 |
Alignment of Executive Board remuneration to stakeholder expectations
The table below provides a non-limitative overview of the main stakeholders for EB remuneration.
Stakeholder alignment
 | |||||||||||||||
 Our people |  Shareholders |  Regulators |  Our customers |  Society at large | |||||||||||
§The Executive Board Remuneration Policy is aligned with the remuneration principles that apply to all ING employees. §Salaries for the EB are reviewed in the context of salary developments across ING's wider workforce and benchmark data from ING's core peer group. §EB members' variable remuneration is determined using a multi-step and integrated process, which is closely aligned to the approach used to determine variable remuneration for the wider workforce. §We communicate with our employees through our ongoing engagement with the Works Council in the Netherlands on EB remuneration. In recent years, this stakeholder group has focused on ensuring EB remuneration levels and decisions are acceptable to society at large. | §Remuneration outcomes take into account performance against financial and non-financial targets that are consistent with ING's strategy. §Variable remuneration for EB members is awarded fully into ING Group shares. The shares are deferred. §In recent years, shareholders continuously expressed their concerns about the low variable remuneration and low total remuneration levels of EB members. §Alignment of EB performance targets and variable remuneration serves as an important driver of ING’s strategic priorities and long-term shareholder value creation. | §Variable remuneration outcomes reflect ex-ante and ex-post risk performance. §Variable remuneration pay structures are in accordance with regulatory requirements, including deferral, malus and clawback. | §Through a qualitative survey conducted by a third-party provider, we gathered and listened to customer views on a range of executive compensation topics, which helped inform our Remuneration Policy and decision-making. §Total remuneration is designed with appropriate consideration of the views and interest of customers and clients, ensuring this is represented in the Executive Board Remuneration Policy and decision-making. | §Through a qualitative survey conducted by a third-party provider, we gathered and listened to customer views on a range of executive compensation topics, which helped inform our Remuneration Policy and decision-making. §In recent years, there has been increased interest in the way EB remuneration is linked to environmental and social objectives. §Environmental and social objectives within variable remuneration for the EB reflects ING's wider purpose and strategy. §Variable remuneration includes measures to drive our ambitions to ensure an inclusive workforce. | |||||||||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 87 |
Executive Board remuneration
Executive Board Remuneration Policy
The EB Remuneration Policy presents the remuneration approach
designed to attract, motivate, and retain leaders. Retention is an
important goal since this contributes to long-term performance. In
addition, delivery of both financial and non-financial KPIs, including ESG
performance targets, contributes towards sustainable long-term value
creation for stakeholders.
The current EB Remuneration Policy was approved by shareholders at the
2024 AGM and became effective retroactively from 1 January 2024.
In 2025, ING engaged with its stakeholders in an open dialogue on
proposed changes to the EB and SB remuneration policies, and updates
are being put forward for 2026. These updated EB and SB remuneration
policies will be presented for shareholder approval at the 2026 AGM. For
more information on the updated policies, see the '2026 Executive Board
remuneration'.
The remuneration decisions for the EB are a result of the application of the
remuneration principles as included in the EB Remuneration Policy in
respect of 2025. A summary of the remuneration components under the
current policy for the EB is provided in the table on this page. The full
policy, including arrangements for recruitment and leaver provisions, is
published on ING.com/about-us/corporate-governance/remuneration.
Executive Board Remuneration Policy summary
Remuneration component | Operation | |
Base salary | §Base salary is set to reflect the individual's role, responsibilities, and experience, and to reward ongoing contribution to the role. Base salary is fully paid out in cash. | |
Variable remuneration | §In compliance with regulatory requirements, the maximum annual variable remuneration opportunity is capped at 20 percent of annual base salary. §Variable remuneration is delivered fully in ING Group shares, of which 40 percent upfront and 60 percent is deferred. The deferred portion vests in equal annual tranches over five years. The vested shares have a retention period of five years from date of grant with a minimum of 12 months post vest. §The amount of variable remuneration is based on performance as measured against agreed financial, non-financial and risk objectives. At least 50 percent of variable remuneration metrics must be based on non-financial targets. | |
Benefits | §Benefits are offered if considered appropriate by the SB in the context of the executive’s role, specific individual circumstances and benefits offered to the wider workforce, and for comparable roles in ING’s peer group. | |
Pension | §Participation in ING's general collective defined contribution (CDC) pension plan is aligned with all employees in the Netherlands. As with other Dutch CDC participants earning above the pensionable salary cap, EB members receive a monthly individual savings allowance to compensate for the lack of pension accrual. | |
Delivery of Executive Board variable remuneration
Illustrated below is the pay-out scheme of variable remuneration for EB members.
Variable remuneration is awarded taking into consideration performance over the prior year. | 100% of variable remuneration | ||||||||||
Delivery fully in shares | Upfront shares are awarded and vest on the same date and have a five-year retention period. | 40% | |||||||||
60% | |||||||||||
Deferred shares are awarded on the same date but vest in five tranches. There is a holding period requirement of five years from the award date plus a minimum retention period of 12 months post vesting. | 12% | ||||||||||
12% | |||||||||||
12% | |||||||||||
12% | |||||||||||
12% | |||||||||||
Holdback | Unvested tranches are subject to holdback provision. | ||||||||||
Clawback | Vested tranches remain subject to clawback provision. Clawback provision applies during the maximum limitation period as permitted by applicable law. | ||||||||||
1The benchmark approach used for CFO and CRO functions is aligned to ING's EB Remuneration Policy and our principle to pay the CFO and CRO the same. This approach takes into account observations in the market, where most peer firms outside the financial services industry do not have a comparable CRO
function and the remit of the CRO in other peer firms is materially different from the responsibilities ING's CRO has as a member of the Executive Board. (Benchmark source data: Willis Towers Watson)
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 88 |
Executive Board benchmark approach
ING competes for executive talent in a global marketplace, with many of
our key competitors based outside the Netherlands, predominantly in the
United Kingdom and Continental Europe. In line with the Dutch Banking
Code, we review the actual total direct compensation of EB members
against a peer group of Dutch and international organisations – in both the
financial services and general industry sectors – to ensure it remains
balanced and appropriately competitive. Our peer group includes Dutch
firms and other UK and European banks, recognising our broader
international footprint where we largely compete for talent. Market data
used in benchmarking is based on total direct compensation, which is the
total of fixed and variable remuneration, excluding benefits such as
pension and allowances.
The peer group is based on five guiding principles that reflect ING’s current
profile and is further explained in the Executive Board Remuneration
Policy. These principles are described in the table below:
Guiding principle | Short description |
Size | ING acknowledges the importance of including companies that are broadly comparable in terms of size and complexity. |
Governance framework | ING is subject to the Dutch (financial services) regulatory framework and operates within a Dutch stakeholder environment. |
Geography | ING is a leading European universal bank with a global presence and is headquartered in the Netherlands. |
Talent market | ING is increasingly experiencing a cross-pollination of talent across sectors/industries, not limited to traditional banking competitors. |
Balancing | ING acknowledges the importance of not losing sight of relevant peer companies that do not match on the other criteria. |
The peer group is aligned to ING in terms of size, business profile, and the
changing landscape in the markets in which ING competes for executive
talent (as defined by the peer group guiding principles).
The peer group comprises:
§ABN AMRO §Ahold Delhaize §ASR Nederland §ASML §Banco Santander §BBVA §BNP Paribas §Commerzbank §Crédit Agricole §Deutsche Bank | §Heineken §Intesa Sanpaolo §KBC §Lloyds Banking Group §NatWest §NN Group §Philips §Rabobank §Société Générale §UniCredit |
In line with the requirements laid out in the Dutch Banking Code, the actual
earned total direct compensation of members of the EB under the
Executive Board Remuneration Policy should be below the market median
of the peer group. The calculation of pay positioning of the EB members
against the peer group is performed on this basis (i.e. actual fixed salary
plus actual variable remuneration). The latest available survey data shows
that the current actual total direct compensation earned by ING's EB
members remains well below the market median, even though ING's size,
complexity, and performance place the company between the median
and upper quartile levels of our peers as shown in the chart on the right.
The CEO is positioned 59 percent below the median on total compensation,
the CFO is positioned 37 percent below the median, and the CRO is
positioned 37 percent below the median on total compensation.1
As outlined in the letter from the Chairperson of the Supervisory Board
Remuneration Committee (SB RemCo), the further widening gap between
EB remuneration and that of our peers is the reason the SB concluded that
action is needed and is therefore proposing an updated EB Remuneration
Policy at the 2026 AGM.
The next two visuals show that ING is positioned between the median and
upper quartile based on market capitalisation (size and complexity) and
financial performance (Profit before Tax) relative to our core peer group,
while EB pay is around or below the market lower quartile.
ING's relative size & financial performance vs. peer group (€ bln)
g 1st Quantile g 2nd Quantile g 3rd Quantile g 4th Quantile ING (2025) Median
Source: Refinitiv / Thomson Reuters
1Market Capitalisation is averaged over one year (September 1, 2024 to September 1, 2025).
2Profit before Tax as per last reported financial year (as of 31 December 2024).
EB Actual total direct compensation vs. peer group (€ mln)
g 1st Quantile g 2nd Quantile g 3rd Quantile g 4th Quantile ING (2025) Median
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 89 |
Annual review of the Executive Board remuneration
The SB annually reviews and determines EB members' actual
remuneration, in accordance with the Executive Board Remuneration
Policy and advice from the Remuneration Committee of the SB.
The Remuneration Committee’s responsibilities include preparing and
advising the SB for decisions regarding the individual remuneration of
members of the EB. In performing its tasks, the Remuneration Committee
takes note of the views of individual EB members with regard to the
amount and structure of their own remuneration. Fixed remuneration
proposals for individual EB members are drawn up in accordance with the
Executive Board Remuneration Policy and cover the following aspects:
remuneration structure, external benchmark results based on an annual
review, validation of the EB peer group, the performance criteria used and,
if and when considered appropriate, stakeholder engagement and the pay
ratios within the company and its affiliated enterprises. In performing its
tasks, the Remuneration Committee works with the Risk Committee.
The EB variable remuneration proposals were determined based on a
scenario analysis performed against different performance standards and
payout levels – including threshold, target and maximum – and presented
to the SB for consideration. In conclusion, the proposed variable
remuneration awards for the EB members were considered fair,
appropriate, and in line with legislative requirements of maximum of 20
percent of base salary. The scenario analysis did not identify any issues or
new insights that would warrant further adjustments to the proposed
variable remuneration awards by the SB.
2025 Executive Board performance management and reward
process
The EB performance management and reward process includes a number
of key steps. This process serves as the foundation to determine the
variable remuneration for EB members.
1 | Target-setting before the start of the year | |
2 | Quarterly check-ins during the financial year | |
3 | Mid-year review | |
4 | Year-end review after the end of the financial year | |
5 | Risk assessment after the end of the financial year |
Performance measures and targets
At the start of each performance year, the SB approves performance
measures and targets to ensure alignment with strategic priorities and
support the delivery of ING’s strategy. The target areas cover:
§Financial performance target areas, including profit-based and return-
based targets; and
§Non-financial and risk performance target areas, including customer-
related factors (except the CRO), risk & regulatory matters, strategy,
and environment and social (sustainability) targets.
Each performance target area is weighted and when combined, all
weightings total 100 percent. The CEO is aligned fully to Group
performance, while for the CFO, it is a mix of both Group and functional
performance targets. The non-financial targets for the CRO are
predominantly based on performance targets that are linked to the
function and role.
The applicable non-financial performance targets are based on ING's
strategy, with customers and sustainability as the core pillars. The
performance targets for the EB members reflect ING's priorities for the
financial year, aiming to drive sustainable outcomes, including financial
returns that drive shareholder returns in both the short and longer term. In
addition, non-financial targets, including ESG-related targets, are taken
into account and contribute towards sustainable long-term value creation
for both ING and society. ING's remuneration approach is strongly linked to
a robust and transparent performance-management process, which aims
to reward sustainable performance.
The target areas, targets and weightings are included in the performance
target cards for each EB member (see table '2025 variable remuneration
outcome'). The performance target card consists of both quantitative- and
qualitative-based targets to achieve a balanced and holistic assessment.
The qualitative-based targets are assessed using a standard five-point
rating scale, which is the same as ING's Step Up Performance rating
approach used for the wider workforce. The overall outcome of the
performance target card assessment described above is the starting point
for determining the variable remuneration of the EB members.
Throughout the year, regular conversations take place between the SB and
EB members to review their performance. Progress against performance
measures is formally tracked and discussed at least twice a year in the
mid-year and year-end reviews. The Nomination and Corporate
Governance Committee takes an active role in assessing the performance
of individual EB members and informs both the Risk Committee and the
Remuneration Committee.
At the end of the year, the Risk Committee and Remuneration Committee
provide input and assess the performance of EB members to determine
the variable remuneration to be awarded. They jointly advise the SB on the
recommendations to obtain final approval of the awards.
There is strong alignment and cross-participation between the
Remuneration Committee, Risk Committee, Nomination and Corporate
Governance Committee and ESG Committee to support effective
performance and remuneration decision-making.
Managing risk and conduct (including holdback and clawback)
The integrated performance assessment process for determining variable
remuneration also takes into account financial and operational
performance, risk and compliance, and the behaviour and conduct of each
EB member. This is supported by a robust framework for considering risk
and conduct with potential adjustments to their variable remuneration
awards. This is in line with regulations and the wider workforce. It includes
the following elements:
1A holdback is the forfeiture of up to 100 percent of the awarded and unvested variable remuneration, and a clawback is an arrangement under which staff have to return ownership of up to 100 percent of the paid and/or vested variable remuneration.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 90 |
§Performance hurdles – EB members are only eligible for consideration
of their variable remuneration if both the performance hurdles are met.
This is in line with all employees who are eligible for discretionary
variable remuneration. For more information, see Step 2 of the
'Variable Remuneration Accrual Model'.
§Risk and regulatory adjustments – Performance against risk and
regulatory targets within the core performance target cards are made,
including an assessment of financial risk and non-financial risk targets
measured on an ex-ante basis. The targets and ranges are set at the
beginning of the financial year, taking into account ING’s risk appetite
statement framework. Performance against these risk and regulatory
targets may lead to a downward or upward adjustment in variable
remuneration.
§Additional risk adjustments – Further downward risk adjustments may
also be made to variable remuneration based on broader risk
management performance not within risk appetite, including additional
ex-ante risk performance that needs to be considered and/or ex-post
risk events that may lead to a financial or reputational impact on ING.
Finally, the Risk function assesses individual risk requirements that
apply to identified staff, including EB members, who are considered risk
takers, which can also lead to a downward adjustment in variable
remuneration, also known as a risk modifier. In the most serious of
incidents, additional risk adjustments in the form of holdbacks or
clawbacks1 can also impact individual variable remuneration in line
with regulatory requirements.
The CRO is responsible for recommending any risk adjustments to variable
remuneration awards for the CEO and CFO. The Risk Committee is
responsible for recommending this for the CRO. The SB, based on the
advice of the Remuneration Committee and Risk Committee, decides on
any risk adjustments to variable remuneration (potentially to zero) for EB
members. As a final step in the process, and only in exceptional
circumstances, the SB may exercise its discretion to adjust the variable
remuneration of EB members, either upwards or downwards.
2025 Executive Board performance and remuneration
This section provides more details on the financial and non-financial performance of the EB members in 2025. Key financial and non-financial achievements against the 2025 predefined target areas are summarised in the table for
each of the EB members. The SB has discussed and approved this. The individual performance against non-financial performance targets for each EB member is further summarised in a separate overview per board member in the
following pages.
2025 variable remuneration outcomes | ||||||||||||||
Target – Minimum | Target | Target – Maximum | Performance | Steven van Rijswijk (CEO) | Tanate Phutrakul (CFO) | Ljiljana Čortan (CRO) | ||||||||
Weighting | Assessment | Outcome | Weighting | Assessment | Outcome | Weighting | Assessment | Outcome | ||||||
Financial | Profit before tax | 6,664 | 8,330 | 9,997 | 9,148 | 16.7% | 90% | 15% | 16.7% | 90% | 15% | 8.3% | 90% | 7% |
Return on equity | 9.7% | 12.1% | 14.5% | 13.2% | 16.7% | 89% | 15% | 16.7% | 89% | 15% | 8.3% | 89% | 7% | |
Operational expenses | 13,306 | 12,672 | 12,038 | 12,583 | 16.7% | 83% | 14% | 16.7% | 83% | 14% | 8.3% | 83% | 7% | |
Non-financial | Customer | Performance against non-financial measures are organised around these target areas. Please see the following pages for more details on the non-financial performance of each Executive Board member. | 7.5% | 86% | 6% | 5.0% | 86% | 4% | NA | NA | NA | |||
Risk & Regulatory | 15.0% | 100% | 15% | 17.5% | 100% | 18% | 45.0% | 92% | 41% | |||||
Strategy | 12.5% | 80% | 10% | 12.5% | 100% | 13% | 15.0% | 83% | 13% | |||||
Environment | 10.0% | 95% | 10% | 10.0% | 80% | 8% | 10.0% | 90% | 9% | |||||
Social | 5.0% | 87% | 4% | 5.0% | 80% | 4% | 5.0% | 88% | 4% | |||||
Total | 100% | 89% | 100% | 90% | 100% | 89% | ||||||||
Final 2025 variable remuneration outcomes | 89% | 90% | 89% | |||||||||||
Payout of 20 percent variable remuneration cap (16 percent is at target variable remuneration) | 18% | 18% | 18% | |||||||||||
*Due to rounding, percentages presented in the table may not add up precisely to the total percentages provided.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 91 |
| Steven van Rijswijk CEO | |||||||||||||
Customer |  Risk & Regulatory |  Strategy |  Environment |  Social | ||||||||||
§Increase number of mobile primary customers as this leads to deeper relationships, greater customer satisfaction, and ultimately customers choosing ING for more of their financial needs §Increase customer satisfaction of Retail and Wholesale customers by increasing NPS | §Manage financial risk within risk appetite, with a specific focus on the revision of the use of internal models §Manage non-financial risk within risk appetite with a specific focus on the IT risk management §Maintain operational effectiveness of KYC | §Increase digitisation and straight-through- processing (STP) rate of customer processes | §Increase sustainable volume mobilised §Support the transition of the most carbon- intensive sectors in Wholesale Banking towards a better carbon performance, in line with our 2030 decarbonisation target | §Strengthen organisational health with a focus on five priority areas: –Strategic clarity –Role clarity –Customer orientation –Data-driven decision-making –Talent development §Increase gender balance in ING's leadership cadre | ||||||||||
§In 2025, as part of the mobile-first ambition, the mobile primary customer base increased by over one million to 15.4 million, in line with the target. §In 2025, ING ranked number one in five of our Retail markets on NPS: Australia, Poland, Germany, Romania and Spain, which was slightly below target. ING ranks in the top three in four markets. §In Wholesale Banking the NPS score exceeded target, as it increased to 77, up from 74 in 2024, with clients recognising ING's sector expertise, global reach and local experts. | §Despite the dynamic geopolitical environment credit, financial and non- financial risk were managed well within ING’s risk appetite. §The delivery of credit risk models in 2025 was in line with the defined multi-year plan for redevelopment of credit models. §Solid development of technology resilience capabilities including the delivery of enhancements in measuring and reporting on IT risk. §The bank’s KYC activities maintained a sustainable level of Operational Effectiveness during 2025 with enhanced oversight and challenge from the second line of defence. | §In 2025 the digitalisation of key customer journeys continued in line with target to create the foundation for providing a superior customer experience. This is measured by the percentage of customer journeys that is handled without manual intervention, which went up from 77.2% year-end 2024 to 81.8% year-end 2025. §Through expanded and improved digital services, customer friction was further reduced and self service options increased, including GenAI chatbots. In 2025, the number of inbound contacts to contact centres was further reduced, to an overall decline of 23 percent (versus 2021). §Building on the targeted AI approach in five priority domains – contact centres, Know Your Customer (KYC), hyper- personalisation in marketing, Wholesale Banking Lending, and software engineering – solutions were further scaled and new opportunities explored. | §Increased the WB financing for clients in order to allow them to pursue their sustainability objectives, as reflected in the volume mobilised methodology. In 2025 €166 billion of volumes mobilised was recorded compared to €130 billion in 2024. §In 2025, ING became the first global systemically important bank to receive 1.5°C-aligned science-based target validation from the Science Based Targets initiative (SBTi) in relation to Terra. §ING uses the 'Terra' approach to manage climate-related risks within the most carbon-intensive parts of our lending portfolio ultimately to converge towards net-zero by 2050. The transition of the most carbon-intensive Wholesale Banking sectors was measured using eight sector indicators. Overall, we demonstrated good progress, and two of the most carbon- intensive sectors showed a significant advance. | §In 2025, two OHI surveys were held and from 80 percent of our workforce feedback was received. There is sustained engagement among ING's employees and feedback showed that employees continue to value and appreciate their colleagues, the ability to work hybrid, and the opportunities that support their wellbeing. §Female representation in senior management exceeded expectations with an increase from 32% at the end of 2024 to 35% at the end of 2025 with progress in nearly all domains. | ||||||||||
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| Tanate Phutrakul CFO | |||||||||||||
Customer | Risk & Regulatory | Strategy | Environment | Social | ||||||||||
§Increase number of mobile primary customers as this leads to deeper relationships, greater customer satisfaction, and ultimately customers choosing ING for more of their financial needs §Increase customer satisfaction of Retail and Wholesale customers by increasing NPS | §Manage financial risk within risk appetite with a specific focus on the revision of the use of internal models §Manage non-financial risk within risk appetite with a specific focus on the IT risk management | §Increase efficiency of finance processes while maintaining the effectiveness of controls | §Continuous refinement of CSRD disclosures | §Strengthen organisational health with a focus on five priority areas: –Strategic clarity –Role clarity –Customer orientation –Data-driven decision-making –Talent development §Increase gender balance in ING's leadership cadre | ||||||||||
§In 2025, as part of the mobile-first ambition, the mobile primary customer base increased by over one million to 15.4 million, in line with the target. §In 2025, ING ranked number one in five of our Retail markets: Australia, Poland, Germany, Romania and Spain, which was slightly below target. ING ranks in the top three in four markets. §In Wholesale Banking the NPS score exceeded target, as it increased to 77, up from 74 in 2024, with clients recognising ING's sector expertise, global reach and local experts. | §Despite the dynamic geopolitical environment credit, financial and non- financial risk were managed well within ING’s risk appetite. §The delivery of credit risk models in 2025 was in line with the defined multi-year plan for redevelopment of credit models. §Solid development of technology resilience capabilities including the delivery of enhancements in measuring and reporting on IT risk. | §Increased effectiveness of the financial reporting control environment while facilitating accelerated closing timelines, with continued focus on efficiency across Finance and IT processes. | §Continued improvement of the governance and internal controls supporting the preparation of the 2025 sustainability disclosures, structurally embedding the related control standard in ING’s overall risk governance. §Refined environmental disclosures to enhance readability, reflecting stakeholder feedback on 2024 reporting. | §In 2025, two OHI surveys were held and from 80 percent of our workforce feedback was received. There is sustained engagement among ING's employees and feedback showed that employees continue to value and appreciate their colleagues, the ability to work hybrid, and the opportunities that support their wellbeing. §Female representation in senior management exceeded expectations with an increase from 32% at the end of 2024 to 35% at the end of 2025 with progress in nearly all domains. | ||||||||||
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| Ljiljana Čortan CRO | |||||||||||||
Risk & Regulatory | Strategy | Environment | Social | |||||||||||
§Manage financial risk within risk appetite with a specific focus on the revision of the use of internal models §Manage non-financial risk within risk appetite with a specific focus on the IT risk management §Maintain operational effectiveness of KYC | §Increase efficiency of risk processes while maintaining the effectiveness of controls | §Continuous refinement of ESG risk assessment methodology | §Strengthen organisational health with a focus on five priority areas: –Strategic clarity –Role clarity –Customer orientation –Data-driven decision-making –Talent development §Increase gender balance in ING's leadership cadre | |||||||||||
§Despite the dynamic geopolitical environment credit, financial and non- financial risk were managed well within ING’s risk appetite. §The delivery of credit risk models in 2025 was in line with the defined multi-year plan for redevelopment of credit models. §Solid development of technology resilience capabilities including the delivery of enhancements in measuring and reporting on IT risk. §The bank’s KYC activities maintained a sustainable level of Operational Effectiveness during 2025 with enhanced oversight and challenge from the second line of defence. | §Increased the efficiency of non-financial risk control processes in line with expectation while maintaining the effectiveness. §Strengthened governance to scale AI responsibly by establishing a dedicated central AI Risk Committee to oversee emerging risks in new domains such as voicebots and agentic AI capabilities. §Contributed to the digitalisation of lending processes by delivering on the defined automation milestones in risk processes of the retail and business banking lending journeys beyond target. | §Strengthened ING's climate stress-testing framework to assess the impact of physical and transition risks on corporate and mortgage exposures under multiple climate scenarios, using both short-term and long-term methodologies. §Launched an enhanced ESG risk assessment platform that integrates environmental, social, and governance factors, replacing the previous ESR framework. | §In 2025, two OHI surveys were held and from 80 percent of our workforce feedback was received. There is sustained engagement among ING's employees and feedback showed that employees continue to value and appreciate their colleagues, the ability to work hybrid, and the opportunities that support their wellbeing. §Female representation in senior management exceeded expectations with an increase from 32% at the end of 2024 to 35% at the end of 2025 with progress in nearly all domains. | |||||||||||
1The IRRF consists of the most important regulatory requirements with respect to remuneration, to which all remuneration policies of majority-owned entities have to adhere. Furthermore, it consists of our general remuneration principles that apply to all staff globally working under the responsibility of ING.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 94 |
2025 variable remuneration and total direct compensation
outcomes
In 2025, we continued to deliver strong results and executed consistently
on our strategy to accelerate growth, increase impact and deliver value for
all stakeholders, despite ongoing macroeconomic and geopolitical
uncertainty. Our net result of €6.3 billion, corresponding with a return on
equity of 13.2 percent reflects solid commercial momentum, as we did
more business with more customers. Total income rose to €23 billion,
driven by a 15 percent increase in fee income and substantial growth in
lending and deposits. Operating expenses increased year-on-year in line
with guidance, reflecting continued investment in the business, while risk
costs remained below the through-the-cycle average.
The number of mobile primary customers increased by over one million,
bringing us to 15.4 million out of nearly 41 million total customers. Net
core lending has risen by €56.9 billion, of which 38.6 billion in Retail, mainly
driven by €28.5 billion of mortgage growth and €6.6 billion in Business
Banking, as we remain committed to supporting small and mid-sized
enterprises across our markets. In Wholesale Banking, lending grew by
€18.3 billion following sustained demand in corporate lending and Working
Capital Solutions. In Retail, we maintained our number one NPS position in
five out of 10 retail markets, while in Wholesale Banking, we achieved an
NPS of 77 in 2025, up from 74 in 2024.
Sustainability remains a strategic, business and commercial priority for
ING. Sustainable volume mobilised increased to €166 billion for the full
year, a 28 percent increase from 2024, demonstrating strong progress
towards our long-term ambitions. We continued to support clients in their
sustainability transitions across sectors and geographies, while further
embedding sustainability into our core business activities.
Financial and capital results in 2025 were again well above the
performance hurdles. Following this performance, the SB has conducted a
thorough and balanced assessment. Based on the outcomes of this and
their overall achievements, the SB concluded that the EB members
delivered strong results in 2025.
Furthermore, the SB considered whether any discretionary adjustment
was required, and determined that both the financial and non-financial
results speak for themselves in the current environment. The SB also
considered the behaviour of the EB members and saw no reason to apply
any discretionary adjustments.
In the final step, the SB took into account the feedback from the CRO and
Risk Committee on risk and compliance matters. Here, there was no
reason to apply any individual additional risk adjustments in accordance
with ING's Remuneration Regulations Framework (IRRF)1.
Following this performance assessment process, the resulting variable
remuneration award for Steven van Rijswijk is €341,666; for Tanate
Phutrakul €242,193; and for Ljiljana Čortan €240,006. For the CEO, this
equates to a variable remuneration award at 18 percent out of the
maximum 20 percent cap. For the CFO, it represents 18 percent out of the
maximum 20 percent cap, and for the CRO, it represents 18 percent out of
the maximum 20 percent cap (see table '2025 variable remuneration
outcomes').
Certain components of variable remuneration are not recognised in the
statement of profit or loss directly, but are allocated over the vesting
period of the award. As recognised in the profit or loss statement of 2025,
the expenses for each EB member, relating to their role on the EB, amount
to €2.8 million for the CEO, €3.3 million for the CFO, and €2.1 million for the
CRO. These amounts include deferred elements from previous years, paid
out in 2025.
1ING indemnifies the members of the EB against direct financial losses in connection with claims from third parties filed, or threatened to be filed, against them by virtue of their service as a member of the EB, as far as permitted by law, on the conditions laid down in the Articles of Association and their commission
contract. ING has taken out liability insurance for the members of the EB.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 95 |
The following tables (i.e. total direct compensation, pension costs and benefits) show the remuneration awarded to individual Executive Board members, with respect to the performance years 2025 and 2024.1 All EB remuneration is
paid directly by ING.
2025 remuneration outcomes | ||||||||||
1. Fixed remuneration | 2. Variable remuneration | 3. Extraordinary items | 4. Pension benefits | 5. Total remuneration | 6. Proportion of fixed and variable remuneration | |||||
Amounts in euros (rounded figures) | Base salary | Fees | Other benefits | One-year variable1 | Multi-year variable | |||||
Steven van Rijswijk (CEO) | 2025 | 1,921,200 | — | 534,500 | 341,700 | — | — | 27,700 | 2,825,100 | 87.9% / 12.1% |
2024 | 1,847,300 | — | 507,200 | 311,800 | — | — | 27,900 | 2,694,200 | 88.4% / 11.6% | |
Tanate Phutrakul (CFO) | 2025 | 1,346,800 | — | 377,300 | 242,200 | — | 1,346,800 2 | 27,700 | 3,340,700 | 92.8% / 7.2% |
2024 | 1,270,500 | — | 336,100 | 219,700 | — | — | 27,900 | 1,854,300 | 88.2% / 11.8% | |
Ljiljana Čortan (CRO) | 2025 | 1,346,800 | — | 521,900 | 240,000 | — | — | 27,700 | 2,136,400 | 88.8% / 11.2% |
2024 | 1,270,500 | — | 495,000 | 223,600 | — | — | 27,900 | 2,017,100 | 88.9% / 11.1% | |
1The variable remuneration percentages over 2025 for the EB members are as follows: CEO 18%, CFO 18% and CRO 18%. Thus the ratio between base salary and total direct compensation is as follows: CEO 84.9%, CFO 84.8% and CRO 84.9%.
2In accordance with the Executive Board Remuneration Policy and with due observance of applicable legal requirements, a severance payment equal to one year's base salary has been granted.
Benefits
The individual members of the EB receive benefits. The table below shows the breakdown of all benefits paid in 2025.
Breakdown of benefits paid in 2025 | |||
Amounts in euros (rounded figures) | Steven van Rijswijk (CEO) | Tanate Phutrakul (CFO) | Ljiljana Čortan (CRO) |
Contribution individual savings plans | 67,200 | 47,100 | 47,100 |
Individual savings allowance | 395,800 | 268,300 | 268,300 |
Travel and accident insurance | 16,400 | 16,400 | 16,400 |
Other benefits1 | 55,100 | 45,400 | 190,000 |
Total | 534,500 | 377,300 | 521,900 |
1This includes expatriate allowances (such as housing, school/tuition fees and international health insurances, if applicable); banking and insurance benefits from ING (on the same terms as for other
employees of ING in the Netherlands); tax and financial planning services to ensure compliance with the relevant legislative requirements, and the use of a company car or driver service.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 96 |
Shares
Deferred shares, awarded as part of the variable remuneration, are shares conditionally granted subject to a tiered vesting over a period of five years, with the ultimate value of each deferred share based on ING’s share price on the vesting
date. This is conditional on there being no holdback. The main condition for vesting is that these shares require continued employment through vesting date. The table below details all share-based remuneration for the EB members.
Share-based remuneration for Executive Board members | ||||||||||||||
The main conditions of share award plans | Information regarding the reported financial year | |||||||||||||
Opening balance | During the year | Closing balance | ||||||||||||
1 | 2 | 3 | 4 | 5 | 6A | 6B | 6C | 7 | 8 | 9 | 10 | 11A | 11B | |
Specification of plan1 | Performance period | Granting/ offering date | Vesting date | End of retention period | Shares held at the beginning of the year | Shares subject to retention at the beginning of the year | Shares sold- to-cover2 | Shares granted/ offered | Shares vested | Shares subject to a performance condition | Shares granted/ offered unvested at YE | Shares subject to a retention period | Vested shares sold-to-cover2 | |
Steven van Rijswijk (CEO) | LSPP Upfront Shares | 2019 | 11/05/2020 | 11/05/2020 | 11/05/2025 | - | 4,193 | 3,350 | - | - | - | - | - | - |
LSPP Deferred Shares Idnt | 2019 | 11/05/2020 | 11/05/2021 | 11/05/2025 | - | 1,241 | 1,022 | - | - | - | - | - | - | |
LSPP Deferred Shares Idnt | 2019 | 11/05/2020 | 11/05/2022 | 11/05/2025 | - | 1,224 | 1,039 | - | - | - | - | - | - | |
LSPP Deferred Shares Idnt | 2019 | 11/05/2020 | 11/05/2023 | 11/05/2025 | - | 1,202 | 1,061 | - | - | - | - | - | - | |
LSPP Deferred Shares Idnt | 2019 | 11/05/2020 | 11/05/2024 | 11/05/2025 | - | 1,174 | 1,089 | - | - | - | - | - | - | |
LSPP Deferred Shares Idnt | 2019 | 11/05/2020 | 11/05/2025 | 11/05/2026 | 2,263 | - | - | - | 2,263 | - | - | 1,174 | 1,089 | |
LSPP Upfront Shares | 2021 | 09/05/2022 | 09/05/2022 | 09/05/2027 | - | 5,108 | 4,082 | - | - | - | - | 5,108 | - | |
LSPP Deferred Shares Idnt | 2021 | 09/05/2022 | 11/05/2023 | 09/05/2027 | - | 1,512 | 1,245 | - | - | - | - | 1,512 | - | |
LSPP Deferred Shares Idnt | 2021 | 09/05/2022 | 11/05/2024 | 09/05/2027 | - | 1,491 | 1,266 | - | - | - | - | 1,491 | - | |
LSPP Deferred Shares Idnt | 2021 | 09/05/2022 | 11/05/2025 | 09/05/2027 | 2,757 | - | - | - | 2,757 | - | - | 1,464 | 1,293 | |
LSPP Deferred Shares Idnt | 2021 | 09/05/2022 | 11/05/2026 | 11/05/2027 | 2,757 | - | - | - | - | - | 2,757 | - | - | |
LSPP Deferred Shares Idnt | 2021 | 09/05/2022 | 11/05/2027 | 11/05/2028 | 2,757 | - | - | - | - | - | 2,757 | - | - | |
LSPP Upfront Shares | 2022 | 11/05/2023 | 11/05/2023 | 11/05/2028 | - | 4,846 | 3,872 | - | - | - | - | 4,846 | - | |
LSPP Deferred Shares Idnt | 2022 | 11/05/2023 | 11/05/2024 | 11/05/2028 | - | 1,434 | 1,181 | - | - | - | - | 1,434 | - | |
LSPP Deferred Shares Idnt | 2022 | 11/05/2023 | 11/05/2025 | 11/05/2028 | 2,615 | - | - | - | 2,615 | - | - | 1,415 | 1,200 | |
LSPP Deferred Shares Idnt | 2022 | 11/05/2023 | 11/05/2026 | 11/05/2028 | 2,615 | - | - | - | - | - | 2,615 | - | - | |
LSPP Deferred Shares Idnt | 2022 | 11/05/2023 | 11/05/2027 | 11/05/2028 | 2,615 | - | - | - | - | - | 2,615 | - | - | |
LSPP Deferred Shares Idnt | 2022 | 11/05/2023 | 11/05/2028 | 11/05/2029 | 2,618 | - | - | - | - | - | 2,618 | - | - | |
LSPP Upfront Shares | 2023 | 10/05/2024 | 10/05/2024 | 10/05/2029 | - | 5,415 | 4,327 | - | - | - | - | 5,415 | - | |
LSPP Deferred Shares Idnt | 2023 | 10/05/2024 | 11/05/2025 | 10/05/2029 | 2,922 | - | - | - | 2,922 | - | - | 1,602 | 1,320 | |
LSPP Deferred Shares Idnt | 2023 | 10/05/2024 | 11/05/2026 | 10/05/2029 | 2,922 | - | - | - | - | - | 2,922 | - | - | |
LSPP Deferred Shares Idnt | 2023 | 10/05/2024 | 11/05/2027 | 10/05/2029 | 2,922 | - | - | - | - | - | 2,922 | - | - | |
LSPP Deferred Shares Idnt | 2023 | 10/05/2024 | 11/05/2028 | 11/05/2029 | 2,922 | - | - | - | - | - | 2,922 | - | - | |
LSPP Deferred Shares Idnt | 2023 | 10/05/2024 | 11/05/2029 | 11/05/2030 | 2,925 | - | - | - | - | - | 2,925 | - | - | |
LSPP Upfront Shares | 2024 | 09/05/2025 | 09/05/2025 | 09/05/2030 | - | - | - | 7,965 | 7,965 | - | - | 4,427 | 3,538 | |
LSPP Deferred Shares Idnt | 2024 | 09/05/2025 | 11/05/2026 | 09/05/2030 | - | - | - | 2,389 | - | - | 2,389 | - | - | |
LSPP Deferred Shares Idnt | 2024 | 09/05/2025 | 11/05/2027 | 09/05/2030 | - | - | - | 2,389 | - | - | 2,389 | - | - | |
LSPP Deferred Shares Idnt | 2024 | 09/05/2025 | 11/05/2028 | 09/05/2030 | - | - | - | 2,389 | - | - | 2,389 | - | - | |
LSPP Deferred Shares Idnt | 2024 | 09/05/2025 | 11/05/2029 | 11/05/2030 | - | - | - | 2,389 | - | - | 2,389 | - | - | |
LSPP Deferred Shares Idnt | 2024 | 09/05/2025 | 11/05/2030 | 11/05/2031 | - | - | - | 2,391 | - | - | 2,391 | - | - | |
Total | 35,610 | 28,840 | 23,534 | 19,912 | 18,522 | - | 37,000 | 29,888 | 8,440 | |||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 97 |
Share-based remuneration for Executive Board members – continued | ||||||||||||||
The main conditions of share award plans | Information regarding the reported financial year | |||||||||||||
Opening balance | During the year | Closing balance | ||||||||||||
1 | 2 | 3 | 4 | 5 | 6A | 6B | 6C | 7 | 8 | 9 | 10 | 11A | 11B | |
Specification of plan1 | Performance period | Granting/ offering date | Vesting date | End of retention period | Shares held at the beginning of the year | Shares subject to retention at the beginning of the year | Shares sold- to-cover2 | Shares granted/ offered | Shares vested | Shares subject to a performance condition | Shares granted/ offered and unvested at year-end | Shares subject to a retention period | Vested shares sold-to-cover2 | |
Tanate Phutrakul (CFO) | LSPP Deferred Units Idnt (Equity settled) | 2017 | 27/03/2018 | 27/03/2024 | NULL | - | 200 | 201 | - | - | - | - | - | - |
LSPP Deferred Shares Idnt | 2018 | 27/03/2019 | 27/03/2024 | 27/03/2025 | - | 117 | 110 | - | - | - | - | - | - | |
LSPP Upfront Shares | 2019 | 11/05/2020 | 11/05/2020 | 11/05/2025 | - | 3,934 | 3,144 | - | - | - | - | - | - | |
LSPP Deferred Shares Idnt | 2019 | 11/05/2020 | 11/05/2021 | 11/05/2025 | - | 1,164 | 959 | - | - | - | - | - | - | |
LSPP Deferred Shares Idnt | 2019 | 11/05/2020 | 11/05/2022 | 11/05/2025 | - | 1,148 | 975 | - | - | - | - | - | - | |
LSPP Deferred Shares Idnt | 2019 | 11/05/2020 | 11/05/2023 | 11/05/2025 | - | 1,127 | 996 | - | - | - | - | - | - | |
LSPP Deferred Shares Idnt | 2019 | 11/05/2020 | 11/05/2024 | 11/05/2025 | - | 1,102 | 1,021 | - | - | - | - | - | - | |
LSPP Deferred Shares Idnt | 2019 | 11/05/2020 | 11/05/2025 | 11/05/2026 | 2,124 | - | - | - | 2,124 | - | - | 1,102 | 1,022 | |
LSPP Upfront Shares | 2021 | 09/05/2022 | 09/05/2022 | 09/05/2027 | - | 3,700 | 2,956 | - | - | - | - | 3,700 | - | |
LSPP Deferred Shares Idnt | 2021 | 09/05/2022 | 11/05/2023 | 09/05/2027 | - | 1,095 | 902 | - | - | - | - | 1,095 | - | |
LSPP Deferred Shares Idnt | 2021 | 09/05/2022 | 11/05/2024 | 09/05/2027 | - | 1,080 | 917 | - | - | - | - | 1,080 | - | |
LSPP Deferred Shares Idnt | 2021 | 09/05/2022 | 11/05/2025 | 09/05/2027 | 1,997 | - | - | - | 1,997 | - | - | 1,061 | 936 | |
LSPP Deferred Shares Idnt | 2021 | 09/05/2022 | 11/05/2026 | 11/05/2027 | 1,997 | - | - | - | - | - | 1,997 | - | - | |
LSPP Deferred Shares Idnt | 2021 | 09/05/2022 | 11/05/2027 | 11/05/2028 | 1,997 | - | - | - | - | - | 1,997 | - | - | |
LSPP Upfront Shares | 2022 | 11/05/2023 | 11/05/2023 | 11/05/2028 | - | 3,351 | 2,678 | - | - | - | - | 3,351 | - | |
LSPP Deferred Shares Idnt | 2022 | 11/05/2023 | 11/05/2024 | 11/05/2028 | - | 991 | 817 | - | - | - | - | 991 | - | |
LSPP Deferred Shares Idnt | 2022 | 11/05/2023 | 11/05/2025 | 11/05/2028 | 1,808 | - | - | - | 1,808 | - | - | 978 | 830 | |
LSPP Deferred Shares Idnt | 2022 | 11/05/2023 | 11/05/2026 | 11/05/2028 | 1,808 | - | - | - | - | - | 1,808 | - | - | |
LSPP Deferred Shares Idnt | 2022 | 11/05/2023 | 11/05/2027 | 11/05/2028 | 1,808 | - | - | - | - | - | 1,808 | - | - | |
LSPP Deferred Shares Idnt | 2022 | 11/05/2023 | 11/05/2028 | 11/05/2029 | 1,811 | - | - | - | - | - | 1,811 | - | - | |
LSPP Upfront Shares | 2023 | 10/05/2024 | 10/05/2024 | 10/05/2029 | - | 4,051 | 3,237 | - | - | - | - | 4,051 | - | |
LSPP Deferred Shares Idnt | 2023 | 10/05/2024 | 11/05/2025 | 10/05/2029 | 2,186 | - | - | - | 2,186 | - | - | 1,198 | 988 | |
LSPP Deferred Shares Idnt | 2023 | 10/05/2024 | 11/05/2026 | 10/05/2029 | 2,186 | - | - | - | - | - | 2,186 | - | - | |
LSPP Deferred Shares Idnt | 2023 | 10/05/2024 | 11/05/2027 | 10/05/2029 | 2,186 | - | - | - | - | - | 2,186 | - | - | |
LSPP Deferred Shares Idnt | 2023 | 10/05/2024 | 11/05/2028 | 11/05/2029 | 2,186 | - | - | - | - | - | 2,186 | - | - | |
LSPP Deferred Shares Idnt | 2023 | 10/05/2024 | 11/05/2029 | 11/05/2030 | 2,188 | - | - | - | - | - | 2,188 | - | - | |
LSPP Upfront Shares | 2024 | 09/05/2025 | 09/05/2025 | 09/05/2030 | - | - | - | 5,612 | 5,612 | - | - | 3,119 | 2,493 | |
LSPP Deferred Shares Idnt | 2024 | 09/05/2025 | 11/05/2026 | 09/05/2030 | - | - | - | 1,683 | - | - | 1,683 | - | - | |
LSPP Deferred Shares Idnt | 2024 | 09/05/2025 | 11/05/2027 | 09/05/2030 | - | - | - | 1,683 | - | - | 1,683 | - | - | |
LSPP Deferred Shares Idnt | 2024 | 09/05/2025 | 11/05/2028 | 09/05/2030 | - | - | - | 1,683 | - | - | 1,683 | - | - | |
LSPP Deferred Shares Idnt | 2024 | 09/05/2025 | 11/05/2029 | 11/05/2030 | - | - | - | 1,683 | - | - | 1,683 | - | - | |
LSPP Deferred Shares Idnt | 2024 | 09/05/2025 | 11/05/2030 | 11/05/2031 | - | - | - | 1,686 | - | - | 1,686 | - | - | |
Total | 26,282 | 23,060 | 18,913 | 14,030 | 13,727 | - | 26,585 | 21,726 | 6,269 | |||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 98 |
Share-based remuneration for Executive Board members – continued | ||||||||||||||
The main conditions of share award plans | Information regarding the reported financial year | |||||||||||||
Opening Balance | During the year | Closing balance | ||||||||||||
1 | 2 | 3 | 4 | 5 | 6A | 6B | 6C | 7 | 8 | 9 | 10 | 11A | 11B | |
Specification of plan1 | Performance period | Granting/ offering date | Vesting Date | End of retention period | Shares held at the beginning of the year | Shares subject to retention at the beginning of the year | Shares sold- to-cover2 | Shares granted/ offered | Shares vested | Shares subject to a performance condition | Shares granted/ offered and unvested at year-end | Shares subject to a retention period | Vested shares sold-to-cover2 | |
Ljiljana Čortan (CRO) | LSPP Upfront Shares | 2021 | 09/05/2022 | 09/05/2022 | 09/05/2027 | - | 4,478 | 1,936 | - | - | - | - | 4,478 | - |
LSPP Deferred Shares Idnt | 2021 | 09/05/2022 | 11/05/2023 | 09/05/2027 | - | 1,331 | 593 | - | - | - | - | 1,331 | - | |
LSPP Deferred Shares Idnt | 2021 | 09/05/2022 | 11/05/2024 | 09/05/2027 | - | 1,319 | 605 | - | - | - | - | 1,319 | - | |
LSPP Deferred Shares Idnt | 2021 | 09/05/2022 | 11/05/2025 | 09/05/2027 | 1,924 | - | - | - | 1,924 | - | - | 1,302 | 622 | |
LSPP Deferred Shares Idnt | 2021 | 09/05/2022 | 11/05/2026 | 11/05/2027 | 1,924 | - | - | - | - | - | 1,924 | - | - | |
LSPP Deferred Shares Idnt | 2021 | 09/05/2022 | 11/05/2027 | 11/05/2028 | 1,925 | - | - | - | - | - | 1,925 | - | - | |
LSPP Upfront Shares | 2022 | 11/05/2023 | 11/05/2023 | 11/05/2028 | - | 4,419 | 1,911 | - | - | - | - | 4,419 | - | |
LSPP Deferred Shares Idnt | 2022 | 11/05/2023 | 11/05/2024 | 11/05/2028 | - | 1,313 | 586 | - | - | - | - | 1,313 | - | |
LSPP Deferred Shares Idnt | 2022 | 11/05/2023 | 11/05/2025 | 11/05/2028 | 1,899 | - | - | - | 1,899 | - | - | 1,301 | 598 | |
LSPP Deferred Shares Idnt | 2022 | 11/05/2023 | 11/05/2026 | 11/05/2028 | 1,899 | - | - | - | - | - | 1,899 | - | - | |
LSPP Deferred Shares Idnt | 2022 | 11/05/2023 | 11/05/2027 | 11/05/2028 | 1,899 | - | - | - | - | - | 1,899 | - | - | |
LSPP Deferred Shares Idnt | 2022 | 11/05/2023 | 11/05/2028 | 11/05/2029 | 1,899 | - | - | - | - | - | 1,899 | - | - | |
LSPP Upfront Shares | 2023 | 10/05/2024 | 10/05/2024 | 10/05/2029 | - | 4,724 | 2,042 | - | - | - | - | 4,724 | - | |
LSPP Deferred Shares Idnt | 2023 | 10/05/2024 | 11/05/2025 | 10/05/2029 | 2,029 | - | - | - | 2,029 | - | - | 1,403 | 626 | |
LSPP Deferred Shares Idnt | 2023 | 10/05/2024 | 11/05/2026 | 10/05/2029 | 2,029 | - | - | - | - | - | 2,029 | - | - | |
LSPP Deferred Shares Idnt | 2023 | 10/05/2024 | 11/05/2027 | 10/05/2029 | 2,029 | - | - | - | - | - | 2,029 | - | - | |
LSPP Deferred Shares Idnt | 2023 | 10/05/2024 | 11/05/2028 | 11/05/2029 | 2,029 | - | - | - | - | - | 2,029 | - | - | |
LSPP Deferred Shares Idnt | 2023 | 10/05/2024 | 11/05/2029 | 11/05/2030 | 2,033 | - | - | - | - | - | 2,033 | - | - | |
LSPP Upfront Shares | 2024 | 09/05/2025 | 09/05/2025 | 09/05/2030 | - | - | - | 5,713 | 5,713 | - | - | 3,989 | 1,724 | |
LSPP Deferred Shares Idnt | 2024 | 09/05/2025 | 11/05/2026 | 09/05/2030 | - | - | - | 1,713 | - | - | 1,713 | - | - | |
LSPP Deferred Shares Idnt | 2024 | 09/05/2025 | 11/05/2027 | 09/05/2030 | - | - | - | 1,713 | - | - | 1,713 | - | - | |
LSPP Deferred Shares Idnt | 2024 | 09/05/2025 | 11/05/2028 | 09/05/2030 | - | - | - | 1,713 | - | - | 1,713 | - | - | |
LSPP Deferred Shares Idnt | 2024 | 09/05/2025 | 11/05/2029 | 11/05/2030 | - | - | - | 1,713 | - | - | 1,713 | - | - | |
LSPP Deferred Shares Idnt | 2024 | 09/05/2025 | 11/05/2030 | 11/05/2030 | - | - | - | 1,717 | - | - | 1,717 | - | - | |
Total | 23,518 | 17,584 | 7,673 | 14,282 | 11,565 | - | 26,235 | 25,579 | 3,570 | |||||
1All Executive Board members participate in the ING Group Long-term Sustainable Performance Plan (LSPP) and receive their shares under its plan rules.
2These refer to the number of shares sold at the vesting date to cover the estimated tax liabilities on the vested awards.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 99 |
Loans and advances to Executive Board members
EB members may obtain banking and insurance services from ING Group
and its subsidiaries in the ordinary course of their business and on terms
that are customary in the sector. The EB members do not receive
privileged financial services. On 31 December 2025, there were no loans or
advances outstanding to the EB members.
ING shares held by Executive Board members
EB members are encouraged to hold ING shares as a long-term investment
to maintain alignment with ING. The table below shows an overview of the
shares held by members of the EB on 31 December 2025 and 2024.
ING shares held by Executive Board members | ||
Numbers of shares | 2025 | 2024 |
Steven van Rijswijk (CEO) | 111,990 | 101,908 |
Tanate Phutrakul (CFO) | 40,618 | 33,160 |
Ljiljana Čortan (CRO) | 25,579 | 17,584 |
Internal ratio
In line with the Dutch Corporate Governance Code, ING calculates the
internal ratio of the remuneration for the CEO compared to the average
remuneration of all ING staff. Using the CEO's total remuneration (i.e., the
total of fixed and variable remuneration, including benefits such as
pension and allowances) compared to the average remuneration for all
ING staff, the ratio in 2025 was 1:24. The ratio is the same as disclosed last
year. It declined initially and has since remained unchanged for the past
three years, mainly because the CEO’s average remuneration has
increased in line with the average remuneration increases of ING staff.
CEO pay ratio
ING is also required to disclose the annual total remuneration ratio based
on the European Sustainability Reporting Standards (ESRS), which deviates
from the internal ratio.
Furthermore, we calculated the average ratio of total remuneration for the
CFO and CRO compared to all ING staff. On that basis, the average ratio in
2025 for the CFO and CRO was 1:18, which is comparable to that of 2024.
Remuneration versus company performance and average
employee remuneration
The table on the next page shows the development of directors’
remuneration (EB and SB members), company performance, and the
average remuneration of an ING employee. This is carried out by showing
the development of the remuneration for EB and SB members over the
past five years presented in percentages. This table comes from the draft
(non-binding) 'Guidelines on the standardised presentation of the
remuneration report' from the European Commission.
To maintain the Supervisory Board's independent role, its remuneration is
not linked to company performance metrics.
The relative performance of the company is presented on three different
metrics over the past five years. The metrics consist of:
§Mobile primary customer;
§Profit before tax for ING Group; and
§Return on equity based on IFRS-EU equity.
Finally, we present the development of the remuneration on average (per
employee). For this number, we use the same data as for the internal ratio.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 100 |
Development of directors’ remuneration, company performance and employee remuneration ¹ | |||||||||||
Amount in thousands of euros unless otherwise stated | FY 2025 | FY 2025 vs FY 2024 | FY 2024 vs FY 2023 | FY 2023 vs FY 2022 | FY 2022 vs FY 2021 | FY 2021 vs FY 2020 | |||||
Directors' remuneration (Executive Board) 2, 3, 4, 5 | |||||||||||
Steven van Rijswijk (CEO) | 2,263 | 104 | 4.8% | 83 | 4.0% | 23 | 1.1% | -24 | -1.2% | 578 | 38.6% |
Tanate Phutrakul (CFO) | 1,589 | 99 | 6.6% | 44 | 3.0% | 33 | 2.3% | -27 | -1.9% | 218 | 17.9% |
Ljiljana Čortan (CRO) | 1,587 | 93 | 6.2% | 64 | 4.5% | 7 | 0.5% | - | - | - | - |
Directors' remuneration (Supervisory Board) 6 | |||||||||||
Karl Guha (chairperson) | 222 | 16 | 7.6% | - | - | - | - | - | - | - | - |
Mike Rees (vice-chairperson) | 170 | 12 | 7.8% | 7 | 4.6% | 12 | 8.8% | 10 | 7.8% | 0 | 0% |
Juan Colombás | 154 | 13 | 8.9% | 18 | 14.7% | 21 | 20.4% | 8 | 8.5% | - | - |
Stuart Graham | 86 | - | - | - | - | - | - | - | - | - | - |
Margarete Haase | 147 | 19 | 14.6% | 11 | 9.3% | 6 | 4.9% | 8 | 7.7% | -1 | -1.0% |
Lodewijk Hijmans van den Bergh | 117 | 6 | 5.2% | 4 | 3.4% | 11 | 10.8% | - | - | - | - |
Petri Hofsté | 46 | - | - | - | - | - | - | - | - | - | - |
Herman Hulst | 117 | 6 | 5.2% | 4 | 3.4% | 8 | 7.5% | 5 | 5.0% | - | - |
Harold Naus | 117 | 11 | 10.2% | 8 | 8.7% | 6 | 6.0% | -3 | -2.9% | - | - |
Alexandra Reich | 132 | 14 | 11.4% | - | - | - | - | - | - | - | - |
Herna Verhagen | 128 | 17 | 15.1% | 4 | 3.4% | 6 | 5.4% | 2 | 2.0% | -21 | -17.4% |
Company’s performance | |||||||||||
Mobile primary customer (in mln) 7 | 15.4 | - | - | - | - | - | - | - | - | - | - |
Profit before tax ING Group (in mln) | 9,148 | -152 | -2% | -1,192 | -11% | 4,990 | 91% | -1,280 | -19% | 2,973 | 78% |
Return on equity based on IFRS-EU equity | 13.2% | 0.2% | 1.5% | -1.8% | -12% | 7.6% | 106% | -2% | -22% | 4.4% | 92% |
Average employee remuneration | |||||||||||
Average fixed and annual variable remuneration | 85 | 3.9 | 4.8% | 3.8 | 4.9% | 4.8 | 6.5% | 2.4 | 3.5% | 2.7 | 4.0% |
1For consistency reasons, this table only makes a comparison between two full financial years, in which the respective EB or SB member served in their role as board member.
2The remuneration of the EB consists of base salary and variable remuneration (total direct compensation).
3Variable remuneration for the EB is included in the year in which the performance was delivered i.e. prior to the year in which it is paid out.
4Fixed remuneration for EB members is not linked to company performance but is predominantly based on a benchmark exercise. Total direct compensation of EB members should stay below the median of the benchmark, in line with the Dutch Banking Code. This has a mitigating effect on the correlation with
company performance.
5The relative total compensation increase from 2020 to 2021 is mainly caused by the fact that no variable remuneration was awarded for the performance year 2020.
6There is no relation between SB remuneration and company performance. SB members do not receive any variable remuneration. This remuneration is based on fixed fees related to their role and number of meetings. The high fluctuations are caused by the role changes during the year and differences in the
number of meetings.
7In 2025, ING moved from the metric primary customers to mobile primary customers.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 101 |
Proposed updates to Executive Board Remuneration
Policy
In 2025 we conducted an extensive review of our Executive Board
Remuneration Policy and the remuneration level of our EB. Over the past
years, ING was successful, based on our strong brand, digital DNA,
entrepreneurial culture, good employee engagement and strong results.
That makes us attractive as an employer, but it is imperative we continue
to remain so. Our review showed that the EB compensation is well below
the market level and that the gap has widened in recent years. These
factors reinforce the need to act now, applying a balanced approach to
ensure long-term competitiveness and success in retaining and
attracting talent.
Remuneration is an important and sensitive topic, and viewpoints on the
topic vary for different stakeholder groups. For this reason, in 2025 and
2026 as part of the renewal process of the Remuneration Policy, the
Supervisory Board conducted a comprehensive stakeholder engagement
process with shareholders, regulators, customers, employees (via the
Central Works Council), and wider society to take their views into
account. This resulted in valuable feedback on the proposals, which were
broadly supported.
ING’s goal is to position the total direct compensation of the EB slightly
below the market median of the peer group, using a progressive, step-by-
step approach as further explained in the proposed new Remuneration
Policy for the EB. As part of this approach, the Supervisory Board aims to
increase the CEO's base salary by 5-7 percent per year and the CFO's and
CRO's base salaries by 7-9 percent per year. If any of the Executive Board
positions reaches just below median, the increase will cease and again be
reviewed the following year. For the avoidance of doubt: any increases to
the annual base salary remain at the full discretion of the SB and are
therefore not guaranteed. In making such decisions, the SB will consider
all relevant circumstances, including performance, market developments,
internal pay ratios and salary increase for other employees within ING
(including Dutch CLA and wider workforce increases), stakeholder views,
and the other factors that are considered when determining base salaries.
The proposed new Remuneration Policy for the Executive Board also
includes a fixed shares plan for its members. To strengthen alignment with
long-term shareholder experience, at least 50 percent of any annual base
salary increase for the EB will be delivered as fixed share salary, to be used
to acquire ING Groep N.V. ordinary shares (fixed shares). These fixed shares
will be acquired quarterly in arrears and will be subject to a five-year
holding period.
For more information on the proposed new Executive Board Remuneration
Policy, please refer to the letter of the Chairperson of the SB RemCo. The
full proposed updated Executive Board Remuneration Policy is available on
ing.com/about-us/corporate-governance/remuneration.
2026 Executive Board remuneration
For 2026, the SB considers it appropriate to increase the CEO’s base salary
by 5 percent, and the CFO's and CRO's base salaries each by 7 percent. The
proposed increase for the CEO is broadly in line with the Dutch CLA and
wider workforce increases. These adjustments represent a step in reducing
the gap with the market median, while still remaining well below median
levels after the 2026 adjustments and continuing to follow our policy aim
of positioning total direct remuneration just below the median over time.
Delivering 50 percent of the increase in fixed shares, subject to a five-year
retention period, further strengthens alignment with long-term
shareholder interests.
2026 annual variable remuneration performance measures
Performance measures with appropriately stretching targets have been
selected to cover a range of financial, non-financial, and risk objectives
that support ING's key strategic priorities. The performance measures and
weightings for the 2026 annual variable remuneration are presented on
the next page.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 102 |
For 2026, the table below outlines the target areas and their respective percentage weightings for EB members, as well as the corresponding stakeholder groups:
2026 Target areas | CEO | CFO | CRO | Alignment stakeholder groups | |
Weighting | Weighting | Weighting | |||
Financial | |||||
Profit before tax | 16.7% | 16.7% | 8.3% |  | |
Return on tangible equity | 16.7% | 16.7% | 8.3% | | |
Operational expenses | 16.7% | 16.7% | 8.3% | | |
50% | 50% | 25% | |||
Non-financial | |||||
Customer | §Increase number of mobile primary customers as this leads to deeper relationships, greater customer satisfaction, and ultimately customers choosing ING for more of their financial needs1 §Increase customer satisfaction of Retail and Wholesale by increasing NPS2 | 7.5% | 5% | NA |  |
Risk & Regulatory | §Manage financial risk within risk appetite §Manage non-financial risk within risk appetite §Delivery on regulatory programmes including risk data and reporting enhancements | 15% | 17.5% | 45% |  |
Strategy | §Increase digitisation and straight-through-processing (STP) rate of customer processes §Accelerating the responsible and effective use of artificial intelligence to unlock new opportunities and efficiencies | 12.5% |  | ||
§Harden the internal and external reporting processes | 12.5% | ||||
§Increase efficiency of risk processes while maintaining the effectiveness of controls §Accelerate AI use in risk practices in a responsible and effective way | 15% | ||||
Environment | §Increase WB financing for clients to allow them to pursue their sustainability objectives (as reflected in sustainable volume mobilised)3 §Managing and mitigating transition risk exposure relating to WB clients in the most carbon-intensive sectors4 | 10% |  | ||
§Further enhancement of ESG disclosures in line with applicable reporting requirements | 10% | ||||
§Continuous refinement of ESG risk assessment methodology5 | 10% | ||||
Social | §Strengthen organisational health with a focus on five priority areas: strategic clarity, role clarity, customer orientation, data-driven decision making, talent development §Increase ING’s attractiveness as an employer as reflected in the gender balance in ING's leadership cadre6 | 5% | 5% | 5% | |
50% | 50% | 75% | |||
Total | 100% | 100% | 100% | ||
| | | | | ||||||
Legend | Our people | Shareholders | Regulators | Our customers | Society at large | |||||
1The number of mobile primary customers means the number of customers who are primary customers with at least one mobile interaction through our app or mobile website per quarter (2025: 15.4 million; 2024: 14.4 million).
2NPS means net promoter score and indicates whether customers would recommend ING to others. See 'Our NPS performance' for more information.
3For more information on the detailed methodology, see ing.com (2025: €166 billion; 2024: €130 billion).
4Transition risk exposure is evaluated by reference to the Terra approach.
5ESG risk-assessment methodology refers to designing and integrating the Prudential Transition Plan in line with EBA ESG Risk Guidelines.
6Gender balance is measured as the percentage of female representation in senior management positions. The evaluation of gender balance for the purposes of determining whether this non-financial target has been satisfied should exclude any employees located in jurisdictions where gender-based targets may
be subject to any restrictions or other considerations under applicable law or regulation.
1SB members are not eligible for retirement benefits nor any other benefits in relation to their position on the SB.
2Stuart Graham was appointed to the SB by the AGM on 22 April 2025 with effect from 1 July 2025. The remuneration figures for 2025 reflect a partial year as a member of the SB.
3 Petri Hofsté was appointed to the SB by the AGM on 22 April 2025 with effect from 1 July 2025. The remuneration figures for 2025 reflect a partial year as a member of the SB.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 103 |
Supervisory Board remuneration
Our Supervisory Board Remuneration Policy was approved by shareholders at
the 2024 AGM and became effective retroactively from 1 January 2024 until
the 2028 AGM at the latest. The full policy, including contract information and
governance, can be found on ING.com/remuneration. The Supervisory Board
Remuneration Policy aims to enable ING to attract qualified SB members with
the ability, experience, skills, values, and behaviours to deliver on ING's
strategy, long-term interests, and sustainability.
Supervisory Board Remuneration Policy summary
The SB remuneration structure is outlined in the Supervisory Board
Remuneration Policy. The remuneration components and operation of the
Supervisory Board Remuneration Policy are set out below.
Remuneration component | Operation |
Annual remuneration, committee fees and attendance fees | §SB members receive fees for their service on the SB as set out in the remuneration structure table below. The remuneration is awarded to the SB members by the General Meeting.1 §The remuneration structure reflects the roles and responsibilities of individual SB members. §All fees are paid out fully in cash. No variable remuneration is provided (and therefore none is disclosed) to ensure that the SB members can maintain independence and provide objective stewardship of ING, thereby contributing to the long- term performance of the company. §Any changes in the fee levels will be presented in ING’s Annual Report for the relevant year.1,2 |
Expenses | §SB members are reimbursed for their travel and business-related expenses incurred in their capacity as SB members. |
Annually the total fees of SB members are reviewed against comparable
positions in the market. For this benchmarking process, the SB uses the
same peer group as is used for the EB, see 'Executive Board benchmark
approach'.
In accordance with the Articles of Association, ING indemnifies the
members of the SB as far as legally permitted, against direct financial
losses in connection with claims from third-parties filed, or threatened to
be filed against them by virtue of their services as a member of the SB.
2025 Supervisory Board remuneration
The following visual shows the remuneration, including attendance fees,
for each SB member. All fees for the SB are paid directly by ING. For total
costs for the SB, see Note 45 'Related parties'.3
Loans and advances to Supervisory Board members
SB members may obtain banking and insurance services from ING and its
subsidiaries in the ordinary course of their business and on terms that are
customary in the sector. The SB members do not receive privileged
financial services. On 31 December 2025, there were no loans or advances
outstanding to SB members.
ING shares held by Supervisory Board members
SB members are permitted to hold ING shares as a long-term investment.
The table below shows the holdings by members of the SB on 31
December 2025 and 2024.
ING shares held by Supervisory Board members | ||
Numbers of shares | 2025 | 2024 |
Stuart Graham | 4,100 | - |
Herman Hulst | 3,650 | 3,650 |
Harold Naus | 1,645 | 1,645 |
1 Included are all countries within the Eurozone where ING operates the full scope of banking services.
2 For display and administrative purposes, the increased/index-linked figures are rounded down to nearest hundred.
3 The Supervisory Board may appoint ad hoc committees to provide flexibility in its supervisory tasks, allowing for efficient handling of certain matters such as complex projects and decisions or strategic planning.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 104 |
Proposed updates to Supervisory Board
Remuneration Policy
In 2025 we undertook an extensive review of our Supervisory Board
Remuneration Policy and the remuneration level of our Supervisory Board.
Our review showed that roles have changed, and required time
commitment and regulatory complexity have increased. At the same
time, the compensation of our Supervisory Board is well below market
levels and the gap has widened in recent years. These factors reinforce the
need to act now, taking a balanced approach to ensure long-term
competitiveness and success in retaining and attracting talent.
Remuneration is an important and sensitive topic, and viewpoints on the
topic vary for different stakeholder groups. For this reason, in 2025 and
2026 as part of the renewal process of the Remuneration Policy, the
Supervisory Board conducted a comprehensive stakeholder engagement
process with shareholders, regulators, customers, employees (via the
Central Works Council), and wider society to take their views into account.
This resulted in valuable feedback on the proposals, which were broadly
supported.
ING proposed to take a progressive, step-by-step approach by moving the
Supervisory Board fees closer to the market median over the lifetime of
the proposed new Supervisory Board Remuneration Policy. This includes
increasing the annual retainer fees of the Supervisory Board annually by 9
percent. In addition, the Supervisory Board committee fees will be
increased annually by €10,000 for the Chairpersons of the Risk and Audit
Committees, €7,500 for all other Committee Chairpersons, and €3,000 for
Committee members.
ING will continue with the annual process of performing a benchmark
review. For the duration of the policy the above-mentioned annual
increases will continue to apply, unless the annual benchmark review
demonstrates that applying this increase would result in the fees for a
specific role exceeding the threshold of 3 percent below market median of
comparable positions in the peer group. In such a case, the increase for
that specific role for the relevant year will be limited to the exact
percentage required to achieve a fee that is 3 percent below the market
median. Once a fee for a specific role has reached a position that is 3
percent below the market median, the fee will be indexed annually based
on the salary increases for the wider workforce within ING (or lower) for
that relevant year, provided that such an indexation does not result in the
fee exceeding the threshold of 3 percent below the market median.
ING furthermore proposes to introduce a travel allowance for the
Supervisory Board. In certain circumstances they are required to travel
outside country or continent of residence for additional meetings with
external parties that go beyond and cannot be combined with scheduled
board meetings. The travel allowance compensates for the time and effort
associated with these additional activities. The amounts will be the same
as the attendance fees and reflect the additional time spent.
2026 Supervisory Board remuneration
For 2026, Supervisory Board annual retainer and committee fees will be
increased in line with the proposed new Supervisory Board Remuneration
Policy. The attendance fees will be increased by 4.3 percent in line with the
annual indexation percentage increase of the wider workforce.1 These
changes are subject to adoption at the 2026 Annual General Meeting of
the updated Supervisory Board Remuneration Policy and would take effect
retroactively from 1 January 2026.
These adjustments represent the first step in a gradual process to reduce
the gap with the market median, while remaining well below median levels
after the 2026 adjustments and continuing to follow our policy aim of
positioning just below median over time.
This results in the following amounts:
Supervisory Board remuneration | ||
Amounts in euros2 | 2025 | 2026 |
Annual remuneration | ||
Chairperson SB | 138,500 | 150,900 |
Vice-chairperson SB | 105,300 | 114,700 |
SB Member | 77,500 | 84,400 |
Committee/Ad hoc Committee fees (annual amounts) 3 | ||
Audit & Risk Committee chairperson | 22,000 | 32,000 |
Other Committee chairperson | 22,000 | 29,500 |
Committee Member | 11,000 | 14,000 |
Attendance fees (per meeting) | ||
Attendance fee outside country of residence | 2,100 | 2,100 |
Attendance fee outside continent of residence | 7,800 | 8,100 |
Travel allowance (per meeting) | ||
Travel allowance outside country of residence | - | 2,100 |
Travel allowance outside continent of residence | - | 8,100 |
1 For 2025, it was applied to 49 staff members worldwide. This mandate is used on an exceptional basis by ING and in 2022, 2023 and 2024 also applied to a limited number of employees worldwide.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 105 |
FOR INFORMATION ONLY AT 2026 ING GROEP N.V. ANNUAL GENERAL MEETING (AGM)
Group variable remuneration outcomes
In determining the 2025 Group discretionary variable remuneration pool,
the SB considered:
§the Group's financial and non-financial performance in 2025;
§the performance of business lines within the Group and their
contributions to our strategic targets; and
§the Group's capital position and current and future risks.
The award of discretionary variable remuneration is based on a
transparent, structured, and robust mechanism for measuring
performance and applying risk adjustments (the Variable Remuneration
Accrual Model or VRAM). The VRAM construct follows a five-step process –
as shown in the graphic to the right – to determine Group and business
line risk-adjusted variable remuneration pools.
Based on this, the SB approved a Group discretionary VR pool for 2025
performance of €477.3 million (2024: €421.6 million), representing an
increase of 7.7 percent compared to the target baseline ('starting point')
and 13.2 percent compared to the final VR pool for 2024. Risk and conduct
adjustments to the 2025 VR pool are slightly higher than those applied
in 2024.
Collective variable remuneration is determined by collective labour
agreements, which are shaped by regulations, laws and/or workers council
agreements across various countries. In recent years the total amount of
collective variable remuneration has remained relatively stable and typically
accounts for around 20 percent of the total spend on variable remuneration.
Overall, the total actual amount of both discretionary and collective
variable remuneration awarded to all eligible employees globally for 2025
was €576.1 million (€98.8 million in collective variable remuneration),
compared to the total staff expenses of €7,600 million. For 2024, the total
amount was €522.7 million (€101.1 million in collective variable
remuneration) on €7,184 million staff expenses.
In 2025, 26 employees, excluding members of the Management Board
Banking, were awarded total annual remuneration (including employer
pension contributions and excluding severance payments made) of €1
million or more. For more information on our CRR disclosure (including a
breakdown by each group of employees), see the section ‘Annual reports’
on ing.com.
At the 2021 AGM, shareholders approved an increased maximum
percentage of 100 percent up to 200 percent for employees outside the
EEA, applicable for five performance years through to the end of 2026, in
line with the Dutch Wbfo1. At the 2026 AGM, we will ask for a new
mandate to apply an increased maximum percentage of up to 200
percent for employees outside the EEA for a further period of five
performance years, from 2027 until 2031.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 106 |
Variable Remuneration Accrual Model
Step 1 | u | Step 2 | u | Step 3 | u | Step 4 | u | Step 5 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
Set-up of target Group VR pool | Conditions to qualify for a VR award or reduce pools potentially to zero Meeting basic prudential & performance risk conditions | Performance measures Assessing performance | Set-up final Group and business line VR pool: CEO discretion | Additional risk adjustment Applying additional ex-ante and ex-post risk adjustment (material risk events and individual risk modifiers) | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
Financial performance | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
Individual targets | Return on equity | Common equity tier 1 (SREP) | Profit before tax | Return on equity | Operating expenses | Business line quantitative | Additional performance factors | Step 5i Additional ex-ante and ex-post risk adjustments | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
q | Non-financial & risk performance | q | q | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
Target Group VR pool | Customer | Risk & Regulatory | Strategy | CEO discretion | Step 5ii Employee significant incidents and ex-post risk adjustments | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
q | q | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
Environment | Social | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
Final Group VR pool | Business line VR pool | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
Final Group VR pool | Business line VR pool | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
Step 1 | Step 2 | Step 3 | Step 4 | Step 5 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
Target VR pool is a sum of individual VR targets which are set in reference to market pay levels. | ROE and CET1 hurdles, as qualifiers, are requirements that both need to be met before the VR pools can be unlocked. | Performance scorecards are based on assessments against financial, non-financial and risk measures, and the pool may increase or decrease depending on financial and non-financial results. | Group CEO reviews the VR pools and, where appropriate, makes a discretionary recommendation to adjust upwards or downwards the VR pools based on performance parameters. | Final and independent risk assessment where the Group CRO can recommend to adjust upwards or downwards the VR pools based on any exceptional risk performance at a Group, business line, entity or team level. Furthermore, the Group CRO also recommends risk modifiers to individual variable awards where risk requirements are below expectations applicable only to IDS Risk Takers* as well as holdback (i.e. forfeiture of up to 100 percent of the unvested variable remuneration awards) and/or clawback sanctions (i.e. repayment of up to 100 percent of the paid or vested variable remuneration) for employee significant incidents. | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
* Identified staff reporting hierarchically to a business line and not working in a control function. | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 107 |
C.Board practices
For information regarding board practices, see Item 6.A.
Severance payments to members of the Executive Board
The contracts entered into with the members of the EB provide for severance payments that become due upon
termination of the applicable member’s contract, including if termination occurs in connection with a public bid as
defined in section 5:70 of the Dutch Financial Supervision Act. Severance payments to the members of the
Executive Board are limited to a maximum of one year’s fixed salary.
Transactions between ING Group and significant shareholders
ING Group did not enter into any transactions with shareholders holding at least 10 percent of the share capital.
D. Employees
The average number of internal employees at a full time equivalent basis was 62,770 in 2025, of which 15,280 or
24%, were employed in the Netherlands. Substantially all of the Group’s Dutch employees are subject to a
collective labor agreement covering ING in the Netherlands.
The distribution of employees with respect to the Group’s continuing operations for the years 2025, 2024 and 2023
were as follows:
Number of employees | |||||||||
Netherlands | Rest of the world | Total | |||||||
2025 | 2024 | 2023 | 2025 | 2024 | 2023 | 2025 | 2024 | 2023 | |
Total average number of internal employees at full time equivalent basis | 15,280 | 14,821 | 14,449 | 47,490 | 46,301 | 44,985 | 62,770 | 61,121 | 59,434 |
The Group employs a number of temporary employees. The average number of temporary employees, not
included in the table above, at a full time equivalent basis was 3,058 at the end of 2025.
E.Share ownership
For information regarding share ownership, see Item 6.B of this Form 20-F, Note 45 'Related parties' and Note 25
'Staff expenses' in the consolidated financial statements.
F.Disclosure of a registrant’s action to recover erroneously awarded
compensation
Not applicable.
Reference is made to Exhibit 97 to this Form 20-F for the policy on 'Clawback rules for erroneously awarded
variable remuneration for executive officers'.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 108 |
Item 7. Major Shareholders and Related Party
Transactions
A. Major shareholders
ING Group ordinary shares are listed on the stock exchanges of
Amsterdam (Euronext Amsterdam) and Brussels (Euronext Brussels). ING
Group American Depositary Shares (“ADSs”) are listed on the New York
Stock Exchange (NYSE). Options on ING Group ordinary shares or in the
form of American depository receipts (ADRs) are traded on the Euronext
Amsterdam Derivative Markets and the Chicago Board Options Exchange.
Major shareholders as filed with SEC
According to the U.S. Securities and Exchange Commission, shareholders in
a company which have registered a class of their equity securities under
the Exchange Act, are required to file beneficial owner reports if the
ownership exceeds more than 5% of the outstanding shares of that class.
The shareholder is obliged to file Schedule 13D or 13G until their holdings
drop below 5%.
To the best of our knowledge, as of 31 December 2025, no holder of
ordinary shares or ADSs, other than BlackRock Inc. held 5% or more of ING
Group’s issued share capital.
On 1 February 2023, BlackRock, Inc. disclosed by way of a Schedule 13G
filed with the SEC, beneficial ownership of 259,211,756 ordinary shares of
ING Group as of 31 December 2022, representing 7.0% of ING Group's
issued share capital. On 13 February 2023, Capital Research Global
Investors disclosed by way of a Schedule 13G filed with the SEC, beneficial
ownership of 57,557,399 ordinary shares of ING Group as of 30 December
2022, representing 1.5% of ING Group's issued share capital. On 6 February
2024, BlackRock, Inc. disclosed by way of a Schedule 13G filed with the SEC,
beneficial ownership of 255,592,935 ordinary shares of ING Group as of 31
December 2023, representing 7.3% of ING Group's issued share capital.
On 12 November 2024, Capital Research Global Investors disclosed by way
of a Schedule 13G filed with the SEC, beneficial ownership of 214,691,773
ordinary shares of ING Group as of September 30, 2024, representing 6.5%
of ING Group's issued share capital. On 13 February 2025, Capital Research
Global Investors disclosed by way of a Schedule 13G filed with the SEC,
beneficial ownership of 152,644,673 ordinary shares of ING Group as of 31
December 2024, representing 4.8% of ING Group's issued share capital.
Major shareholders as filed with AFM
Pursuant to section 5.3 of the Dutch Financial Supervision Act (“Major
Holdings Rules”), any person who, directly or indirectly, acquires or
disposes of an interest in the voting rights and/or the capital of (in short) a
public limited company incorporated under the laws of the Netherlands
with an official listing on a stock exchange within the European Economic
Area, as a result of which acquisition or disposal the percentage of his
voting rights or capital interest - whether through ownership of shares,
American depositary receipts (ADRs) or any other financial instrument,
whether stock-settled or cash-settled, such as call or put options,
warrants, swaps or any other similar contract - reaches, exceeds or falls
below the threshold levels of 3%, 5%, 10%, 15%, 20%, 25%, 30%, 40%,
50%, 60%, 75% and 95% is required to provide updated information on its
holdings and are recorded in the Dutch AFM (Authority for the Financial
Markets) register (http://www.afm.nl/nl-en/professionals/registers/
meldingenregisters/substantiele-deelnemingen). This notification
obligation also applies in respect of gross short positions that exceed the
relevant threshold levels.
In addition, any person who acquires or disposes of a net short position
relating to the issued share capital of ING Group, whether by a transaction
in shares or ADRs, or by a transaction creating or relating to any financial
instrument where the effect or one of the effects of the transaction is to
confer a financial advantage on the person entering into that transaction
in the event of a change in the price of such shares or ADRs, is required to
notify the AFM if, as a result of such acquisition or disposal, the person’s
net short position reaches, exceeds or falls below 0.1% of the issued share
capital of ING Group and each 0.1% above that. Each reported net short
position equal to 0.5% of the issued share capital of ING Group and any
subsequent increase of that position by 0.1% will be made public via the
short selling register on afm.nl/en/.
Based on the AFM register as per 31 December 2025, shareholders with
(potential) holdings of 3% or more are BlackRock Inc. (5.28% interest and
6.33% voting rights reported on 15 March 2024), Capital Research and
Management Company (4.99% voting rights reported on 26 November
2024) and Amundi Asset Management (3.02% interest and voting rights
reported on 13 August 2025). ING Groep N.V. and its subsidiaries held
90,753,376 ordinary shares or ADSs, representing 3.00% of ING Group's
issued share capital. ING Groep N.V. does not have voting rights in respect
of shares and ADSs it holds or which are held by its subsidiaries.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 109 |
As a result, other than based on information available from public filings
available under the applicable laws of any other jurisdiction, ING Groep
N.V. is not aware of any changes in the ownership of ordinary shares or
ADSs between the thresholds levels mentioned in the previous sentence.
On 31 December 2025, no person is known to ING Groep N.V. to be the
owner of more than 10% of the ordinary shares or ADSs.
As of 31 December 2025, members of the Supervisory Board and their
related third parties held 9,395 Ordinary Shares. Members of the
Supervisory Board do not hold ING options.
As at 31 December 2025, members of the Executive Board and their
related third parties held 100.994 ordinary shares.
As at 31 December 2025, members of the Management Board Banking
and their related third parties held 69.247 ordinary shares.
Change of control matters
As at 31 December 2025 ING Groep N.V. was not a party to any material
agreement that becomes effective, or is required to be amended or
terminated in case of a change of control of ING Groep N.V. following a
public bid as defined in the Dutch Financial Supervision Act. ING Groep
N.V.’s subsidiaries may have customary change of control arrangements
included in agreements related to various business activities, such as joint
venture agreements, letters of credit and other credit facilities, ISDA-
agreements, hybrid capital and debt instruments, reinsurance contracts
and futures and option trading agreements. Following a change of control
of ING Groep N.V. (as the result of a public bid or otherwise), such
agreements may be amended or terminated, leading, for example, to an
obligatory transfer of the interest in the joint venture, early repayment of
amounts due, loss of credit facilities or reinsurance cover and liquidation of
outstanding futures and option trading positions.
As of 31 December 2025 ING Groep N.V. was not aware of any
arrangements the operation of which may result in a change of control of
ING Groep N.V.
B. Related Party Transactions
In the normal course of business, ING Group enters into various
transactions with related parties. Parties are considered to be related if
one party has the ability to control or exercise significant influence over
the other party in making financial or operating decisions. Related parties
of ING Group include, among others, its associates, joint ventures, key
management personnel, and various defined benefit and contribution
plans. Transactions between related parties include rendering or receiving
of services, leases, transfers under finance arrangements and provisions of
guarantees or collateral. There are no significant provisions for doubtful
debts or individually significant bad debt expenses recognised on
outstanding balances with related parties.
ING Group has entered into various transactions with related parties. For
more information, reference is made to Note 45 “Related parties” in the
consolidated financial statements.
As described under “Item 6. Directors, Senior Management and
Employees”, some members of the Supervisory Board are current or
former senior executives of leading multi-national corporations based
primarily in the Netherlands. ING Group may at any time have lending,
investment banking or other financial relationships with one or more of
these corporations in the ordinary course of business on terms which we
believe are no less favorable to ING than those reached with unaffiliated
parties of comparable creditworthiness.
C. Interests of experts and counsel
This item does not apply to annual reports on Form 20-F.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 110 |
Item 8. Financial information
A.Consolidated statements and other
financial information
Consolidated statements
For information regarding consolidated statements and other
financial information, see Item 18 of this Form 20-F.
Legal Proceedings
For a description of ING’s legal proceedings, see Note 42 'Legal
proceedings' in the consolidated financial statements.
Dividend and distribution policy
ING’s distribution policy is a pay-out ratio of 50% of resilient net profit
and additional distributions in case of structural excess capital.
Prerequisite for a distribution is a CET1 ratio of at least prevailing
Maximum Distributable Amount (MDA) level after distribution. For
detailed information on ING’s 2025 dividend, reference is made to
‘Capital Management’ in Additional Information.
Cash distributions on ING Groups ordinary shares are generally paid in
Euros. However, the Executive Board may decide, with the approval of
the Supervisory Board, to declare dividends in the currency of a
country other than the Netherlands in which the shares are traded.
Amounts payable to holders of ADRs that are paid to the Depositary
in a currency other than dollars will be converted to dollars and
subjected to a charge by the Depositary for any expenses incurred by
it in such conversion.
If the Executive Board has been designated as a body authorised to
resolve to issue shares, it may decide, with the approval of the
Supervisory Board, that a distribution on ordinary shares shall be
made in the form of ordinary shares instead of cash or to decide that
the holders of ordinary shares shall be given the choice of receiving
the distribution in cash or in the form of ordinary shares.
The right to dividends and distributions in respect of the ordinary
shares will lapse if such dividends or distributions are not claimed
within five years following the day after the date on which they were
made available.
There are no legislative or other legal provisions currently in force in
the Netherlands or arising under ING Groups’ Articles of Association
restricting the remittance of dividends to holders of ordinary shares,
or ADRs not resident in the Netherlands. Insofar as the laws of the
Netherlands are concerned, cash dividends paid in Euro may be
transferred from the Netherlands and converted into any other
currency, except that for statistical purposes such payments and
transactions must be reported by ING Group to DNB and, further, no
payments, including dividend payments, may be made to jurisdictions
or persons, that are subject to certain sanctions, adopted by the
Government of the Netherlands, implementing resolutions of the
Security Council of the United Nations, or adopted by the European
Union.
Dividends are subject to withholding taxes in the Netherlands as
described under "Item 10. Additional Information - Taxation -
Netherlands Taxation”.
ING’s distribution policy may be changed at any time and there is no
guarantee that any dividends or other distributions will be made in
accordance with the distribution policy in effect from time to time or
at all.
B. Significant changes
For information on subsequent events reference is made to Note 48
‘Subsequent events’ of the consolidated financial statements.
Since 31 December 2025, until the filing of this report, no other
significant changes have occurred in the financial statements of the
Group included in “Item 18. Consolidated Financial Statements” of this
document.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 111 |
Item 9. The Offer and Listing
A.Offer and listing details
Ordinary Shares (nominal value EUR 0.01 per share) are traded on
Euronext Amsterdam, the principal trading market for the Ordinary
Shares, under the symbol “INGA”. The Ordinary Shares are also listed
on the stock exchange of Euronext Brussels, under the symbol “INGA”.
ADSs, representing an equal number of Ordinary Shares, are traded on
the New York Stock Exchange under the symbol “ING”.
B.Plan of distribution
This item does not apply to annual reports on Form 20-F.
C.Markets
For information regarding markets, see Item 9.A of this Form 20-F.
D.Selling shareholders
This item does not apply to annual reports on Form 20-F.
E.Dilution
This item does not apply to annual reports on Form 20-F.
F.Expenses of the issue
This item does not apply to annual reports on Form 20-F.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 112 |
Item 10. Additional information
A.Share capital
This item does not apply to annual reports on Form 20-F.
B.Memorandum and articles of association
For a description of ING’s memorandum and articles of association, please
see Exhibit 2.1 “Description of Securities Registered under Section 12 of the
Exchange Act”, which is incorporated by reference herein.
Reference is made to Exhibit 1.1 to this Form 20-F for the articles of
association.
C.Material contracts
There have been no material contracts outside the ordinary course of
business to which ING Groep N.V. or any of its subsidiaries is a party in the
last two years.
D. Exchange controls
Cash distributions, if any, payable in Euros on Ordinary Shares and ADSs
may be officially transferred from the Netherlands and converted into any
other currency without violating Dutch law, except that for statistical
purposes such payments and transactions must be reported by ING Groep
N.V. to the Dutch Central Bank and, further, no payments, including
dividend payments, may be made to jurisdictions or persons subject to
certain sanctions, adopted by the government of the Netherlands or the
European Union.
E.Taxation
The following is a summary of certain Netherlands tax consequences, and
the United States federal income tax consequences, of the ownership of
our Ordinary Shares or American Depositary Shares (“ADSs”) by U.S.
Shareholders (as defined below) who hold Ordinary Shares or ADSs as
capital assets for tax purposes.
For the purposes of this summary, a “U.S. Shareholder” is a beneficial
owner of Ordinary Shares or ADSs that is, for United States federal income
tax purposes:
§an individual citizen or resident of the United States,
§a corporation organized under the laws of the United States or of any
state of the United States, or any entity taxable as United States
corporation,
§an estate, the income of which is subject to United States federal
income tax without regard to its source, or
§a trust if a court within the United States is able to exercise primary
supervision over the administration of the trust and one or more United
States persons have the authority to control all substantial decisions of
the trust.
Further, this summary is limited to U.S. Shareholders who are not, and are
not deemed to be, a resident of the Netherlands for Dutch tax purposes.
This summary is based on the United States Internal Revenue Code of
1986 and the laws of the Netherlands, each as amended, their legislative
history, existing and proposed regulations, published rulings and court
decisions, and the tax treaty between the United States and the
Netherlands for the Avoidance of Double Taxation and the Prevention of
Fiscal Evasion with respect to Taxes on Income (“Treaty”), all as applicable
as of the date hereof. These laws are subject to change, possibly on a
retroactive basis. The information provided below is neither intended as
tax advice nor purports to describe all of the tax considerations that may
be relevant to investors and prospective investors including foreign, state
or local tax consequences, estate and gift tax consequences, and tax
consequences arising under the Medicare contribution tax on net
investment income or the alternative minimum tax. It should not be read
as extending to matters not specifically discussed, and investors should
consult their own advisors as to the tax consequences of their ownership
and disposal of Ordinary Shares or ADSs. In particular, the summary does
not take into account the specific circumstances of particular investors
(such as tax-exempt organizations, banks, insurance companies, dealers in
securities, traders in securities that elect to use a mark-to-market method
of accounting for their securities holdings, investors whose functional
currency is not the U.S. dollar, investors that actually or constructively own
10% or more of the combined voting power of the voting stock or of the
total value of ING Groep N.V., investors that hold Ordinary Shares or ADSs
as part of a straddle or a hedging or conversion transaction or investors
that acquired or dispose of Ordinary Shares or ADSs as part of a wash sale
for tax purposes, some of which may be subject to special rules). If an
entity or arrangement that is treated as a partnership for United States
federal income tax purposes holds the Ordinary Shares or ADSs, the United
States federal income tax treatment of a partner will generally depend on
the status of the partner and the tax treatment of the partnership. A
partner in a partnership holding the Ordinary Shares or ADSs should
consult its tax advisor with regard to the United States federal income tax
treatment of an investment in the Ordinary Shares or ADSs.
Moreover, this summary does not discuss (i) the Dutch tax treatment of a
holder of Ordinary Shares or ADSs who is an individual receiving income or
capital gains derived from the Ordinary Shares and ADSs if such income or
capital gains are attributable to the past, present or future employment
activities of such holder and (ii) the potential consequences for corporate
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 113 |
holders of Ordinary Shares or ADSs pursuant to the Dutch Minimum Tax
Act 2024 (Wet Minimumbelasting 2024).
The summary is based in part upon the representations of the Depositary
and the assumption that each obligation in the Deposit Agreement and
any related agreement will be performed in accordance with its terms. In
general, for United States federal income tax and Netherlands tax
purposes, holders of ADSs will be treated as the owners of the Ordinary
Shares underlying the ADSs, and exchanges of Ordinary Shares for ADSs,
and exchanges of ADSs for Ordinary Shares, will not be subject to United
States federal income tax or Netherlands income tax. References to
Ordinary Shares in this section include references to ADSs.
It is assumed, for purposes of this summary, that a U.S. Shareholder is
eligible for the benefits of the Treaty and that a U.S. Shareholder’s
eligibility is not limited by the limitation on benefits provisions of the
Treaty.
Netherlands Taxation
Dutch dividend withholding tax
The Netherlands imposes a withholding tax on a distribution of a dividend
at the statutory rate of 15%. Dividends include:
1.dividends paid in cash and in kind;
2.deemed and constructive dividends;
3.the consideration for the repurchase or redemption of shares in excess
of the qualifying average paid-in capital unless such repurchase is
made for temporary investment purposes or is exempt by law;
4.any (partial) repayment of paid-in capital not qualifying as capital for
Dutch dividend withholding tax purposes;
5.liquidation proceeds in excess of the qualifying average paid-in capital
for Dutch dividend withholding tax purposes; and
6.stock dividends up to their nominal value (unless distributed out of ING
Groep N.V.’s qualifying paid-in capital).
Reduction of Dutch dividend withholding tax based on Dutch law
Under certain circumstances, a reduction of Dutch dividend withholding
tax can be obtained based on Dutch law:
1.An exemption at source is available if the Dutch participation
exemption applies and the Ordinary Shares or ADSs are attributable to
a business carried out in the Netherlands. To qualify for the Dutch
participation exemption, the U.S. Shareholder must generally hold at
least 5.0 percent of our nominal paid-in capital and meet certain other
requirements.
2.An exemption at source is available for dividend distributions to certain
qualifying corporate U.S. Shareholders owning our Ordinary Shares or
ADSs if such shareholder would have been able to apply the Dutch
participation exemption if it would have been resident of the
Netherlands, unless such shareholder holds the Ordinary Shares or
ADSs with the primary aim or one of the primary aims to avoid the levy
of Dutch dividend withholding tax at the level of another person and
the Ordinary Shares or ADSs are not held for valid commercial reasons
that reflect economic reality.
3.Certain tax exempt organizations (e.g. pension funds and excluding
collective investment vehicles) may be eligible for a refund of Dutch
dividend withholding tax upon their request or in certain cases, an
exemption at source.
4.Upon request and under certain conditions, certain qualifying individual
and corporate U.S Shareholders of Ordinary Shares or ADSs which are
not subject to personal or corporate income tax in the Netherlands
may request a refund of Dutch dividend withholding tax insofar as the
withholding tax withheld on the gross dividend is higher than the
personal or corporate income tax which would have been due on the
net dividend if they were resident or established in the Netherlands.
This refund is however not applicable when, based on the Treaty, the
Dutch dividend withholding tax can be fully credited in the United
States by the U.S. Shareholder. However, it is unclear whether (i) which
(financing) costs can be taken into account when determining the
hypothetical personal or corporate income tax due on the net income
(ii) or how the Netherlands would determine whether, based on the
double taxation convention, a full credit is available in the country of
residence of the holder for purposes of this refund. See “United States
Taxation—Taxes on dividends” for more information. The provision in
essence is intended to be a codification of certain judgments by both
the European Free Trade Association Court of Justice and the European
Court of Justice that already indicated that in certain circumstances a
refund should be available prior to the introduction of the provision in
Dutch law. It is possible that this provision is an insufficient codification
of these judgments and that based on EU law a larger refund should be
provided.
Reduction of Dutch dividend withholding tax based on the Treaty
Pursuant to the provisions of the Treaty, certain corporate U.S.
Shareholders owning directly at least 10% of our voting power are eligible
for a reduction to 5% Dutch dividend withholding tax provided that the U.S.
Shareholder is the beneficial owner of the dividends received and does not
have an enterprise or an interest in an enterprise that is, in whole or in
part, carried on through a permanent establishment or permanent
representative in the Netherlands to which the dividends are attributable.
The Treaty also provides for a dividend withholding tax exemption on
dividends, but only for a shareholder owning directly at least 80.0 percent
of our voting power and meeting all other requirements.
Provided that certain conditions are met, under the Treaty dividends paid
to qualifying exempt pension trusts and other qualifying exempt
organizations, as defined in the Treaty, are exempt from Dutch dividend
withholding tax. To obtain a refund of the tax withheld such qualifying
exempt pension trusts are required to file a request. Only if certain
conditions are fulfilled, such qualifying exempt pension trusts may be
eligible for relief at source upon payment of the dividend. Qualifying
exempt organizations (other than qualifying exempt pension trusts) can
only file for a refund of the tax withheld.
Anti-dividend stripping rules
Pursuant to the Dutch anti-dividend stripping rules, in the case of dividend-
stripping, the 15% dividend withholding tax cannot be reduced or
refunded. Dividend-stripping is deemed to be present if the recipient of a
dividend is, contrary to what has been assumed above, not the beneficial
owner thereof and is entitled to a larger credit, reduction or refund of
dividend withholding tax than the beneficial owner of the dividends. Under
these rules, a recipient of dividends will not be considered the beneficial
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 114 |
owner thereof if as a consequence of a combination of transactions a
person other than the recipient wholly or partly benefits from the
dividends, whereby such person retains, whether directly or indirectly, an
interest similar to the shares on which the dividends were paid.
Credit for ING Groep N.V.
ING Groep N.V. may, with respect to certain dividends received from
qualifying non-Netherlands subsidiaries, credit taxes withheld from those
dividends against the Netherlands withholding tax imposed on certain
qualifying dividends that are redistributed by ING Groep N.V., up to a
maximum of the lesser of:
§3% of the amount of qualifying dividends redistributed by ING Groep
N.V.; and
§3% of the gross amount of certain qualifying dividends received by ING
Groep N.V.
The reduction is applied to the Dutch dividend withholding tax that ING
Groep N.V. must pay to the Dutch tax authorities and not to the Dutch
dividend withholding tax that ING Groep N.V. must withhold.
Dutch conditional withholding tax
From 1 January 2024 onwards, in addition to Dutch dividend withholding
tax, Dutch conditional withholding tax may apply at a statutory rate of
25.8% on dividends and other (deemed) distributions to certain affiliated
(gelieerde) entities of ING Groep N.V. for the purpose of the Dutch
Withholding Tax Act 2021 (Wet bronbelasting 2021).
The Dutch conditional withholding tax only applies on dividends and other
(deemed) distributions to entities that are resident (gevestigd), or have a
permanent establishment to which the dividend or distribution is
attributable, in a jurisdiction that is listed in the yearly updated Dutch
Regulation on low-taxing states and non-cooperative jurisdictions for tax
purposes (Regeling laagbelastende staten en niet-coöperatieve
rechtsgebieden voor belastingdoeleinden), and in certain deemed abusive
situations.
An entity is generally affiliated within the meaning of the Dutch
Withholding Tax Act 2021 if there is a controlling relationship between
such entity and ING Groep N.V.
Taxes on income and capital gains
Income and capital gains
Income and capital gains derived from the Ordinary Shares or ADSs by an
individual or corporate U.S. Shareholder are generally not subject to
Netherlands income tax or corporation tax, unless:
1.such income and gains are attributable to a (deemed) permanent
establishment or (deemed) permanent representative in the
Netherlands of the U.S. Shareholder; or
2.the shareholder is entitled to a share in the profits of an enterprise or
(in case of a non-Dutch resident corporate shareholder only) a co-
entitlement to the net worth of an enterprise, that is effectively
managed in the Netherlands (other than by way of securities) and to
which enterprise the Ordinary Shares or ADSs are attributable; or
3.such income and capital gains are derived from a direct, indirect or
deemed substantial interest in the share capital of ING Groep N.V. (such
substantial interest not being a business asset), and in the case of a
non-Dutch resident corporate shareholder only, that substantial
interest is being held with the primary aim or one of the primary aims
to avoid the levy of income tax from another person and is put in place
without valid economic reasons that reflect economic reality;
4.in case of a non-Dutch resident corporate shareholder, such
shareholder is a resident of Aruba, Curaçao or Saint Martin with a
permanent establishment or permanent representative in Bonaire,
Eustatius or Saba to which the Ordinary Shares or ADS are attributable,
while the profits of such shareholder are taxable in the Netherlands
pursuant to Article 17(3)(c) of the Dutch Corporate Tax Act 1969; or
5.in case of a non-Dutch resident individual, such individual derives
income or capital gains from the Ordinary Shares or ADSs that are
taxable as benefits from ‘miscellaneous activities’ in the Netherlands
(‘resultaat uit overige werkzaamheden’, as defined in the Dutch Income
Tax Act 2001), which includes the performance of activities with respect
to the Ordinary Shares or ADSs that exceed regular portfolio
management.
Substantial interest
Generally speaking, for Dutch tax purposes, an interest in the share capital
of ING Groep N.V., should not be considered a substantial interest if the
holder of such interest, and, in case of an individual, his or her spouse,
registered partner, certain other relatives or certain persons sharing the
holder’s household, alone or together, does or do not hold, either directly
or indirectly, the ownership of, or certain rights over, shares or rights
resembling shares representing 5% or more of the total issued and
outstanding capital, or the issued and outstanding capital of any class of
shares, of ING Groep N.V.
Gift or inheritance tax
No Netherlands gift or inheritance tax will be imposed on the transfer or
deemed transfer of the Ordinary Shares or ADSs by way of a gift by or on
the death of a U.S. Shareholder if, at the time of the gift or the death of
that shareholder, such shareholder is not a (deemed) resident of the
Netherlands.
Netherlands inheritance or gift taxes (as the case may be) are due,
however, if the transfer of the Ordinary Shares or ADSs is construed as an
inheritance or as a gift made by or on behalf of a person who, at the time
of the gift or death, is deemed to be a resident of the Netherlands. For the
purposes of Netherlands gift or inheritance tax, an individual of Dutch
nationality is deemed to be a resident of the Netherlands if he or she has
been a resident thereof at any time during the ten years preceding the
time of the gift or death. For the purposes of Netherlands gift tax, any
person is deemed to be a resident of the Netherlands if he or she has
resided therein at any time in the twelve months preceding the gift.
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United States Taxation
Taxes on dividends
The tax treatment of owning Ordinary Shares or ADSs will depend in part
on whether or not ING Groep N.V. is classified as a passive foreign
investment company, or PFIC, for United States federal income tax
purposes. Except as discussed below under “-PFIC Rules”, this discussion
assumes that ING Groep N.V. is not classified as a PFIC for United States
federal income tax purposes.
Under the United States federal income tax laws, a U.S. Shareholder will be
required to include in gross income the gross amount of a cash dividend
(including any Netherlands withholding tax withheld) as ordinary income
when the dividend is actually or constructively received by the U.S.
Shareholder in the case of Ordinary shares, or by the Depositary, in the
case of ADSs. For this purpose, a “dividend” will include any distribution
paid by ING Groep N.V. with respect to the Ordinary Shares or ADSs, but
only to the extent such distribution is not in excess of ING Groep N.V.’s
current and accumulated earnings and profits as determined for United
States federal income tax purposes. Distributions in excess of current and
accumulated earnings and profits, as determined for United States federal
income tax purposes, will be treated as a non-taxable return of capital to
the extent of a U.S. Shareholder’s basis in the Ordinary Shares or ADSs and
thereafter as capital gain. Because ING Groep N.V. does not keep account
of its earnings and profits, as determined for United States federal income
tax purposes, U.S. Shareholders should generally expect to treat any
distribution as a dividend for U.S. federal income tax purposes.
For foreign tax credit limitation purposes, dividends will generally be
income from sources outside the United States and will, depending on the
circumstances of the U.S. Shareholder, generally be “passive” income for
purposes of computing the foreign tax credit allowable to the shareholder.
However, if (a) we are 50% or more owned, by vote or value, by United
States persons and (b) at least 10% of our earnings and profits are
attributable to sources within the United States, then for foreign tax credit
purposes, a portion of our dividends would be treated as derived from
sources within the United States. With respect to any dividend paid for any
taxable year, the United States source ratio of our dividends for foreign tax
credit purposes would be equal to the portion of our earnings and profits
from sources within the United States for such taxable year, divided by the
total amount of our earnings and profits for such taxable year.
A dividend will not be eligible for the dividends-received deduction
generally allowed to U.S. corporations in respect of dividends received
from other U.S. corporations. Dividends paid to a non-corporate U.S.
Shareholder that are considered qualified dividend income will be taxable
to the shareholder at preferential rates applicable to long-term capital
gains provided that the shareholder holds the Ordinary Shares or ADSs for
more than 60 days during the 121-day period beginning 60 days before
the ex-dividend date and meets other holding period requirements.
Dividends paid by ING Groep N.V. with respect to the Ordinary Shares or
ADSs generally will be qualified dividend income, provided that, in the year
that you receive the dividend, we are eligible for the benefits of the Treaty.
We believe that we are currently eligible for the benefits of the Treaty and
we therefore expect that dividends on the Ordinary Shares or ADSs will be
qualified dividend income, but there can be no assurance that we will
continue to be eligible for the benefits of the Treaty.
Subject to certain limitations, a U.S. Shareholder may generally deduct
from income, or credit against its United States federal income tax liability,
the amount of any Netherlands withholding taxes withheld under the
Treaty and paid over to the Netherlands Tax Administration. However, the
Netherlands withholding tax may not be creditable unless a U.S.
Shareholder is eligible for and elects to apply the benefits of the Treaty.
Even in such case, the Netherlands withholding tax will likely not be
creditable against the U.S. Shareholder’s United States tax liability to the
extent that ING Groep N.V. is allowed to reduce the amount of dividend
withholding tax paid over to the Netherlands Tax Administration by
crediting withholding tax imposed on certain dividends paid to ING Groep
N.V. In addition, special rules apply in determining the foreign tax credit
limitation with respect to dividends that are subject to preferential rates.
To the extent a reduction or refund of the tax withheld is available to a U.S.
Shareholder under Dutch law or under the Treaty, the amount of tax
withheld that could have been reduced or is refundable will not be eligible
for credit against the U.S. Shareholder's United States federal income tax
liability. In addition, to the extent an amount of Dutch tax withheld is
contingent on the availability of a credit against the amount of income tax
owed to another country, that amount of Dutch tax withheld will not be
eligible for a credit against the U.S. Shareholder's United States federal
income tax liability. It is unclear whether or how the Netherlands would
apply this rule in determining whether, based on the Treaty, a credit is
available in the United States for purposes of the dividend withholding tax
refund provision described in Section IV under “Netherlands Taxation—
Withholding tax on dividends—Reduction of Dutch dividend withholding
tax based on Dutch law”.
Since payments of dividends with respect to Ordinary Shares or ADSs will
be made in Euros, a U.S. Shareholder will generally be required to
determine the amount of dividend income by translating the Euro into U.S.
dollars at the “spot rate” on the date the dividend is distributed, regardless
of whether the payment is in fact converted into U.S. dollars. Generally,
any gain or loss resulting from currency exchange fluctuations during the
period from the date the dividend is distributed to the date such payment
is converted into U.S. dollars will be treated as ordinary income or loss and
will not be eligible for the special tax rate applicable to qualified dividend
income. Such gain or loss will generally be income or loss from sources
within the United States for foreign tax credit limitation purposes.
Taxes on capital gains
Gain or loss on a sale or exchange of Ordinary Shares or ADSs by a U.S.
Shareholder will generally be a capital gain or loss for United States federal
income tax purposes equal to the difference between the U.S. dollar value
of the amount that such U.S. Shareholder realizes and such U.S.
Shareholder's tax basis, determined in U.S. dollars, in the Ordinary Shares
or ADSs. If such U.S. Shareholder has held the Ordinary Shares or ADSs for
more than one year, such gain or loss will generally be long-term capital
gain or loss. Long-term capital gain of a non-corporate U.S. Shareholder is
generally taxed at preferential rates. In general, gain or loss from a sale or
exchange of Ordinary Shares or ADSs by a U.S. Shareholder will be treated
as income or loss from sources within the United States for foreign tax
credit limitation purposes.
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PFIC rules
ING Groep N.V. believes it is not a PFIC for United States federal income tax
purposes, and it does not expect to become a PFIC in the foreseeable
future. However, this conclusion is a factual determination that must be
made annually and thus may be subject to change. It is therefore possible
that we could become a PFIC in a future taxable year.
If ING Groep N.V. were to be treated as a PFIC, unless a U.S. Shareholder
made an effective election to be taxed annually on a mark-to-market
basis with respect to the Ordinary Shares or ADSs, any gain from the sale
or disposition of Ordinary Shares or ADSs by a U.S. Shareholder would be
allocated ratably to each year in the holder’s holding period and would be
treated as ordinary income. Tax would be imposed on the amount
allocated to each year prior to the year of disposition at the highest rate in
effect for that year, and interest would be charged at the rate applicable
to underpayments on the tax payable in respect of the amount so
allocated. The same rules would apply to “excess distributions”, defined
generally as any distributions in a single taxable year, other than the
taxable year in which the U.S. Shareholder's holding period in the shares or
ADSs begins, exceeding 125% of the average annual distribution made by
ING Groep N.V. in respect of the Ordinary Shares or ADSs over the shorter
of the three preceding taxable years or the portion of the holder’s holding
period that preceded the taxable year in which the holder receives the
distribution. Dividends received by a U.S. Shareholder will not be eligible for
the special tax rates applicable to qualified dividend income if ING Groep
N.V. were a PFIC (or were to be treated as a PFIC with respect to the
shareholder) either in the taxable year of the distribution or the preceding
taxable year, but instead will be taxable at rates applicable to ordinary
income. A U.S. Shareholder who owns Ordinary Shares or ADSs during any
year that ING Groep N.V. is a PFIC may be required to file Internal Revenue
Service Form 8621.
F.Dividends and paying agents
This item does not apply to annual reports on Form 20-F.
G.Statement by experts
This item does not apply to annual reports on Form 20-F.
H.Documents on display
ING Groep N.V. is subject to the informational requirements of the
Securities Exchange Act of 1934, as amended. In accordance with these
requirements, ING Groep N.V. files reports and other information with the
Securities and Exchange Commission (”SEC”). These materials, including
this Annual Report and its exhibits, may be inspected and copied on the
SEC’s website at www.sec.gov. You may also inspect ING Groep N.V.’s SEC
reports and other information on the website of ING Groep N.V.
(www.ing.com).
I.Subsidiary information
This item does not apply to annual reports on Form 20-F.
J.Annual Report to Security Holders
Not applicable.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 117 |
Item 11. Quantitative and Qualitative Disclosure
of Market Risk
See “Item 5. Operating and Financial Review and Prospects – Factors Affecting Results of Operations” and
“Additional information - ING Group Risk Management” for these disclosures, including disclosures relating to
operational, compliance and other non-market-related risks.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 118 |
Item 12. Description of Securities other than
Equity Securities
A.Debt securities
This item does not apply to annual reports on Form 20-F.
B.Warrants and rights
This item does not apply to annual reports on Form 20-F.
C.Other securities
This item does not apply to annual reports on Form 20-F.
D.American depositary shares
Fees and Charges Payable by a Holder of ADSs
JPMorgan Chase Bank, N.A., as ADR depositary, may collect fees for, among other things, the delivery and
surrender of ADSs directly from investors, or from intermediaries acting for them, depositing Ordinary Shares or
surrendering ADSs for the purpose of withdrawal.
The charges of the ADR depositary payable which may be payable by investors are as follows:
Type of Service | ADR Depositary Actions | Fee Payable | ||
Depositing or substituting the underlying Ordinary Shares | Issuance of ADSs against the deposit of Ordinary Shares, including deposits and issuances in respect of: §share distributions, rights and other distributions. §a stock dividend or stock split. §a merger, exchange of securities or other transactions or events affecting the ADSs or the underlying Ordinary Shares. | $5.00 for each 100 ADSs (or portion thereof) issued, delivered or upon which a share distributive or elective distribution is made or offered. The ADR depositary may sell sufficient securities or property received in respect of share distributions, rights and other distributions prior to such deposit to pay such charge. | ||
Receiving or distributing cash dividends | Distribution of cash dividends or other cash distributions, or offering of elective cash/stock dividends. | $0.05 or less per ADS held. | ||
Selling or exercising rights | §additional ADRs resulting from a dividend or free distribution consisting of Ordinary Shares, or U.S dollars resulting from sales of Ordinary Shares received in a distribution. §Instruments representing rights to acquire additional ADRs as a result of distribution on Ordinary Shares, or U.S dollars resulting from sales of such rights. §other securities available to the ADR depositary resulting from any distribution on the deposited Ordinary Shares, or U.S dollars resulting from sales of such other securities. | An amount equal to the fee for the execution and delivery of ADSs which would have been charged as a result of the deposit of such securities. | ||
Withdrawing an underlying Ordinary Share | Acceptance of ADSs surrendered for withdrawal of deposited Ordinary Shares | $5.00 for each 100 ADSs (or portion thereof) reduced, cancelled or surrendered. | ||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 119 |
Type of Service | ADR Depositary Actions | Fee Payable | ||
Transferring, splitting or grouping of ADRs | Registration, registration of transfer, combination and split-up of ADRs in the ADR register as evidenced by the ADRs surrendered or upon delivery of proper instruments of transfer | $1.50 per ADR. | ||
General depositary services, particularly those charged on an annual basis | Other services performed by the ADR depositary in administering the ADR program | $0.05 per ADS per calendar year (or portion thereof), which may be charged on a periodic basis during each calendar year against holders of the record date(s) set by the ADR depositary and shall be payable at the sole discretion of the ADR depositary by billing such holders or deducting such charge from one or more cash distributions. | ||
Reimbursement of fees, charges and expenses of the ADR depositary | The ADR depositary and/or any of its agents may incur fees, charges and expenses (including expenses incurred on behalf of holders of ADRs in connection with compliance with foreign exchange control regulations or any law or regulation relating to foreign investment) in connection with the servicing of the underlying Ordinary Shares or other deposited securities, the sale of securities (including, without limitation, deposited securities), the delivery of deposited securities or otherwise in connection with the ADR depositary’s compliance with applicable law, rule or regulation. | Fees and charges shall be assessed on a proportionate basis against holders of ADRs as of the record date or dates set by the ADR depositary and shall be payable at the sole discretion of the ADR depositary by billing such holders of ADRs or by deducting such charge from one or more cash dividends or other cash distributions. | ||
Type of Service | ADR Depositary Actions | Fee Payable | ||
Other charges and expenses of the ADR depositary | The ADR depositary may incur charges and expenses on behalf of holders in connection with: §stock transfer or other taxes and other governmental charges. §SWIFT, cable, telex and facsimile transmission and delivery charges incurred at the request of persons §depositing, or holders of ADRs delivering underlying Ordinary Shares, ADRs or deposited securities. §transfer or registration fees for the registration or transfer of deposited securities. | Payable by holders or persons depositing Ordinary Shares. Payable by persons depositing, or holders of ADRs delivering underlying Ordinary Shares, Ads or deposited securities. Payable by persons depositing or withdrawing deposited securities. | ||
Fees and Payments made by the ADR depositary to ING
In consideration for acting as depositary, the ADR depositary has agreed to provide ING with certain amounts on
an annual basis. In the year ended 31 December 2025, the ADR depositary paid aggregate fees and made other
direct and indirect payments to ING in an amount of USD 6,092,292.
Under certain circumstances, including removal of the ADR depositary or termination of the ADR program by ING,
ING is required to repay the ADR depositary certain amounts reimbursed and/or expenses paid to or on behalf of
ING.
Part II
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 121 |
Item 13. Defaults, Dividend Arrearages and Delinquencies
None.
Item 14. Material Modifications to the Rights of
Security Holders and Use of Proceeds
None.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 122 |
Item 15. Controls and Procedures
Internal control over financial reporting
Due to the listing of ING shares on the New York Stock Exchange, ING
Group is required to comply with the SEC regulations adopted pursuant to
Section 404 of the Sarbanes-Oxley Act (SOX 404). These regulations require
that the Chief Executive Officer (“CEO”) and the Chief Financial Officer
(“CFO”) of ING Group report and certify on an annual basis on the
effectiveness of ING Group’s internal control over financial reporting.
Moreover, the external auditors are required to provide an opinion on the
effectiveness of ING Group’s internal control over financial reporting.
SOX 404 activities are organised along the lines of the governance
structure and involve the participation of senior management across ING.
Following the SOX 404 process, ING is in the position to publish an
unqualified statement that the Company’s internal control over financial
reporting was effective as of 31 December 2025. The SOX 404 statement
by the Executive Board is included on this page, followed by the report of
the external auditor as issued on Form 20-F.
Disclosure Controls and Procedures
The Company’s management, under the supervision and with the
participation of the CEO and CFO, has performed an evaluation of the
effectiveness of the design and operation of the Company’s disclosure
controls and procedures. Based on that evaluation, the CEO and CFO
concluded that the Company’s disclosure controls and procedures were
effective as of December 31, 2025, the end of the period covered by the
2025 Form 20-F.
Report of the Executive Board on Internal Control Over Financial
Reporting
The Executive Board is responsible for establishing and maintaining
adequate internal control over financial reporting. ING’s internal control
over financial reporting is a process designed under the supervision of our
principal executive and principal financial officers to provide reasonable
assurance regarding the reliability of financial reporting and the
preparation of financial statements for external purposes in accordance
with generally accepted accounting principles.
Our internal control over financial reporting includes those policies and
procedures that:
§Pertain to the maintenance of records that, in reasonable detail,
accurately and fairly reflect the transactions and dispositions of assets
of ING;
§Provide reasonable assurance that transactions are recorded as
necessary to permit preparation of financial statements in accordance
with generally accepted accounting principles, and that our receipts
and expenditures are being made only in accordance with
authorisations of our management and directors; and
§Provide reasonable assurance regarding prevention or timely detection
of unauthorised acquisition, use or disposition of our assets that could
have a material effect on our financial statements.
Because of its inherent limitations, internal control over financial reporting
may not prevent or detect misstatements. Also, projections of any
evaluation of effectiveness to future periods are subject to the risk that
controls may become inadequate because of changes in conditions, or
that the degree of compliance with the policies or procedures may
deteriorate.
The Executive Board assessed the effectiveness of internal control over
financial reporting as of 31 December 2025. In making this assessment,
the Executive Board performed tests based on the criteria of the
Committee of Sponsoring Organizations of the Treadway Commission
(“COSO”) in Internal Control – Integrated Framework (2013 Framework).
Based on the Executive Board’s assessment and those criteria, the
Executive Board concluded that the Company’s internal control over
financial reporting was effective as of 31 December 2025.
Attestation Report of the Registered Public Accounting Firm
Our independent registered public accounting firm has audited and issued
their report on ING’s internal control over financial reporting, which
appears on the page below.
Changes in Internal Controls over Financial Reporting
There have been no changes in the Company’s internal controls over
financial reporting during the period covered by this Annual Report that
have materially affected or are reasonably likely to materially affect, our
internal control over financial reporting.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 123 |
Report of Independent Registered Public Accounting Firm
To the Shareholders and the Supervisory Board ING Groep N.V.
Opinion on Internal Control Over Financial Reporting
We have audited ING Groep N.V. and subsidiaries’ (the Company) internal
control over financial reporting as of December 31, 2025, based on criteria
established in Internal Control – Integrated Framework (2013) issued by
the Committee of Sponsoring Organizations of the Treadway Commission.
In our opinion, the Company maintained, in all material respects, effective
internal control over financial reporting as of December 31, 2025, based on
criteria established in Internal Control – Integrated Framework (2013)
issued by the Committee of Sponsoring Organizations of the Treadway
Commission.
We also have audited, in accordance with the standards of the Public
Company Accounting Oversight Board (United States) (PCAOB), the
consolidated statements of financial position of the Company as of
December 31, 2025 and 2024, the related consolidated statements of
profit or loss, comprehensive income, changes in equity, and cash flows for
each of the years in the three-year period ended December 31, 2025, and
the related notes and specific disclosures described in Note 1 as being part
of the consolidated financial statements (collectively, the consolidated
financial statements), and our report dated February 23, 2026 expressed
an unqualified opinion on those consolidated financial statements.
Basis for Opinion
The Company’s management is responsible for maintaining effective
internal control over financial reporting and for its assessment of the
effectiveness of internal control over financial reporting, included in the
accompanying Report of the Executive Board on Internal Control Over
Financial Reporting. Our responsibility is to express an opinion on the
Company’s internal control over financial reporting based on our audit. We
are a public accounting firm registered with the PCAOB and are required to
be independent with respect to the Company in accordance with the U.S.
federal securities laws and the applicable rules and regulations of the
Securities and Exchange Commission and the PCAOB.
We conducted our audit in accordance with the standards of the PCAOB.
Those standards require that we plan and perform the audit to obtain
reasonable assurance about whether effective internal control over
financial reporting was maintained in all material respects. Our audit of
internal control over financial reporting included obtaining an
understanding of internal control over financial reporting, assessing the
risk that a material weakness exists, and testing and evaluating the design
and operating effectiveness of internal control based on the assessed risk.
Our audit also included performing such other procedures as we
considered necessary in the circumstances. We believe that our audit
provides a reasonable basis for our opinion.
Definition and Limitations of Internal Control Over Financial Reporting
A company’s internal control over financial reporting is a process designed
to provide reasonable assurance regarding the reliability of financial
reporting and the preparation of financial statements for external
purposes in accordance with generally accepted accounting principles. A
company’s internal control over financial reporting includes those policies
and procedures that (1) pertain to the maintenance of records that, in
reasonable detail, accurately and fairly reflect the transactions and
dispositions of the assets of the company; (2) provide reasonable
assurance that transactions are recorded as necessary to permit
preparation of financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the company
are being made only in accordance with authorizations of management
and directors of the company; and (3) provide reasonable assurance
regarding prevention or timely detection of unauthorized acquisition, use,
or disposition of the company’s assets that could have a material effect on
the financial statements.
Because of its inherent limitations, internal control over financial reporting
may not prevent or detect misstatements. Also, projections of any
evaluation of effectiveness to future periods are subject to the risk that
controls may become inadequate because of changes in conditions, or
that the degree of compliance with the policies or procedures may
deteriorate.
/s/ KPMG Accountants N.V.
Utrecht, The Netherlands
February 23, 2026
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 124 |
Item 16A. Audit Committee Financial Expert
The Supervisory Board has determined that Margarete Haase, who is a
member of the Supervisory Board, qualifies as an “audit committee
financial expert” as defined by the SEC pursuant to section 407 of the
Sarbanes-Oxley Act of 2002. The Supervisory Board has further
determined that Margarete Haase is “independent”, as defined in Rule
10A-3 under the Securities Exchange Act of 1934. She was appointed as a
member of the Supervisory Board at the General Meeting in May 2017 and
her appointment became effective as per 1 May 2018, as decided by the
Supervisory Board in January 2018. Margarete Haase is chair of the Audit
Committee.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 125 |
Item 16B. Code of Ethics
ING has adopted a Code of Ethics (as defined in Item 16B of Form 20-F)
that applies to all employees including ING’s principal executive officer,
principal financial officer and principal accounting officer. The provisions of
ING’s Code of Ethics are contained in the ING Orange Code, the ING Global
Code of Conduct and the ING Whistleblower Policy.
In 2025, there were no amendments to the provisions of the ING Orange
Code, the ING Global Code of Conduct or the ING Whistleblower Policy.
In 2025, ING did not grant any waivers (including implicit waivers) under
the provisions of the ING Orange Code, the ING Global Code of Conduct or
the ING Whistleblower Policy that constitute the Code of Ethics to ING’s
principal executive officer, principal financial officer or principal accounting
officer.
The ING Orange Code is available on the ING website at the following
hyperlink: https://ing.com/about-us/purpose-and-values.
The ING Global Code of Conduct is available on the ING website at the
following hyperlink: https://ing.com/about-us/purpose-and-values.
The ING Whistleblower Policy is available on the ING website at the
following hyperlink: www.ing.com/about-us/compliance/whistleblower-
policy.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 126 |
Item 16C. Principal Accountant Fees and Services
At the Annual General Meeting held on 24 April 2023, KPMG (KPMG
re-appointed as the external audit firm for ING Group for the financial
years 2024 and 2025 which is the maximum term for KPMG as the external
auditor. This appointment includes the responsibility to provide an audit
opinion on the financial statements and internal control over financial
reporting on 31 December 2025 and to report on the outcome of these
audits to the Executive Board and the Supervisory Board.
The external auditor may be questioned at the Annual General Meeting in
relation to its audit opinion on the financial statements. The external
auditor will therefore attend and be entitled to address this meeting. The
external auditor attended the meetings of the Risk Committee and of the
Audit Committee and attended and addressed the 2024 Annual General
Meeting, at which the external auditor provided an explanation on the
audit activities and the audit opinion.
The external auditor may only provide services to ING Group and its
subsidiaries with the permission of the Audit Committee, in line with the
ING Group Global Procedure on External Auditors’ Independence. All
services were approved by the Audit Committee.
More information on the ING Group Global Procedure on External Auditors’
Independence is available on the website of ING Group www.ing.com.
Audit fees
Audit fees were paid for audit and assurance services provided by the
auditors. The services provided include the audit of ING Group’s
consolidated financial statements and Form 20-F. Moreover, these services
include the audits of the statutory financial statements of its subsidiaries.
And, it includes assurance services provided by the auditor regarding other
filings for regulatory and supervisory purposes as well as the review on
interim financial statements. Furthermore, it includes the assurance
services relating to comfort letters issued in connection with prospectuses
and reviews of SEC product filings.
Audit-related fees
Audit-related fees were paid for assurance and related services that are
reasonably related to the performance of the audit or review of the
consolidated financial statements not reported under the audit fee item
above. These services consisted primarily of specific agreed-upon
procedure engagements and assurance engagements for third parties.
Tax fees
Over 2025 no tax fees were paid. Under the current ING Group Global
Procedure on External Auditors’ Independence most tax services are
prohibited. Some tax services are only allowed after specific approval
under an ‘exception procedure’.
Reference is made to Note 27 ‘Audit fees’ in the consolidated financial
statements for audit, audit-related, tax and all other fees paid to the
external auditors in 2025, 2024 and 2023.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 127 |
Item 16D. Exemptions from the Listing Standards for Audit
Committees
Not applicable.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 128 |
Item 16E. Purchases of Equity Securities by the Issuer
and Affiliated Purchasers
Share buyback programmes executed in 2025
On 30 October 2025, ING announced a shareholder distribution of up to
EUR 1,600 million. The distribution consists of a share buyback programme
for a maximum total amount of EUR 1,100 million and a cash payment of
EUR 500 million. The share buyback programme is expected to end no
later than 27 April 2026. The total number of ordinary shares repurchased
under the programme in 2025 is 17,537,269 at an average price of EUR
22.62 for a total consideration of EUR 397 million. The EUR 500 million in
cash has been paid on 15 January 2026.
On 2 May 2025, ING announced a share buyback programme under which
it planned to repurchase ordinary shares of ING Groep N.V., for a maximum
total amount of EUR 2,000 million. The share buyback programme was
completed on 27 October 2025. The total number of ordinary shares
repurchased under the programme is 101,193,469 at an average price of
EUR 19.77 for a total consideration of EUR 2,000 million. The purchases
exceeded 100% due to performance arrangements with our executing
broker for the programme. The broker repurchased shares until the
performance arrangements were fulfilled. The total consideration for ING
was limited to EUR 2,000 million. The excess purchases above this amount
were funded by the executing broker. Based on the total programme
period, the effective average price for ING was EUR 19.76.
On 3 March 2025, ING announced a share buyback programme for a
maximum total amount of EUR 70 million. The share buyback programme
was executed by ING and completed on 4 March 2025. The total number of
shares repurchased under the programme is 3,674,043 ordinary shares at
an average price of EUR 17.44 for a total consideration of EUR 64 million.
The purpose of the share repurchase programme was to meet obligations
under the share-based compensation plans. After fulfilling delivery
obligations under the employee share-based compensation scheme, the
buyback programme had negligible impact on our CET1 ratio.
On 31 October 2024, ING announced a shareholder distribution of up to
EUR 2,500 million. The distribution consists of a share buyback programme
for a maximum total amount of EUR 2,000 million and an additional cash
distribution of EUR 500 million. The share buyback programme was
completed on 30 April 2025. The total number of ordinary shares
repurchased under the programme in 2025 is 75,371,667 at an average
price of EUR 16.42 for a total consideration of EUR 1,238 million. The shares
have been cancelled in July 2025.
General
All share buyback programmes have been approved by the ECB and were
executed within the limitations of the existing authority of a maximum of
20% of the issued shares as granted by the general meeting of
shareholders on 22 April 2025 and 22 April 2024 in compliance with the
Market Abuse Regulation. For each buyback, ING entered into a non-
discretionary arrangement with a financial intermediary to conduct the
buybacks except for the share repurchase programmes for the employee
share-based compensation plans which were executed by ING.
ING Groep N.V. has no other publicly announced plans or programmes to
repurchase shares. In 2025, ING Groep N.V. did not determine to terminate
any publicly announced plans or programmes prior to expiration, or
determine that it intends not to make any further purchases under any
publicly announced plans or programmes.
There were no other purchases by us or any of our affiliated purchasers of
any of our equity securities registered pursuant to Section 12 of the
Securities Exchange Act of 1934 during the fiscal years ended December
31, 2025 and 2024.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 129 |
Purchases of Equity Securities by the Issuer and affiliated Purchasers | ||||
Month of purchase | Total number of shares purchased1 | Average price paid per share in EUR | Total number of shares purchased as part of publicly announced plans or programmes 2, 3, 4, 5 | Maximum Value of shares that may yet be purchased under the plans or programmes in EUR million |
January 2025 | 18,026,522 | 15.62 | 18,026,522 | 963 |
February 2025 | 17,005,344 | 16.20 | 17,005,344 | 687 |
March 2025 | 14,701,980 | 18.19 | 14,701,980 | 484 |
April 2025 | 29,311,864 | 16.29 | 29,311,864 | |
May 2025 | 20,055,856 | 18.49 | 20,055,856 | 1,629 |
June 2025 | 20,176,361 | 18.20 | 20,176,361 | 1,262 |
July 2025 | 11,872,104 | 19.63 | 11,872,104 | 1,029 |
August 2025 | 15,542,589 | 20.34 | 15,542,589 | 713 |
September 2025 | 17,582,981 | 21.35 | 17,582,981 | 337 |
October 2025 | 17,136,494 | 21.19 | 17,136,494 | 1,074 |
November 2025 | 8,499,025 | 22.04 | 8,499,025 | 887 |
December 2025 | 7,865,328 | 23.35 | 7,865,328 | 703 |
Total | 197,776,448 | 18.70 | 197,776,448 | |
Of which: | ||||
Purchased in the open market | 197,776,448 | 18.70 | 197,776,448 | 703 |
Acquired through exercise of call options / settlement of forward contracts | n.a. | n.a. | n.a. | n.a. |
1The table excludes purchases on behalf of clients in ING Groep N.V. shares.
2On 30 October 2025, ING announced a share buyback programme for a maximum total amount of EUR 1,600 million. The distribution consists of a share
buyback programme for a maximum total amount of EUR 1,100 million and a cash payment of EUR 500 million. The share buyback programme is
expected to end no later than 27 April 2026. The EUR 500 million in cash has been paid on 15 January 2026. The total number of shares repurchased in
2025 under the programme is 17,537,269 ordinary shares at an average price of EUR 22.62 per share for a total consideration of EUR 397 million with
EUR 703 million remaining to be purchased in 2026. The programme is executed by an intermediary to allow for purchases in the open market during
both open and closed periods. The purpose of the additional distribution is to converge our CET1 ratio towards our target of ~13%.
3On 2 May 2025, ING announced a share buyback programme for a maximum total amount of EUR 2,000 million. The programme was completed on 27
October 2025. The total number of shares repurchased under the programme is 101,193,469 ordinary shares at an average price of EUR 19.77 per share
for a total consideration of EUR 2,000 million. The programme is executed by an intermediary to allow for purchases in the open market during both
open and closed periods. The purchases exceeded 100% due to performance arrangements with our executing broker for the programme. The broker
repurchased shares until the performance arrangements were fulfilled. The total consideration for ING was limited to EUR 2,000 million. The excess
purchases above this amount were funded by the executing broker. Based on the total programme period, the effective average price for ING was EUR
19.76. The purpose of the share buyback programme is to converge our CET1 ratio towards our target of ~13%. The shares have been cancelled in
January 2026.
4On 3 March 2025, ING announced a share buyback programme for EUR 70 million. The programme was completed on 4 March 2025. The total number of
shares repurchased under the programme is 3,674,043 ordinary shares at an average price of EUR 17.44 per share for a total consideration of EUR 64
million. The programme is executed by ING during a two day period. The purpose of the share buyback programme was to meet obligations under the
employee share-based compensation plans.
5On 31 October 2024, ING announced an additional distribution for a maximum total amount of EUR 2,500 million. The distribution consists of a share
buyback programme for a maximum total amount of EUR 2,000 and a cash payment of EUR 500 million. The share buyback programme was completed
on 30 April 2025. The total number of shares repurchased under the programme in 2025 is 75,371,667 ordinary shares at an average price of EUR 16.42
per share for a total consideration of EUR 1,238 million with EUR 708 million purchased in 2024. The programme is executed by an intermediary to allow
for purchases in the open market during both open and closed periods. The shares have been cancelled in July 2025.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 130 |
Item 16F. Changes in Registrant’s Certifying Accountant
While there has been no change in ING’s certifying accountant during the
most recent two financial years, in the 2024 Annual General Meeting of
Shareholders, the shareholders of ING appointed Deloitte Accountants BV
(Deloitte), as the new external audit firm for ING Group for the audit of the
annual accounts for the financial years 2026 through 2029. The proposal
to appoint Deloitte was the result of a thorough tender process overseen
by the Audit Committee of the Supervisory Board and in accordance with
ING Group’s policy on the Auditors’ Independence. The change in auditors
is being made based on European and Dutch legislation. Accordingly, the
engagement of KPMG Accountants N.V. (KPMG), ING Group’s current
auditor, cannot be renewed in respect of financial year 2026.
The information required by Item 16F was previously reported in ING’s
Annual Report on Form 20-F for the year ended December 31, 2023.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 131 |
Item 16G. Corporate Governance
Dutch Corporate Governance Code, Banking Code
and Dutch Tax Governance Code
As ING Group is established and listed in the Netherlands, it must comply
with Dutch laws and regulations and is subject to the Dutch Corporate
Governance Code (the DCGC).
The DCGC provides guidance for ING’s corporate governance structure and
practices. ING supports the DCGC and its principles to ensure sound
corporate governance within its organisation. ING’s application of the DCGC
is described in the booklet ‘Application of the Dutch Corporate Governance
Code by ING Groep N.V. (FY2025)' dated 26 February 2026, which is
available on ing.com. The DCGC can be downloaded from the website of
the Corporate Governance Monitoring Committee (mccg.nl).
The Dutch Banking Code (the Banking Code) is only applicable to ING Bank,
but ING Group voluntarily applies the principles of the Banking Code on
remuneration for its Executive Board members and senior management.
The Banking Code can be downloaded from the website of the Dutch
Banking Association (nvb.nl). ING Group also voluntarily applies the
principles of the Dutch Tax Governance Code.
Differences between Dutch and US corporate governance
practices
ING Group qualifies as a foreign private issuer under the US Securities and
Exchange Commission (SEC) rules and is permitted to follow home-country
practice in some circumstances, in lieu of certain corporate governance
standards required by the New York Stock Exchange (NYSE) applicable to
US domestic companies. Accordingly, ING Group must disclose in its
Annual Report on Form 20-F any significant differences between its
corporate governance practices and those applicable to US companies
under NYSE listing standards. ING Group believes these differences are the
following:
§ING Group has a two-tier board structure, in contrast to the one-tier
board structure used by most US companies. In the Netherlands, a
public limited liability company with a two-tier board structure has an
executive board as its management body and a supervisory board that
advises and supervises the executive board. Supervisory board
members are often former state or business leaders and sometimes
former members of the executive board. A member of the executive
board or other officer or employee of the company cannot
simultaneously be a member of the supervisory board. The supervisory
board must approve specified decisions of the executive board.
§Under the DCGC, all members of the supervisory board, with the
exception of not more than one person, should be ‘independent’ as
determined under the DCGC. However, the definition of ‘independent’
under the DCGC differs in its details from the definition of ‘independent’
under the NYSE listing standards. All members of ING’s Supervisory
Board are independent as determined under the DCGC.
§NYSE listing standards require a US company to have a compensation
committee and a nominating/corporate governance committee, each
composed entirely of independent directors (as determined under the
NYSE listing standards). ING’s Nomination and Corporate Governance
Committee and Remuneration Committee are composed entirely of
members of the Supervisory Board who are independent as
determined under the DCGC.
§NYSE listing standards require that, when a member of the audit
committee of a US company serves on four or more audit committees
of public companies, the company should disclose (on its website, in its
annual proxy statement or in its annual report filed with the SEC) that
the board of directors has determined this simultaneous service would
not impair the director’s service to the company. Dutch law does not
require the Supervisory Board to make such a determination.
§In contrast to the NYSE listing standards, the DCGC contains a ‘comply-
or-explain’ principle, offering the possibility of deviating from the DCGC.
For any deviations by ING Group, please refer to the paragraph ‘Dutch
Corporate Governance Code, Banking Code and Dutch Tax Governance
Code’.
§NYSE listing standards require external auditors to be appointed by the
audit committee. By contrast, Dutch law requires ING Group’s external
auditors to be appointed by the General Meeting and not by the Audit
Committee. The Audit Committee is responsible for preparing the
Supervisory Board’s nomination to the General Meeting for the
appointment and remuneration of ING Group’s external auditor, and
annually evaluates the independence and functioning of, and
developments in the relationship with, ING Group’s external auditor and
informs the Supervisory Board of its findings and proposed measures.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 132 |
§Under NYSE listing standards, shareholders of US companies must be
given the opportunity to vote (of which the result is advisory in nature)
on all equity compensation plans applicable to any employee, director
or other service provider of a company (or on material revisions
thereto), with limited exceptions set forth in the NYSE rules. Under
Dutch law and the DCGC, binding shareholder approval is only required
for equity compensation plans (or changes thereto) for members of the
executive board and supervisory board, and not for equity
compensation plans for other groups of employees.
§The NYSE listing standards require certain transactions with related
parties to be reviewed by a company’s audit committee or another
independent body of the board of directors for potential conflicts of
interest, and for the audit committee or other independent body to
prohibit such a transaction if it determines it to be inconsistent with the
interests of the company and its shareholders. However, foreign private
issuers can rely on home country practice with respect to review and
approval of related party transactions. ING has adopted internal
policies and procedures for the purposes of identifying, assessing, and
recording conflicts of interest, including with respect to whether related
party transactions are on customary or arm’s length terms. These
policies and procedures are intended, if and to the extent required
under applicable law, prudential rules and other applicable guidelines,
to enable the Executive Board and Supervisory Board to assess the
terms of these intended transactions.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 133 |
Item 16H. Mine Safety Disclosure
Not applicable.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 134 |
Item 16I. Disclosure Regarding Foreign Jurisdictions
that Prevent Inspections
Not applicable.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 135 |
Item 16J. Insider Trading Policies
ING has adopted insider trading policies and procedures governing the
purchase, sale, and other dispositions of our securities by directors, senior
management, employees, and ING itself that are reasonably designed to
promote compliance with applicable insider trading laws, rules, and
regulations, and any listing standards applicable to us. Reference is made
to Exhibit 11 to this Form 20-F for the policy on 'Insider trading' and
‘Market Abuse’.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 136 |
Item 16K. Cybersecurity
Introduction
Cybercrime remains a continuous threat to companies in general and to
financial institutions in particular. Both the frequency and the intensity of
attacks continue to increase on a global scale. The sophistication and
implications of ransomware attacks are of particular concern in the threat
landscape. Phishing or email-based social engineering attacks, usually
used to initiate ransomware/malware infection or plant an info/password
stealer for password reuse of valid accounts, or drive-by compromise
attacks. Distributed denial of service attacks, against financial sector and
digital services operators are used for reputational damage and/or
extortion. There has been noticeable increase in supply chain attacks using
compromised 3rd party vendors as a delivery of attack vectors. This
includes abusing cloud misconfigurations to gain access to cloud
infrastructure and applications.
and detect and respond to- distributed denial-of-service (DDoS), targeted
attacks and more specific ransomware attacks is of the highest priority.
Based on regular scenario analysis done in ING’s first line of defence,
additional defensive controls continue to be embedded in the organisation
as part of the overall internal control framework and are continuously re-
assessed against existing and new threats.
exchange of information via different consumer channels, use of and
dependency on third-party vendors for services are likely to present
ongoing cybercrime-resilience and IT-security challenges, both in the short
and medium-term. ING continuously invest in fraud awareness and fraud
IT and Cyber Risk Assessment and Reporting
Chief Information Security Officer (CISO) is predicting, preventing,
engineering, and Identity and Access Management are preventive
measures to define, implement and review components that mitigate the
risk of unauthorised access to IT systems and the data processed and
stored therein. Security detection and Response functionality is
implemented to identify and provide timely alerts of malicious behaviour.
Cyber threat assessments delivers awareness about new and existing
threats and vulnerabilities targeting ING infrastructure.
We continued to invest in cybersecurity and third‑party risk controls
aligned with DORA requirements, ensuring greater resilience, operational
continuity, and readiness for the regulatory enforcement timeline.
industry, but are increasingly hitting its supply chains. We are monitoring
these Cybersecurity risks from our suppliers, via the Third-Party Cyber Risk
Management process. This process is part of the generic risk management
framework as defined in the Non-Financial Risk Framework Policies. These
policies are detailed out in a set of Minimum Standards, amongst which
The policy documents (policies, minimum standards, process control
standards) identify inherent risks and contain objectives and controls to
mitigate identified inherent risks as well as a section on roles and
responsibilities regarding IT and controls.
The different processes for assessing, identifying, and managing material
risks from cybersecurity threats address the objectives as defined in the
Information and Technology Risk Policy.
The Global CISO and key security positions are held by internal staff. ING
Group IT Audit function is fully internally staffed. The key controls in the
risk management framework relevant for internal control over financial
reporting are being audited by an external auditor.
In addition, ING continues to strengthen its global cybercrime resilience
through collaboration, with financial industry peers, law enforcement
authorities, government (e.g. National Cyber Security Centre) and Internet
Cybersecurity incidents
impacted the availability of ING banking channels for private individuals in
Belgium, Italy and the Netherlands. The other incident caused temporary
interruptions in third-party service availability in the Polish mobile
payment system. Both incidents were swiftly contained, minimising the
impact to our customers.
are likely to materialise and have a material adverse impact in the near
future.
Cybersecurity Governance
LoD”) model. The 3 LoD model aims to provide a sound governance
framework for financial and non-financial risk management by defining
and implementing three risk management ‘layers’, with distinct roles,
execution, and oversight responsibilities. In 2025 the Paradigm Shift
program changed the way IT Risk is reported by implementing the IT Risk
Opinion Reporting process and the increasing use of IT Risk Metrics over
manual Key Control Testing. That has also resulted in defining a Global CoE
IT & Cyber Risk Management within the 1st line Global CISO department
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 137 |
that owns the IT Risk Opinion process and functionally steers the local 1st
line CoE’s IT & Cyber Risk Management. The Global Information and
Technology Risk department is the 2nd LoD which objectively challenges
the execution in the 1st LoD and 3rd LoD Corporate Audit Services (CAS)
provides an independent assessment of the internal controls.
The IT Risk Opinion Reporting process ensures that local entities report
their IT Risk posture on a quarterly basis using the IT Risk metric results
available on the IT Risk Metric Dashboards (ITRMD) and where needed
additional manual Key Control Testing via the IT Risk Management
Platform (ITRMP). The ITRMD and ITRMP dashboards also enables the local
1st line entities to continuous management of its own control state.
Material deviations found by the 1st LoD or by 2nd LoD (through second-
line monitoring, i.e. quality assurance, risk assessments, etc.) or by the 3rd
LoD (internal IT audits), are monitored by also 2nd LoD and 3rd LoD to
ensure adequate mitigation of issues and risks by 1st LoD. The Global IT
Risk Opinion report, which is the summary of all local IT Risk Opinion
reports, is presented to and discussed with the IT Bank NFRC every quarter.
The Risk monitoring processes, as described, report the cybersecurity risks
to the Bank non-financial risk Committee on a quarterly basis. The 3LoD
reports quarterly (CAS reports) to the Management Board Banking,
the key reports issued during the quarter and the follow-up of reported
findings. The 3LoD Annual Report to the Management Banking Board,
Executive Board and Audit Committee provides the relevant results of the
CAS activities and a CAS’ view on the adequacy and effectiveness of ING’s
processes for controlling its activities and managing its risk in all the areas
of ING.
informed of key IT / cybersecurity risks on a quarterly basis via Non-
Financial Risk updates, and IT risks are included as well in regular
Integrated Risk updates. In addition, the MBB is immediately informed of
any material cybersecurity incident after it occurred. The Risk Committee
(RiCo) of ING’s Supervisory Board (SB) receives the aforementioned Non-
Financial Risk (NFR) update as well. Whenever a larger cyber incident
occurs, this is in principle also discussed in the RiCo and SB on an ad hoc
basis.
Those quarterly reports are pre-discussed by the Bank Non-Financial Risk
Committee, in which senior NFR/Risk management is represented, before
they are shared with the MBB/EB and RiCo.
Relevant expertise
To ensure that the entire Workforce have appropriate competences and
capabilities to fulfil their assigned tasks and responsibilities, ING developed
Global Job Profiles which are embedded in the Global Job Architecture.
These profiles describe in detail and regularly assess the maturity of the
workforce on required competences and capabilities as well as on
behavioural aspects. Development gaps, if any, are identified quickly,
regularly reviewed, and closed when possible. Relevant training and
certification are being offered by the Tech academy or the local IT
academies to help our employees develop further.
Every year ING enrols a mandatory cybersecurity e-learning to all
countries, covering both in- and external employees. The content is based
on the basic cybersecurity topics, and it is mandatory during the year for
all new onboarded employees as well. The Management Board steers on
92% completeness (due to in/outflow, maternity leaves, illness) this is
proven realistic. During the year there are many global (newsletters) and
local (presentations) initiatives to cover the trending cybersecurity threat
topics.
The annual programme of both EB/MBB and SB include recurring topics
related to IT/ digitalisation, such as IT risk management, operational
resilience, cybersecurity, ransomware, artificial intelligence, data and
analytics development. The Permanent Education Plan complements
these sessions with a curriculum of key priority topics- including IT/
digitalisation - to keep the boards up to date and further strengthen their
knowledge.
Cybersecurity, and since 2024 the SB has established a dedicated
Technology & Operations Committee. Cybersecurity updates are provided
to the Technology & Operations Committee (including in combined
sessions with the Risk Committee) by management. In the Management
Board Banking of ING Bank, which has ING Groep as its sole shareholder, a
dedicated Chief Technology Officer role is embedded. The Global Head of
CISO reports directly to the CTO. The CTO is a technology executive with
over 20 years of experience in leadership roles in the financial industry.
The CTO has a strong understanding of data, technology, the application
of it in ING’s operations and the risks related to it.
ING Global CISO is actively involving internal and external stakeholders on
actions to manage cybersecurity relevant measures and impacts. This
includes staff, board members, customers, partners, suppliers,
governments, and regulators. Examples of active involvement are a yearly
mandatory cybersecurity e-learning, covering both in- and external
employees, ING podcasts, webinars and round table sessions with clients
and suppliers, and on our websites we provide useful information to
improve resilience for retail customers.
Part III
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 139 |
Item 17. Consolidated Financial Statements
Not applicable.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 140 |
Item 18. Consolidated Financial Statements
Reference is made to the Consolidated financial statements of ING Group on page F-223.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 141 |
Item 19. Exhibits
The following exhibits are filed as part of this Annual Report:
Exhibit 1.1 | Amended and Restated Articles of Association of ING Groep N.V., dated 12 May 2022 (incorporated by reference to Exhibit 99.1 of ING Groep N.V.’s Report on Form 6-K filed on 17 May 2022) |
Exhibit 2.1 | Description of Securities Registered under Section 12 of the Exchange Act |
Exhibit 2.2 | Subordinated Indenture, dated 18 July 2002, between the Company and The Bank of New York (incorporated by reference to Exhibit 2.1 of ING Groep N.V.’s Annual Report on Form 20-F for the year ended 31 December 2002, File No. 1-14642 filed on 27 March 2003) |
Exhibit 2.3 | Third Supplemental Indenture, dated 28 October 2003, between the Company and The Bank of New York (incorporated by reference to Exhibit 2.4 of ING Groep N.V.’s Annual Report on Form 20-F for the year ended 31 December 2003, File No. 1-14642 filed on 30 March 2004) |
Exhibit 2.4 | Fourth Supplemental Indenture, dated 26 September 2005, between the Company and The Bank of New York (incorporated by reference to Exhibit 4.2 of ING Groep N.V.’s Report on Form 6-K filed on 23 September 2005) |
Exhibit 2.5 | Sixth Supplemental Indenture, dated 13 June 2007, between the Company and The Bank of New York (incorporated by reference to Exhibit 4.1 of ING Groep N.V.’s Report on Form 6-K filed on 12 June 2007) |
Exhibit 2.6 | Indenture, dated as of April 16, 2015, between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, (incorporated by reference to Exhibit 4.1 of ING Groep N.V.’s Report on Form 6-K filed on 16 April 2015) |
Exhibit 2.7 | First Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 16 April 2015, in respect of 6.000% Perpetual Additional Tier 1 Contingent Convertible Capital Securities (incorporated by reference to Exhibit 4.2 of ING Groep N.V.’s Report on Form 6-K filed on 16 April 2015) |
Exhibit 2.8 | Second Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 16 April 2015, in respect of 6.500% Perpetual Additional Tier 1 Contingent Convertible Capital Securities (incorporated by reference to Exhibit 4.3 of ING Groep N.V.’s Report on Form 6-K filed on 16 April 2015) |
Exhibit 2.9 | Senior Debt Securities Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as Trustee, dated 29 March 2017 (incorporated by reference to Exhibit 4.1 of ING Groep N.V.’s Report on Form 6-K filed on 29 March 2017) |
Exhibit 2.10 | First Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 29 March 2017, in respect of 3.150% Fixed Rate Senior Notes due 2022, 3.950% Fixed Rate Senior Notes due 2027 and Floating Rate Senior Notes due 2022 (incorporated by reference to Exhibit 4.2 of ING Groep N.V.’s Report on Form 6-K filed on 29 March 2017) |
Exhibit 2.11 | Second Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 2 October 2018, in respect of 4.100% Fixed Rate Senior Notes due 2023, 4.550% Fixed Rate Senior Notes due 2028 and Floating Rate Senior Notes due 2023 (incorporated by reference to Exhibit 4.1 of ING Groep N.V.’s Report on Form 6-K filed on 2 October 2018) |
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 142 |
Exhibit 2.12 | Third Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 9 April 2019, in respect of 3.550% Fixed Rate Senior Notes due 2024 and 4.050% Fixed Rate Senior Notes due 2029 (incorporated by reference to Exhibit 4.1 of ING Groep N.V.'s Report on Form 6-K filed on 9 April 2019) |
Exhibit 2.13 | Third Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 10 September 2019, in respect of 5.750% Perpetual Additional Tier 1 Contingent Convertible Capital Securities (incorporated by reference to Exhibit 4.1 of ING Groep N.V.'s Report on Form 6-K filed on 10 September 2019) |
Exhibit 2.14 | Fourth Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 1 April 2021, in respect of 1.726% Callable Fixed-to-Floating Rate Senior Notes due 2027, 2.727% Callable Fixed-to-Floating Rate Senior Notes due 2032 and Callable Floating Rate Senior Notes due 2027 (incorporated by reference to Exhibit 4.1 of ING Groep N.V.'s Report on Form 6-K filed on 1 April 2021) |
Exhibit 2.15 | Fourth Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 14 September 2021, in respect of 3.875% Perpetual Additional Tier 1 Contingent Convertible Capital Securities and 4.250% Perpetual Additional Tier 1 Contingent Convertible Capital Securities (incorporated by reference to Exhibit 4.1 of ING Groep N.V.'s Report on Form 6-K filed on 14 September 2021) |
Exhibit 2.16 | Fifth Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 28 March 2022, in respect of 3.869% Callable Fixed-to- Floating Rate Senior Notes due 2026, 4.017% Callable Fixed-to-Floating Rate Senior Notes due 2028, 4.252% Callable Fixed-to-Floating Rate Senior Notes due 2033 and Callable Floating Rate Senior Notes due 2026 (incorporated by reference to Exhibit 4.1 of ING Groep N.V.'s Report on Form 6-K filed on 28 March 2022) |
Exhibit 2.17 | Sixth Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 11 September 2023, in respect of 6.083% Callable Fixed-to- Floating Rate Senior Notes due 2027, 6.114% Callable Fixed-to-Floating Rate Senior Notes due 2034 and Callable Floating Rate Senior Notes due 2027 (incorporated by reference to Exhibit 4.1 of ING Groep N.V.'s Report on Form 6-K filed on 11 September 2023) |
Exhibit 2.18 | Seventh Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated as of 19 March 19 2024, in respect of 5.335% Callable Fixed- to-Floating Rate Senior Notes due 2030 and 5.550% Callable Fixed-to-Floating Rate Senior Notes due 2035 (incorporated by reference to Exhibit 4.1 of ING Groep N.V.'s Report on Form 6- K filed on 19 March 2024) |
Exhibit 2.19 | Eighth Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 25 March 2025, in respect of 4.858% Callable Fixed-to- Floating Rate Senior Notes due 2029, 5.066% Callable Fixed-to-Floating Rate Senior Notes due 2031, 5.525% Callable Fixed-to-Floating Rate Senior Notes due 2036 and Callable Floating Rate Senior Notes due 2029 (incorporated by reference to Exhibit 4.1 of ING Groep N.V.'s Report on Form 6-K filed on 25 March 2025) |
Exhibit 2.20 | Fifth Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 9 September 2025, in respect of 7.000% Perpetual Additional Tier 1 Contingent Convertible Capital Securities (incorporated by reference to Exhibit 4.1 of ING Groep N.V.'s Report on Form 6-K filed on 9 September 2025) |
Exhibit 8 | List of Subsidiaries of ING Groep N.V. |
Exhibit 11 | Insider Trading Policies |
Exhibit 12.1 | Certification of the Registrant’s Chief Executive Officer pursuant to Section 302 of the Sarbanes Oxley Act of 2002 |
Exhibit 12.2 | Certification of the Registrant’s Chief Financial Officer pursuant to Section 302 of the Sarbanes- Oxley Act of 2002 |
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 143 |
Exhibit 13.1 | Certification of the Registrant’s Chief Executive Officer pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 |
Exhibit 13.2 | Certification of the Registrant’s Chief Financial Officer pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 |
Exhibit 15.1 | Consent of KPMG Accountants |
Exhibit 97 | Clawback rules for erroneously awarded variable remuneration for executive officers (incorporated by reference to Exhibit 97 of ING Groep N.V.'s Annual Report on Form 20-F for the year ended 31 December 2023, File No. 1-14642 filed on 8 March 2024) |
Exhibit 101 | Inline eXtensible Business Reporting Language (Inline XBRL) |
Exhibit 104 | Cover Page Interactive Datafile (embedded in Exhibit 101) |
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 144 |
Signatures
The registrant hereby certifies that it meets all the requirements for filing on Form 20-F and that it has duly caused
and authorised the undersigned to sign this annual report on its behalf.
ING Groep N.V.
(Registrant)
By:/s/T. Phutrakul
T. Phutrakul
Chief Financial Officer
Date: February 23, 2026
Additional
information
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 146 |
Capital management
ING’s capital management strategy is designed to
maintain a robust capital position that adequately
covers all material risks, including economic risks,
across the Group, while ensuring compliance with
applicable local and global regulatory
requirements. At the same time, the strategy
supports sustainable value creation for
shareholders and enables ING to serve its clients
and underpin commercial activities. Despite an
uncertain and volatile geopolitical environment,
ING’s capital position remained strong during the
year. At both consolidated and entity levels, ING
maintains sufficient capital buffers to withstand a
range of adverse stress scenarios.
Capital management strategy
Group Treasury (GT) is responsible for maintaining adequate capitalisation
across ING Group and its banking entities to support the management of
risks associated with ING’s business activities. This includes capital
planning, allocation, and management within the Group, as well as the
execution of capital market, term capital funding, and risk management
transactions. ING employs an integrated approach to assessing capital
adequacy, whereby GT considers regulatory and internal economic capital
metrics alongside the interests of key stakeholders, including customers,
shareholders, and rating agencies.
ING applies the following main capital definitions:
§Common Equity Tier 1 (CET1) capital consists of shareholders’ equity
after the correction for applicable regulatory adjustments. The CET1
ratio is calculated as CET1 capital divided by risk-weighted assets
(RWAs).
§Tier 1 capital is defined as CET1 capital plus Additional Tier 1 (AT1)
securities and other regulatory adjustments. The Tier 1 capital ratio is
defined as Tier 1 capital divided by RWAs.
§Total capital consists of Tier 1 capital plus Tier 2 subordinated liabilities,
after regulatory adjustments. The Total capital ratio is calculated as
Total capital divided by RWAs.
§ING’s CET1 target ratio is built on the CET1 requirements specified for
ING, potential increase in the regulatory requirements, the potential
impact of a standardised and predetermined stress scenario and
available mitigating actions, and general uncertainties in its baseline
planning.
§Leverage ratio (LR) is defined as Tier 1 capital divided by the leverage
exposure.
§Minimum Required Eligible Liabilities (MREL)/Total Loss Absorbing
Capacity (TLAC) is Total capital plus senior unsecured bonds and
amortisations. Related MREL and TLAC ratios are expressed relative to
both risk-weighted assets and leverage exposure.
Processes for managing capital
GT ensures adherence to ING’s solvency risk appetite statements by
capital planning and executing capital management transactions. The
ongoing assessment and monitoring of capital adequacy is embedded in
the capital planning process as part of the internal capital adequacy
assessment process (ICAAP) framework. As part of the dynamic business
planning process, ING prepares a capital and funding plan on a regular
basis for all its material businesses, and continuously assesses the timing,
need and feasibility for capital management actions in scope of its
execution strategy. Sufficient financial flexibility should be preserved to
meet important financial objectives. Risk appetite statements are at the
foundation of the capital plan and are cascaded to the different businesses
in line with ING’s risk management framework. Contingency capital
measures and early warning indicators are in place – in conjunction with
ING’s contingency and recovery plan – to support the strategy in times of
stress.
Adverse planning and stress testing, which reflect the outcome of the
annual risk assessment, are integral components of ING’s risk and capital
management framework. It allows us to (i) identify and assess potential
vulnerabilities in ING’s business model, business portfolios or operating
environment; (ii) understand the sensitivities of the core assumptions used
in ING’s strategic and capital plan; and (iii) improve decision-making and
business steering through balancing risk and return following a forward-
looking and prudent management approach.
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Capital position as of 31 December 2025
ING Group capital position according to CRR III / CRD V | ||
in EUR million | 2025 | 2024 |
Shareholders’ equity 1 | 49,698 | 50,314 |
- Interim profits not included in CET1 capital | -2,125 | -2,152 |
- Other adjustments | -3,006 | -2,902 |
Regulatory adjustments | -5,130 | -5,054 |
Available common equity Tier 1 capital | 44,567 | 45,260 |
Additional Tier 1 securities | 7,459 | 7,965 |
Regulatory adjustments additional Tier 1 | 112 | 66 |
Available Tier 1 capital | 52,138 | 53,291 |
Supplementary capital Tier 2 bonds | 10,608 | 9,852 |
Regulatory adjustments Tier 2 | 98 | 50 |
Available Total capital | 62,845 | 63,194 |
Risk weighted assets | 340,739 | 333,708 |
Common equity Tier 1 ratio | 13.1% | 13.6% |
Tier 1 ratio | 15.3% | 16.0% |
Total capital ratio | 18.4% | 18.9% |
1Shareholders' equity is determined in accordance with IFRS-EU.
Capital developments
In 2025, we adjusted our CET1 capital ratio target to ~13% to cater for
higher (expected) capital requirements. Operating at the right level of
capital is in the best interests of all our stakeholders, including our
customers and the economies where we do business. The CET1 target level
of ~13% is well above the prevailing maximum distributable amount (MDA)
level of 11.03% at 31 December 2025, implying a management buffer of
about 195 basis points.
The CET1, Tier 1 and Total capital ratios decreased compared to the end of
2024, primarily due to the continued distribution of CET1 capital to steer
towards the CET1 capital ratio target, as well as higher risk-weighted
assets. ING Group had a CET1 ratio of 13.1% as of 31 December 2025
(13.6% at 31 December 2024). ING Group’s Tier 1 ratio decreased from
16.0% to 15.3% and the Total capital ratio decreased from 18.9% at the
end of 2024 to 18.4% at the end of 2025.
CET1 capital decreased, primarily due to additional distributions, partly
offset by the inclusion of net profit after dividend reserving. Next to the
regular 50% distribution of resilient net profit, ING distributed an additional
€3.6 billion, mostly through share buybacks, to converge towards its
external CET1 target of ~13%. Risk-weighted assets increased by €7.0
billion in 2025, mainly as a result of business growth, partly mitigated by
the RWA relief from significant risk-transfer (SRT) transactions executed in
November. The combined impact from the implementation of CRR III and
other model updates on ING’s CET1 ratio was negligible. At both the
consolidated and entity level, ING has sufficient buffers to withstand
various stressed scenarios.
Risk transfer
ING employs securitisation initiatives as part of its capital management
strategy to achieve effective risk transfer, optimise RWAs, and support
efficient capital allocation. These transactions, which may include
securitisations but also credit insurance, credit derivatives and guarantees,
are executed in accordance with applicable EU regulatory requirements.
ING ensures that securitisation activities meet prudential standards,
maintain the continued effectiveness of risk transfer, and are supported by
a sound economic rationale. In November 2025, ING successfully executed
two significant risk transfer transactions, aligned with these objectives.
Capital velocity initiatives are embedded in ING’s capital planning
processes and are consistent with the Group’s risk appetite and capital
targets.
Dividend and distribution policy
ING’s distribution policy is a pay-out ratio of 50% of resilient net profit.
Resilient net profit is defined as net profit adjusted for significant items not
linked to the normal course of business. The 50% pay-out may be in the
form of cash, or a combination of cash and share repurchases, with the
majority in cash. Additional distributions are to be considered periodically,
taking into account alternative opportunities, macroeconomic
circumstances and the outcome of our capital planning. The prerequisite
for a distribution is a CET1 ratio of at least the prevailing MDA level after
distribution.
For 2025, the resilient net profit amounts €6,327 million, equal to the IFRS-
EU net result, of which €3,164 million was reserved for regular distribution
outside of CET1 capital, reflecting ING’s distribution policy of a 50% pay-
out ratio.
Following ING’s distribution policy of a 50% pay-out ratio on resilient net
profit:
§A final dividend over 2024 of €0.71 per share was paid was paid in May
2025.
§An interim dividend over 2025 of €0.35 per share was paid in August
2025.
§The boards have proposed to pay a final cash dividend over 2025 of
€0.736 per share. This is subject to the approval by shareholders at the
Annual General Meeting on 14 April 2026.
In addition, ING announced two additional distributions of €3.6 billion in
total in 2025:
§An additional distribution of €2.0 billion, by means of a share buyback
programme, was announced on 2 May 2025. Between 2 May 2025 and
27 October 2025, almost 101 million ordinary shares were repurchased
for a total consideration of €2.0 billion.
§An additional distribution of €1.6 billion was announced on 30 October
2025, of which €1.1 billion as a share buyback programme and €0.5
billion as an additional cash distribution. Between 30 October 2025 and
31 December 2025, approximately 17.5 million of ordinary shares were
repurchased for a total consideration of around €0.4 billion.
Regulatory requirements
Capital adequacy and regulatory capital requirements are based on the
standards issued by the Basel Committee on Banking Supervision (the
Basel Committee) and implemented in the European Union Directives
through the Capital Requirements Regulation (CRR) and Capital
Requirements Directive (CRD), as implemented by De Nederlandsche Bank
(DNB) and the European Central Bank (ECB). Under the CRR, the minimum
Pillar 1 capital requirements applicable to ING Group are a CET1 ratio of
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 148 |
4.5%, a Tier 1 ratio of 6.0%, and a Total capital ratio of 8.0% of
risk‑weighted assets.
The overall SREP CET1 requirement, including buffer requirements, for ING
Group at a consolidated level increased during 2025, mainly due to an
increase of the countercyclical buffer requirement (CCyB), and was 11.03%
at 31 December 2025. This requirement is the sum of a 4.5% Pillar 1
requirement, a 0.93% Pillar 2 requirement, a 2.5% capital conservation
buffer (CCB), a 0.93% CCyB, 0.16% Sectoral Systemic Risk buffer (s-SyRB),
and a 2.0% Other Systemically Important Institutions (O-SII) buffer that is
set separately for Dutch systemic banks by DNB. This requirement
excludes the Pillar 2 guidance, which is not disclosed. ING met the
externally imposed regulatory capital requirements in 2025.
ING’s fully loaded CET1 requirement stood at 11.09% at the end of 4Q2025
(4Q2024: 10.88%), which is higher than the prevailing CET1 ratio
requirement. This reflects an update of the s-SyRB in Belgium, an increase
in the CCyB requirements in Belgium, Poland and Spain, and a higher Pillar
2 requirement.
The MDA trigger level stood at 11.03% per end of 4Q2025 for CET1,
12.84% for Tier 1 Capital, and 15.25% for Total capital. These MDA levels
are in line with the application of Art.104a in CRD V, which allows ING to
partly fulfil the total Pillar 2 requirement with Additional Tier 1 and Tier 2
capital.
An MDA requirement on the leverage ratio of 3.5% applies to ING Group. In
the event that ING Group breaches an MDA level, ING may face restrictions
on dividend payments, coupons on AT1 securities and payment of variable
remuneration.
MREL and TLAC requirements
The minimum requirement for own fund and eligible liabilities (MREL) and
total loss absorbing capacity (TLAC) apply to ING Group at the consolidated
level of the resolution group. MREL and TLAC provide additional capacity to
absorb losses and facilitate recapitalisation in the case of resolution. ING
Group has a single point of entry resolution strategy.
MREL requirements, including buffer requirements, were 28.22% on RWA
and 7.24% on leverage exposure as of December 2025. TLAC requirements
were 23.60% of RWA and 6.75% of leverage exposure as of December
2025. ING meets these MREL/TLAC requirements with a MREL/TLAC ratio of
31.8% on RWA and 9.4% on leverage exposure at the end of December
2025. MREL is for ING Group more binding than TLAC.
Regulatory developments
In 2024, the European Union adopted CRR III and CRD VI, implementing the
finalised Basel III framework. These regulations became effective as from 1
January 2025, with several elements subject to phased implementation. In
particular, the output floor will be introduced gradually over a multi‑year
period, with certain transitional provisions extending through 2032.
CRR III impacts RWA measurement through:
§enhancing the robustness and/ or risk sensitivity of the standardised
approaches for credit risk, credit valuation adjustment (CVA) risk, and
operational risk;
§constraining the use of the internal model approaches by placing limits
on certain inputs used to calculate capital requirements under the
internal ratings-based (IRB) approach for credit risk, and by removing
the use of the internal model approaches for CVA risk and for
operational risk; and
§the introduction of a risk-sensitive output floor based on the
standardised approaches.
Ratings
ING’s credit ratings and outlook are shown in the table below. Each of
these ratings only reflects the view of the applicable rating agency at the
time the rating was issued. Any explanation of the significance of a rating
may only be obtained from the rating agency. Scope has been added as
fourth rating agency in 2025, with comparable credit ratings.
Main credit ratings of ING at 31 December 2025 | ||||
S&P | Moody’s | Fitch | Scope | |
ING Groep N.V. | ||||
Issuer rating | ||||
Long-term | A- | n/a | A+ | AA- |
Short-term | A-2 | n/a | F1 | S-1+ |
Outlook | Stable | Stable 1 | Stable | Stable |
Senior unsecured rating | A- | Baa1 | A+ | A+ |
ING Bank N.V. | ||||
Issuer rating | ||||
Long-term | A+ | A1 | AA- | AA- |
Short-term | A-1 | P-1 | F1+ | S-1+ |
Outlook1 | Stable | Stable | Stable | Stable |
Senior unsecured rating | A+ | A1 | AA- | AA- |
1Outlook refers to the senior unsecured rating.
A security rating is not a recommendation to buy, sell or hold securities.
Each rating should be evaluated independently of other ratings. There is
no assurance that any credit rating will remain in effect for any given
period of time, or that it will not be lowered, suspended, or withdrawn
entirely by the rating agency if, in the rating agency’s judgement,
circumstances so warrant. ING accepts no responsibility for the accuracy
or reliability of the ratings.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 149 |
Risk management
As a global financial institution with a strong
European base, offering banking services, ING is
exposed to a variety of risks. We manage these
through a comprehensive risk management
framework that integrates risk management into
strategic planning and daily business activities.
This aims to safeguard ING’s financial strength and
reputation by promoting the identification,
measurement and management of risks at all
levels of the organisation. Taking measured risks
aligned with our risk appetite is core to ING’s
business.
This section sets out how ING manages its risks on a day-to-day basis.
It explains how the risk management function is embedded within the
organisation based on the ‘three-lines-of-defence’ (3 LoD) model. It
describes the key risks that arise from ING’s business model and how
these are managed. The section provides qualitative and quantitative risk
disclosures on solvency, credit, market, funding and liquidity, ESG
(environmental, social, and governance), operational, information
technology (IT), compliance, model, and business and strategy risks.
Basis of disclosures (*) The risk management section contains information relating to the nature and extent of the risks of financial instruments as required by International Financial Reporting Standards (IFRS) 7 ‘Financial Instruments: Disclosures’. These disclosures are an integral part of the ING Group Consolidated financial statements and are indicated by the symbol (*). This is applicable for the chapters, paragraphs, graphs, or tables within the risk management section that are indicated with this symbol in the respective headings or table header. This risk management section includes additional disclosures beyond those required by IFRS, such as certain legal and regulatory disclosures. Not all information in this section can be reconciled back to the primary financial statements and corresponding notes, as it has been prepared using risk data that differs from the accounting basis of measurement. Disclosures in accordance with Part Eight of the CRR3 and CRD VI, and as required by the supervisory authority, are published in our ‘Additional Pillar III Report’, which can be found on our corporate website ing.com. | ||
Top and emerging risks
The risks listed below are defined as the top existing and emerging risks
that could cause ING’s results to differ, in some instances materially, from
those anticipated. They may have a material impact on the reputation of
the company, introducing volatility in future operating results. These risks
can also impact ING’s medium- and long-term strategy, affecting its ability
to pay dividends, maintain appropriate levels of capital, or meet liquidity
and funding targets. An emerging risk is defined as a new or future risk
that might impact ING. Therefore, these risks require proactive
identification and monitoring as their impact on the organisation is more
difficult to assess compared to other risks. The key existing and emerging
risks are identified through the annual risk identification and risk
assessment process, covering both the ING Group and local entity
perspectives. Top risks are determined through an annual risk assessment
that evaluates the likelihood and potential impact of the risks, while
emerging risks are identified using horizon scanning and expert
judgement. The annual risk assessment is executed through risk surveys
and scenario analysis, with validation by senior management committees.
ING ensures that identified key risks feed into, among others, the annual
review of the Risk Appetite Framework (RAF) and Stress Testing
Framework. A number of key risks are listed below, with their sequence not
indicative of their likelihood or potential impact on ING.
Geopolitical risk
Geopolitical risk remains a key focus area for ING, requiring continuous
monitoring. In 2025, persistent policy uncertainty, intensifying trade
frictions, geo-economic confrontation and sanctions-related and supply-
chain restrictions shape the global landscape. These developments have
made cross-border trade and logistics increasingly challenging, driving up
costs and creating operational bottlenecks for global businesses. The
resulting uncertainty spills over into financial markets, heightening
volatility as investors react to tariff announcements and fluctuating risk
premium. These pressures translate into slower global growth and uneven
disinflation, with fragmented trade flows and elevated input costs
affecting productivity and monetary policy transmission. This could impact
ING beyond headline volatility, potentially leading to deteriorating credit
quality in exposed sectors, increased refinancing risk, and potential ratings
migration among ING clients. In addition, geopolitical events could trigger
the materialization of non-financial risks, for example the unavailability of
services provided by third-parties and increase of regulatory diversion.
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Global trade and policy volatility
Global trade tensions intensified, reshaping economic relationships and
market dynamics. Trade relations between major economies deteriorated
as the US adopted protectionist measures through higher trade tariffs,
while the EU targeted Chinese industrial goods, including electric vehicles.
Transatlantic disputes over technology controls, digital taxation, and
green-trade measures escalated, prompting retaliatory actions from China
and the EU. Allegations of dumping and subsidy disputes added pressure
in the markets, contributing to episodic equity sell-offs, wider credit
spreads, and pressure on supply chain-linked commodities. For ING, this
backdrop could lead to reduced client cash flows, variability in collateral
quality, and changes in market risk and funding dynamics.
Europe
Fragmented policymaking and structural fiscal pressures, such as ageing
populations and higher defence spending, added complexity to the
European landscape. Due to the persistence of a higher-for-longer rate
environment, fiscal rules and national adjustment plans were closely
monitored. The challenges in implementing reforms were particularly
visible in France, as shown by its parliamentary deadlock and budget
disputes. These developments resulted in wider sovereign spreads and
tighter credit conditions. This backdrop affects ING through pressure on
corporate and household lending, changes in fixed-income pricing, and
higher costs for euro funding.
United States
US policy in 2025 featured efforts to advance a comprehensive omnibus
policy package ('One Big Beautiful Bill') combining tax reforms, industrial
policy, and border measures. The subsequent focus on reshoring and
strategic support reinforced tariff use as a negotiation tool. While
discussions on de-dollarisation gained momentum, the US dollar remained
dominant in global funding. Potential effects for ING include sector-specific
credit risk, variability in global funding costs, and changes in USD liquidity,
influencing both client exposures and wholesale funding markets.
Asia-Pacific
Security tensions persisted across key maritime and airspace zones due to
Chinese military activity near Taiwan and the Philippines. In South Asia,
renewed skirmishes and diplomatic strains between India and Pakistan
added to instability. These conditions may dampen regional investment
sentiment and equity markets, affecting ING through weaker trade finance
flows, increased counterparty risk, and potential stress on clients with
Asia-focused supply chains.
Ukraine
The war in Ukraine remained a central driver of European geopolitical risk.
Military activity continued without decisive shifts, while cross-border
strikes and attacks on energy infrastructure escalated concerns. Sanctions
tightened throughout the year, and debates over using frozen Russian
assets for Ukraine’s reconstruction raised legal and financial stability
questions. This environment heightens volatility in energy-sensitive
sectors, exposing ING to heightened credit risk across Eastern European
portfolios and increasing compliance costs linked to sanctions screening.
For more information on sanctions, see 'Compliance risk’.
Our credit exposure remained stable at €547 million (2024: €550 million),
mainly with Central Bank liquidity facilities and other lending. A significant
part is guaranteed by international parents or benefits from strong
collateral.
Exposure in Russia
In March 2022, we announced a decision to no longer do new business
with Russian counterparties. Nevertheless, ING’s remaining operations in
Russia and with Russian counterparties are subject to various risks,
including, but not limited to, credit risk, changes in laws and regulations –
including sanctions and counter sanctions – as well as conflicts of law,
potential litigations, and events that would trigger loss of control.
In December 2025, ING’s remaining credit exposures to Russian
counterparties, booked outside of Russia, was €0.6 billion (2024: €1.0
billion).
On 28 January 2025, ING announced the proposed sale of ING Bank
(Eurasia) JSC to Global Development JSC. Completion of the transaction is
subject to various regulatory approvals. This transaction will effectively
end ING’s activities in the Russian market. Under the terms of the
agreement, Global Development will acquire all shares of ING Bank
(Eurasia) JSC, taking over all Russian onshore activities and staff. Global
Development intends to continue to serve customers in Russia under a
new brand. As of the date of this report and as announced in September
2025, the buyer has not received all necessary approvals yet. We continue
working towards completing the transaction and our exit from the Russian
market. In the meantime, we are in discussion with regulators on the
conflicting regulatory requirements in various jurisdictions with respect to
the activities of ING Bank (Eurasia) JSC.
ING expects a negative P&L impact of around €0.8 billion post tax. This
includes an estimated book loss of around €0.5 billion, representing the
difference between the sale price and the book value of the business. It
also includes an estimated negative impact of around €0.3 billion from
recycling the currency translation adjustment through P&L, which is
capital neutral. The sale is expected to have a negligible impact on ING’s
CET1 ratio.
Starting from 2024 a trend emerged whereby Russian parties hold
Western banks liable in Russian courts. The Russian parties claim that such
banks, by complying with sanctions imposed by the EU, US and other
authorities, have caused damage to the Russian party. There have also
been instances where Russian courts ruled in favour of the Russian party.
In these cases, Russian courts did not recognise such sanctions, did not
respect the choice of law and courts pursuant to the applicable contracts,
and held Russian subsidiaries of Western banks liable for acts by other
entities in that banking group. For more information on litigation involving
ING, see Note 42 ‘Legal proceedings’.
Middle East
The Israel-Gaza conflict moved through fragile ceasefire phases,
repeatedly disrupted by renewed hostilities. International mediation
efforts have focused on providing humanitarian relief to alleviate civilian
suffering and to reduce the risk of regional escalation. In the Red Sea,
maritime security incidents increased the risks of wider escalation, while
concerns grew over a potential spillover involving Israeli strikes on Iran and
Qatar. These developments could destabilise energy and logistics markets,
leading to higher commodity price volatility and operational challenges in
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key trading routes. For ING, this also affects valuation risks in client
portfolios and sovereign and corporate exposures in the area.
Interest rate risk
Diverging monetary policy paths among major central banks reintroduced
volatility in interest rate and foreign exchange markets. The European
Central Bank (ECB) shifted from easing policy rates to holding them steady
as euro-area disinflation continued. Meanwhile, the US Federal Reserve
adopted a gradual return towards neutral policy, implementing rate cuts
and suspending Treasury runoff amid persistent inflation pressures.
Uneven disinflation and country-specific fiscal concerns kept interest rate
highly volatile. For ING, this environment affects funding costs, asset
valuations, and client behaviour, with knock-on effects on earnings
stability.
Cyber and Information Technology (IT) risk
Cybercrime remains an important risk. Threat actors are increasingly
sophisticated, leveraging emerging technologies such as generative AI to
develop advanced attack methods, including state-linked campaigns
targeting financial infrastructure. Regulatory requirements, including the
EU’s Digital Operational Resilience Act (DORA), reshaped expectations for
ICT risk management, incident reporting, and third-party oversight.
Operational resilience and business continuity have become central
themes, with regulators emphasising resilience testing, recovery
objectives, and contingency planning for critical service providers. The
growing complexity of IT ecosystems and reliance on cloud and third-party
vendors amplify these challenges, making resilience a systemic priority.
Disruptions in IT systems or third-party services can lead to service
outages, transaction delays, data breaches, and financial or reputational
losses for ING. IT resilience remains a priority for ING to ensure continuity
of services and protection of data. ING continues to strengthen its
measurement and reporting of IT and cyber risks while further developing
its ability to recover from large-scale ransomware events and maintain
recovery readiness for global, shared systems. These efforts are supported
by the Global Infrastructure organisation and the Chief Information
Security Office (CISO).
AI risk
AI adoption accelerated across 2025, moving from pilots to day-to-day use
in areas such as analytics, software development, and customer service.
This rapid rollout introduced risks related to data privacy and security,
model accuracy, bias, and accountability. The EU AI Act established clearer
obligations for high-risk systems; however, uneven global governance
continues to create compliance complexity and cybersecurity challenges.
These factors increase ING’s exposure to cyber incidents, misuse, and
compliance gaps, which can lead to operational and reputational impact.
As AI adoption grows, ING continues to strengthen its governance and risk
oversight through specialised structures such as the AI Risk Committee
and Centre of Excellence (CoE).
Environmental risk
Environmental risk remains an important concern for ING and the global
financial sector. This risk is increasingly shaped by the interplay of physical
climate impacts and accelerating transition pressures. Extreme weather
events and climate-related disruptions are now becoming systemic,
affecting infrastructure, supply chains, and asset valuations. The global
shift towards decarbonisation continues, but with uneven momentum:
regulatory mandates and technological advances are driving progress,
while political reality in regions such as the US and EU to ease climate
policies brings uncertainty. At the same time, increased polarisation and
politicisation of climate and broader ESG issues can produce conflicting or
rapidly changing policy signals, complicating transition pathways and
planning for financial institutions and clients. This divergence heightens
climate risk and amplifies political and macroeconomic volatility.
Biodiversity loss and resource scarcity further strain environmental
stability. These developments translate into heightened credit risk in
vulnerable sectors, market risk through valuation shifts, and operational
risks through supply chain disruptions and physical damage. Reputational
risk also intensifies as some stakeholders demand credible climate action
and others demand less.
For more details and mitigation actions, see ‘Environmental, social and
governance risk’ and ‘Credit risk’.
Risk governance
Effective risk management requires company-wide risk governance. ING’s
risk and control structure is based on the ‘three-lines-of-defence’ model.
This model aims to provide a sound governance framework for risk
management by defining and implementing three lines. Each line has a
specific role and defined responsibilities, with the execution of tasks being
distinct from the control of these same tasks. The three lines work closely
together to identify, assess, mitigate, and monitor risks.
This governance framework is designed in such a way that risk is managed
in line with the risk appetite approved by the Management Board Banking
(MBB), the Executive Board (EB) and the Supervisory Board (SB), and this
approach is cascaded throughout ING.
Board-level risk oversight
Both the EB (for ING Group) and the MBB (for ING Bank) play an important
role in managing and monitoring our risk management framework. For
more information on the SB, MBB, and EB duties, and powers and
responsibilities in relation to risk management, see ‘Corporate
governance’.
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Risk committees
In 2025, ING changed its risk-led MBB-key committees structure reporting
into the EB and MBB. The key risk committees described below act within
the overall risk policy and delegated authorities granted by the EB and/ or
MBB:
§The Global Financial Risk Committee (GFRC) is the highest authority,
except for the MBB, to discuss and approve global policies,
methodologies, and procedures related to financial risk, covering
solvency, credit, market, funding & liquidity, and environmental, social
& governance risk. GFRC is a risk committee responsible for setting and
monitoring risk appetite statements & limits, stress testing and
financial risk frameworks & policies. The GFRC meets monthly.
§The Model Risk Management Committee (MoRMC) is the owner of the
overall governance around models’ approval. MoRMC approves
frameworks, policies and procedures related to model risks. It sets
model risk strategies and monitors the model risk profile against the
RAS. The MoRMC meets monthly.
§The Global Credit Committee – Transaction Approval (GCC(TA))
discusses and approves transactions that entail taking credit risk
(including investment risk), country, legal, and environmental and
social risk and approves Wholesale Banking transactions. The GCC(TA)
meets twice a week.
§Group Non-Financial Risk Committee (Group NFRC) oversees the holding
company ING Group and all subsidiaries other than ING Bank N.V. It
opines on and approves non-financial risk matters. It ensures
appropriate action is taken by responsible management.
§The Bank Non-Financial Risk Committee (Bank NFRC) is accountable for
the design and maintenance of the non-financial risk management
framework, including operational risk management, compliance and
legal policies, minimum standards, procedures and guidelines,
development of tools, methods, and key parameters (including major
changes) for risk identification, assessment, measurement, mitigating,
and monitoring/reporting. Bank NFRC meetings are held at least
monthly.
In addition, several other committees are involved in various steps in the different risk management frameworks, as illustrated in the graph below:
EB/MBB | |||||||||||||||||||
GFRC Group Financial Risk Ct | MoRMC Model Risk Management Ct | GCC-TA Global Credit Ct for Transaction approvals | Group & Bank NFRC Group & Bank Non-Financial Ct | ||||||||||||||||
CRC Credit Risk Ct | CRMC Credit Risk Model Ct | GUC Global Underwriting Ct | IT BNFRC | ||||||||||||||||
CARC Capital and ALM Risk Ct | AIRCO AI Risk Ct | DREC Distress Real Estate Ct | GPAC Global Client Protection and Approval Ct | ||||||||||||||||
TCRC Trading and CP Risk Ct | |||||||||||||||||||
ERC ESG Risk Ct | |||||||||||||||||||
1Although support functions are part of the first line of defence, they provide subject matter expertise to both the first and second lines of defence
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Three lines of defence
First line of defence | Second line of defence | Third line of defence | ||||||||||
Who | Who | Who | ||||||||||
Heads or their delegates of: banking business, support functions 1, geographies, countries | COO | CTO | Risk including Compliance | Internal audit function CAS | ||||||||
Responsible for §Running business with clients and accountable for assessing, controlling, mitigating, and reporting all risks affecting their businesses, to ensure risks are within risk appetite, i.e. 1st LoD risk management activities §Completeness and accuracy of the financial statements and risk reports with respect to their areas of responsibility | Responsible for §Setting, operating, and maintaining effective and efficient processes and running operations for the bank, and managing risks arising from these activities | Responsible for §Setting, operating, and maintaining an effective and efficient IT architecture and IT services provision for the bank, and managing risks arising from these activities | Responsible for §Develops, owns, and maintains the risk taxonomy, including clear and consistent risk categories and definitions, forming the basis for consistent risk identification, measurement, reporting, and escalation. §Defines and owns risk measurement methodologies, models, and assessment frameworks used to quantify and assess risks, including risk materiality assessment frameworks to determine which risks are significant. §Designs, maintains, and monitors the Risk Appetite Framework (RAF), ensuring that risk appetite statements, limits, and thresholds are aligned with strategy, capital planning, and regulatory expectations, and that breaches and emerging risks are escalated in a timely and transparent manner. §Provides independent monitoring and reporting of risks to support informed decision making and effective governance by senior management and governing bodies. §Oversees, advises, and challenges the First Line of Defence on risk management and compliance activities, providing subject matter expertise while maintaining independence. §Exercises escalation and veto powers in relation to activities or decisions assessed to present unacceptable risks, ensuring escalation to the appropriate governance bodies when required. | Responsible for §Independent assurance to the MB, the Audit Committee, and the SB on the quality and effectiveness of ING's internal control, risk management, governance, and implemented systems and processes in both the first and second lines of defence | ||||||||
1 | ||||||||||||
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Regional and business unit level
ING’s regional and/or business unit management have primary
responsibility for the management of risks (credit, market, funding and
liquidity, operational, IT, compliance and model) that arise in their daily
operations. They are accountable for the implementation and execution of
appropriate risk frameworks affecting their businesses in compliance with
procedures and processes at the corporate level. Where necessary, the
implementation is adapted to local requirements.
Organisational structure
The CRO function is organised along the lines of a matrix structure
integrating (i) the Global Risk functions, (ii) the Regional/Country Risk
functions at entity level, and (iii) the Risk Segments. Global Risk functions,
organised by risk types into risk domains (departments), are ultimately
responsible and accountable for the functional steering of the respective
risk type globally. They ensure a uniform taxonomy and methodology are
used for the setting of the relevant risk appetite levels, further cascading
risk appetite into detailed risk strategies, and for the effective monitoring
and reporting of risks, on an individual and consolidated basis.
The Group Chief Risk Officer (CRO) and the Chief Compliance Officer (CCO)
each have direct access to the SB Risk Committee and its chair. Conversely,
the chair of the SB Risk Committee holds periodic bilateral consultations
individually with both the Group CRO and the CCO.
The current organisation chart outlines the reporting lines within the risk
management function. A refreshed chart will be introduced in 2026 to
align with the enhanced Risk Strategy designed to further strengthen and
future‑proof the Group Risk organisation. The proposed updates are guided
by four key principles: (i) reinforcing the Risk organisation by emphasising
its core activities, (ii) enhancing global functional steering, (iii) enabling
business strategies through expanded skills and capabilities, and (iv)
building a more effective, agile, and streamlined Risk organisation.
The departments in the purple colour reflect hierarchical reporting lines,
whereas the dotted lines are for the functional reporting lines:
The Group Chief Risk Officer | |||||||||||||
 | |||||||||||||
Credit Risk | Financial Risk | ||||||||||||
Non-Financial Risk | Model Risk | ||||||||||||
Integrated Risk | Risk Culture & Behavioural Risk | ||||||||||||
Compliance Risk | Retail/ Rest of the World | ||||||||||||
Wholesale Banking | |||||||||||||
COO Risk | CRO Belgium | CRO Netherlands | CRO Germany | ||||||||||
Risk management framework
Risk policies and internal control documents
ING maintains a comprehensive system of risk management frameworks,
policies, mandatory instructions, procedures, and control standards
(collectively referred to as ‘internal control documents’), which establish
binding requirements for all ING locations. ING locations shall comply with
both internal control documents and local requirements. Internal control
documents are regularly reviewed, updated, and approved in accordance
with ING internal control binding principles. Senior management is
responsible for ensuring the implementation of, and staff adherence to,
internal control documents.
Internal risk management and control system
The enterprise risk management (ERM) framework and its related internal
control documents constitute the internal control framework in ING. The
ERM framework establishes an ING-wide governance model that aligns
strategy to risk appetite for all risk types. It applies to all business lines and
ING locations on the global and local level. The internal control framework
is based on the following principles:
§Consistent Risk Governance at global and local level is defined
and adhered to using the three-lines-of-defence model and clear
decision-making.
§Risk Appetite framework sets forward-looking risk limits and process to
ensure that risk-taking activities remain within acceptable ranges.
§Risk Taxonomy sets a common risk language to identify and manage
all relevant risks.
§Internal Control Documents facilitate effective risk management and
compliance with legal requirements and approved risk appetite.
§Continuous Risk Management Cycle to identify, assess, mitigate,
monitor, and report risks supported by adequate Risk Data and Risk
Systems.
§Strong risk culture and people that enable proactive risk management
balancing risk and reward.
The ERM Framework and underlying risk management frameworks are
based on the EBA Guidelines on Internal Governance (EBA/GL/2021/05,
2 July 2021) which is one of the drivers for the ING Governance Framework
and are aligned with the public criteria of the Committee of Sponsoring
Organisations of the Treadway Commission in Internal Reporting (COSO) –
Integrated Control Framework (2013 Framework).
Risk effectiveness
ING’s Internal Risk Management & Control (IRM&C) systems are designed
to safeguard risk effectiveness through:
§Adequate and timely risk identification, assessment, measurement,
mitigation, monitoring, reporting, and follow up; and
§Sufficient reliable insight that risks stay within risk appetite and can be
steered.
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Internal monitoring of risk effectiveness safeguards and confirms
adequate functioning of our IRM&C systems and enables ING to adapt
them in response to emerging risks, regulatory changes, or lessons
learned.
The effectiveness of risk management and internal control systems is
monitored through the risk management activities themselves (e.g. risk
monitoring and reporting) and through dedicated mechanisms (e.g. risk
framework monitoring and quality assurance).
Risk culture
At ING, we attach great importance to a sound risk culture, which is
essential for keeping the bank safe and secure. We determine our risk
culture as the way in which employees identify, understand, discuss, and
act on the many financial and non-financial risks we are confronted with
every day.
Learning
In 2025, we continued to expand and strengthen our required learning
curriculum. This foundational learning ensures all staff understand key
regulations, policies, and risks, supporting compliance and protecting the
bank and its customers. The curriculum is tracked centrally to support
timely completion. We continue to refine our learning formats to enhance
engagement and ensure practical application of knowledge. The topics
covered in 2025 were Conflicts of Interest, the Global Code of Conduct,
Operational Resilience, the EU AI Act, Cybersecurity, and Record Retention.
In addition, we continue to expand our learning offering on a range of risk
topics for targeted audiences across the bank, including risk staff. Working
with risk experts, the Risk Academy created and curated role-based
learning for risk colleagues, providing a wide selection of learning to
support both immediate job performance and long-term professional
growth.
Dutch Banker’s Oath
In the Netherlands, all employees working for a bank are required to take
the Banker’s Oath. By taking the oath, employees declare that they will
work with integrity, diligence, and in accordance with the related Code of
conduct (gedragscode). ING requires employees to follow trainings before
taking the actual oath – to understand the content and stress the
importance of the oath, enable all employees in the Netherlands to discuss
any dilemmas they may face in their daily work, and how to carefully
balance the interests of all ING’s stakeholders therein. All employees who
have taken the oath are subject to the Dutch Disciplinary Law and
Regulations, executed by the ‘Stichting Tuchtrecht Banken’ (Foundation for
Disciplinary Law of the banking sector).
Remuneration
ING aims to align its remuneration policy with its risk profile and the
interests of all stakeholders. For more information on ING’s remuneration
approach and its relation to the risk taken, see the Capital Requirements
Regulation (CRR) remuneration disclosure published on ing.com.
Risk cycle process
ING identifies, measures, and manages risks through five recurrent phases
of the management cycle: risk identification, risk assessment, risk
mitigation, risk monitoring, and risk reporting. The risk cycle process is
embedded within dedicated risk domain frameworks, such as the Non-
Financial Risk Framework, Model Risk Framework, and ESG Risk Framework.
Each risk domain is responsible for ensuring its risk cycle process and
frameworks are operational and effective. Key components of the risk
cycle process are defined in the Enterprise Risk Management Framework
as follows:
Risk identification
Risk identification is performed periodically through a joint effort of the
business and the risk management functions, linked to ING’s common risk
language and ad hoc in case of material internal or external change.
Risk assessment
Risk assessment ensures that each identified risk is assessed (qualitatively
and quantitatively) in a structured and fact-based manner and classified
for importance based on impact and likelihood. This enables management
to decide which of the identified risks need mitigating (control) measures,
how strict or tolerant these measures should be, and to assign a Risk
Owner.
Risk mitigation
Risks mitigation refers to the process of dealing with (and controlling) risk
exposures through one or a combination of strategies: risk-level reduction
(e.g. controls), risk avoidance (e.g. stop activity), risk transfer (e.g.
insurance or securitisation), and/or risk acceptance.
Risk monitoring
Risk monitoring is a continuous process, performed at individual and
aggregate risk level. It involves tracking and reviewing risk exposures and
the effectiveness of risk management strategies, including the design and/
or operating effectiveness of mitigating (control) measures.
Risk reporting
Risk reporting provides senior and local management with comprehensive
and actionable risk information. It facilitates the measurement,
monitoring, and oversight of risk exposures against risk appetite and
tolerance.
The Enterprise risk Management Framework is reviewed regularly to
ensure it reflects regulatory developments, and incorporates changes
based on external and internal triggers.
Risk Appetite Framework
The Risk Appetite Framework (RAF) is one of the key elements of the ERM
framework. Its objective is to set an appropriate risk appetite at a
consolidated level across different risk categories and to allocate the risk
appetite throughout the organisation.
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Procedure
The RAF procedure explains the setup of the overarching global risk
appetite. Within the RAF, ING monitors a range of financial and non-
financial risk metrics to ensure that our risk profile is in line with our risk
appetite while executing our strategy. ING’s RAF, which is approved by the
SB, defines the desired risk profile that is to be integrated in the strategic
decision-making and financial planning process. It is designed to be able to
withstand market volatility and stress, while meeting regulatory
requirements. The framework, including underlying metrics and
assumptions, is reviewed at least annually so that it remains relevant. The
RAF combines various financial and non-financial risk appetite statements
(RAS) into a single, coordinated approach.
Process
The RAF and underlying limit allocation are reviewed on an annual basis, or
more frequently if necessary, based on their monthly review in the MBB
and quarterly review in the EB and the SB. It is therefore a top-down
process, which bases itself on the ambition of the bank in terms of its risk
profile, the regulatory environment, and the economic context. Limits that
require SB approval are called boundaries, and the underlying instruments
supporting the boundaries require EB and MBB approval.
Step 1. Identify and assess ING’s key risks
The outcome of the risk-identification and risk-assessment process is used
as the starting point for the review of the RAF. Within this step, the risks
ING faces when executing its strategy are identified in the context of the
current economic, political, social, regulatory, and technological
environment. The assessment identifies whether the potential impact is
material and if it is sufficiently controlled.
Step 2. Set risk appetite framework
Based on ING’s risk assessment and risk purpose, boundaries and
instruments for the overarching risk frameworks are set. Once the
overarching risk appetite statements have been set and approved by the
EB/MBB and subsequently by the SB, the statements are translated into
risk type-specific statements and lower-level risk metrics. These are set
and approved by senior risk committees, like the Global Financial Risk
Committee (GFRC), Model Risk Management Committee (MoRMC) and Bank
Non-Financial Risk Committee (NFRC). Cascading is done via several
detailed risk appetite statements defined for each risk type. Together,
these statements aim to ensure compliance with the overarching
solvency, (credit) concentration, and funding and liquidity RAS.
ING includes climate risk in its RAF by, among other things, introducing
climate risk as one of the dimensions to determine sector concentration as
part of the credit risk appetite statements. In the coming years, ING will
extend the inclusion of climate risk impact on other risk types, ensuring
that potential risks – such as transition and physical risks – are properly
reflected in the RAF.
Step 3. Cascade into statements per risk type and business unit
The bank-wide risk appetite is defined per risk type, which is further
cascaded into the organisation. Risk appetite statements are then
translated into dedicated underlying risk limits that are used for the day-
to-day monitoring and management of ING’s risks. The risk appetite
statements serve as input for the quarterly planning process as well as for
the establishment of key performance indicators and targets for senior
management. The next graph is an illustrative and non-exhaustive
overview of the RAF.
Step 4. Monitor and manage underlying risk limits
To verify that ING remains within the RAF, it reports the risk positions vis-à-
vis their limits on a regular basis to senior management committees. A
monthly report is submitted to the MBB reflecting the exposure of ING
against the risk appetite. An extended report is submitted quarterly to the
EB and the SB’s Risk Committee. Moreover, the financial plan is checked
every quarter for potential limit excess within a one-year horizon, where in
the Strategic Dialogue the MBB can take mitigating measures or make
adjustments to the dynamic plan.
Stress testing
Stress testing is an important risk-management tool that provides input
for strategic decisions and capital planning. The purpose of stress testing is
to assess the impact of severe but plausible stress scenarios on ING’s
capital and liquidity position. Stress tests provide complementary and
forward-looking insights into vulnerabilities the bank is exposed to, with
regards to adverse macroeconomic circumstances, stressed financial
markets, changes in the political and geopolitical climate, and idiosyncratic
events. The outcomes of these stress tests help management get insight
into risk the bank is exposed to as well as mitigating actions to offset the
potential impact.
Types of stress tests
Within ING, we perform different types of stress tests. The most
comprehensive type of stress tests are the firm-wide scenario analyses,
which involve setting scenario assumptions for all the relevant
macroeconomic and financial market variables in all countries relevant to
ING. These assumptions usually follow a qualitative narrative that provides
a background to the scenario. In addition to firm-wide scenario analyses,
ING executes scenario analyses for specific countries or portfolios.
Furthermore, sensitivity analyses are performed, which focus on stressing
one or more risk drivers – usually without an underlying scenario narrative.
Finally, ING performs reverse stress tests, which aim to determine
scenarios that could lead to a predefined severe adverse outcome.
Process
ING’s stress-testing process consists of several stages:
§Risk identification and risk assessment: it identifies and assesses the
risks ING or the relevant entity is facing when executing its strategy,
based on the current and possible future economic, political,
regulatory, and technological environment. It provides a description of
the main risks and risk drivers related to the nature of ING’s business,
activities, and vulnerabilities.
§Scenario definition and parameterisation: based on the outcome of the
previous step, a set of scenarios is determined with the relevant scope
and set of risk drivers for each scenario, as well as its severity, the key
assumptions, and input parameters. The output of this phase includes a
quantitative description of the stress scenarios to be analysed, the
relevant output metrics, and, when applicable, a narrative description.
§Impact calculation and aggregation: based on the quantitative
description of the stress scenarios, the impact is determined for the
relevant scenario, scope, and horizon. The impact calculation and
aggregation can be part of a recurring process or part of a specific
process set-up for one-off stress tests.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 157 |
§Scenario reporting: for each stress test, a report is prepared after each
calculation, which describes the results of the scenario and gives a
recap of the scenario with its main assumptions and parameters. The
stress-test report is sent to the relevant risk committees and/or senior
management. It is complemented, if needed, with advice for
management action based on the stress-testing results.
§Scenario control and management assessment: depending on the
outcomes of the stress test and the likelihood of the scenario,
mitigating actions may be proposed. Mitigating actions may include,
but are not limited to, sales or transfers of assets and reductions
of risk limits.
Methodology
Detailed and comprehensive models are used to assess the impact of the
scenarios. In these models, statistical analysis is combined with expert
opinion to make sure the results adequately reflect the scenario
assumptions. The methodologies are granular and portfolio-specific, and
use different macroeconomic and market variables as input. The stress-
testing models are subject to review by Model Risk management and
underlying assessments are in line with financial and regulatory reporting
frameworks.
Framework Policy and Procedures | ING Group Risk Appetitie Framework (RAF) Integrated Risk | |||||||||||||||||||||||||||
Boundaries / Instruments | Boundaries and instruments for overarching and risk-type specific RAS Integrated Risk, Financial Risk, Credit Risk, Non-Financial Risk | |||||||||||||||||||||||||||
Solvency RAS Integrated Risk | Funding & Liquidity RAS Financial Risk | Concentration RAS Credit Risk | Credit RAS Credit risk | Market RAS Financial Risk | Non-Financial RAS Non-Financial Risk | Business & Strategy RAS Integrated Risk | Compliance RAS Compliance Risk | Model RAS Model Risk | ||||||||||||||||||||
Local application of RAF | ||||||||||||||||||||||||||||
Group Treasury Limits & Qualitative Statements | Local entity / Business Line / Unit A Limits & Qualitative Statements | Local entity / Business Line / Unit B Limits & Qualitative Statements | Local entity / Business Line / Unit C Limits & Qualitative Statements | |||||||||||||||||||||||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 158 |
Solvency risk
Introduction
Solvency risk is the risk of lacking sufficient capital to fulfil business
objectives, regulatory requirements, or market expectations. An insolvent
bank is unable to pay its debts and will be forced into bankruptcy.
The level and quality of capital is crucial for the resilience of individual
banks. Banks are expected to assess the risks they face and, in a forward-
looking manner, ensure they identify and manage all material risks. They
must also make sure these risks are sufficiently covered by loss-absorbing
capital to provide continuity if unexpected risks materialise in times of
stress. Given the interdependencies with other financial and non-financial
risks, this balancing act of capital adequacy needs to be done within a
sound and integrated management approach. It must coherently link and
align all the moving parts of the bank with its long-term business strategy.
ICAAP framework
ING’s internal capital adequacy assessment process (ICAAP) framework
aims to ensure that capital levels remain adequate – both forward-looking
and under adverse conditions, in terms of covering material risks-to-
capital from both a normative and an economic (internal) perspective. The
assessment of ING’s capital adequacy takes into account its business
strategy and risk profile, market environment, and operating macro
environment. This implies that views of various stakeholders, such as
regulators, shareholders, investors, rating agencies, clients, and customers
play an important role.
The continued strength of ING’s capital position, the adequacy of the
financial position, and risk management effectiveness are essential to
achieving the strategy. ING’s capital and funding strategy determines the
underlying ICAAP elements, and thereby contributes to ING’s business
continuity from different perspectives.
Managing ING’s capital entails finding the right balance between supply
and demand, while considering market and macro circumstances. The
process of balancing these strategic goals is captured in the ICAAP
framework. It is enabled by six building blocks and underlying elements
facilitating the ICAAP. The following building blocks have been defined in
the ICAAP framework, which are applied for both the ‘normative’ and
‘economic’ perspective, as defined in the ECB guide to ICAAP:
§Risk identification and assessment;
§Risk appetite;
§Solvency stress testing;
§Planning and forecasting;
§Capital management; and
§Continuity.
Risk identification and assessment
ING’s capital management and solvency risk management starts with the
risk-identification and risk-assessment process, which is performed on an
annual basis. In addition to this annual process, ING also reassesses its
risks as part of its capital adequacy statement, a quarterly process to
assess ING’s capital adequacy.
Risk appetite
ING has solvency risk appetite statements in place for the following
metrics: CET1 ratio, total capital ratio, leverage ratio, total loss-absorbing
capacity (TLAC), and minimum requirement for own funds and eligible
liabilities (MREL) based on RWA/leverage ratio and economic capital
adequacy.
Solvency stress testing
Solvency stress testing allows ING to examine the effect of plausible but
severe stress scenarios on the solvency position. It also provides insight
into which entities or portfolios are vulnerable to certain types of risks or
scenarios. Solvency stress testing is an important tool in identifying,
assessing, measuring, and controlling risks to capital, providing a
complementary and forward-looking perspective to other solvency risk
management tools. For solvency stress testing, ING follows the same steps
described in the overall section on stress testing.
The outcomes of solvency stress test analyses are taken into account in
capital planning, but also for setting risk appetite statements and the
capital management buffer.
Planning and forecasting
The capital and funding plan is an integral part of the dynamic plan, ING’s
financial and business planning process. For more information, see section
‘Capital management’.
Capital management
Formulation of the CET1 target is a key element in solvency risk
management. The target ratio, based on the management buffer concept,
enables ING’s senior management to steer, benchmark, and assess the
bank’s current and future capital levels much more efficiently. The target
level clearly supports trust-building among ING’s key stakeholders (e.g.
regulators, investors, and customers).
The capital management buffer aims to protect the interests of key
stakeholders and plays an important role in the overall capital adequacy
governance. The rationale behind the buffer is that it provides an
additional cushion on top of the (local) regulatory minimum requirements
(e.g. supervisory review and evaluation process (SREP) requirements) to
withstand a certain level of stress and facilitate awareness and
preparedness to take management actions. ING reviews its capital
management buffer on a regular basis to determine its effectiveness and
robustness, updating it as appropriate. For more information, see section
‘Capital management’.
Continuity
Risk events with high severity or significant deteriorations of economic and
market conditions beyond ING’s control could cause deviations from the
business and capital plans, which may result in a potential capital shortfall.
ING has established a continuity (safety) net of contingency and recovery
planning. This includes ongoing monitoring of relevant indicators to
maintain awareness and enable proactive action to ensure continuity. The
intervention measures, which can be activated when deemed necessary,
consist of predefined RWA reduction measures, as well as direct capital-
increasing measures. The escalation mechanisms are defined, governed,
and detailed in the contingency and recovery plans.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 159 |
Both plans aim to restore ING’s capital adequacy. Depending on the
severity of the situation, the contingency plan can be activated at this
warning phase, as well as trigger further mitigating action and the
formation of the contingency crisis teams. Further drops in capital levels
trigger the alert phase for recovery monitoring and/or the activation of the
recovery plan and corresponding crisis teams.
Assessing capital adequacy: Capital Adequacy Statement
The Capital Adequacy Statement is ING Group’s quarterly assessment of its
capital adequacy and considers different elements with respect to its
capital position. The degree to which ING’s capital position is considered
adequate depends on a variety of internal and external drivers:
§Current supervisory requirements and (expected) requirements going
forward;
§Current internal requirements and (expected) requirements going
forward (economic capital/view);
§Coherence of the available capital with the (realisation of) strategic
plans; and
§The ability to meet internal and external requirements in the case of
stressed events or should a risk materialise.
The Capital Adequacy Statement assesses the adequacy of ING’s capital
position in relation to the above-mentioned drivers and states the extent
to which the capital position consequently is considered as adequate. The
Capital Adequacy Statement document is prepared on a quarterly basis.
Additionally, each year the EB/MBB signs and provides a comprehensive
assessment of ING’s capital adequacy, supported by the ICAAP outcomes,
in the form of a capital adequacy statement.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 160 |
Credit risk
Introduction
Credit risk is the risk of loss from the default and/or credit rating
deterioration of clients. Credit risks arise in ING’s lending, financial markets,
and investment activities. The credit risk section provides information on
how ING measures, monitors, and manages credit risk, and gives an
insight into the portfolio from a credit risk perspective.
In the table below, we describe the different types of credit and
counterparty risk categories and include a reconciliation with the notes in
the financial statements:
Credit risk appetite and concentration risk framework (*)
The credit risk appetite and concentration risk framework is designed to
prevent undesired high levels of credit risk and credit concentrations within
various levels of the ING portfolio. It is derived from the concepts of
boundaries and instruments as described in the ING Risk Appetite Framework.
Credit risk appetite is the maximum level of credit risk ING is willing to
accept for growth and value creation. The credit risk appetite is linked to
the overall bank-wide framework and is expressed in quantitative and
qualitative measures.
The credit risk appetite is set at different levels and dimensions within ING.
The credit risk appetite framework specifies the scope and focus of the
credit risk ING is willing to take, as well the composition of the credit
portfolio, including the concentration and diversification objectives across
business lines, locations, sectors, and products.
Reconciliation between credit & counterparty risk categories and financial position (*) | ||
Credit risk categories | Notes in the financial statements | |
Lending risk: The risk that the client (counterparty, corporate, or individual) does not pay the principal interest or fees on a loan when they are due, or on demand for letters of credit (LCs) and guarantees provided by ING. | 2 | Cash and balances with central banks |
3 | Loans and advances to banks | |
4 | Financial assets at fair value through profit or loss | |
5 | Financial assets at fair value through other comprehensive income | |
7 | Loans and advances to customers | |
41 | Commitments | |
Investment risk: The credit default and risk rating migration risk that is associated with ING’s investments in bonds, commercial paper, equities, securitisations, and other similar publicly traded securities. This can be viewed as the potential loss that ING may incur from holding a position in underlying securities whose issuer's credit quality deteriorates or defaults. | 4 | Financial assets at fair value through profit or loss |
5 | Financial assets at fair value through other comprehensive income | |
6 | Debt securities | |
Money market risk: This arises when ING places short-term deposits with a counterparty in order to manage excess liquidity. In the event of a counterparty default, ING may lose the deposit placed. | 2 | Cash and balances with central banks |
3 | Loans and advances to banks | |
7 | Loans and advances to customers | |
Pre-settlement risk: This arises when a client defaults on a transaction before settlement and ING must replace the contract by a trade with another counterparty at the then prevailing (possibly unfavourable) market price. This credit risk category is associated with derivatives transactions (exchange-traded derivatives, over-the-counter (OTC) derivatives and securities financing transactions). | 4 | Financial assets at fair value through profit or loss |
14 | Financial liabilities at fair value through profit or loss | |
40 | Offsetting financial assets and liabilities | |
Settlement risk: This arises when there is an exchange of value (funds or instruments) and receipt from its counterparty is not verified or expected until after ING has given irrevocable instructions to pay or has paid or delivered its side of the trade. The risk is that ING delivers but does not receive delivery from its counterparty. | 4 | Financial assets at fair value through profit or loss |
11 | Other assets | |
14 | Financial liabilities at fair value through profit or loss | |
16 | Other liabilities | |
The credit concentration risk framework is composed of:
§Country risk concentration: Country risk is the risk that arises due to
events in a specific country (or group of countries). To manage the
maximum country loss ING is willing to accept, boundaries are
approved by the SB. The estimated level is correlated to the risk rating
assigned to a given country. Actual country limits are set by means of
country instruments, which are monitored monthly and updated when
needed. For countries with elevated levels of geopolitical or severe
economic cycle risk, monitoring is performed on a more frequent basis,
with strict pipeline and exposure management.
§Single name concentration (including secondary risk): ING has an
established credit concentration risk framework to identify, measure,
and monitor single name concentration, including secondary risk. The
same concept of boundaries and instruments is applicable.
§Sector and product concentration risk are managed via the credit risk
appetite framework.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 161 |
Credit risk models (*)
Within ING, internal CRR-compliant models are used to determine
probability of default (PD), exposure at default (EAD), and loss given
default (LGD) for regulatory and economic capital purposes. These models
also form the basis of ING’s IFRS 9 loan loss provisioning (see ‘IFRS 9
models’ below).
There are two main types of PD, EAD and LGD models used throughout the
bank:
§Statistical models are created where a large set of default or detailed
loss data is available. They are characterised by sufficient data points
to facilitate meaningful statistical estimation of the model parameters.
The model parameters are estimated with statistical techniques based
on the data set available.
§Hybrid models are statistical models supplemented with knowledge
and experience of experts from risk management and front-office staff,
literature from rating agencies, supervisors and academics. These
models are only used for ‘(ultra) low default portfolios’, where limited
historical defaults exist.
Credit risk rating process (*)
The majority of risk ratings are based on a risk rating (PD) model that
complies with the minimum requirements detailed in CRR/CRD, ECB
Supervisory Rules and European Banking Authority (EBA) guidelines. This
concerns all borrower types and segments.
ING’s PD rating models are based on a 1-22 internal risk rating scale (1 =
best rating; 22 = worst rating) referred to as the ‘master scale’, which
roughly corresponds to the rating grades that are assigned by external
rating agencies, such as Standard & Poor’s, Moody’s and Fitch. For
example, an ING rating of 1 corresponds to an S&P/Fitch rating of AAA and
a Moody’s rating of Aaa; an ING rating of 2 corresponds to an S&P/Fitch
rating of AA+ and a Moody’s rating of Aa1, and so on.
The 22 internal risk rating grades are composed of the following
categories:
§Investment grade (risk rating 1-10);
§Non-investment grade (risk rating 11-17);
§Performing Restructuring (risk rating 18-19); and
§Non-performing (risk rating 20-22).
The first three categories (1-19) are risk ratings for performing loans.
Ratings are calculated in IT systems with internally developed models,
based on manually or automatically fed data, or for part of the non-
performing loans set by the global or regional credit restructuring
department. Under certain conditions, the outcome of a manually fed
model can be challenged through a rating appeal process. For
securitisation portfolios, the external ratings of the tranche in which ING
has invested are leading indicators.
Risk ratings assigned to clients are reviewed at least annually, with the
performance of the underlying models monitored regularly. Some of these
models are global in nature, such as those for large corporates,
commercial banks, insurance companies, central governments, funds,
fund managers, project finance, and leveraged companies. Other models
are more regional or country-specific: there are PD models for small and
medium enterprises (SMEs) in the Netherlands, Belgium and Poland, as
well as residential mortgage and consumer loan models in the various
retail markets.
Rating models for Retail clients are predominantly statistically driven and
automated, such that ratings can be updated on a monthly basis. Rating
models for large corporates, institutions and banks include both statistical
characteristics and expert input, with the ratings being manually updated
at least annually. More frequent reviews (e.g. quarterly) are performed
where considered necessary.
Credit risk tools and data standards
The acceptance, maintenance, measurement, management, and
reporting of credit risks at all levels of ING are executed through single,
common credit risk data standards using shared credit risk tools that
support standardised and transparent credit risk practices. ING has chosen
to develop and implement credit risk tools centrally with the philosophy of
using a single source of data in an integrated way.
Within ING, credit risk exposures are classified into four sources: 1)
Consumer Lending (to private individuals), 2) Business Lending, 3)
Investment and Money Market and 4) Pre-settlement. ING’s credit
exposure is mainly related to lending to individuals (also referred to as
consumer lending, all Retail) and businesses (referred to as business
lending, both in Retail and Wholesale), followed by investments in bonds
and securitised assets, and money market (Wholesale). Loans to
individuals are mainly mortgage loans secured by residential property.
Loans (including guarantees issued) to businesses are often collateralised,
but may be unsecured based on the internal analysis of the borrower’s
creditworthiness. Bonds in the investment portfolio are generally
unsecured, but predominantly consist of bonds issued by central
governments and EU and/or OECD-based financial institutions. Secured
bonds, such as mortgage-backed securities and asset-backed securities,
are secured by the underlying diversified pool of assets (commercial or
residential mortgages, car loans and/or other assets) held by the securities
issuer. For money market, exposure is mainly deposits to central banks.
The last major credit risk source involves pre-settlement exposures which
arise from trading activities, including derivatives, repurchase transactions
and securities lending/borrowing transactions. This is also commonly
referred to as counterparty credit risk.
Overall portfolio (*)
During 2025, ING’s portfolio size increased by €41.1 billion (4.3 %) to
€1,002.9 billion outstanding. Foreign exchange rate changes had a €22.0
billion negative impact on the portfolio size, mainly driven by the
depreciation of the US dollar which had an impact of €16.6 billion mainly in
Wholesale Banking. Following this, net growth in Wholesale Banking was
€4.4 billion. Retail Banking outstandings increased by €38.4 billion mainly
due to underlying growth in residential mortgages.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 162 |
Rating distribution (*)
Overall, the rating class distribution remained stable in 2025. The share of
investment grade rating classes increased from 78.1 % to 79.3 %, while the
share of non-investment grade decreased from 19.9 % to 18.7 %.
Performing restructuring outstandings remained constant at 0.6 % of the
total portfolio in 2025, whereas non-performing loans (calculated
including Investment and Pre-Settlement exposures) decreased from 1.4 %
to 1.3 %.
With respect to the rating distribution within the business lines, in
Wholesale Banking, investment grade increased to 84.3 % from 83.7 %,
while non-investment grade exposures decreased to 13.9 % from 14.6 %
compared to 2024. Performing restructuring assets increased from 0.6 %
to 0.7 % of total Wholesale Banking assets where non-performing loans for
Wholesale Banking decreased from 1.2 % to 1.1 %.
For Retail Banking, investment grade increased to 75.4 % from 73.3 %,
while non-investment grade exposures decreased to 22.5 % from 24.4 % as
compared to 2024. Performing restructuring decreased to 0.6 % from 0.7 %
whereas NPL remained constant at 1.5 % in 2025.
Industry (*)
The industry breakdown is presented in accordance with the NAICS
definition. The increase of €41.1 billion in total volume during 2025 was
mainly due to the increase in Private Individuals (€28.7 billion) and Central
Governments (€13.4 billion) which was partially offset by the decrease in
Central Banks (€ 21.9 billion). The share of Private Individuals increased
from 39.5 % last year to 40.7 %.
Portfolio analysis per business line (*)
Outstandings per line of business (*) 1, 2, 3 | |||||||||
in EUR million | Wholesale Banking | Retail Banking | Corporate line | Total | |||||
Rating class | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | |
Investment grade | 1 (AAA) | ||||||||
2-4 (AA) | |||||||||
5-7 (A) | |||||||||
8-10 (BBB) | |||||||||
Non-investment grade | 11-13 (BB) | ||||||||
14-16 (B) | |||||||||
17 (CCC) | |||||||||
Performing Restructuring loans | 18 (CC) | ||||||||
19 (C) | |||||||||
Non-performing loans | 20-22 (D) | ||||||||
Total | |||||||||
Industry | |||||||||
Private Individuals | |||||||||
Central Banks | |||||||||
Natural Resources | |||||||||
Real Estate | |||||||||
Commercial Banks | |||||||||
Non-Bank Financial Institutions | |||||||||
Central Governments | |||||||||
Transportation & Logistics | |||||||||
Utilities | |||||||||
Food, Beverages & Personal Care | |||||||||
Services | |||||||||
General Industries | |||||||||
Lower Public Administration | |||||||||
Other | |||||||||
Total | |||||||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 163 |
Outstandings per line of business (*) - continued 1, 2, 3 | |||||||||
in EUR million | Wholesale Banking | Retail Banking | Corporate line | Total | |||||
Region | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | |
Europe | Netherlands | ||||||||
Belgium | |||||||||
Germany | |||||||||
Poland | |||||||||
United Kingdom | |||||||||
France | |||||||||
Spain | |||||||||
Luxembourg | |||||||||
Rest of Europe | |||||||||
America | |||||||||
Asia | |||||||||
Australia | |||||||||
Africa | |||||||||
Total | |||||||||
1Based on credit risk measurement contained in lending, pre-settlement, money market and investment activities.
2Based on the total amount of credit risk in the respective column using ING’s internal credit risk measurement methodologies. Economic sectors (industry) below 2% are not shown separately but grouped in Other.
3Geographical areas are based on country of residence, except for private individuals, for which the geographical areas are based on the primary country of risk.
Portfolio analysis per geographical area (*)
The portfolio analysis per geographical area re-emphasises the
international distribution of ING’s credit portfolio. The Netherlands
maintains the largest portfolio share in a single country with 21.5 %
(2024: 21.9 %) of the total amount, followed by Germany with 16.6 %
(2024: 16.2 %), and Belgium with 12.4 % (2024: 12.7 %).
In terms of region, the majority of the portfolio balance remained in
Europe with 80.1 % (2024: 79.6 %), followed by the Americas with 8.6 %
(2024: 9.3 %), and Australia with 6.0 % (2024: 6.0 %).
The top five countries within Rest of Europe based on outstandings were
Italy (€25.2 billion), Romania (€14.0 billion), Switzerland (€10.9 billion),
Türkiye (€9.7 billion) and Ireland (€5.2 billion).
The main contributors for the overall increase in outstanding are Germany
(€10.6 billion), Spain (€ 6.1 billion), Poland (€ 5.8 billion), and the
Netherlands (€4.8 billion).
Private Individuals remained the largest composition of portfolio balances
for the Netherlands at 62.0 % (2024: 58.3 %), Belgium at 37.7 %
(2024: 37.4 %), Germany at 68.5 % (2024: 68.8 %), and Australia at 68.1 %
(2024: 66.1 %).The decrease in Central Banks is mainly attributed to the
Netherlands (€13.8 billion), Belgium (€3.6 billion), and Asia (€3.1 billion).
In individual countries, the total share of investment grade/non-
investment grade remains substantial for the Netherlands at 98.5 %
(2024: 98.5 %), Germany at 98.7 % (2024: 98.9 %), and Belgium 96.8 %
(2024: 96.6 %).
In Europe, the increase in investment grade outstandings was mainly
observed in Germany (€11.9 billion), Spain (€ 8.4 billion), Poland (€ 5.2
billion), and France (€3.0 billion).
The net decrease in non-investment grade outstandings was mainly
observed in Spain (€ 2.4 billion), America (€1.9 billion), and Germany (€1.7
billion).
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 164 |
Outstandings by economic sectors and geographical area (*) 1 | ||||||||||||||
in EUR million | Region | Total | ||||||||||||
Industry | Netherlands | Belgium | Germany | Poland | Spain | United Kingdom | Luxembourg | France | Rest of Europe | America | Asia | Australia | Africa | 2025 |
Private Individuals | ||||||||||||||
Central Banks | ||||||||||||||
Natural Resources | ||||||||||||||
Real Estate | ||||||||||||||
Commercial Banks | ||||||||||||||
Non-Bank Financial Institutions | ||||||||||||||
Central Governments | ||||||||||||||
Transportation & Logistics | ||||||||||||||
Utilities | ||||||||||||||
Food, Beverages & Personal Care | ||||||||||||||
Services | ||||||||||||||
General Industries | ||||||||||||||
Lower Public Administration | ||||||||||||||
Other | ||||||||||||||
Total | ||||||||||||||
Rating class | ||||||||||||||
Investment grade | ||||||||||||||
Non-investment grade | ||||||||||||||
Performing Restructuring | ||||||||||||||
Non-performing loans | ||||||||||||||
Total | ||||||||||||||
1Geographical areas are based on country of residence, except for Private Individuals for which the geographical areas are based on the primary country of risk.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 165 |
Outstandings by economic sectors and geographical area (*) 1 | ||||||||||||||
in EUR million | Region | Total | ||||||||||||
Industry | Netherlands | Belgium | Germany | Poland | Spain | United Kingdom | Luxembourg | France | Rest of Europe | America | Asia | Australia | Africa | 2024 |
Private Individuals | ||||||||||||||
Central Banks | ||||||||||||||
Natural Resources | ||||||||||||||
Real Estate | ||||||||||||||
Commercial Banks | ||||||||||||||
Non-Bank Financial Institutions | ||||||||||||||
Central Governments | ||||||||||||||
Transportation & Logistics | ||||||||||||||
Utilities | ||||||||||||||
Food, Beverages & Personal Care | ||||||||||||||
Services | ||||||||||||||
General Industries | ||||||||||||||
Lower Public Administration | ||||||||||||||
Other | ||||||||||||||
Total | ||||||||||||||
Rating class | ||||||||||||||
Investment grade | ||||||||||||||
Non-investment grade | ||||||||||||||
Performing Restructuring | ||||||||||||||
Non-performing loans | ||||||||||||||
Total | ||||||||||||||
1Geographical areas are based on country of residence, except for Private Individuals for which the geographical areas are based on the primary country of risk.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 166 |
Credit risk mitigation (*)
ING uses various techniques and instruments to mitigate the credit risk
associated with an exposure and to reduce the losses incurred subsequent
to a default by a customer. The most common terminology used in ING for
credit risk protection is ‘cover’. While a cover may be an important
mitigant of credit risk and an alternative source of repayment, generally it
is ING’s practice to lend on the basis of the customer’s creditworthiness
rather than relying on the value of the cover.
Cover forms (*)
Within ING, there are two distinct forms of covers. First, where the asset
has been pledged to ING as collateral or security, ING has the right to
liquidate it should the customer be unable to fulfil its financial obligation.
As such, the proceeds can be applied towards full or partial compensation
of the customer's outstanding exposure. This may be tangible (such as
cash, securities, receivables, inventory, plant and machinery, and
mortgages on real estate properties) or intangible (such as patents,
trademarks, contract rights, and licences). Second, where there is a third-
party obligation, indemnification or undertaking (either by contract and/or
by law), ING has the right to claim from that third party an amount if the
customer fails in its obligations. The most common examples are
guarantees, such as parent guarantees, export credit insurances, or third-
party pledged mortgages. Insurance or reinsurance covers, including
comprehensive private risk insurance (CPRI) may be recognised as
guarantees and effectively function in an equivalent manner. ING accepts
credit risk insurance companies and export credit agencies (ECAs) as cover
providers.
Cover valuation methodology (*)
General guidelines for cover valuation are established with the objective of
ensuring consistent application within ING. These also require that the
value of the cover is monitored on a regular basis. Covers are revalued
periodically and whenever there is reason to believe that the market is
subject to significant changes in conditions. The frequency of monitoring
and revaluation depends on the type of cover.
The valuation method also depends on the type of covers. For asset
collateral, the valuation sources can be the customer’s balance sheet (e.g.
inventory, machinery, and equipment), nominal value (e.g. cash and
receivables), market value (e.g. securities and commodities), independent
valuations (e.g. commercial real estate) and market indices (e.g. residential
real estate). For third-party obligations, the valuation is based on the value
that is attributed to the contract between ING and that third party.
Where collateral values are used in the calculation of Stage 3 individual
loan loss provisions, haircuts may be applied to the valuation in specific
circumstances to sufficiently include all relevant factors impacting future
cash flows. ING applies haircuts to the collateral values of real estate,
shipping and aviation assets that are used in the calculation of the loss-
given-default in recovery scenarios. The haircut reflects the risks of
adverse price developments between the moment of valuation of an asset
and the actual settlement/cash receipt.
Cover values (*)
This section provides insight into the types of cover and the extent to
which exposures benefit from collateral or guarantees. The disclosure
differentiates between risk categories (lending, investment, money market
and pre-settlement). The most relevant types of cover include mortgages
(market values), financial collateral (cash and securities), guarantees, and
other covers (mainly pledges). The scope of covers in this overview has
been revised due to CRR3 implementation to align with regulatory
reporting. This explains the decrease in the values of 'other covers', which
had only a limited effect on the fully covered part of the portfolio, as ING's
portfolio remains well collateralised. Collateral covering financial market
transactions is valued on a daily basis (margining), and is as such not
included in the following tables. To mitigate the credit risk arising from
financial markets transactions, the bank enters into legal agreements
governing the exchange of financial collateral (high-quality government
bonds and cash).
The cover values are presented for the total portfolio of ING, both the
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 167 |
Cover values including guarantees received (*) | ||||||||
in EUR million | Cover type and value | Collateralisation | ||||||
2025 | Outstandings | Mortgages | Financial Collateral | Guarantees | Other covers | No cover | Partially covered | Fully covered |
Consumer lending | ||||||||
Business lending | ||||||||
Investment and money market | ||||||||
Total lending, investment and money market | ||||||||
of which NPL | ||||||||
Pre-settlement | ||||||||
Total Group | ||||||||
Cover values including guarantees received (*) | ||||||||
in EUR million | Cover type and value | Collateralisation | ||||||
2024 | Outstandings | Mortgages | Financial Collateral | Guarantees | Other covers | No cover | Partially covered | Fully covered |
Consumer lending | ||||||||
Business lending | ||||||||
Investment and money market | ||||||||
Total lending, investment and money market | ||||||||
of which NPL | ||||||||
Pre-settlement | ||||||||
Total | ||||||||
The above tables gives an overview of the collateralisation of ING’s total
portfolio. Excluding the pre-settlement portfolio, 56.1 % (2024: 55.9 %) of
ING’s outstandings were fully collateralised in 2025. Since investments
traditionally do not require covers, the ‘no covers’ percentage in this
portfolio is over 99.6 %.
Consumer lending portfolio (*)
The consumer lending portfolio accounts for 40.6 % (2024: 39.4 %) of ING’s
total outstanding, primarily consisting of residential mortgage loans and
consequently most collateral consists of mortgages. Mortgage values are
collected in an internal central database and in most cases external data is
used to index the market value.
A significant part of ING’s residential mortgage portfolio is in the
Netherlands (2025: 35.0 %, 2024: 35.0 % ), Germany (2025: 27.0 %,
2024: 27.3 %), Belgium (including Luxembourg) (2025: 12.0 %, 2024: 12.2 %)
and Australia (2025: 10.9 %, 2024: 10.6 %).
Business lending portfolio (*)
Business lending accounts for 38.2 % (2024: 38.3 %) of ING’s total
outstanding. Business lending presented in this section does not include
pre-settlement, investment and money market exposures.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 168 |
Credit quality (*)
ING uses three distinct statuses to categorise the management of clients
with (perceived) deteriorating credit risk profiles. ING makes use of Early
Warning Indicators (EWIs) in daily credit risk management processes,
which relate to a change in (internal and/or external) circumstances or
outlook of the specific obligor, the sector or the portfolio. ING usually
classifies a client with a 'watch list' status (Business lending only) when
there are early warning indicators triggered that detect an increased risk
profile. Watch list status requires more than usual attention, increased
monitoring and quarterly reviews. Some clients with a watch list or EWI
status may develop into a performing restructuring status or a non-
performing status. When there is increasing doubt as to the performance
and collectability of the client’s contractual obligations, the loans are
managed by Global Credit Restructuring (GCR) or by restructuring units in
the various regions and business units. The statuses and links with rating
grades are illustrated in the table below.
Credit risk ratings | ||||
Internal Rating Grade | 1-10 | 11-17 | 18-19 | 20-22 |
Category | Investment Grade | Non- investment Grade | Performing restructuring | Non- performing |
Credit risk management | Regular incl EWI/watch list | Regular incl EWI/watch list | Credit restructuring | Credit restructuring |
ECL Stage | 1/21 | 1/21 | 2 | 3 |
1Stage 2 in case one of the Stage 2 triggers is hit, where Watchlist files are always Stage 2 | ||||
Credit quality outstandings (*) | ||
in EUR million | 2025 | 2024 |
Performing not past due | ||
Business lending performing past due | ||
Consumer lending performing past due | ||
Non-performing | ||
Total lending and investment | ||
Money market | ||
Pre-settlement | ||
Total | ||
Past due obligations (*)
Retail Banking measures its portfolio in terms of payment arrears and
determines on a monthly basis if there are any significant changes in the
level of arrears. This methodology applies to Private Individuals as well as
Business lending. An obligation is considered ‘past due’ if it is more than
one day late, subject to materiality thresholds in line with Definition of
Default Regulation. ING aims to help its customers as soon as they are past
due by reminding them of their payment obligations. In its contact with
customers, ING aims to solve the (potential) financial difficulties by offering
a range of measures (e.g. payment arrangements, restructuring). If the
issues cannot be resolved because the customer is unable or unwilling to
pay, for example, the contract is sent to the recovery unit. The facility is
downgraded to risk rating 20 (non-performing) when the facility or obligor
– depending on the level at which the non-performing status is applied – is
more than 90 days past due and to risk rating 21 or 22 in case of an exit
scenario.
The table below represents the breakdown of lending and investment
credit risk outstandings that are performing by age and geographic area.
The past due but performing consumer lending outstanding increased by
€93 million, due to the increase in 1-30 days (€90 million) and 31-60 days
(€3 million).
The largest single country increase was in Belgium (€42 million), followed
by the Netherlands (€22 million), mainly in the 1-30 days bucket.
The largest decrease was seen in Australia (€21 million).
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 169 |
Ageing analysis (past due but performing): Consumer lending portfolio by geographic area, outstandings (*) | |||||||||
in EUR million | 2025 | 2024 | |||||||
Region | Past due for 1–30 days | Past due for 31–60 days | Past due for 61–90 days | Total | Past due for 1–30 days | Past due for 31–60 days | Past due for 61–90 days | Total | |
Europe | Netherlands | ||||||||
Belgium | |||||||||
Germany | |||||||||
Poland | |||||||||
Spain | |||||||||
Luxembourg | |||||||||
Rest of Europe | |||||||||
America | |||||||||
Asia | |||||||||
Australia | |||||||||
Africa | |||||||||
Total | |||||||||
Ageing analysis (past due but performing): Business lending portfolio by geographic area, outstandings (*) | |||||||||
in EUR million | 2025 | 2024 | |||||||
Region | Past due for 1–30 days | Past due for 31–60 days | Past due for 61–90 days | Total | Past due for 1–30 days | Past due for 31–60 days | Past due for 61–90 days | Total | |
Europe | Netherlands | ||||||||
Belgium | |||||||||
Germany | |||||||||
Poland | |||||||||
United Kingdom | |||||||||
France | |||||||||
Spain | |||||||||
Luxembourg | |||||||||
Rest of Europe | |||||||||
America | |||||||||
Asia | |||||||||
Australia | |||||||||
Africa | |||||||||
Total | |||||||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 170 |
Total past due but performing outstanding of business lending decreased
by €1.1 billion. The decrease was mainly witnessed in the 1–30 days past
due bucket (€1.6 billion) and was offset by the increase in 31-60 days (€0.5
billion) past due bucket, fully in the United Kingdom related to overdue
fees. The largest decreases were in Belgium (€0.7 billion) and America
(€0.6 billion), while the largest increase were in Australia (€0.2 billion),
Germany (€0.2 billion), Poland (€0.2 billion), and the United Kingdom (€0.2
billion).
Forbearance (*)
Forbearance occurs when a client is unable to meet their financial
commitments due to financial difficulties they are facing or are about to
face and ING grants them concessions. Forborne assets are assets for
which forbearance measures have been granted.
Forbearance may enable clients experiencing financial difficulties to
continue repaying their debt.
For business clients, ING mainly applies forbearance measures to support
clients with fundamentally sound business models that are experiencing
temporary difficulties. The aim is to maximise the client’s repayment
ability, thereby avoiding a default situation, and help the client to return to
a performing situation.
For ING Retail units, clear criteria have been established to determine
whether a client is eligible for the forbearance process. Specific approval
mandates are in place to approve the measures, as well as procedures to
manage, monitor, and report the forbearance activities.
ING reviews the performance of forborne exposures at least quarterly,
either on a case-by-case (Business) or portfolio (Retail) basis.
Both performing (risk ratings 1-19) and non-performing (risk ratings 20-22)
exposures are eligible for Forbearance measures. ING uses specific criteria
to move forborne exposures from non-performing to performing or to
remove the forbearance statuses that are consistent with the
corresponding European Banking Authority (EBA) standards. An exposure
is reported as forborne for a minimum of two years. An additional one-
year probation period is applied to forborne exposures that move from
non-performing back to performing.
Summary Forborne portfolio (*) | ||||||||
in EUR million | 2025 | 2024 | ||||||
Business line | Outstandings | Of which: performing | Of which: non-performing | % of total portfolio(1) | Outstandings | Of which: performing | Of which: non-performing | % of total portfolio(1) |
Wholesale Banking | ||||||||
Retail Banking | ||||||||
Total | ||||||||
Summary Forborne portfolio by forbearance type (*) | ||||||||
in EUR million | 2025 | 2024 | ||||||
Forbearance type | Outstandings | Of which: performing | Of which: non-performing | % of total portfolio(1) | Outstandings | Of which: performing | Of which: non-performing | % of total portfolio(1) |
Loan modification | ||||||||
Refinancing | ||||||||
Total | ||||||||
% of total portfolio is based on lending and investment outstandings.
Forborne assets increased by €644 million, mainly due to the increase of
€667 million in Retail Banking, which was offset by a €24 million decrease
in Wholesale Banking. The rise in Retail Banking forborne assets was
primarily driven by residential mortgages in the Netherlands, which
contributed €608 million. This increase was largely the result of the
implementation of an updated framework, under which more clients are
classified as forborne, while outflow is only allowed after a two-year
probation period.
In terms of forbearance type, the increase is mainly witnessed in
refinancing type (€487 million) driven by a few larger files in Wholesale
Banking.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 171 |
Modification of financial assets (*)
The following table shows:
§Financial assets that were modified during the year (i.e. qualified as
forborne) while they had a loss allowance measured at an amount
equal to lifetime ECL; and
§Financial assets that were reclassified to Stage 1 during the period
while being modified before.
§
Financial assets modified (*) | ||
in EUR million | 2025 | 2024 |
Financial assets modified during the period | ||
Amortised cost before modification | ||
Net modification results | - | - |
Financial assets modified since initial recognition | ||
Gross carrying amount at 31 December of financial assets for which loss allowance has changed to 12-month measurement during the period | ||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 172 |
Wholesale Banking (*)
Wholesale Banking forborne assets amounted to €5.9 billion (2024:
€5.9 billion), which represented 1.7 % (2024: 1.9 %) of the total Wholesale
Banking portfolio.
The net decrease in Wholesale Banking forborne assets was driven by a
€27 million reduction in non-performing forborne exposure and partially
offset by a €3 million rise in performing forborne exposures.
Wholesale Bankings' forborne assets show an increase in Telecom due to
refinancing, which was offset by a decrease in other sectors, such as real
estate, food, beverages & personal care, chemicals, health &
pharmaceuticals and natural resources. These five sectors accounted for
Wholesale Banking: Forborne portfolio by geographical area (*) | |||||||
in EUR million | 2025 | 2024 | |||||
Region | Outstandings | Of which: performing | Of which: non- performing | Outstandings | Of which: performing | Of which: non- performing | |
Europe | Netherlands | ||||||
Belgium | |||||||
Germany | |||||||
Poland | |||||||
United Kingdom | |||||||
Italy | |||||||
Rest of Europe | |||||||
America | |||||||
Asia | |||||||
Australia | |||||||
Africa | |||||||
Total | |||||||
Wholesale Banking: Forborne portfolio by economic sector (*) | ||||||
in EUR million | 2025 | 2024 | ||||
Industry | Outstandings | Of which: performing | Of which: non- performing | Outstandings | Of which: performing | Of which: non- performing |
Natural Resources | ||||||
Real Estate | ||||||
Transportation & Logistics | ||||||
Food, Beverages & Personal Care | ||||||
Services | ||||||
Automotive | ||||||
Utilities | ||||||
General Industries | ||||||
Retail | ||||||
Chemicals, Health & Pharmaceuticals | ||||||
Builders & Contractors | ||||||
Telecom1 | ||||||
Other | ||||||
Total | ||||||
1The presentation has been revised to separately disclose Telecom. Comparative figures have been adjusted accordingly.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 173 |
Retail Banking (*)
As of year end, Retail Banking forborne assets amounted to €7.6 billion
(2024: €6.9 billion), which represented 1.4 % (2024: 1.3 %) of the total Retail
Banking portfolio. Retail Banking performing forborne exposure increased
by €0.6 billion.
The main concentration of forborne assets in a single country was in
Belgium with 28.5 % (2024: 28.2 %) of total Retail Banking forborne assets
and 39.0 % (2024: 39.4 %) of the non-performing forborne assets. The other
significant single country concentration is in the Netherlands with 28.3 %
(2024: 22.5 %), which increased during 2025 because of the
implementation of a new framework for mortgages, and Germany having
Retail Banking: Forborne portfolio by geographical area (*) | |||||||
in EUR million | 2025 | 2024 | |||||
Region | Outstandings | Of which: performing | Of which: non- performing | Outstandings | Of which: performing | Of which: non- performing | |
Europe | Netherlands | ||||||
Belgium | |||||||
Germany | |||||||
Poland | |||||||
Spain | |||||||
Italy | |||||||
Türkiye | |||||||
Romania | |||||||
Rest of Europe | |||||||
America | |||||||
Asia | |||||||
Australia | |||||||
Africa | |||||||
Total | |||||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 174 |
Non-performing loans (*)
ING has aligned the regulatory concept of non-performing with that of the
definition of default. Hence, borrowers are classified as non-performing
when a default trigger occurs (non-exhaustive list):
§ING believes the borrower is unlikely to pay. The borrower has
evidenced significant financial difficulty, to the extent that it will have a
negative impact on the future cash flows of the financial asset. The
following events could be seen as indicators of financial difficulty:
–The borrower (or third party) has started insolvency proceedings;
–A group company/co-borrower has NPL status;
–Indication of fraud (affecting the company’s ability to service its
debt);
–There is doubt as to the borrower’s ability to generate stable and
sufficient cash flows to service its debt;
–Restructuring of debt; and
–ING has granted concessions relating to the borrower’s financial
difficulty, the effect of which is a reduction in expected future cash
flows of the financial asset below current carrying amount.
§The obligor has failed in the payment of principal, interest, or fees; the
total past due amount is above the materiality threshold, and this
remains the case for more than 90 consecutive days.
Furthermore, Wholesale Banking has an individual name approach, using
early warning indicators to signal possible future issues in debt service.
Also in Retail Banking early warning indicator frameworks have been
implemented.
The table below represents the breakdown of credit risk outstandings that
have been classified as non-performing by sector and business line.
Non-performing Loans: Outstandings by economic sector and business lines (*) 1 | ||||||
in EUR million | Wholesale Banking | Retail Banking | Total | |||
Industry | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 |
Private Individuals | ||||||
Natural Resources | ||||||
Food, Beverages & Personal Care | ||||||
Transportation & Logistics | ||||||
Services | ||||||
Real Estate | ||||||
General Industries | ||||||
Builders & Contractors | ||||||
Retail | ||||||
Utilities | ||||||
Chemicals, Health & Pharmaceuticals | ||||||
Telecom2 | ||||||
Other | ||||||
Total | ||||||
1Based on lending and investment outstandings.
2The presentation has been revised to separately disclose Telecom. Comparative figures have been adjusted accordingly.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 175 |
Non-performing loans: Outstandings by economic sectors and geographical area (*) | ||||||||||||||
in EUR million | Region | Total | ||||||||||||
Industry | Netherlands | Belgium | Germany | Poland | Spain | United Kingdom | France | Luxembourg | Rest of Europe | America | Asia | Australia | Africa | 2025 |
Private Individuals | ||||||||||||||
Natural Resources | ||||||||||||||
Food, Beverages & Personal Care | ||||||||||||||
Transportation & Logistics | ||||||||||||||
Services | ||||||||||||||
Real Estate | ||||||||||||||
General Industries | ||||||||||||||
Builders & Contractors | ||||||||||||||
Retail | ||||||||||||||
Utilities | ||||||||||||||
Chemicals, Health & Pharmaceuticals | ||||||||||||||
Telecom | ||||||||||||||
Other | ||||||||||||||
Total | ||||||||||||||
Non-performing loans: Outstandings by economic sectors and geographical area (*) | ||||||||||||||
in EUR million | Region | Total | ||||||||||||
Industry | Netherlands | Belgium | Germany | Poland | Spain | United Kingdom | France | Luxembourg | Rest of Europe | America | Asia | Australia | Africa | 2024 |
Private Individuals | ||||||||||||||
Natural Resources | ||||||||||||||
Food, Beverages & Personal Care | ||||||||||||||
Transportation & Logistics | ||||||||||||||
Services | ||||||||||||||
Real Estate | ||||||||||||||
General Industries | ||||||||||||||
Builders & Contractors | ||||||||||||||
Retail | ||||||||||||||
Utilities | ||||||||||||||
Chemicals, Health & Pharmaceuticals | ||||||||||||||
Telecom | ||||||||||||||
Other | ||||||||||||||
Total | ||||||||||||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 176 |
In 2025, the NPL portfolio decreased to €13.0 billion (2024: €13.3 billion),
mainly driven by the decrease of €0.6 billion in Wholesale Banking. The
decrease was offset by the increase in Retail Banking (€0.3 billion) in line
with strong portfolio growth, mainly in residential mortgages.
Total net decrease was mainly seen in sectors Utilities, Real Estate and
Food, Beverage & Personal Care while the largest increase was in Private
Individuals.
Loan loss provisioning (*)
ING recognises loss allowances based on the expected credit loss (ECL)
model of IFRS 9, which is designed to be forward-looking. The IFRS 9
impairment requirements are applicable to on-balance-sheet financial
assets measured at amortised cost or fair value through other
comprehensive income (FVOCI), such as loans, debt securities, and lease
receivables, as well as off-balance-sheet items such as undrawn loan
commitments and financial- and non-financial guarantees issued.
ING distinguishes between two types of calculation methods for credit loss
allowances:
§Collective 12-month ECL (Stage 1) and collective lifetime ECL (Stage 2)
for portfolios of financial instruments, as well as collective lifetime ECL
for credit-impaired exposures (Stage 3) below €1 million; and
§Individual lifetime ECL for credit-impaired (Stage 3) financial
instruments with exposures above €1 million.
IFRS 9 models (*)
ING’s IFRS 9 models leverage on the internal rating-based (IRB) models (PD,
LGD, EAD), which include certain required conservatism. To include IFRS 9
requirements, such regulatory conservatism is removed from the ECL
parameters (PD, LGD and EAD). The IFRS 9 models apply two other types of
adjustments to the IRB ECL parameters: (i) to the economic outlook and (ii)
for Stage 2 and Stage 3 assets only, to the lifetime horizon. The IFRS 9
model parameters are estimated based on statistical techniques and
supported by expert judgement.
ING has aligned the definition of default for regulatory purposes with the
definition of ‘credit-impaired’ financial assets under IFRS 9 (Stage 3). ING
has also aligned its definition of default between IFRS 9 and the regulatory
technical standards (RTS) and EBA guidelines.
Climate and environmental risks in IFRS 9 models (*)
Climate risk drivers (physical and transition risks) can reduce the ability of
businesses and households to fulfil their obligations due, under existing
lending contracts. These climate risks are partly reflected in IFRS9 ECL
through regular credit risk transmission channels such as the
macroeconomic forecast and relevant risk parameters.
On the other hand, future physical or transition risks from climate change
are not yet fully captured within the current ECL models. In our
assessment of physical risks, it is generally expected that these risks will
only become financially significant on the long-term horizon.
Consequently, for short- and medium-term loans, such risks are not
expected to lead to significant credit deterioration over the exposure’s
lifetime. For the long term, the probability and timing of physical risk
events remain highly uncertain. ING is however actively enhancing the
integration of physical and transition risks into collateral valuations,
ensuring that effects on property values are appropriately captured.
In case of risk events that have already occurred (e.g. floods, stranded
assets), the impact of such events is assessed in the calculation of Stage 3
individual provisions, collective SICR or management adjustments to ECL
models. For example, we consider whether affected assets have suffered
from a significant increase in credit risk (or are credit impaired) and
whether the ECL is appropriate.
Additionally, a management adjustment to ECL models for business
clients was introduced to specifically cover for medium- to long-term
transition risk on high greenhouse gas-emitting sectors. The management
adjustment reflects the risk of financial loss foreseen on the longer horizon
for lenders with higher transition risk in these high greenhouse gas-
emitting sectors as consequence of future carbon taxation. ‘See
Management adjustments applied this reporting period’.
ING is continuously improving on climate risk data, which will enable us to
further embed climate risks into the IFRS 9 ECL models. For more
information on ESG risk management, see ‘ESG risk’.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 177 |
Reconciliation gross carrying amount (IFRS 9 eligible) and statement of financial position | ||||||||||||||
in EUR million | 2025 | 2024 | ||||||||||||
Gross carrying amount | Loan loss provisions | Cash and on-demand bank positions | Reverse repurchase transactions | Cash collateral | Other | Statement of financial position | Gross carrying amount | Loan loss provisions | Cash and on-demand bank positions | Reverse repurchase transactions | Cash collateral | Other | Statement of financial position | |
Amounts held at central banks | 53,671 | -17 | -1,297 | 532 | 52,889 | 71,280 | -14 | -1,550 | 637 | 70,353 | ||||
Loans and advances to banks | 8,445 | -18 | 3,053 | 6,836 | 2,649 | 239 | 21,204 | 4,685 | -22 | 3,195 | 10,777 | 2,362 | 773 | 21,770 |
Financial instruments FVOCI loans | 3,244 | -6 | 3,238 | 1,671 | -7 | -56 | 1,608 | |||||||
Financial instruments FVOCI debt securities | 50,868 | -15 | -36 | 50,817 | 42,185 | -12 | 46 | 42,219 | ||||||
Securities at amortised cost | 54,366 | -11 | -487 | 53,867 | 50,701 | -15 | -413 | 50,273 | ||||||
Loans and advances to customers | 721,423 | -5,894 | 3,866 | 4,595 | 3,743 | 727,733 | 679,422 | -5,833 | 3,471 | 4,956 | 1,595 | 683,611 | ||
Total on-balance (IFRS 9 eligible) | 892,017 | -5,961 | 1,756 | 10,702 | 7,244 | 3,990 | 909,748 | 849,944 | -5,902 | 1,645 | 14,248 | 7,318 | 2,581 | 869,834 |
Guarantees and irrevocable facilities (IFRS 9 eligible) | 243,392 | -141 | 198,420 | -146 | ||||||||||
Total gross carrying amount (IFRS 9 eligible) | 1,135,409 | -6,101 | 1,048,364 | -6,049 | ||||||||||
This table presents the reconciliation between the statement of financial
position and the gross carrying amounts used for calculating the expected
credit losses. No expected credit loss is calculated for cash, on-demand
bank positions, reverse repurchase transactions, cash collateral received in
respect of derivatives, and other. Therefore, these amounts are not
included in the total gross carrying amount (IFRS 9 eligible). Other includes
hedge valuation adjustments, deferred acquisition costs on residential
mortgages, and a receivable which is offset against a liquidity facility.
The table below describes the portfolio composition over the different
IFRS 9 stages and rating classes. The Stage 1 portfolio represents 92.0 %
(2024: 91.1 %) of the total gross carrying amounts, mainly composed of
investment grade, while Stage 2 makes up 6.8 % (2024: 7.6 %) and Stage 3
makes up 1.2 % (2024: 1.3 %) of the total gross carrying amounts,
respectively.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 178 |
Gross carrying amount per IFRS 9 stage and rating class (*) 1,2 | |||||||||||||||||
in EUR million | 12-month ECL (Stage 1) | Lifetime ECL not credit impaired (Stage 2) | Lifetime ECL credit impaired (Stage 3) | Total | |||||||||||||
Rating class | Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions | |||||||||
2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | ||
Investment grade | 1 (AAA) | ||||||||||||||||
2-4 (AA) | |||||||||||||||||
5-7 (A) | |||||||||||||||||
8-10 (BBB) | |||||||||||||||||
Non-investment grade | 11-13 (BB) | ||||||||||||||||
14-16 (B) | |||||||||||||||||
17 (CCC) | |||||||||||||||||
Performing Restructuring | 18 (CC) | ||||||||||||||||
19 (C) | |||||||||||||||||
Non-performing loans | 20-22 (D) | ||||||||||||||||
Total | |||||||||||||||||
1Compared to the credit risk portfolio, the differences are due to undrawn committed amounts (€200 billion; 2024: €156 billion) and other positions (2025: nil ; 2024:€6 billion) not included in credit outstandings and non-IFRS 9 eligible assets (€ 68 billion; 2024: €75 billion) included in credit outstandings but not in the
gross carrying amounts.
2Stage 3 lifetime credit impaired provision includes €29 million (2024: €21 million) on purchased or
originated credit impaired.
Changes in gross carrying amounts and loan loss provisions (*)
The table below provides a reconciliation by stage of the gross carrying
amount and allowances for loans and advances to banks and customers,
including loan commitments and financial guarantees. The transfers of
financial instruments represent the impact of stage transfers upon the
gross carrying/nominal amount and associated allowance for ECL. This
includes the net-remeasurement of ECL arising from stage transfers, for
example, moving from a 12-month (Stage 1) to a lifetime (Stage 2) ECL
measurement basis.
The net-remeasurement line represents the changes in provisions for
facilities that remain in the same stage.
Please note the following comments with respect to the movements
observed in the table below:
§Stage 3 gross carrying amount decreased by €0.2 billion from €13.7
billion as at 31 December 2024 to €13.6 billion as at 31 December 2025,
mainly as a result of €3.5 billion net inflow into NPL (credit impaired) in
2025, which is offset by €2.3 billion derecognitions and repayments
and €1.5 billion write-offs and disposals. Following the decrease in
carrying amount, Stage 3 provisions slightly decreased by €33 million.
§Stage 2 gross carrying amounts decreased by €2.4 billion from €79.9
billion as at 31 December 2024 to €77.5 billion as at 31 December 2025,
largely driven by €15.7 billion net transfers from Stage 1 into Stage 2,
including the impact of changes in risk drivers (including updated
macro-economic forecasts), model redevelopments mainly for
Wholesale Banking models, and new Stage 2 overlays. This was offset
by a decrease of exposure by €18.1 billion due to derecognised
financial assets (including sales and repayments) and €1.2 billion
exposure moving to Stage 3. Stage 2 provisions increased by € 49.3
million to €1.2 billion as of 31 December 2025.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 179 |
Changes in gross carrying amounts and loan loss provisions (*) 1, 2 | ||||||||||||||||
in EUR million | 12-month ECL (Stage 1) | Lifetime ECL not credit impaired (Stage 2) | Lifetime ECL credit impaired (Stage 3) | Total | 12-month ECL (Stage 1) | Lifetime ECL not credit impaired (Stage 2) | Lifetime ECL credit impaired (Stage 3) | Total | ||||||||
Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions | |
2025 | 2024 | |||||||||||||||
Opening balance | ||||||||||||||||
Transfer into 12-month ECL (Stage 1) | - | - | - | - | - | - | - | - | - | - | ||||||
Transfer into lifetime ECL not credit impaired (Stage 2) | - | - | - | - | - | - | - | - | ||||||||
Transfer into lifetime ECL credit impaired (Stage 3) | - | - | - | - | - | - | - | - | ||||||||
Net remeasurement of loan loss provisions | - | - | - | - | ||||||||||||
New financial assets originated or purchased | ||||||||||||||||
Financial assets that have been derecognised | - | - | - | - | - | - | - | - | - | - | - | - | - | - | - | - |
Net drawdowns and repayments | - | - | - | - | - | - | - | - | ||||||||
Changes in models/risk parameters | - | - | - | - | - | |||||||||||
Increase in loan loss provisions | - | - | ||||||||||||||
Write-offs | - | - | - | - | - | - | - | - | ||||||||
Disposals | - | - | - | - | - | - | - | - | - | - | - | - | - | - | - | - |
Recoveries of amounts previously written off | ||||||||||||||||
Other movements | - | - | - | - | - | |||||||||||
Closing balance | ||||||||||||||||
1Stage 3 lifetime credit impaired provision includes €29 million (2024: €21 million) on purchased or originated credit impaired.
2The addition to the loan provision (in the consolidated statement of profit or loss) amounts to €1,304 million (2024: €1,194 million) of which €1,301 million (2024: €1,170 million) related to IFRS 9 eligible financial assets, €-5 million (2024: €9 million) to IFRS eligible commitments and €8 million (2024: €15 million) to
modification gains and losses on restructured financial assets.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 180 |
Exposure per stage, coverage ratio and stage ratios 2 | ||||||
in EUR million | 2025 | 2024 | ||||
Balance sheet | Gross carrying amount | Loan loss provisions | Stage ratio | Gross carrying amount | Loan loss provisions | Stage ratio |
Loans and advances to banks (including central banks) | 62,116 | 35 | 75,964 | 35 | ||
Stage 1 | 60,430 | 5 | 97% | 74,632 | 4 | 98% |
Stage 2 | 1,609 | 18 | 3% | 1,258 | 15 | 2% |
Stage 3 | 77 | 12 | 0% | 75 | 16 | 0% |
Loans and advances to customers | 721,423 | 5,894 | 679,422 | 5,833 | ||
Of which: Residential mortgages | 374,780 | 822 | 348,433 | 814 | ||
Stage 1 | 341,281 | 49 | 91% | 315,775 | 49 | 91% |
Stage 2 | 30,181 | 288 | 8% | 29,341 | 307 | 8% |
Stage 3 | 3,318 | 485 | 1% | 3,317 | 458 | 1% |
Of which: Consumer lending (excl. Residential mortgages) | 31,306 | 946 | 26,936 | 957 | ||
Stage 1 | 27,302 | 137 | 87% | 22,556 | 112 | 84% |
Stage 2 | 2,575 | 159 | 8% | 3,090 | 191 | 11% |
Stage 3 | 1,429 | 649 | 5% | 1,290 | 654 | 5% |
Of which: Loans to public authorities | 29,089 | 21 | 23,930 | 17 | ||
Stage 1 | 28,568 | 8 | 98% | 23,214 | 6 | 97% |
Stage 2 | 298 | 3 | 1% | 464 | 3 | 2% |
Stage 3 | 222 | 11 | 1% | 252 | 8 | 1% |
Of which: Corporate lending | 286,249 | 4,105 | 280,123 | 4,045 | ||
Stage 1 | 251,280 | 197 | 88% | 238,606 | 196 | 85% |
Stage 2 | 27,265 | 661 | 10% | 33,427 | 575 | 12% |
Stage 3 | 7,704 | 3,247 | 3% | 8,090 | 3,274 | 3% |
Other IFRS 9 eligible financial Instruments 1 | 351,870 | 173 | 293,187 | 180 | ||
Stage 1 | 335,471 | 51 | 95% | 280,161 | 43 | 96% |
Stage 2 | 15,559 | 49 | 4% | 12,308 | 39 | 4% |
Stage 3 | 840 | 72 | 0% | 718 | 98 | 0.2% |
Total gross carrying amount (IFRS 9 eligible) | 1,135,409 | 6,101 | 1,048,573 | 6,049 | ||
1Includes off-balance sheet IFRS 9 eligible guarantees and irrevocable facilities. See Note 1 'Basis of preparation and material accounting policy information'.
2The exposure classification to residential mortgages, consumer lending, and corporate lending is
aligned to the regulatory definition.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 181 |
of estimation uncertainty (*)
Methodology (*)
This section outlines our methodology for adopting and generating
macroeconomic scenarios. We apply this methodology when producing
our probability-weighted ECL, incorporating alternative scenarios and
management adjustments where necessary. These adjustments are made
when management believes the consensus forecast does not fully capture
the extent of recent credit or economic events. The macroeconomic
scenarios are applicable to the whole ING portfolio in the scope of IFRS 9
ECLs.
The IFRS 9 standard, with its inherent complexities and potential impact on
the carrying amounts of our assets and liabilities, represents a key source
of estimation uncertainty. In particular, ING’s reportable ECL numbers are
sensitive to the forward-looking macroeconomic forecasts used as model
inputs, the probability weights applied to each of the three scenarios, and
the criteria for identifying a significant increase in credit risk. As such,
these crucial components require consultation and management
judgement, and are subject to extensive governance.
Baseline scenario (*)
As a baseline for IFRS 9, ING has adopted a market-neutral view combining
consensus forecasts for economic variables (GDP, unemployment) with
market forwards (for interest rates, exchange rates, and oil prices). Input
from a leading third-party service provider is used to complement the
consensus with consistent projections for variables for which there are no
consensus estimates available (most notably house prices and – for some
countries – unemployment), to generate alternative scenarios, to convert
annual consensus information to a quarterly frequency, and to ensure
general consistency of the scenarios. As the baseline scenario is consistent
with the consensus view, it can be considered as free from any bias.
The relevance and selection of macroeconomic variables is defined by the
ECL models under credit risk model governance. The scenarios are
reviewed and challenged by a panels of ING experts.
Alternative scenarios and probability weights (*)
Two alternative scenarios are taken into account: an upside and a
downside scenario. The alternative scenarios have statistical
characteristics as they are based on the forecast deviations of the leading
third-party service provider.
To understand the baseline level of uncertainty around any forecast, the
leading third-party service provider keeps track of all its deviations (so-
called forecast errors) of the past 30 years. The distribution of forecast
errors for GDP, unemployment, house prices, and share prices is applied to
the baseline forecast creating a broad range of alternative outcomes. In
addition, to understand the balance of risks facing the economy in an
unbiased way, the leading third-party service provider runs a survey with
respondents from around the world and across a broad range of
industries. In this survey, respondents put forward their views of key risks.
Following the survey results, the distribution of forecast errors (that is
being used for determining the scenarios) may be skewed.
For the downside scenario, ING has chosen the 90th percentile of that
distribution because this corresponds with the way risk management
earnings-at-risk is defined within the Group. The upside scenario is
represented by the 10th percentile of the distribution. The applicable
percentiles of the distribution imply a 20 percent probability for each
alternative scenario. Consequently, the baseline scenario has a 60 percent
probability weighting. Please note that, given their technical nature, the
downside and upside scenarios are not based on an explicit specific
narrative and have not changed compared to previous year.
Macroeconomic scenarios applied (*)
The macroeconomic scenarios applied in the calculation of loan loss
provisions are based on the consensus forecasts.
Baseline assumptions (*)
The general picture that the consensus conveys is that global economic
growth is slowing compared to recent years. US growth is expected to
continue to outpace European markets, but the gap is narrowing down.
China is expected to continue a declining growth trend, but still at higher
rates than seen in advanced markets. Inflation is expected to remain near
target for most advanced economies, but a bit above for the United States.
With interest rates moderating, monetary conditions are turning more
favourable for growth. For the housing market, continued price growth is
expected for almost all main markets.
The December 2025 consensus expects global output (as measured by the
weighted average GDP growth rate of ING’s 25 main markets) to remain at
a constant 2.4 % from 2025-2027.
The eurozone economy has shown more resilience than expected despite
global headwinds, with sluggish but positive growth through 2025. The
coming years are expected to see modest growth rates as well. The trade
environment continues to be plagued by higher US tariffs and a stronger
euro. Expectations of a pickup in growth over the course of 2026 come
from stronger consumer spending and investment. German infrastructure
spending is expected to add to this momentum. Southern European
economies continue to benefit from European Recovery Fund investments.
Consensus expects the eurozone to have grown by 1.4 % in 2025, before
slowing to 1.1 % in 2026 and then recovering to 1.3 % in 2027.
Elsewhere in Europe, the growth outlook is stronger. Poland’s growth
momentum remains solid, growing faster than its European peers. The key
growth drivers over the near-term forecast are consumption and public
investments, such as those carried out under the National Recovery Plan
(KPO). The economy is expected to grow by 3.6 % in 2025, picking up to
Türkiye is to see stable growth of 3.5 % and 3.4 % in 2025 and 2026, as
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 182 |
domestic demand remains resilient and fixed investments and inventories
see an uptick. For 2027, a recovery to 3.7 % is expected.
The American economy has held its ground despite the tariff war and
slowing employment growth. Its characterisation by a K-shaped economy
where most of the growth comes from high-income consumers and tech
investments is likely to continue in 2026. Tariffs are not feeding into
inflation as much as expected earlier in the year, and inflation
expectations remain benign, although still above the 2% target. This has
prompted the Federal Reserve to resume its rate cutting cycle. Inflation is
expected to remain around 2.8 % and 2.9 % in 2025 and 2026 before
steadying down at 2.4 % in 2027.The US economy is expected to
experience steady growth of 2.0 % in 2025-2027.
For China, economic underperformance continues as it still struggles with
the impact of the real estate correction and weak domestic demand.
However, the economy has come out resilient to the tariff war with a trade
surplus reaching record levels, making external demand the key driver of
2025. This enables the economy to reach its short-term growth target, but
medium-term consensus continues to be downbeat for the moment
because of its weak domestic economy. For 2025, consensus expects
Economic momentum in Australia is expected to be soft, as much of the
growth in 2025 came from government consumption. The economy is
lacking a clear growth engine, with the private sector struggling against
restrictive policy settings and consumers facing a tough outlook with
weaker employment growth and real wage gains moderating. Growth is
expected to come in at 1.8 % in 2025, with a pick-up expected for 2026 to
When compared to the June 2025 consensus forecast, the December 2025
forecast has improved slightly because of better than expected growth in
major economies. Global GDP is expected to increase by 2.4 % in both
2025 and 2026 (compared to 2.0 % and 2.1 % assumed before). The global
economy showed quite some resilience in 2025 despite trade and
geopolitical tensions, as GDP growth has continued despite political
disruptions. Markets, too, have adjusted to the new world of volatility.
Alternative scenarios and risks (*)
The baseline scenario assumes steady economic growth. However, further
escalation of geopolitical tensions and global trade uncertainty are seen as
key downside risks to the global economy. The balance of risks to the
baseline outlook is negative, and the alternative scenarios have a
downward skew.
The downside scenario sees a recession in 2026 and 2027 for most
countries. Unemployment increases strongly in this scenario and house
prices in most countries show outright falls. The downside scenario
captures the possible impact of geopolitical tensions, global trade policy
and heightened tariff uncertainty.
The upside scenario reflects the possibility of a better economic out-turn
resulting from the avoidance of further trade escalation, an AI-driven
productivity rebound and stronger European growth supported by defence
spending.
Management adjustments applied this reporting period (*)
In times of volatility and uncertainty where portfolio quality and the
economic environment are changing rapidly, models alone may not be
able to accurately predict losses. In these cases, management
adjustments can be applied to appropriately reflect ECL. Management
adjustments may also be applied when the impact of the updated
macroeconomic scenarios is over- or under-estimated by the IFRS 9
models, or to account for model redevelopment, recalibration, and periodic
assessment procedures that have not yet been incorporated into the IFRS9
models.
ING has an internal governance framework and controls in place to assess
the appropriateness of all management adjustments.
Management adjustments to ECL models (*) | ||
in EUR million | 2025 | 2024 |
Commercial Real Estate/ Inflation and interest rate increases | ||
Economic sector / portfolio based adjustments | ||
Mortgage portfolio adjustments | ||
Climate transition risk | ||
Other Post Model Adjustments | - | |
Total management adjustments | ||
The management adjustment of €50 million for the Commercial Real
Estate portfolio, reported at 31 December 2024 due to prevailing risks in
this sector, is released in 2025 due to improved risk profile and partially
replaced with a management adjustment for a recent model update,
which corrects for the effects of the aforementioned risks on the model
outcome. As the model update has not been implemented in production
yet, a management adjustment of €10 million is reported under the Other
Post Model Adjustments category at 31 December 2025.
As at 31 December 2025, an economic sector / portfolio-based adjustment
is reported in the Mortgages portfolio in Australia (€9 million) to address
emerging risk from inflation, interest rate increases and overall cost of
living. The management adjustment reported at 31 December 2024 for the
increased credit risk in the Mortgages and Consumer Lending portfolios in
Spain – due to the effects of floods – has been released, as the remaining
affected performing customers are reported in Stage 2. Also the
adjustment taken in the Business Banking portfolio in Germany at 31
December 2024 to cover for the increased uncertainty in the German
economy has been released due to the agreed sale of the affected
portfolio.
As of 31 December 2025, the overall mortgage portfolio adjustment
amounts to €121 million (31 December 2024: €112 million) and fully
related to the management adjustment in Stage 2 for the risk
segmentation model that captures affordability, repayment, and
refinancing risk on performing mortgage customers with a bullet loan in
the Netherlands.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 183 |
As of 31 December 2025, an adjustment of €47 million is in place to
address the impact of climate transition risk in Wholesale Banking (€31
million) and in Business Banking (€16 million). Climate transition risk is
expected to lead to a structural change in credit risk, which means specific
business activities will become structurally riskier due to environmental
policies, technological progress or changes in market sentiment and
preferences. The current IFRS 9 models do not capture this (novel) risk. The
management adjustment to ECL models for business clients was made to
specifically cover for the medium- to long-term transition risk on high
greenhouse gas-emitting sectors and is reported in Stage 2. The sectors
included in the overlay represent approximately 20% of the exposure
within Wholesale and Business Banking.
Other post-model adjustments mainly relate to the impact of model
redevelopment or recalibration and periodic model assessment
procedures that have not been incorporated in the ECL models yet. The
impact on total ECL can be positive or negative. These adjustments will be
removed once updates to the specific models have been implemented.
The change in balance compared to previous reporting date is due to i)
released negative overlays because of model updates that have been
implemented and ii) new overlays recognised for new recalibrations and
periodic model assessment procedures that have not been incorporated
yet.
Analysis on sensitivity (*)
The table below presents the analysis on the sensitivity of key forward-
looking macroeconomic inputs used in the ECL collective-assessment
modelling process and the probability weights applied to each of the three
scenarios. The countries included in the analysis are the most significant
geographic regions in ING. For Wholesale Banking, the US is the most
significant in terms of both gross contribution to reportable ECL and
sensitivity of ECL to forward-looking macroeconomics. Accordingly, ING
considers these portfolios to present the most significant risk of resulting in
a material adjustment to the carrying amount of financial assets within
the next financial year.
The purpose of the sensitivity analysis is to enable the reader to
understand the extent of the impact from the upside and downside
scenario on model-based reportable ECL.
In the table below, the real GDP is presented in percentage year-on-year
change, the unemployment in percentage of total labour force, and the
house price index (HPI) in percentage year-on-year change.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 184 |
Sensitivity analysis as at December 2025 (*) | |||||||
2026 | 2027 | 2028 | Unweighted ECL (€ mln) | Probability-weighting | Reportable ECL (€ mln)1 | ||
Netherlands Upside scenario | Real GDP | ||||||
Unemployment | |||||||
HPI | |||||||
Baseline scenario | Real GDP | ||||||
Unemployment | |||||||
HPI | |||||||
Downside scenario | Real GDP | - | - | ||||
Unemployment | |||||||
HPI | - | - | - | ||||
Germany Upside scenario | Real GDP | ||||||
Unemployment | |||||||
HPI | |||||||
Baseline scenario | Real GDP | ||||||
Unemployment | |||||||
HPI | |||||||
Downside scenario | Real GDP | - | - | ||||
Unemployment | |||||||
HPI | |||||||
Belgium Upside scenario | Real GDP | ||||||
Unemployment | |||||||
HPI | |||||||
Baseline scenario | Real GDP | ||||||
Unemployment | |||||||
HPI | |||||||
Downside scenario | Real GDP | - | |||||
Unemployment | |||||||
HPI | |||||||
United States Upside scenario | Real GDP | ||||||
Unemployment | |||||||
HPI | |||||||
Baseline scenario | Real GDP | ||||||
Unemployment | |||||||
HPI | |||||||
Downside scenario | Real GDP | - | - | ||||
Unemployment | |||||||
HPI | - | - | - | ||||
1Excluding management adjustments. | |||||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 185 |
Sensitivity analysis as at December 2024 (*) | |||||||
2025 | 2026 | 2027 | Unweighted ECL (€ mln) | Probability-weighting | Reportable ECL (€ mln)1 | ||
Netherlands Upside scenario | Real GDP | ||||||
Unemployment | |||||||
HPI | |||||||
Baseline scenario | Real GDP | ||||||
Unemployment | |||||||
HPI | |||||||
Downside scenario | Real GDP | - | - | - | |||
Unemployment | |||||||
HPI | - | - | |||||
Germany Upside scenario | Real GDP | ||||||
Unemployment | |||||||
HPI | |||||||
Baseline scenario | Real GDP | ||||||
Unemployment | |||||||
HPI | |||||||
Downside scenario | Real GDP | - | - | ||||
Unemployment | |||||||
HPI | - | ||||||
Belgium Upside scenario | Real GDP | ||||||
Unemployment | |||||||
HPI | |||||||
Baseline scenario | Real GDP | ||||||
Unemployment | |||||||
HPI | |||||||
Downside scenario | Real GDP | - | - | ||||
Unemployment | |||||||
HPI | |||||||
United States Upside scenario | Real GDP | ||||||
Unemployment | |||||||
HPI | |||||||
Baseline scenario | Real GDP | ||||||
Unemployment | |||||||
HPI | |||||||
Downside scenario | Real GDP | - | - | - | |||
Unemployment | |||||||
HPI | - | - | - | ||||
1Excluding management adjustments. | |||||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 186 |
When compared to the sensitivity analysis of 2024, the baseline
macroeconomic inputs have become slightly more positive overall,
underpinned by the resilience of the global economy in the face of trade
and geopolitical tensions. House price growth expectations are lower for
the Netherlands, given a rise in supply from the sale of rental properties
and slowdown of wage growth. In the US, a weak labour and housing
market both signal underlying economic challenges due to policy and
trade uncertainty, and persistent affordability issues. The upside and the
downside scenarios are not directly comparable with those of 2024 due to
an update in the basis of their derivation.
On a total ING level, the unweighted ECL for all collective provisioned
clients in the upside scenario was €2,938 million, in the baseline scenario
€3,232 million and in the downside scenario €3,993 million compared to
€3,326 million reportable model ECL as at 31 December 2025 (excluding all
management adjustments). To perform the sensitivity analysis, a point in
time reportable ECL is used as input, which slightly deviates from the total
reportable collective provisions as presented below:
Reconciliation of reportable collective ECL to total ECL (*) | ||
in EUR million | 2025 | 2024 |
Total reportable collective provisions | ||
ECL from individually assessed impairments | ||
ECL from management adjustments | ||
Total ECL | ||
Criteria for identifying a significant increase in credit risk (SICR) (*)
All assets and off-balance-sheet items that are in scope of IFRS 9
impairment and which are subject to collective ECL assessment are
allocated a 12-month ECL if deemed to belong in Stage 1, or a lifetime ECL
if deemed to belong in Stages 2 or 3. An asset belongs in Stage 2 if it is
considered to have experienced a significant increase in credit risk (SICR)
since initial origination or purchase.
The main determinant of SICR is a quantitative test, whereby the lifetime
PD of an asset at each reporting date is compared against its lifetime PD
determined at the date of initial recognition. If either a threshold for
absolute change in lifetime PD or a threshold for relative change in lifetime
PD is reached, the item is considered to have experienced an SICR (for more
details on absolute and relative thresholds, see the following sections).
Furthermore, any facility which shows an increase of 200 percent between
the PD at the date of initial recognition and the lifetime PD at the reporting
date (i.e. threefold increase in PD) must be classified as Stage 2. This is
considered a backstop within the quantitative assessment of SICR.
In Wholesale Banking, a significant increase in lifetime PD is not considered
plausible for assets of obligors with a credit rating at the reporting date in
the top range of investment grade. The assets of these Wholesale Banking
obligors are excluded from the assessment of significant increase in credit
risk triggers. For these obligors the qualitative significant increases in credit
risk triggers remain applicable (see the section below on Qualitative SICR
triggers). These are, for example, the watch list and/or forbearance
triggers. Finally, the 30 days past due backstop also remains applicable for
the top range of investment grade exposures to ensure a significant
increase in credit risk recognition.
Absolute lifetime PD threshold
The absolute threshold is a fixed value calibrated per portfolio/segment
and provides a fixed threshold that, if exceeded by the difference between
lifetime PD at reporting date and lifetime PD at origination, triggers Stage 2
classification. The absolute threshold is calibrated during model
development.
Relative lifetime PD threshold
The relative threshold defines a relative increase of the lifetime PD, beyond
which a given facility is classified in Stage 2 because of a significant
increase in credit risk. The relative threshold is dependent on the individual
PD assigned to each facility at the moment of origination, and a scaling
factor calibrated in the model development phase.
Ultimately, the relative threshold provides a criterion to assess whether
the ratio (i.e. increase) between lifetime PD at reporting date and lifetime
PD at origination date is deemed a significant increase in credit risk. If the
threshold is breached, SICR is identified and Stage 2 is assigned to the
given facility.
The threshold for the relative change in lifetime PD is inversely correlated
with the PD at origination; the higher the PD at origination, the lower the
threshold. The logic behind this is to allow facilities originated in very
favourable ratings to downgrade for longer without the need of a Stage 2
classification. In fact, it is likely that such facilities will still be in favourable
ratings even after a downgrade of a few notches. On the contrary, facilities
originated in already unfavourable ratings grades are riskier and even a
single-notch downgrade might represent a significant increase in credit
risk and thus a tighter threshold will be in place. Still, the relative threshold
is relatively sensitive for investment-grade assets while the absolute
threshold primarily affects non-investment grade assets.
Average threshold ratio
The table below shows the average increase in PD at origination needed to
be classified in Stage 2 is reported, taking into account the PD at
origination of the facilities included in each combination of asset class and
rating quality. In terms of rating quality, assets are divided into
'investment grade' and 'non-investment grade' facilities. Rating 18 and 19
are not included in the table, since facilities are not originated in these
ratings and they constitute a staging trigger of their own (i.e. if a facility is
ever to reach rating 18 or 19 at reporting date, it is classified in Stage 2). In
the table, values are weighted by IFRS 9 exposure and shown for both
year-end 2024 and year-end 2025.
To represent the thresholds as a ratio (i.e. how much should the PD at
origination increase in relative terms to trigger Stage 2 classification) the
absolute threshold is recalculated as a relative threshold for disclosure
purposes. Since breaching only relative or absolute threshold triggers
Stage 2 classification, the minimum between the relative and recalculated
absolute threshold is taken as value of reference for each facility.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 187 |
Quantitative SICR thresholds (*) | ||||
2025 | 2024 | |||
Average threshold ratio | Investment grade (rating grade 1-10) | Non-investment grade (rating grade 11-17) | Investment grade (rating grade 1-10) | Non-investment grade (rating grade 11-17) |
Asset class category | ||||
Mortgages | ||||
Consumer lending | ||||
Business lending | ||||
Governments and financial institutions | ||||
Other Wholesale Banking | ||||
As it is apparent from the disclosures above, as per ING’s methodology, the
threshold is tighter the higher the riskiness at origination of the assets,
illustrated by the difference between the average threshold applied to
investment grade facilities and non-investment grade facilities.
Sensitivity of ECL to PD lifetime PD thresholds
The setting of PD threshold bands requires management judgement and is
a key source of estimation uncertainty. On Group level, the total model
ECL on performing assets, which is the ECL collective assessment without
taking management adjustments into account, was €1,501 million as at
31 December 2025 (31 December 2024: €1,328 million). To demonstrate
the sensitivity of the ECL to these PD threshold bands, hypothetically
solely applying the upside scenario would result in total model ECL on
performing assets of €1,159 million and a decrease in the Stage 2 ratio by
total model ECL on performing assets of €2,193 million and an increase in
the Stage 2 ratio by 1.6 %-point.
Qualitative SICR thresholds
It should be noted that the lifetime PD thresholds are not the only drivers
of stage allocation as ING Group also relies on a number of qualitative
indicators to identify and assess SICR. An asset can also change stages as
a result of other triggers, such as having over 30 days arrears (used as a
backstop), the occurrence of an early warning indicator, collective SICR
assessment, being on a watch list, being under intensive care
management, having a substandard internal rating, or being forborne.
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Introduction (*)
Market risk is the risk that movements in market variables, such as interest
rates, equity prices, foreign exchange rates, credit spreads, and real-estate
prices negatively impact the bank’s earnings, capital, market value, or
liquidity position. Market risk either arises through positions in banking
books or trading books.
The banking book positions are intended to be held for the long term (or
until maturity) or for the purpose of hedging other banking book positions.
The trading book positions are typically held with the intention of short-
term trading or to hedge other positions in the trading book. Policies and
processes are in place to monitor the inclusion of positions in either the
trading or banking book as well as to monitor the transfer of risk between
the trading and banking books.
The following sections elaborate on the various elements of the risk
management framework for:
§Market risk in banking books;
§Market risk in trading books; and
§Market risk capital.
ING distinguishes between the trading and banking (non-trading) books.
Positions in banking books originate from the market risks inherent in
commercial products that are sold to clients, Group Treasury exposures, and
from the investment of our own funds (core capital). Both the commercial
products and the products used to hedge related market-risk exposures are
intended to be held until maturity, or at least for the long term.
Risk transfer (*)
Market risks in the banking book are managed via the risk transfer process.
In this process the interest rate, FX, funding, and liquidity risks are
transferred from the commercial books through matched funding or
replication to Group Treasury, where they are centrally managed. The
scheme below presents the transfer and management process of market
risks in the banking books.
The main concepts and metrics used for measuring market risk in the
banking book are described below per risk type.
Interest rate risk in banking book (*)
Interest rate risk in the banking book is defined as the exposure of a bank’s
earnings, capital, and market value to adverse movements in interest
rates originated from positions in the banking book.
ING centralises interest rate risk management from commercial books
(that capture the products sold to clients) to globally managed interest
rate risk books. This enables a clear demarcation between commercial
business results and results based on unhedged interest rate positions.
ING distinguishes between three types of activities that generate interest
rate risk in the banking book:
§Investment of own funds;
§Commercial business; and
§Group Treasury exposures, including strategic interest rate positions.
Group Treasury is responsible for managing the investment of own funds
(core capital). Capital is invested for longer periods to contribute to stable
earnings within the risk appetite boundaries set by ALCO Bank.
Commercial activities can result in linear interest rate risk due to different
re-pricing properties of assets and liabilities. Also, interest rate risk can
arise from customer behaviour and/or convexity risk, depending on the
nature of the underlying product characteristics.
To determine interest rate risk in specific products (such as savings or
mortgages) certain assumptions may need to be applied. Customer
behaviour risk is defined as the potential future loss (value) arising from
deviations between actual client behaviour and the modelled behaviour
regarding embedded options within commercial products. General sources
of customer behaviour risk include, among other things, the state of the
economy, competition, changes in regulation, legislation and tax regime,
developments in the housing market, and interest rate developments.
From an interest rate risk perspective, commercial activities can typically
be divided into the following main product types: savings and current
accounts (funds entrusted), demand deposits, mortgages, and loans.
Savings and demand deposits are generally invested in such a way that
both the value is hedged and the sensitivity of the margin to market
interest rates is minimised. This is achieved by creating the investment
profile distributed from short term to long term, which dampens the
immediate impact from changes in the market rates and stabilises margin
in the longer horizon. Interest rate risk is modelled based on the stability of
deposits and the pass-through rate. This takes account of different
elements, such as pricing strategies, volume developments, and the level
and shape of the yield curve.
In determining the interest rate profile of mortgages, prepayment or other
embedded optionality can be an important risk driver. In modelling this
risk, both interest-rate-dependent prepayments and constant
prepayments are considered. Next to a dependence on interest rates,
modelled prepayments may include other effects such as loan-to-value,
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 189 |
seasonality, and the reset date of the loan. In addition, the interest
sensitivity of embedded offered rate options is typically considered.
Wholesale Banking loans typically do not experience interest-rate-
dependent prepayment behaviour, as these are mostly floating rate
products. These portfolios are match-funded, taking the constant
prepayment model into account, and typically do not contain significant
convexity risk. Wholesale Banking loans can have an all-in rate floor or a
floor on a reference rate.
Customer behaviour in relation to mortgages, loans, savings, and demand
deposits is modelled based on extensive analysis of historical data.
However, the substantial fluctuations in the interest rate environment in
recent years make the analysis more challenging than before and may
increase model risk. Models are backtested and updated when deemed
necessary, at least annually. Model parameters and the resulting risk
measures are approved by (local) ALCO, and are closely monitored on a
monthly basis.
Linear risk transfers take place from commercial business books to the
treasury book (Group Treasury), if necessary, by using estimations of
customer behaviour. The originating commercial business is ultimately
responsible for estimating this customer behaviour, leaving convexity risk
and (unexpected) customer behaviour risk with the commercial business.
Risk measurement and the risk transfer process take place at least
monthly. If deemed necessary, additional risk transfers can take place.
The commercial business manages the convexity risk that is the result of
products that contain embedded options, like mortgages. Here the
convexity risk is defined as the optionality effects in the value due to
interest rate changes, excluding the first-order effects. In some cases,
convexity risk is hedged by treasury using cap/floor contracts and
swaptions.
NII at Risk (*)
The NII-at-Risk measures the impact of changing interest rates on the
forecasted net interest income (before tax) of the banking book, excluding
the impacts of credit spread sensitivity, fees, and fair value impact. Future
projected balance sheet developments (dynamic plan) are included in this
risk metric. NII-at-Risk provides insight into the sensitivity of ING’s NII under
shocked interest rate scenarios against what is projected in a base case
scenario.
In its risk management, ING monitors the NII-at-Risk under a three-year
time frame. Interest rates are shocked during the first year of analysis
through the gradual application of shock. The rate changes considered
encompass both upward and downward scenarios, as well as both parallel
(equal movements across the yield curve) and non-parallel scenarios.
The impact of changing interest rates on ING’s NII is predominantly caused
by the following factors:
§Change in returns of (re)investments of client deposits;
§Change in client deposit rates (mainly savings), (partially) tracking
changes in market interest rates;
§Change in the amortisation profile of mortgages, due to an increase or
decrease in expected prepayments;
§Higher/lower returns of (re-)investments of core capital investment;
§Open interest rate positions, leading to changes in return because of
different market rates; and
§Assumed volume development of the balance sheet in line with ING’s
dynamic plan.
For projecting the change in client deposit rates, ING uses a client rate
model that describes the relation between market interest rates and client
deposit rates. The model is calibrated under a range of interest rate
scenarios. Per scenario, the actual change in client deposit rates may
deviate from this calibrated model. The actual NII development of
customer deposits may, indeed, differ from the provided scenarios,
depending on, among other things, actual interest rate and savings client
rate evolution, as well as changes to ING’s balance sheet composition,
such as net deposit growth and relative share of savings deposits and non-
remunerated current accounts.
The NII-at-Risk figures in the table below represent a parallel, linear
interest rate shift over one year (‘ramped’) based on the assumption that
balance sheet developments follow ING’s dynamic plan within a one-year
horizon.
The NII-at-Risk is mainly influenced by the difference in the sensitivity
between client liabilities and client assets and investments to rate
changes. The primary factor of NII-at-Risk are the investments of current
accounts, while the investments of own funds have a marginal effect, as
only a relatively small portion needs to be (re)invested within a one-year
period.
NII-at-Risk banking book per currency - year one (*) | ||||
in EUR million | 2025 | 2024 | ||
Ramped, floored | Ramped, floored | |||
parallel ▼ | parallel ▲ | parallel ▼ | parallel ▲ | |
By currency | ||||
Euro | - | - | ||
US dollar | - | - | ||
Other | - | - | ||
Total | - | - | ||
EUR ramped (floored at -100bps) is at +/- 120bps in 1 year | ||||
USD ramped (floored at -100bps) is at +/- 120bps in 1 year | ||||
The change in NII under declining and upward interest rate scenarios may
not be equal. This is due to different expected reactions in prepayment
behaviour of mortgages and different pricing developments of commercial
loans and deposits products (mainly savings). This is caused by embedded
options, explicit or implicit pricing floors, and other (assumed) pricing
factors.
The metrics mentioned above are internal metrics, which therefore deviate
from the regulatory NII SOT metric. Both internal and regulatory measures
are part of the bank's risk appetite framework and are actively managed.
Year-on-year variance analysis (*)
In 2025, ING maintained its dynamic hedging strategy, transferring
interest rate risk from business units to Group Treasury, where it was
subsequently hedged in financial markets, resulting in overall limited
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 190 |
sensitivity of NII at Risk (NIIaR) compared to ING’s total net interest income.
Year-on-year NIIaR increase by €100 million under a parallel down (worst
case) scenario, is primarily driven by revised repricing assumptions and
positions taken by treasury.
Net present value (NPV) at Risk (*)
NPV-at-Risk measures the impact of changing interest rates on the value
of the positions in the banking book and it is defined as the outcome of an
instantaneous increase or decrease in interest rates from applying
currency-specific scenarios. The metric primarily reflects the impact of
interest rate fluctuations on the bank’s strategic interest rate positions
(e.g. investments of own funds), as well as on the savings and mortgage
portfolios. While strategic positions typically adjust proportionally with
changing rates, the savings and mortgage products exhibit more complex
behavior due to embedded optionalities. Customers can prepay or
reallocate their balances, resulting in non-linear value changes. As a result,
these portfolios may incur value losses both when interest rates increase
and decrease, contributing to the asymmetric NPV-at-Risk pattern
highlighted in the annual report.
The full value impact cannot be directly linked to the financial position or
profit or loss account, as fair value movements in banking books are not
necessarily reported through the profit or loss account or through other
comprehensive income (OCI). The changes in value are expected to
materialise over time in the profit and loss account if interest rates develop
according to forward rates throughout the remaining maturity of the
portfolio. The majority of the risk comes from the investments of own
funds and from positions exhibiting negative convexity due to embedded
optionality (most notably variable rate savings and fixed rate mortgages).
The metrics mentioned above are internal metrics, which therefore deviate
from the regulatory EVE SOT metric. Both internal and regulatory
measures are part of the bank’s risk appetite framework and are actively
managed.
NPV-at-Risk banking books per currency (*) | ||||
in EUR million | 2025 | 2024 | ||
floored | floored | |||
parallel ▼ | parallel ▲ | parallel ▼ | parallel ▲ | |
By currency | ||||
Euro | - | - | ||
US dollar | - | - | ||
Other | - | - | ||
Total | - | - | ||
EUR (floored at -100bps) is at +/- 120bps | ||||
USD (floored at -100bps) is at +/- 120bps | ||||
Year-on-year variance analysis (*)
The overall NPV sensitivity increased considerably compared to the
previous year. The parallel up scenario continues to represent the worst-
case outcome, and the calculation shock for the primary currencies (EUR
and USD) was maintained at 120 basis points, consistent with the level
used in 2024. Year-over-year variations are explained by the evolving
balance sheet composition, movements in interest rates, and shifting
market expectations.
The impact of the benchmark rate reform (*)
In line with the recommendations of the Financial Stability Board, a
fundamental review of important interest rates benchmarks has been
undertaken. Some interest rate benchmarks have been reformed, while
others have or will be replaced by risk-free rates and discontinued.
In 2025, the benchmark rate reform of only one reference rate, to which
ING has significant exposures as at 31 December 2025, was continuing (i.e.
WIBOR in Poland).
On 24 January 2025, the Steering Committee of the National Working
Group (NWG SC) in Poland selected POLSTR (Polish Short Term Rate) as the
ultimate interest rate benchmark to replace WIBOR. POLSTR is calculated
based on unsecured deposits of Credit and Financial Institutions and is
expected to replace WIBOR by 31 December 2027.
In April 2025, the NWG SC published the updated transition roadmap of the
replacing process of WIBOR and announced in June 2025 that the official
determination of the POLSTR has started.
During the second half of 2025, the NWG SC approved several
recommendations for products based on POLSTR, and informed that
POLSTR has been applied for the first time in the domestic financial market
on 1 September 2025. Therefore, POLSTR gained a status of a benchmark
in accordance with the requirements of the EU Benchmark Regulation.
On 30 September 2025, the benchmark administrator GPW Benchmark
S.A, published the decision to cease providing the WIBOR reference rate for
various tenors in phases, between the end of 2025 and the end of 2026.
On 21 November 2025, the Ministry of Finance (of Poland) conducted the
first pilot issuance of treasury bonds linked to the POLSTR benchmark
during a sale auction.
Other important milestones of the process are planned in subsequent
years, including the construction of a market for financial products based
on the new benchmark and achieving regulatory and operational
readiness of all market participants to offer and operate these financial
products.
Due to the discontinuation of WIBOR, ING, its customers, and in general
those market participants with exposure to this benchmark rate will be
faced with a number of risks. These risks include legal, financial,
operational, reputational, and conduct risk. The WIBOR rates are used in
several of our lending and derivative products, and hence a project team
has been established to manage the transition. The WIBOR transition is
especially important for our Polish subsidiary (ING Bank Śląski S.A.) with a
significant amount of Polish zloty-denominated assets and liabilities
including derivatives that are continuously rebalanced to hedge the risk
exposures.
The tables below summarise the approximate gross exposure of ING that
has yet to transition related to WIBOR, excluding exposures expiring before
the transition date of 31 December 2027.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 191 |
Non-derivative financial instruments to transition from WIBOR to POLSTR (*) | |||
Financial assets non-derivative | Financial liabilities non- derivative | Off-balance sheet commitments | |
in EUR million | Carrying value | Carrying value | Nominal value |
31 December 2025 | |||
31 December 2024 | |||
Derivative financial instruments to transition from WIBOR to POLSTR (*) | ||
31 December 2025 | 31 December 2024 | |
in EUR million | Nominal value | Nominal value |
WIBOR | ||
See sections 1.5.4 of Note 1 ‘Basis of preparation and material accounting
policy information’ for information on the Phase 1 amendments to IFRS.
As at 31 December 2025, Phase 1 reliefs are applicable to WIBOR indexed
fair value and cash flow hedge accounting relationships as there is
uncertainty arising from the WIBOR reform with respect to the timing and
the amount of the underlying cash flows that the Group is exposed to.
Therefore, for WIBOR financial instruments designated in hedge
accounting the applicable Phase 1 reliefs will continue to apply until the
relevant contract is modified. At that point in time, the reliefs of Phase 2
amendments to IFRS will become applicable.
Following the Phase 1 reliefs that allow ING to continue applying hedge
accounting, ING has to assume that the WIBOR-based cash flows from the
hedging instrument and hedged item will remain unaffected for the
affected fair value and cash flow hedge relationships. In addition, for the
forecast transactions that are subject to cash flow hedge accounting,
under the Phase 1 reliefs ING has to assume that the WIBOR benchmark on
which the hedged cash flows are based is not altered as a result of the
reform and, therefore, the forecast transactions still meet the highly
probable requirement.
The total gross notional amounts of hedging instruments that are used in
ING’s hedge accounting relationships for which the Phase 1 amendments
to IAS 39 were applied are:
Notional amounts of hedging instruments from WIBOR to POLSTR (*) | ||
31 December 2025 | 31 December 2024 | |
in EUR million | Nominal value | Nominal value |
WIBOR | ||
As at 31 December 2025, 50 % (31 December 2024: 32 %) of the notional
amounts have a maturity date beyond 31 December 2027. The notional
amounts of the derivative hedging instruments provide a close
approximation of the extent of the risk exposure ING manages through
these hedging relationships.
Credit spread risk in banking books (CSRBB) (*)
Credit spread risk is defined as risk driven by the changes of the market
price for credit risk, for liquidity and potentially other characteristics of
credit-risky instruments, which is not captured by another existing
prudential framework such as Interest Rate Risk in Banking Book or by
expected credit/(jump-to-) default risk. The CSRBB framework is
implemented based on EBA Guidelines. Metrics used are NPV-at-Risk, NII-
at-Risk and Market Value Changes-at Risk and view the positions across
different accounting treatments.
Credit spread risk is not part of the internal risk transfer towards Group
Treasury and therefore remains in the business unit it originated in. Group
Treasury itself is also an important driver of credit spread risk via its high-
quality liquid assets (HQLA) investment portfolio and issuance activities.
Risk appetite limits are set on a combination of metrics and accounting
scopes and are cascaded to local ALCOs depending on the type of limit
and materiality. Metrics and limits are monitored and reported monthly to
global and local risk committees, and various stakeholders.
Foreign exchange (FX) risk in banking books (*)
FX exposures in banking books result from core banking business activities
(business units doing business in currencies other than their base
currency), foreign currency investments in subsidiaries (including realised
net profit and loss), and strategic equity stakes in foreign currencies. The
policy regarding these exposures is briefly explained below.
Core banking business (*)
Every business unit hedges the FX risk resulting from core banking
business activities into its base currency to prevent volatility in profit and
loss. Consequently, assets and liabilities are matched in terms of currency,
within certain friction limits.
FX translation (*)
ING’s strategy is to protect the CET1 ratio against adverse impact from FX
rate fluctuations, while limiting the volatility in the profit and loss account
due to this CET1 hedging and limiting the RWA impact under the
regulatory framework. Currency exposure of Return on Equity is also
considered. Hedge accounting is applied to the largest extent possible.
Taking this into account, the CET1 ratio hedge can be achieved by
deliberately taking foreign currency positions equal to certain target
positions, such that the CET1 capital and risk-weighted assets are equally
sensitive in relative terms to changing FX rates.
Risk profile – FX translation (*)
The following table presents the currency exposures in the banking books
for the most important currencies for the FX translation result. Positive
figures indicate long positions in the respective currency. As a result of the
strategy to hedge the CET1 ratio, an open structural FX exposure exists.
To measure the volatility of the CET1 ratio from FX rate fluctuations,
different metrics are used, including the CET1 Ratio-at-Risk. The impact is
controlled via the Solvency and Financial Risk RAS.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 192 |
Foreign currency exposures banking books (*) | ||||||
in EUR million | Foreign Investments | Hedges | Net exposures | |||
2025 | 2024 | 2025 | 2024 | 2025 | 2024 | |
US Dollar | - | - | ||||
Pound Sterling | - | - | ||||
Polish Zloty | - | - | ||||
Australian Dollar | - | - | ||||
Turkish Lira | ||||||
Chinese Yuan | - | |||||
Russian Rouble | ||||||
Romanian Leu | - | - | ||||
Thai Baht | - | - | ||||
Other currency | - | - | ||||
Total | - | - | ||||
1.The FX sensitivity is expressed as the FX spot equivalent position.
EBA Structural FX guidelines
In line with the EBA guidelines on Structural FX, upon permission from the
competent authorities, certain currency positions are being excluded from
the calculation of net open currency positions under CRR article 352(2).
The resulting impact is presented in the Pillar 3 disclosure.
Equity price risk in banking books (*)
ING maintains a portfolio with substantial equity exposure in its banking
books.
Risk profile (*)
Equity price risk arises from the possibility that an equity security’s price
will fluctuate, affecting the values of the equity security itself as well as
other instruments whose values react similarly to the particular security, a
defined basket of securities, or a securities index. ING’s equity exposure
mainly consists of the investments in associates and joint ventures of
€1,607 million (2024: €1,679 million) and equity securities held at fair value
through other comprehensive income (FVOCI) of €2,607 million (2024:
€2,562 million). The value of equity securities held at FVOCI is directly
linked to equity security prices with increases/decreases being recognised
in the revaluation reserve.
Investments in associates and joint ventures are measured in accordance
with the equity method of accounting, and the balance sheet value is
therefore not directly linked to equity security prices. The equity sensitivity
is expressed as the equity position.
Year-on-year variance analysis (*)
In 2025, the revaluation reserve equity securities decreased by €372
million from €1,816 million to €1,444 million due to revaluation of the
shares in Bank of Beijing with €-403 million. In 2025, the equity securities
at fair value through OCI increased by €45 million mainly due to increased
stake in Van Lanschot Kempen.
Revaluation reserve equity securities at fair value through other comprehensive income (*) | ||
in EUR million | 2025 | 2024 |
Positive remeasurement | ||
Negative remeasurement | - | - |
Total | ||
Market risk in trading books (*)
Within the trading portfolios, the positions are maintained in the financial
markets. These positions are often a result of transactions with clients and
may benefit from short-term price movements. In 2025, ING continued its
strategy of undertaking trading activities to develop its client-driven
franchise and deliver a differentiating experience by offering multiple
market and trading products.
With respect to the trading portfolios, Trading Risk Management (TRM)
focuses on the management of market risks of Wholesale Banking (mainly
Financial Markets) as this is the only business line within ING where trading
activities take place. Trading activities include facilitation of client business
and market making. TRM is responsible for the development and
implementation of trading risk policies and risk measurement
methodologies, and for reporting and monitoring risk exposures against
approved trading limits. TRM also reviews trading mandates and global
limits, and performs the gatekeeper role in the product review process
(PARP).
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 193 |
Risk measurement (*)
ING uses a comprehensive set of methodologies and techniques to
measure market risk in trading books: Value at Risk (VaR) and Stressed
Value at Risk (SVaR), Incremental Risk Charge (IRC), and stress testing.
Systematic validation processes are in place to validate the accuracy and
internal consistency of data and parameters used for the internal models
and modelling processes.
Value at Risk (*)
TRM uses the historical simulation VaR methodology (HVaR) as its primary
risk measure. The HVaR for market risk quantifies, with a one-sided
confidence level of 99 percent, the maximum overnight loss that could
occur in the trading portfolio of ING due to changes in risk factors (e.g.
interest rates, equity prices, foreign exchange rates, credit spreads, implied
volatilities), considering the positions remain unchanged for a time period
of one day.
Next to general market movements in these risk factors, HVaR also takes
into account market data movements for specific moves in, for example,
the underlying issuer or securities. A single model which diversifies general
and specific risk is used. In general, a full revaluation approach is applied,
while for a limited number of linear trading positions and risk factors in
commodity and equity risk classes, a sensitivity-based approach is applied.
The potential impact of historical market movements on today’s portfolio
is estimated, based on equally weighted observed market movements of
the previous year (260 business days). When simulating potential
movements in risk factors, depending on the risk factor type, either an
absolute or a relative shift is used.
The data used in the computations is updated daily. ING uses HVaR with a
one-day horizon for internal risk measurement, management control, and
backtesting, and HVaR with a 10-day horizon for determining regulatory
capital. To compute HVaR with a 10-day horizon, the one-day risk factor
shifts are scaled by the square root of 10 and then used as an input for the
revaluation. The same model is used for all legal entities within ING with
market risk exposure in the trading portfolio.
Limitations (*)
HVaR has some limitations: it uses historical data to forecast future price
behaviour, but future price behaviour could differ substantially from past
behaviour. Moreover, the use of a one-day holding period (or 10 days for
regulatory capital calculations) assumes that all positions in the portfolio
can be liquidated or hedged in one day. In periods of illiquidity or market
events, this assumption may not hold. Also, the use of a 99 percent
confidence level means that HVaR does not take into account any losses
that occur beyond this confidence level.
Backtesting (*)
Backtesting is a technique for the ongoing monitoring of the plausibility of
the HVaR model in use. Although HVaR models estimate potential future
trading results, estimates are based on historical market data. In a backtest,
the actual daily trading result (excluding fees and commissions) is
compared with the one-day HVaR.
In addition to using actual results for backtesting, ING also uses hypothetical
results, which exclude the effects of intraday trading, fees, and
commissions. When an actual or a hypothetical loss exceeds the HVaR, an
‘outlier’ occurs. Based on ING’s one-sided confidence level of 99 percent, an
outlier is expected once in every 100 business days.
On an overall level in 2025, there was one outlier for hypothetical P&L and
zero outliers for actual P&L. The hypothetical outlier occurred in the first
quarter of 2025, mainly driven by higher EUR rates due to anticipated
changes in German fiscal policy.
Stressed HVaR (*)
The stressed HVaR (SVaR) is intended to replicate the HVaR calculation that
would be generated on the bank’s current portfolio with inputs calibrated to
the historical data from a continuous 12-month period of significant
financial stress relevant to the bank’s portfolio.
To calculate SVaR, ING uses the same model that is used for 1DHVaR, with a
10-day horizon. The data for the historical stress period used currently
includes the height of the credit crisis around the fall of Lehman Brothers
(2008-2009), and this stressed period selection is reviewed annually. The
historical data period is chosen so that it gives the worst-scenario loss
estimates for the current portfolio. The same SVaR model is used for
management purposes and for regulatory purposes. The same SVaR model
is used for all legal entities within ING with market risk exposure in the
trading portfolio.
Incremental risk charge (*)
The incremental risk charge (IRC) for ING is an estimate of the default and
migration risks for credit products (excluding securitisations) in the trading
book, over a one-year capital horizon, with a 99.9 percent confidence level.
Trading positions (excluding securitisations) of ING, which are subject to
specific interest rate risk included in the internal model approach for market
risk regulatory capital, are in scope of the IRC model. By model choice,
equity is excluded from the model. For the calculation of IRC, ING performs a
Monte Carlo simulation based on a multi-factor t-copula. In the multi-factor
IRC model the supervisory asset correlations are no longer applicable and
the calibration of the correlations is based on historical market data. The
rating change is simulated for all issuers over the different liquidity horizons
(i.e. time required to liquidate the position or hedge all significant risks)
within one year. Movements across different rating categories and
probabilities of default are governed by a credit-rating transition matrix. An
internal transition matrix along with internal LGDs is used, to comply with
the consistency requirement. The financial impact is then determined for
the simulated migration to default, or for the simulated migration to a
different rating category, based on LGD or credit spread changes,
respectively.
The liquidity horizon has been set to the regulatory minimum of three
months for all positions in scope. ING reviews the liquidity horizons on a
yearly basis, based on a structured assessment of the time it takes to
liquidate the positions in the trading portfolio.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 194 |
Stress testing and event risk (*)
Stress testing is a valuable risk management tool. In addition to the bank-
wide stress-test framework as described in the stress-testing section,
Trading Risk Management performs stress tests specific to the trading book
with various frequencies. The trading book stress tests evaluate the impact
on the bank’s trading book under severe but plausible stress scenarios, using
a full revaluation approach. The framework is based on historical as well as
hypothetical scenarios. The stress result is an estimate of the profit and loss
caused by a potential event and its worldwide impact for ING. The results of
the stress tests are used for decision-making, aimed at maintaining a
financially healthy going-concern institution after a severe event occurs.
In stress scenarios, shocks are applied to prices (credit spreads, interest
rates, equity, commodities, and FX rates) and volatilities. Depending on the
type of the stress test, additional scenario assumptions can be made, for
example on correlations, dividends, or recovery rates. The structural
scenarios are defined to cover market moves in various directions and
capture different asset class correlations. Scenarios are calculated using a
full revaluation approach. The worst scenarios are determined for each
product line, business line, and super business line, and compared against
limits.
Other trading limits
HVaR and event risk limits are the most important limits to control the
trading portfolios. Additionally, limits have been set on SVaR and IRC, and
ING uses a variety of other controls to supplement these limits. Position
and sensitivity limits are used to prevent large concentrations in specific
issuers, sectors, or countries. Moreover, other risk limits are set with
respect to the activities in complex derivatives trading. The market risk of
these products is controlled by product-specific limits and constraints.
Risk profile
The following chart shows the development of the overnight HVaR under a
99 percent confidence level and a one-day horizon versus actual and
hypothetical daily trading profits and losses. In calculation of the
hypothetical daily profit and loss, the trading position is kept constant and
only the market movement is taken into account. The overnight HVaR is
presented for the ING trading portfolio for 2025.
EU MR4. Consolidated trading VaR ING Bank |
in EUR million |
The risk figures shown in the backtesting graph above and in the following table relate to all trading books that use the internal model approach.
1d VaR for internal model approach trading portfolios | ||||||||
in EUR million | Minimum | Maximum | Average | Year end | ||||
2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | |
Interest rate 1 | 6 | 6 | 23 | 17 | 10 | 12 | 6 | 11 |
Equity and commodity | 4 | 2 | 9 | 7 | 7 | 4 | 6 | 6 |
Foreign exchange | 2 | 1 | 6 | 14 | 3 | 3 | 4 | 2 |
Credit spread | 2 | 2 | 6 | 12 | 3 | 4 | 2 | 3 |
Diversification 2 | -9 | -7 | -8 | -6 | ||||
Total VaR 2 | 10 | 7 | 19 | 21 | 14 | 15 | 11 | 16 |
1For calculation of HVaR per risk class the full valuation is performed according to HVaR methodology using a set of scenario changes for the risk factors for the particular risk class, while risk factors for all other
risk classes are kept unchanged.
2The total HVaR for the columns Minimum and Maximum cannot be calculated by taking the sum of the individual components since the minimum/maximum observations for both the individual markets as
well as for total HVaR may occur on different dates. Therefore, diversification is not calculated for the minimum and maximum categories.
Average 1D/10D HVaR, SVaR, and IRC over 2025 has decreased compared to 2024, resulting in a decrease in overall capital for 2025. The overall average
has decreased in 2025 for all trading portfolios, mainly due to an increase in diversification, despite high volatility due to the ongoing geopolitical tensions
and increased trade frictions.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 195 |
ING does not calculate comprehensive risk capital charge and therefore it
appears as n/a in the table below.
EU MR3: internal model approach values for trading portfolios | ||
in EUR million | 2025 | 2024 |
VaR (10 day 99%) | ||
1 Maximum value | 59 | 73 |
2 Average value | 41 | 48 |
3 Minimum value | 29 | 29 |
4 Period end | 33 | 47 |
Stressed VaR (10 day 99%) | ||
5 Maximum value | 149 | 175 |
6 Average value | 90 | 109 |
7 Minimum value | 47 | 56 |
8 Period end | 51 | 98 |
Incremental risk charge (99.9%) | ||
9 Maximum value | 288 | 232 |
10 Average value | 144 | 125 |
11 Minimum value | 46 | 64 |
12 Period end | 144 | 100 |
Comprehensive risk capital charge (99.9%) | ||
13 Maximum value | n/a | n/a |
14 Average value | n/a | n/a |
15 Minimum value | n/a | n/a |
16 Period end | n/a | n/a |
As part of the risk monitoring framework, TRM actively monitors the
sensitivities of the trading portfolios. Sensitivities measure the impact of
movements in individual market risk factors (foreign exchange rates,
interest rates, credit spreads, equity and commodity prices) on profit and
loss results of the trading positions and portfolios.
The following tables show the five largest trading positions in terms of
sensitivities to foreign exchange, interest rate, and credit spread risk factor
movements. These largest exposures also reflect concentrations of risk in
FX risk per currency, interest rate risk per currency, and credit spread risk
per country, rating, and sector. Due to the nature of the trading portfolios,
positions in the portfolios can change significantly from day to day, and
sensitivities of the portfolios can change daily accordingly.
Most important foreign exchange year-end trading positions (*) | |||
in EUR million | 2025 | 2024 | |
Foreign exchange | Foreign exchange | ||
US Dollar | - | US Dollar | - |
Turkish Lira | Turkish Lira | ||
Chinese Yuan | Korean Won | ||
Japanese Yen | - | Japanese Yen | |
Romanian Leu | Chinese Yuan | - | |
Most important interest rate and credit spread sensitivities at year-end (*) | |||
in EUR thousand | 2025 | 2024 | |
Interest rate (BPV) 1 | Interest rate (BPV) 1 | ||
Euro | - | Euro | - |
US Dollar | - | US Dollar | - |
British Pound | - | British Pound | - |
Japanese Yen | Korean Won | - | |
Philippine Peso | - | Philippine Peso | - |
Credit spread (CSO1) 2 | Credit spread (CSO1) 2 | ||
France | United States | ||
United Kingdom | Netherlands | - | |
Netherlands | France | - | |
Indonesia | - | Poland | |
South Korea | Germany | ||
1.Basis point value (BPV) measures the impact on value of a one basis point increase in interest
rates.
2.Credit spread sensitivity (CS01) measures the impact on value of a one basis point increase in
Credit spread sensitivities per risk class and sector at year-end (*) | ||||
2025 | 2024 | |||
in EUR thousand | Corporate | Financial institutions | Corporate | Financial institutions |
Credit spread (CSO1) 1 | ||||
Risk classes | ||||
1 (AAA) | - | - | - | - |
2–4 (AA) | - | - | - | |
5–7 (A) | - | - | ||
8–10 (BBB) | - | - | ||
11–13 (BB) | - | - | ||
14–16 (B) | - | |||
17–22 (CCC and NPL) | ||||
Total | - | - | ||
1Credit Spread Sensitivity (CS01) measures the impact on value of a 1 basis point increase in credit spreads. | ||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 196 |
Internal model approach
Market risk regulatory capital has decreased during 2025 compared to
2024. This mainly reflect lower interest rate positions during 2025, as well
as the reduced regulatory-driven capital multiplier.
EU MR2-A: Market risk under Internal Model Approach | |||||
in EUR million | 2025 | 2024 | |||
RWA | Total own funds requirements | RWA | Total own funds requirements | ||
1 | VaR (higher of values a and b) | 1,521 | 122 | 1,964 | 157 |
(a) | Previous day’s VaR (VaRt-1) | 33 | 49 | ||
(b) | Multiplication factor (mc) x average of previous 60 working days (VaRavg) | 122 | 157 | ||
2 | SVaR (higher of values a and b) | 2,877 | 230 | 4,915 | 393 |
(a) | Latest available SVaR (SVaRt-1)) | 51 | 116 | ||
(b) | Multiplication factor (ms) x average of previous 60 working days (sVaRavg) | 230 | 393 | ||
3 | IRC (higher of values a and b) | 2,014 | 161 | 1,457 | 117 |
(a) | Most recent IRC measure | 144 | 116 | ||
(b) | 12 weeks average IRC measure | 161 | 117 | ||
4 | Comprehensive risk measure (higher of values a, b and c) | ||||
(a) | Most recent risk measure of comprehensive risk measure | ||||
(b) | 12 weeks average of comprehensive risk measure | ||||
(c) | Comprehensive risk measure - Floor | ||||
5 | Other | 582 | 47 | 340 | 27 |
6 | Total | 6,994 | 560 | 8,676 | 694 |
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 197 |
Standardised approach
EU MR1: market risk under standardised approach | ||
in EUR million | 2025 | 2024 |
RWA | RWA | |
Outright products | ||
1 Interest rate risk (general and specific) | 92 | 31 |
2 Equity risk (general and specific) | ||
3 Foreign exchange risk | 4,968 | 4,374 |
4 Commodity risk | ||
Options | ||
5 Simplified approach | ||
6 Delta-plus method | ||
7 Scenario approach | ||
8 Securitisation (specific risk) | ||
9 Total | 5,060 | 4,405 |
The MRWA under standardised approach have increased compared to
2024.
Market risk capital
Economic capital
Market risk economic capital (MREC) measures the capital ING must hold to
protect itself against losses due to market risks. MREC covers the entire
balance sheet of ING Group, and includes market risk sub-types such as:
interest rate and basis risk, credit spread risk, customer behaviour risk, FX
risk, equity risk, and commodity risk.
MREC is calculated as the 99.9 percent worst value loss that can be
incurred from one-year shocks to the underlying risk drivers. While
aggregating the different economic capital market risk figures for the
different portfolios, diversification benefits are taken into account as it is
not expected that all extreme market movements will appear at the same
moment.
Regulatory capital
Market risk regulatory capital is the amount of capital that ING has to hold
to protect itself against losses due to market risks, as required by the
financial regulator. From a regulatory capital perspective, market risk
stems from all the positions included in a bank’s trading book, as well as
from commodity and foreign exchange risk positions in the whole balance
sheet of ING Group. According to the Capital Requirements Regulation
(CRR/CRD IV), regulatory capital (own funds requirements) for market risk
can be calculated using the standardised approach or an internal model
approach.
FX risk in banking book
Regulatory Capital requirements for FX risk in banking book is set out in
Part 3, Title IV, Chapter 3 of the Capital Requirements Regulation (CRR). This
is further supplemented by EBA guidelines on Structural FX for the
calculation of the net open currency positions (CRR Art 352(2)). ING uses
the standardised approach where the capital requirement is 8 percent of
this total net currency and gold position.
Equity risk in banking book
Equity regulatory capital is included as part of Credit RWA as prescribed by
regulations. As of January 2025, ING applies the Standardised Approach
(SA) for the calculation of Regulatory Capital as described in Capital
Requirements Regulation (CRR3) Art 133. Under CRR3 SA, the RWA amount
is calculated by multiplying the risk weight with the exposure value (not
tailored to a specific internal model). The capital requirement is 8 percent
of the RWA value.
Trading book
ING has regulatory approval to use an internal model to determine the
regulatory capital for the market risk in all trading books of ING. Market risk
capital of trading books is calculated according to the CRR, using internal
HVaR, SVaR, and IRC models, where diversification is taken into account.
Collective investment undertakings (CIUs), cryptocurrency assets (Bitcoin
NDF) and asset-backed securities (ABS) exposures in trading books are
calculated using the standardised approach with fixed risk weights. ING
does not have a correlation trading portfolio in the trading book.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 198 |
Introduction (*)
Funding and liquidity (F&L) risk is the risk that ING or one of its subsidiaries
cannot meet their financial obligations upon their maturity date at a
reasonable cost and in a timely manner. ING incorporates funding and
liquidity risk management in its business strategy and has established a
funding and liquidity risk framework to manage these risks within pre-
defined boundaries.
The following sections elaborate on the various elements of funding and
liquidity risk:
§Funding and liquidity risk framework;
§Funding and liquidity risk management strategy and objectives;
§Funding and liquidity adequacy and risk appetite;
§Funding and liquidity risk indicators;
§Liquidity stress testing; and
§Contingency funding planning.
Funding and liquidity risk framework (*)
Macroeconomic and market environments are important considerations in
ING’s F&L framework. The macroeconomic environment is comprised of
various exogenous factors over which ING has no control, but which may
have a material impact on ING’s F&L position. Exogenous factors analysed
on a regular basis include:
§performance of global and local macroeconomic indicators, e.g. shifts
in gross domestic product, inflation rates, unemployment rates, and
public deficit/surplus;
§developments and risks arising from geopolitical tensions and trends;
§monetary policy with a focus on the alternative monetary measures
employed by central banks in recent years as a result of the global
energy crisis and periods of high inflation; and
§regulatory requirements, e.g. understanding the changing regulatory
landscape as well as the impact of ING’s actions on existing regulatory
boundaries.
The strategic ambitions of ING, together with the design and execution of
the funding plan, are assessed under both current and projected market
conditions. An emphasis is placed on understanding overall market trends
and developments, credit rating changes, and peer comparisons.
The EB, MBB, and staff departments from the CRO and CFO domains, as
well as Group Treasury, have oversight of, and are responsible for,
managing funding and liquidity risks.
Funding and liquidity management strategy and objectives (*)
The main objective of ING’s funding and liquidity risk management is to
maintain sufficient liquidity to fund the commercial activities of ING both
under normal and stressed market circumstances across various locations,
currencies and tenors.
ING’s funding consists mainly of retail and corporate deposits contributing
to 53 percent and 22 percent of total funding, respectively. These funding
sources provide a stable funding base. The remainder of the required
funding is attracted primarily through a combination of long-term and
short-term professional funding. Group Treasury manages the professional
funding in line with the F&L risk appetite with the aim of ensuring a
Funding mix 1 | ||
2025 | 2024 | |
Funding type | ||
Customer deposits (private individuals) | 53% | 53% |
Customer deposits (other) | 22% | 22% |
Lending/repurchase agreements | 5% | 5% |
Interbank | 2% | 2% |
CD/CP | 5% | 5% |
Long-term senior debt | 11% | 11% |
Subordinated debt | 2% | 2% |
Total | 100% | 100% |
1Liabilities excluding trading securities and IFRS equity. | ||
currencies. The main portion of long-term professional funding is euro and
US dollar denominated, which is in line with the currency composition of
customer lending.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 199 |
ING Group long-term debt maturity profile by currency at year-end 2025 1 | ||||||||
in EUR billion (nominal amounts) | 2026 | 2027 | 2028 | 2029 | 2030 | 2031 | Beyond 2031 | Total |
Currency | ||||||||
EUR | 7.7 | 7.0 | 10.7 | 10.3 | 11.7 | 7.2 | 29.3 | 84.0 |
USD | 1.1 | 4.2 | 2.6 | 2.4 | 1.6 | 1.0 | 7.9 | 20.7 |
Other | 2.2 | 1.7 | 2.4 | 2.7 | 1.5 | 0.4 | 3.6 | 14.3 |
Total | 10.9 | 12.9 | 15.7 | 15.3 | 14.8 | 8.6 | 40.8 | 119.0 |
1Amounts adjusted to exclude Tier 1 instruments.
ING Group long-term debt maturity profile by currency at year-end 2024 1 | ||||||||
in EUR billion (nominal amounts) | 2025 | 2026 | 2027 | 2028 | 2029 | 2030 | Beyond 2030 | Total |
Currency | ||||||||
EUR | 4.7 | 9.2 | 7.1 | 9.7 | 10.3 | 10.6 | 27.0 | 78.6 |
USD | 0.3 | 3.9 | 4.8 | 3.3 | 1.4 | 1.5 | 7.5 | 22.8 |
Other | 1.2 | 2.7 | 1.7 | 1.8 | 2.6 | 0.2 | 3.1 | 13.3 |
Total | 6.2 | 15.8 | 13.6 | 14.8 | 14.3 | 12.4 | 37.6 | 114.7 |
1Amounts adjusted to exclude Tier 1 instruments.
ING identifies key drivers of short-term and future liquidity and funding
needs on an ongoing basis through the periodic risk-identification process.
Taking into consideration the identified risk drivers, ING regularly assesses
its current and future liquidity adequacy and, if deemed necessary, takes
action to further improve ING’s liquidity position and maintain sufficient
counterbalancing capacity. A Liquidity Adequacy Statement is formulated
on a regular basis to substantiate and reflect the management view on
the current funding and liquidity position as well as the potential future
challenges. The Liquidity Adequacy Statement is an important part of
ING’s Internal Liquidity Adequacy Assessment Process (ILAAP).
Additionally, ING completes ad-hoc funding and liquidity assessments if
deemed necessary.
ING assesses its F&L adequacy through three lenses – stress, economic,
and normative:
§Through the stress lens, ING evaluates its ability to withstand periods of
prolonged F&L stress for both normative and economic requirements.
Limits under idiosyncratic, market-related, combined idiosyncratic and
market-related, and climate risk scenarios, which lead to customer
deposit outflows, deterioration of access to funding markets, and lower
liquidity value of counterbalancing capacity are evaluated.
§Through the economic lens, ING assesses the extent to which its
customers, professional counterparties, and investors are comfortable
to provide deposits and funding in the tenors, currencies, and
instruments necessary to sustainably fund the business (intraday,
short-term, and long-term) in a going-concern situation.
§Through the normative lens, ING ascertains that the bank is in the
position to meet current and future domestic and host regulatory
requirements.
For each lens, ING has established a related set of risk appetite statements,
which define ING’s risk appetite, commensurate with the principles of
liquidity adequacy.
The F&L risk appetite statements are translated into metrics with
appropriate boundaries and instruments which are used to regularly
measure and manage ING’s funding and liquidity risk. The risk appetite
with respect to the stress lens aims to have sufficient counterbalancing
capacity under various internally defined stress scenarios. Regarding the
economic perspective, an internally defined stable funding to loans (SFtL)
ratio and stable funding surplus (SFS) metric (supplemented by other
metrics) is used to stimulate a diversified funding base and to prevent
overreliance on professional funding. Finally, the liquidity coverage ratio
(LCR) and the net stable funding ratio (NSFR) regulatory metrics are
monitored in terms of both ING’s risk appetite and normative
requirements.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 200 |
Funding and liquidity risk indicators
ING Group liquidity risk indicators | ||
2025 | 2024 | |
Liquidity buffer (in € billion) 1 | 328.4 | 338.6 |
LCR 2 | 140% | 143% |
NSFR 3 | 128% | 133% |
Asset encumbrance (AE) 4 | 18% | 19% |
Survival period (severe stress) 5 | >12 months | >12 months |
1Consolidated Liquidity Buffer is reflected as a fixed point in time.
2Consolidated LCR is based on a 12-month rolling average.
3Consolidated NSFR is reflected as a fixed point in time.
4Consolidated AE is reflected as a median of the end-of period values for each of the four quarters
of the reporting year.
5Consolidated Survival period after management actions.
The liquidity buffer (counterbalancing capacity) is expressed as the market
value of the underlying positions and consists largely of deposits at central
banks and highly liquid assets qualifying as HQLA for the LCR. In addition
to the HQLA, other securities, mainly retained covered bonds and ABS,
further strengthen the available liquidity buffer. Depending on the
underlying assets, haircuts are applied on the market value to determine
the liquidity value of the buffer.
Funding and liquidity stress testing forms part of the overall F&L
framework. It allows ING to examine the effects of exceptional but
plausible future events on ING’s funding and liquidity position and provides
insight into which entities, business lines, or portfolios are vulnerable to
which types of risk drivers or scenarios.
The stress-testing framework encompasses the funding and liquidity risks
of the consolidated balance sheet of ING Group, including all entities,
business lines as well as on- and off-balance sheet positions. The net
liquidity position (NLP) is the main stress-testing measure and is measured
at different time buckets.
The stress-testing framework considers idiosyncratic, market-wide,
combined (idiosyncratic and market-wide) and climate-stress scenarios.
The design of the framework is based on empirical evidence supplemented
by expert judgment. The framework can be extended to additional ad-hoc
scenarios. For example, it can be used as input for firm-wide stress testing
and reverse stress testing.
Outcomes of the stress tests are considered in the key aspects of ING’s F&L
risk framework and F&L risk management, including:
§Risk Appetite Framework (through risk appetite statements);
§Risk identification and assessment;
§Monitoring of the liquidity and funding position;
§Business actions (if needed);
§Contingency funding plan; and
§Early-warning indicators.
The funding and liquidity stress-testing framework is also subject to
regular internal validation by model validation.
In line with supervisory expectations, ING’s liquidity position is stress tested
on (at minimum) a monthly basis using scenarios that form part of the
F&L risk appetite statement. The results of all internal stress scenarios are
monitored and assessed on a monthly basis. In addition, ad-hoc scenarios
based on current economic and market developments are run to
determine their potential impacts on the funding and liquidity position of
ING. In 2025, this included stress-test scenarios assessing the impact of a
shutdown of US short- and long-term funding markets and FX markets.
The internal stress scenarios and their corresponding results serve as input
in the decision on holding additional contingency measures.
Contingency funding planning (*)
ING’s contingent F&L risks are addressed in its Contingency Capital and
Funding Plan (CCFP). The objectives of the CCFP include:
§Establishment of a monitoring framework to detect approaching
contingent events as well as their impact on ING’s F&L position;
§Provision of a plan for responding to various and increasing levels of a
bank’s liquidity and capital shortfall under adverse and stressed
conditions;
§Designation of management responsibilities, crisis communication
methods and channels, and reporting requirements;
§Identification of contingent capital and liquidity sources under
escalating adverse and stressed conditions; and
§Description of the steps needed to ensure the bank’s capital and
liquidity sources are sufficient to fund scheduled operating
requirements and meet the institution’s commitments, with minimal
costs and disruption.
The contingency funding measures are developed in conjunction with the
ING Recovery Plan and are reviewed and tested on a regular basis.
1 In line with the European Central Bank (ECB) guide on climate-related and environmental risks.
2 As per the ING Group Risk Identification and Risk Assessment Procedure for ICLAAP purposes.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 201 |
Environmental, social and governance (ESG) risk
Introduction
ESG risk is defined as any negative financial and/or non-financial impact
on ING due to the present or future impact to/dependencies from factors
on and stemming from ING’s full value chain.
ESG risk is not an independent risk category/risk type but rather a set of
drivers1 affecting the likelihood and severity of existing risk categories/risk
types. ESG risk is an overarching set of risk drivers affecting:
§Financial risks: credit risk, market risk, funding and liquidity risk;
§Non-financial risks and compliance risk; and
§Other overarching risks: model risk and business and strategy risk.
The risk drivers2 are defined as risk events that lead to an impact on ING’s
financial solvency or funding and liquidity position via the above-
mentioned risk types. Our comprehensive approach ensures we integrate
ESG considerations into our risk management practices, aligning with our
commitment to sustainable growth and resilience.
Definitions | ||||||||||||||||
ESG factors ESG factors are defined as environmental, social or governance matters that may have a positive or negative impact on the non-financial/financial performance or solvency of an entity, sovereign, or individual. ING's ESG taxonomy of ESG factors are defined through the consideration of the CSRD and EUT. | ||||||||||||||||
 Environment §Climate-change adaptation §Climate-change mitigation §Pollution §Water & marine resources §Circular economy §Biodiversity and ecosystems |  Social §Own workforce and workers in the value chain §Customers §Communities |  Governance §Business conduct | ||||||||||||||
Value chain Value chain is a concept derived from CSRD Annex II as 'the full range of activities, resources and relationships related to the business model(s) of the undertaking and the external environment in which it operates'. For ING, the concept of the value chain defines the scope of the ESG risk management lifecycle. | ||||||||||||||||
Supply chain | Own operations | Wholesale Banking | Business Banking | Private Individuals & Private Banking | Treasury & other investments | |||||||||||
Double materiality ING must identify both actual and potential: §impacts on people and the environment (impact materiality, inside-out); as well as §sustainability matters that impact ING's financial positions (financial materiality, outside-in). Impact materiality and financial materiality assessments are interrelated, as financial materiality may stem from negative impact, dependency on resources and context analysis. ING defines material ESG factor per value chain for both impact and financial materiality. | ||||||||||||||||
1Important ESG factors are determined on a case by case basis and consider international standards such as the OECD Guidelines for Multinational Enterprises on responsible business conduct and the UNGPs on Business and Human Rights.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 202 |
The ESG risk framework
The ESG risk framework provides a definition of ESG risk, the governance
structure supporting the management of ESG risk, and an overview of the
various roles and responsibilities related to ESG risk. The framework assists
in managing ESG risk effectively through the application of the risk
management process at various levels of the organisation. The framework
integrates governance components, including the three lines of defence,
defined organisational responsibilities, and ESG oversight bodies, and is
underpinned by a continuous ESG Risk Management Cycle (aligned with
the Risk Management Cycle) encompassing identification, assessment,
mitigation, reporting, and monitoring, as described in detail below.
Governance
ING has a governance structure with well-defined, transparent, and
consistent lines of responsibility in managing ESG risk in line with the three
lines of defence. For more information, see ‘Three lines of defence’.
ESG risk bodies
The ESG committees and bodies at ING are responsible for overseeing and
integrating ESG matters into ING’s strategy and daily operations in line
with our sustainability governance. The following committees, bodies, and
their associated charters are relevant with regard to the framework:
§Supervisory Board ESG Committee (SB-ESG): The ESG Committee assists
the SB by generally monitoring and advising on relevant ESG
developments.
§Executive Board (EB) and Management Board Banking (MBB): ING’s EB/
MBB has overall responsibility for the ESG risk framework and is
accountable for having it implemented and embedded.
§The key risk committees: Acting within delegated authorities granted
by the MBB, support on implementation and execution of the controls
mitigating material ESG risks.
§ESG Risk Committee (ERC): A standing committee that receives its
mandate from the MBB, and is responsible for the approval of ESG risk
procedures and mandatory instructions as well as its rollout in the
different impacted functions. In addition, it advises MBB and MBB-
delegated committees on the implementation and execution of the
controls mitigating material ESG risk.
Organisational bodies
Management of ESG risk is embedded within all material risk types across
the three lines of defence. Within the CRO domain, ESG risk governance is
embedded into the existing global risk governance framework. It aligns
with the structures that steer risk categories and types globally.
The global ESG Risk department’s role is to ensure that all risk functions
incorporate ESG considerations into their processes, while the local (ESG)
risk functions are responsible for the local adoption of the global policies,
methodologies and instructions issued by the global ESG Risk department.
Managing ESG risk
The primary concern relates to the long-term impact on credit quality and
income, rather than immediate solvency. Climate and environmental-
related risks may increase the risk of borrower default and reduce income
from vulnerable sectors. The focus is on managing underlying risks by
increasing risk management intensity. The ESG risk framework assists in
managing ESG risk effectively through the application of the risk
management process at varying levels of the organisation. The risk cycle
describes the processes by which ING can identify, assess, mitigate,
monitor, and report ESG risk integrated within the existing risk types.
Risk identification
It is our policy to formalise and maintain an up-to-date ESG impact and
risk inventory. This inventory includes descriptions of the drivers of ESG
negative impacts and ESG risks. Regarding the risk drivers, the inventory
further details their transmission channels and maps them to the risk
categories where ESG risk drivers can materialise. Additionally, the
inventory briefly outlines the drivers of positive impact and opportunities.
Risk assessment
ESG metrics are defined and assessed against predetermined thresholds to
determine materiality. The outcome of the double materiality assessment
(DMA) defines the way ESG risk is adopted in the business strategy and the
risk management of each risk category/risk type to be mitigated. In
addition to the results of the DMA, ING considers some ESG factors to be
important1 for the risk assessment and due-diligence processes that
follow.
1Material with reputational risk
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Transmission channels | Material: Financial & non-financial risks1 | |||||||
E1: Climate change; E4: Biodiversity and ecosystems | ||||||||
Business §Property damage & Business disruption §Stranded assets & New capital expenditure Households §Loss of income §Property damage Macro economy §Shifts in prices §Productivity changes §Labour market frictions | Risk category | Short term | Medium-long term | |||||
Credit risk | E1, E4 | E1, E4 | ||||||
Compliance risk | S1, S4, G1 | E1, E4, S1, S4, G1 | ||||||
Market risk | In scope of the assessment, no material risks identified | |||||||
Liquidity risk | ||||||||
Non financial risk | S1 | S1 | ||||||
Business risk | E1 (climate change mitigation) | E1 (climate change mitigation) | ||||||
S1: Own workforce; S4: Consumers and end-users | Social and governance §Negative customer and investor preference §Legal liability for damages caused and loss of customer preference §Negative impact on workforce | |||||||
G1: Business conduct | ||||||||
The above visualisation and the following paragraphs illustrate the
mapping of ESG risk drivers to financial and non-financial risks across
different time horizons.
§Credit risk
–Climate transition risk: ING has credit exposure to clients whose
business models may be more vulnerable to climate transition risks,
potentially resulting in business disruption and reduced earnings,
which could impair their ability to repay loans or meet other
financial obligations. In addition, adverse climate conditions may
lead to depreciation in the value of collateral.
•Entities may be affected by increased operating costs and
reduced revenue due to fines, taxes and adaptation costs which,
in turn, might decrease clients' affordability and ability to repay,
thus increasing PDs.
•The transition to environmentally sustainable economies might
make carbon intensive assets in ING’s lending portfolio more
vulnerable to disinvestment and demand – leading to potential
write-offs, stranded assets, early retirement of assets (based on
carbon profiling/intensity) and a decrease in the collateral value
for brown assets. This in turn might result in higher loan to
values (LTVs) and LGDs.
–Climate physical risk: Climate-related physical impacts can lead to
significant losses, unexpected expenses, and reduced income and
profits for borrowers. This may impair their ability to repay loans,
thereby increasing credit risk for ING. Additionally, the frequency
and intensity of extreme events can affect the value of real estate
or other collateral, altering the relationship between the loan and
the asset’s value.
•Acute and chronic risks can negatively impact cash flows of
affected entities: 1) as damaged physical capital might generate
less income, 2) operational disruptions might lead to decreased
productivity and increased operational costs and 3) increased
insurance premiums. This might decrease clients’ affordability
and ability to repay debt and therefore increase PDs. For
sovereign and municipal exposures, the income effects from
physical risk events may primarily arise through lower tax
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revenues and higher spending channels to compensate for
negative impacts and adaptation costs.
•Write-offs, asset devaluation and early retirement of existing
assets due to acute events decrease the value of collateral and
have a negative impact on LTVs, and therefore LGDs.
–Biodiversity and ecosystems (impact on species): The negative
impact on biodiversity, which can result in a demise in natural
resources, can disrupt clients’ operations, leading to financial losses.
Financial losses can also occur due to reputational damage. This
may leave them unable to repay loans or meet their obligations on
other financial transactions at the same time as reducing the value
of the business.
§Compliance risk
–Climate transition risk: Assuming that regulation in Europe will
continue to increase in the coming years and decades, the inherent
risk may rise accordingly. These risks are expected to become more
pronounced in the medium and long term, driven by increased
regulatory expectations and stronger embedding in the prudential
framework.
Business Conduct: Financial loss, regulatory fines, and reputational
damage resulting from infringements of our corporate culture, potential
instances of bribery and corruption, and failure to protect whistleblowers.
–Consumers and end-users: materialisation of negative impact
due to not providing access to quality information on transition and
physical risks. Also includes privacy risk when failing to protect our
customers’ data.
–Own workforce: privacy risk linked to data protection of our own
employees.
Non-financial risk
§Own workforce: due to People Risk and/or Employment & Practice Risk
(EPR), regarding the employment and inclusion of persons with
disabilities and from diverse background. Moreover, EPR due to
significant concerns raised on violence & harassment in the workplace.
§Business and strategy risk
–Climate transition risk: High transition risk may materialise if ING’s
clients are unable to adapt their business models in line with
climate regulation. In such cases, increasing carbon costs,
regulatory restrictions, or declining market demand can weaken
clients’ profitability and balance‑sheet strength. This may translate
into reduced lending opportunities, ultimately affecting future
income generation.
Failing to meet the commitments made can result into a loss of trust
among ING’s customers and stakeholders, which can result in customers
choosing to take their business elsewhere. ING may therefore face
increased costs related to customer acquisition and retention efforts,
ultimately affecting profitability.
Measurement methodologies and impact
ING measures its exposure to ESG risks by assessing risks through risk
quantification methodologies and tools. The methodologies take into
account qualitative and quantitative criteria, different time horizons, and
scenario analysis and stress testing,supporting an assessment of the
organisation’s resiliency under various climate and ESG‑related conditions..
Quantification leverages on top-down and bottom-up approaches, when
applicable.
§Physical risk tool: ING has developed a tool to measure and assign a
level of physical risk for four chronic and nine acute physical risks
across the short, medium, and long term for portfolios and geographies
in which ING operates. This range of hazards is recognised under EU
Taxonomy. The thorough selection of hazards means this tool caters
for broad, continent-spanning risks as well as local and nuanced ones.
The tool has been developed using physical risk maps obtained and
recognised by academically reputable sources.
§Transition risk scorecard is used by ING to quantify transition risk
with a scorecard approach at client level. Methodology helps to identify
the pool of high-risk clients within specific sectors, in order to
subsequently manage these high-risk subsegments, taking into
account ING’s public commitments and sector-specific climate
strategies (Terra approach). This pool of high-risk clients is
subsequently managed via the climate risk-appetite setting.
§ESG risk-assessment tool: For WB, ING has developed an ESG risk-
assessment approach which considers the (climate and)
environmental, social and governance risk factors, negative impacts
and dependencies of our WB customers, and fully integrates the
previous ESR framework, which is now embedded under the umbrella
of the new ESG Risk Framework. Tooling was developed to support the
implementation of the assessment approach in the credit granting
process. Depending on the ESG risk-assessment outcome and the
impact on financial risks, addition mitigation might be required and
factored in as one factor for the broader credit risk assessment.
§Climate Stress Test and Resilience Analyses: ING continues
enhancing its climate stress-testing methodology to assess the impact
of climate risks on corporate and mortgage exposures from a credit risk
perspective under different climate scenarios.The methodology for
short/medium-term stress test (referred to as Climate Stress Test or
CST) builds on existing stress test methodology (e.g., ICAAP, EBA), while
a dedicated long-term methodology has been developed (referred to
as Climate Resilience Analysis or CRA) to assess the impact on
provisions under various scenarios and portfolio assumptions.
For both CST and CRA, dedicated climate scenarios are used, developed
using NGFS short-term and long-term (Phase V) scenario publications as
foundational inputs. These scenarios cover different narratives and explore
the impact of 1) a baseline/continuation of current policies scenario, 2) a
Net-Zero smooth transition scenario, 3) a delayed and abrupt transition
scenario, 4) a low transition risk but high physical risk scenario. These
scenarios influence macro-economic variables projections (e.g. GDP,
unemployment rate, house prices, etc.) which, in turn, determine the
forecast of the main credit risk parameters (e.g. risk migrations, PDs, LGDs
etc.). This is referred to as the "macro" transmission channel.
In addition, dedicated climate overlays are incorporated to account for the
impact of transition, physical and nature risk on a more granular level. This
is referred to as the "micro" transmission channel.
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For mortgages transition risk is modelled by estimating the relationship
between household income and probability of default (PD), factoring in
rising carbon prices, energy costs, and renovation expenses required for
low energy label properties. A PD multiplier is then derived per portfolio,
per energy performance certificates (EPC) levels. Physical risk is assessed
using ING’s in-house Physical Risk Tool, which combines hazard maps and
property-level exposure data to estimate expected losses. LGD is adjusted
based on modelled damage functions and loss estimates of material
Physical Risk.
For corporates, the dedicated overlays are implemented in the form of PD
multipliers across 16 NACE sectors. These multipliers are derived using
ING’s EEST (Environmental Elasticity Scenario Tool) which assesses the
impact of transition, physical and nature risk shocks on the market price
and volume per sector, and subsequently the impact of these shocks on
the counterparty’s financial position. The resulting financial stress is then
reflected in PDs.
The long‑term analysis informs the resilience of the bank’s business model.
ING’s proactive portfolio steering, sector‑specific transition engagement,
and transaction‑level risk‑management measures collectively enhance the
bank’s capacity to navigate increasing climate pressures and preserve its
business resilience over time.
Risk mitigation
The mitigation of the identified risks in line with the risk appetite can be
performed through several risk mitigating strategies, such as reducing the
risk level, avoiding risk, accepting risk, or transferring the risk. The
measures are embedded as part of the updates of the existing policies and
procedures in the different risk categories/risk types in order to mitigate
ESG risks with a material financial impact. Mitigation activities can be
performed at a process, product, portfolio, client, or transaction level and
include, but are not limited to:
§engaging with high ESG risk counterparties to understand and support
their mitigation plans;
§setting RAS to limit the level of acceptable risks;
§incorporating ESG risks in the collateral valuation process; and
§ensuring appropriate business continuity plans and insurance are in
place to reduce the impact of more frequent and severe ESG events for
ING’s value chain.
Risk monitoring, reporting and disclosures
ING aims to provide regular and transparent ESG reports and regulatory
disclosures to ensure the management body and all relevant units in ING
receive ESG risk information in a timely, accurate, concise, clear and
meaningful manner. These reports cover the identification, assessment,
measurement, monitoring, and management of ESG risks.
The ESG risk dashboard consists of comprehensive and integrated ESG risk-
related, financial and non-financial information on business activities and
own operations, summarising the following:
§Results of the double materiality assessment, detailing negative
impacts, financial and non-financial materiality for each value chain
segment;
§ING key climate risk indicators for material ESG risks across value chain
segments. The depth of reporting is informed by the materiality
assessments performed; and
§The outcome of the latest climate stress-testing assessment.
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Non-Financial risk
Introduction
Non-financial risk (NFR) is defined as the risk of financial loss, legal or
regulatory sanctions, or reputational damage due to inadequate or failing
internal processes, people and systems, a failure to comply with laws,
regulations and standards, or external events.
Non-financial risk management
Risk categories
ING categorises non-financial risks in the following 10 areas:
§Compliance risk is the risk of personal harm, financial loss, regulatory
fines, litigation, business disruption and/or reputational damage due to
impairment of ING Group’s integrity caused by a failure (or perceived
failure) to comply with applicable external laws, regulations and market
standards, societal expectations and internal ING rules.
§Information (technology) risk is the risk of financial loss, regulatory
fines, litigation, business disruption and/or reputational damage,
breach of confidentiality, failure of integrity of systems and
information, inappropriateness or unavailability of systems and
information or inability to change information technology (IT) within a
reasonable timeframe and with reasonable costs when the
environment or business requirements change (i.e. agility). This
includes security risks resulting from inadequate or failed internal
processes or external events including cyberattacks or inadequate
physical security.
§Operational resilience/business continuity risk is the risk of financial
loss, regulatory fines, litigation, business disruption, and/or reputational
damage due to the organisation’s inability to deliver its Critical Business
Services within their impact tolerance levels, and to respond and
recover from severe disruption or crisis within predefined time frames,
service levels, and capacity.
§Control risk is the risk of financial loss, regulatory fines, litigation,
business disruption, and/or reputational damage due to not complying
with controls set through governance procedures and/or project
management methods, caused by improper or insufficient monitoring
(testing) of entities or activities. The key components of Control Risk
include Third and Intragroup Party Risk (TIPM) and Model Risk.
§Processing risk is the risk of financial loss, regulatory fines, litigation,
business disruption and/or reputational damage due to unintentional
(human) error during (transaction) processing, or due to data issues
(including inadequate data governance, poor data quality, data not
available for use, or data architectures not supporting business needs
for data aggregation/consumption or reporting).
§Unauthorised activity risk is the risk of financial loss, regulatory fines,
litigation, business disruptions and/or reputational damage due to
unauthorised employee activities, approvals, or overstepping of
authority that breach delegated mandates without constituting fraud.
§Personal and physical security risk is the risk of financial loss,
regulatory fines, litigation, business disruption, and/or reputational
damage due to criminal and environmental threats that might
endanger the security or safety of ING personnel at work, people in ING
locations, ING assets or assets entrusted to ING, people at ING event
locations, or might impact the organisation’s confidentiality, integrity,
or availability.
§Employment practice risk is the risk of financial loss, regulatory fines,
litigation, business disruptions and/or reputational damage due to
breaches of employment, health, and/or safety laws, regulations or
agreements from payment of personal injury claims, from diversity/
discrimination events, unsafe physical and psychosocial working
conditions, or from the unavailability of staff.
Fraud Risk consists of two risk areas:
§Internal fraud risk is the risk of financial loss, regulatory fines, litigation,
business disruption, and/or reputational damage due to acts of fraud
performed by or in collusion with an ING employee.
§External fraud risk is the risk of financial loss, regulatory fines, litigation,
business disruption, and/or reputational damage due to acts of fraud or
scams by individuals, and/or parties excluding ING staff (and ING
contractors).
In line with ING’s sustainability strategy and regulatory requirements
relating to ESG Risk Management, the NFR Framework has been updated
to ensure ESG Risk is properly embedded in our risk management cycle
and material risk types in line with the overarching ESG Risk Management
Framework.
Risk appetite and tolerances
ING sets a Group-wide risk appetite for non-financial risks, supported by
quantitative and qualitative tolerances. Tolerances are cascaded to
business lines and are calibrated to reflect our strategy, stakeholder
expectations, and regulatory requirements. Performance against appetite
is monitored through a suite of Key Risk Indicators and assessed quarterly
by management committees, with breaches triggering predefined
escalation and remediation. The Supervisory Board is informed of material
movements relative to appetite through regular risk reporting.
Issue management and remediation
Issues arising from risk assessments, control testing, events, audits, and
supervisory reviews are recorded in a central issue management system.
Each issue has a clearly defined owner, risk classification, target
remediation date, and acceptance criteria. Progress is tracked through
regular governance routines, and overdue items are periodically reported
to senior management for follow-up. Closure is subject to evidence-based
validation.
Measurement approach
As of 1 January 2025, following CRR3 regulation, ING is using the
Standardised Measurement Approach (SMA), a non-model-based formula
to calculate regulatory operational risk capital. An internal Operational Risk
Economic Capital (OREC) model is used for economic capital and stress
testing purposes (Pillar II). The OREC model estimates the economic capital
required to cover potential losses arising from various non-financial risks
within ING. The OREC model involves the use of historical internal and
external losses together with forward-looking and expert-driven loss
estimates to arrive at bank-level loss distribution. The outcomes of the
OREC model are reported quarterly.
Main developments in 2025
The external environment continues to present significant uncertainty and
complexity. Geopolitical tensions and regulatory divergence across
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jurisdictions create challenges for global operations. These dynamics may
increase exposure to non-financial risks, requiring ongoing enhancement
of risk mitigation measures and capabilities. At the same time, evolving
consumer expectations and strengthened consumer protection
regulations are likely to raise the standards for secure and resilient
banking operations. ING is continuously working to further mature its risk
management practices, ensuring continued readiness and resilience in this
changing landscape.
Continuity Risk
Providing safe, secure, and seamless services for our customers is central
to ING’s strategy as we focus on providing superior value to our customers.
Operational and IT Resilience measures are key in preventing disruptions
and ensuring a quick recovery when disruptions do occur. During 2025, ING
has further strengthened the implementation of the Operational Resilience
framework in the organisation. The framework aims at safeguarding the
resilience of our most critical business services and the related processes
and systems, facilities, people, data, and third- and intragroup services. As
an example, more real-life simulations of outages are performed to test
the resilience of our critical business services under severe stress scenarios,
including the effectiveness of anticipated contingency measures. The bank
continues to strengthen the framework, including measures related to
concentration risk and the oversight of material subcontractors in
outsourcing. Strengthening our Operational Resilience is a multi‑year
journey and a lot of progress has already been made. Over the coming
period, we will further enhance areas such as supplier concentration risk
management, oversight of material sub‑contractors, and the scope and
realism of our outage simulations.
Information (Technology) Risk
The mission of Information (Technology) Risk, together with the IT
organisation, is to help ING stay safe and secure by preventing and
mitigating unauthorised access to systems and safeguarding the
confidentiality, integrity, and availability of the data within them. To
deliver on this mission, we are continuously strengthening and maturing
our joint framework, ensuring it is equipped to adapt to emerging risks.
These risks arise from new or changing regulations (such as the EU
Artificial Intelligence Act (AI Act) and Payment Services Directive 3 (PSD3)),
rapidly shifting threat landscapes (e.g., AI-enabled attacks, QR-code
phishing, quantum-related risks), ongoing digitalisation of value chains,
adoption of new technologies and digital products, and geopolitical
developments. To keep ahead, ING implemented further enhancements in
measuring and reporting on IT risks in 2025, which will continue in 2026.
The overall cybersecurity maturity increased, due to in particular to
significant progress in the area of Identity & Access Management (IAM). IT
Resilience remains a key focus to prevent and mitigate disruption of
services and data. This is done by further developing capabilities to recover
from large-scale ransomware events and by enhancing failover and
recovery of global, shared systems, supported by the Global Infrastructure
organisation and the Chief Information Security Office (CISO). In 2025, ING
continued to develop, improve, and test these capabilities. Since the
external cyber threat landscape is evolving quickly, which demands
continuous improvement for the coming years.
Fraud Risk
In 2025, ING reinforced its commitment to fraud resilience, focusing on
early detection, smarter prevention, and stronger governance. Our global
strategy is designed to prevent and reduce fraud-related losses and
provide customers with tools to recognise and avoid fraud, like the ‘check
the call’ feature.
Increasing complexity and rising volumes of fraud, driven by technological
developments such as AI-enabled schemes, are already evident.
Capabilities are enhanced through predictive analytics, extended
reporting, and cross-market alignment via the Global Fraud Target
Operating Model. These efforts ensure consistent execution and
continuous improvement across countries. Collaboration remains central
to our approach. ING works closely with industry peers, regulators, and law
enforcement to address fraud as a societal challenge.
Personal & Physical Security Risk
In 2025, the complex geopolitical situation continued to pose significant
threats to the safety and security of ING’s assets and employees (e.g. wars
in Ukraine and the Middle East, hybrid warfare, and unstable political
environments). ING is monitoring these geopolitical risks closely, and
security measures and procedures are being implemented to mitigate
both current and potential impacts on ING’s assets and staff.
Rising activist actions, political extremism, and social polarisation are
creating an increasingly volatile threat landscape, heightening uncertainty
for ING and its operations. These risks require specific actions to protect
assets and people from security threats and disruptive movements,
including heightened vigilance and proactive coordination with authorities.
To strengthen and accelerate response capabilities, a dedicated global
first-line Safety and Security department was established in 2025.
Data risk management
At ING, managing Data Risk is about having the right data of good quality
readily available for business or regulatory purposes, in a secure and
compliant way. As emerging technologies such as AI continue to evolve
and data volumes expand at a rapid pace, our primary objectives are to
address data-related regulatory obligations, manage risks associated with
data-driven technologies like AI, and ensure ongoing alignment with
societal expectations. ING has set up clear governance and initiatives to
ensure the ethical handling of data, and to integrate regulatory
requirements (e.g. EU AI Act, BCBS239) in its policies and way of working.
ING’s data strategy is making steady progress, strengthening data quality
and data governance, and supporting clear accountability across the
organisation. Data Risk Management is applied to the data strategy to
oversee and anticipate business expectations (incl. regulatory
requirements), to measure (e.g. via KRIs) against our defined risk appetite
statement, as well as to monitor the status of regulatory programmes
(e.g. BCBS239). Since the Data Risk landscape is evolving rapidly, ING will
continue to enhance Data Risk Management. In the coming years ING will
invest in data literacy, scaling data capabilities, tooling and strengthening
governance for data and AI-driven technologies.
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Compliance risk
Introduction
ING aims to conduct its business activities in compliance with applicable
internal rules (including ING’s risk appetite statements) and external laws
and regulations, whilst also taking societal expectations into consideration.
Compliance risk is defined as the risk of personal harm, financial loss,
regulatory fines, litigation, business disruption and/or reputational damage
due to the impairment of ING Group’s integrity caused by a failure (or
perceived failure) to comply with applicable external laws, regulations and
market standards, societal expectations and internal ING rules.
Within ING, we apply the following compliance risk categories:
§Financial crime risk refers to the risk of the bank’s products and services
being abused for illicit purposes, generating, facilitating or disguising
financial and/or economic crimes (FEC).
§Conduct risk refers to compliance risk arising from (the perception of)
breaching our obligations towards customers and/or other parties,
including inappropriate market conduct.
§Data protection (personal data protection, data retention) risk refers to
the personal data protection risk of financial loss (regulatory fines,
reputational damage) due to not protecting the personal data rights of
individuals as required, and as to data retention risk, to having the
records being destroyed too soon or retained too long.
The Compliance organisation has the mission to drive compliance risk
management by desire and design throughout the organisation.
Compliance’s primary role is advising, challenging, and overseeing the first
line of defence in how they manage compliance risks, as well as raising
awareness and stimulating a sound compliance risk culture.
Training and awareness
At ING we believe all our people play a role in protecting our customers,
the bank and, through that, society too. A sound risk culture is promoted
by empowering our employees with the skills and knowledge they need to
manage compliance risks. In 2025, we continued to train our people with
mandatory trainings on financial crime, conduct and data protection.
Senior Management (MBB and SB) are trained on various compliance risk
topics based on a multi-year training plan.
Financial crime and fraud prevention
Financial Crime and Fraud Prevention (FCFP) in the first line of defence and
Financial Crime Compliance (FCC) in the second line of defence continue to
jointly play a major role in our aim to make sure we only engage and do
business with people and entities that meet regulatory requirements.
Knowing who we do business with is vital to keeping ING safe, secure, and
compliant. As part of our ongoing anti-money laundering efforts, we
continuously assess relationships with both new and existing customers,
monitor and screen transactions to fulfill our regulatory and reporting
obligations, whilst ensuring unusual and/or potentially suspicious
transactions are reviewed/investigated. Where applicable, we report these
to the relevant authorities.
Financial crime risk management
The day-to-day responsibility for the oversight of ING’s compliance with
our legal and regulatory obligations, in relation to financial crime risks, sits
with the global head of Financial Crime Compliance, who reports to ING’s
CCO, with oversight by the CRO. As a global financial institution combatting
financial crime, and to comply with anti-money laundering and counter-
terrorism financing (AML/CTF) laws and regulations, we have established a
reasonable and risk-based control framework to mitigate continuously
evolving financial crime risk, and seek to provide useful information to
relevant government agencies.
Operational effectiveness (OE)
ING’s global KYC policy and related control standards set the minimum
requirements and control objectives for all ING entities to guard against
involvement in financial crime activity, while reflecting relevant national
and international laws, regulations, guidance documents, and guidelines
from national, European and international authorities, (supra)national risk
assessments, and industry standards. In 2025, our focus has shifted from
foundational maturity to maintaining operational effectiveness, with
oversight and challenge from the second line of defence. This evolution is
supported by the completion of the multi-year KYC Enhancement
Programme, which strengthened our customer due diligence and
transaction monitoring capabilities.
Evolving financial crime and regulatory landscape
Financial crime continues to evolve, whether through technology, new and
sophisticated techniques used by criminals, or the results of geopolitical
events. The widespread digitalisation of the economy and use of AI has led
to a reshaping of the methods used to launder money and finance
terrorism. Criminal groups have adopted and are misusing new
technologies, AI, and anonymity-enhancing technologies, such as virtual
currencies and mixers, to commit criminal activities.
In response to this and heightened supervisory expectations, so too has
the regulatory environment evolved. The EU’s Anti-Money Laundering
Regulation (AMLR) and the establishment of the Anti-Money Laundering
Authority (AMLA) mark a significant step toward harmonised oversight
across member states, with full implementation expected by 2027.
ING actively participates in industry consultations and regulatory
dialogues to shape these frameworks, while embedding operational
effectiveness and advanced analytics into KYC and transaction monitoring
processes. These developments reflect ING’s strategic ambition to
safeguard the integrity of the financial system and strengthen resilience
against financial crime risks. In addition, we are committed to a risk-based
approach (RBA), ensuring resources are focused on higher-risk areas while
maintaining compliance with evolving global standards. This is
underpinned by investment in data-driven, continuous risk assessment
methodologies aimed at providing dynamic insights into emerging threats
and enabling proactive risk mitigation strategies.
These innovative technological capabilities enhance our cooperation with
law-enforcement agencies, industry bodies and regulators, and further
development of intelligence and data-led collaborative solutions to detect
and disrupt financial crime. In this context, this may at times include
sharing information within ING to manage our financial crime risk
exposure, in line with General Data Protection Regulation requirements
and local privacy laws and regulations.
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Bribery and corruption
Bribery and corruption undermine business confidence and corporate
integrity, hinder fair business competition, and harm international trade.
Bribery and corruption risks are considered as part of our client and third-
party due diligence, and financial crime risk monitoring measures. This
supports our zero-tolerance approach to bribery and corruption, which is
also part of the governance elements of our sustainability objectives and a
main principle in our Global Code of Conduct.
Customer tax compliance
Compliance with customer tax-related regulations and reporting
obligations, under the Foreign Account Tax Compliance Act (FATCA), the
Common Reporting Standard (CRS), and Mandatory Disclosure Rules, aims
to ensure that ING is not involved in facilitating tax-related financial crime,
such as tax evasion and harmful aggressive tax-avoidance schemes, on
behalf of its customers.
Sanctions
It is ING’s policy to take into consideration the applicable sanctions regimes
as imposed by international authorities and by local mandatory sanctions
law (as applicable). ING’s policy generally prohibits relationships or
transactions involving sanctioned persons and entities or comprehensively
sanctioned countries, territories and their governments. This sometimes
also means that ING’s risk appetite may be stricter than legal obligations,
and we may choose not to support certain customer relationships,
business activities and transactions, even if permitted by law.
ING continuously monitors external developments to remain proactive to
new sanctions packages or updates to existing sanctions packages.
Throughout 2025, geopolitical risk has grown (e.g. conflict in the Middle
East and the continuation of Russia’s invasion in Ukraine), and global
sanctions regimes remained increasingly active, creating a complex
regulatory and legislative environment. There has been an increasing
focus on the potential circumvention of sanctions against Russia, and the
roles of third countries and companies in facilitating any circumvention or
undermining the sanctions’ measures. This has prompted a concerted
effort by governments to impose pressure on companies operating in
these jurisdictions, and to prevent sanctions measures being sidestepped
by targeted Russian parties. ING’s sanctions programme is designed to
comply with sanctions across the multiple jurisdictions in which ING has
business operations.
Since February 2022, ING has taken measures to not engage in new
business with and in Russia and follows an active de-risking approach. The
approach aims to reduce ING’s overall exposure towards Russia, including
measures to reduce operational risks and to further ringfence activities of
ING Bank (Eurasia) JSC. On 28 January 2025, ING announced the proposed
sale of ING Bank (Eurasia) JSC to Global Development JSC. Completion of
the transaction is subject to various regulatory approvals. As of the date of
this report and as announced in September 2025, the buyer has not
received all necessary approvals yet. We continue working towards
completing the transaction and our exit from the Russian market. In the
meantime, we are in discussion with regulators on the conflicting
regulatory requirements in various jurisdictions with respect to the
activities of ING Bank (Eurasia) JSC.
As a result of frequent evaluation of the business from economic, strategic
and risk-based perspectives, ING, with limited exception, does not engage
in business involving certain countries, including Cuba, Iran, North Korea,
Sudan, Syria and the Crimea region. ING has a policy not to enter into new
relationships with clients from these countries and processes are in place
to discontinue existing relationships involving these countries.
Public-private partnerships
We continue to work with our peers, regulators and law enforcement in
public-private partnerships (PPPs) in our major markets, and on an
international level, by being part of existing PPPs and by initiating new
partnerships, such as those with German stakeholders and counterparts.
We recognise that our risk management frameworks and controls benefit
from having a direct dialogue with public partners as well as
complementing our understanding of relevant and evolving financial crime
threats and risks. Sharing and applying these insights across the
organisation helps us move beyond technical regulatory compliance and
enhances our ability to manage risks.
Conduct compliance and ethics
ING’s product governance and conduct compliance risk management
amplify that we aim to act in the interest of our customers. Focus areas
include customer protection and transparency (referred to as customer
centricity), market conduct (including counteracting market manipulation
and abuse), anti-competitive conduct, and management of conflicts of
interest.
Customer centricity
Putting our customers at the heart of what we do continues to be reflected
in ING’s Compliance framework around customer centricity. The Customer
Centricity Policy (CCP) sets central norms to meet customer needs on a
continuous basis, from the creation of a product and throughout the full
product lifecycle. In order to ensure the customer voice is reflected in the
way we measure compliance with customer centricity norms, we
developed a data driven approach to measure customer outcomes by
combining customer experience-related data with control data, increasing
our insight into trends and allowing business and Compliance to respond
to potential customer harm at an early stage. In 2025, we have
implemented the EU Accessibility Act setting the minimum norms for the
accessibility of products and services.
ESG
In line with ING’s strategy to put sustainability at the heart of what we do,
the ESG & Ethics team in Group Compliance aims to ensure a structural
and embedded approach to ESG within Compliance. Material ESG-related
topics are increasingly influenced by fast-moving regulatory changes, and
rising stakeholder expectations. To proactively manage these risks, ING is
strengthening its Compliance framework on several fronts. We are
continuing to enhance controls to prevent greenwashing, aligning ESG
commitments with evolving disclosure standards, and integrating physical
and transition risks into customer-centricity assessments. As new
regulations emerge, they are systematically incorporated into our
compliance risk management framework.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 210 |
Speak up and ethics
ING wants to create, facilitate and maintain an environment in which
employees feel encouraged and supported to speak up at all times.
Conduct ethics is about supporting and protecting our employees by
means of (i) dealing with dilemmas; (ii) setting the right environment for
ethical decisions and behaviours; and (iii) providing for an escalation/
reporting process in case of concerns, and ensuring fair consequence
management. We rely on our Orange Code, containing the values and
behaviours that guide us, the Global Code of Conduct that prevents and
protects employees from behaving unethically, and the whistleblowing
framework in case of concerns.
A new global platform that enables anonymous reporting has been
implemented across the vast majority of ING locations. We also continued
our focus on anti-retaliation, fair consequence management, deliberate
after-care and aligning best practices and data collection across different
Speak up channels.
Data protection
At ING, data protection is at the core of our strategy and business
operations. As part of our strategic priority of ‘Staying safe & secure’ our
main principle is ‘the right people using the right data for the right
purpose’, i.e. personal data usage and record retention must be strictly
necessary and based on a legitimate basis. More information can be found
in the privacy statement on our corporate website.
As a globally operating bank, our data protection governance and
technical and organisational measures aim to ensure compliance with
European and local data protection laws. A group-wide personal data
protection framework is in place and was overhauled in 2025 to remain
compliant with changing European legislation and guidelines. In addition,
we have binding corporate rules to ensure appropriate safeguards for our
internal data transfers. It is our policy that our business entities, support
functions, as well as third parties that we engage with, ensure that the
data subject is granted a level of protection equivalent to that guaranteed
by the GDPR, especially if personal data is transferred outside of the
European economic area (EEA).
Regulatory developments which potentially lead to emerging or changing
data protection risks are monitored and managed on an ongoing basis.
Advancements in technology, particularly in artificial intelligence and
digitalisation have substantially increased the complexity of personal data
processing activities. These developments demand increased attention
and monitoring to remain within risk appetite and to make sure we
comply with privacy laws and ethical standards. Therefore, we have
further strengthened our data protection risk management by refining
procedures and guidelines, particularly around risk related to technology
and AI. This ensures alignment with applicable information security
standards and enhances our cooperation with third-party providers. This
also includes our regular monitoring and reporting approach.
We will continue to enhance our data protection assessment processes
and continuously perform regular internal audits on the personal data
processing that we do for clients and employees, including ING’s
technologies. We stay closely connected to the relevant supervisory
authorities and notify them as required.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 211 |
Model risk
Introduction
Model risk is the risk of financial loss or reputational damage resulting from
decisions that are principally based on the output of models due to errors
in the development, implementation, or use of models.
Model lines of defence
ING’s model risk and control structure is based on the three-model-lines-
of-defence (MLoD) approach and defines three different management
layers with distinct roles and oversight responsibilities.
§The first MLoD is comprised of business entities which own, use, or
develop models.
§The second MLoD sets the model risk management framework,
monitors and reports on model-related risk, performs independent
model validation, and challenges 1MLoD risk management activities.
§The third MLoD is the internal audit function.
Model Risk Management (MoRM)
The ING MoRM policy framework comprises the total set of measures and
tools in place to manage model risk. ING defines and implements controls
across the model lifecycle. ING uses four classes of models that represent
their inherent level of model risk based on their criticality, financial
materiality, and complexity. The model classification determines the depth
and extent of the applied model risk management activities, including
model validation. Model validation is the independent assessment of
whether a model is valid for its intended use. Models are validated
according to procedures applicable to key model types. These procedures
are continuously being enhanced to keep up to date with regulatory and
technical developments, and industry trends.
Model risk appetite (model RAS)
The model risk appetite is designed to determine the level of model risk
ING is willing to accept in pursuit of its strategic objectives. The model RAS
metrics focus on the most material models for ING as reflected via the
model classification. These metrics are reported to the MBB monthly.
On an aggregated level, model risk is monitored via analysis of data from
the global model inventory, collected across the bank to manage ING’s
model landscape. Insights are shared with the MoRM Committee, MBB, and
other stakeholders, enabling senior management to make informed
decisions on whether to accept or further mitigate model risk.
AI risk management
In 2025, ING strengthened its commitment to responsible AI adoption by
creating an AI governance framework and control mechanisms, supported
by ethical principles that are applicable to all AI solutions. There are
dedicated staff allocated to AI risk management to support the risk
assessments in collaboration with the various risk functions. ING adopted a
qualitative Generative AI RAS (Risk Appetite Statement) focused on
customer protection, ethics, and accuracy and performance. The ING RAS
guides early-stage decision-making in areas where quantitative thresholds
are still under development, ING is committed to continue to strengthen its
AI risk management to ensure AI adoption remains safe and secure.
Business & strategy risk
Introduction
Business & strategy risk for ING has been defined as the risk inherent to
strategy decisions and internal efficiency measured by the value or
earnings loss from planning deviations, e.g. non-bank competition, internal
cost pressure, decreasing demand for loans, etc. This risk can be expressed
as earnings loss in terms of volumes, margins, expenses, and fee and
commission income. Business risk is accounted for within the economic
capital framework using a statistical model combined with a forward-
looking scenario module, which covers fee and commission income,
operating expenses, and regulatory expenses/costs.
Risk management
ING applies an explicit risk appetite statement regarding business and
strategy risk. It reflects the risks not already covered within the main risk-
type specific RAS, e.g. capturing risk costs, RWA, or NII. The underlying
economic capital risk types (expense risk, volume-margin risk, and
regulatory costs) are mitigated and managed via the financial
performance of the bank and the business units. Through this process, the
reported numbers are compared quarterly against financial projections
and discussed continuously within different parts of the organisation.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 212 |
Selected Statistical Information on Banking Operations
Reference is made to Note 1 ‘Basis of preparation and material accounting
policy information’ of the Consolidated financial statements for
information on Changes in accounting principles, estimates and
presentation of the consolidated financial statements and related notes.
The information in this section sets forth selected statistical information
regarding the Group’s operations. Information for 2025, 2024 and 2023 is
set forth under IFRS-IASB. Unless otherwise indicated, average balances,
when used, are calculated from monthly data and the distinction between
domestic and foreign is based on the location of the office where the
assets and liabilities are booked, as opposed to the domicile of the
customer. However, the Company believes that the presentation of these
amounts based upon the domicile of the customer would not result in
material differences in the amounts presented in this section.
Average balances and interest rates
The following tables show the Group’s operations, average interest-earning
assets and average interest-bearing liabilities, together with average rates,
for the periods indicated. The calculation of average balance is based on
balances as per month-end, while for certain products (such as Securities
purchased/sold under agreements to repurchase) balances can fluctuate
substantially during the month. The interest income, interest expense and
average yield figures do not reflect interest income and expense on
derivatives and other interest income and expense not considered to be
directly related to interest-bearing assets and liabilities. These items are
reflected in the corresponding interest income, interest expense and net
interest income figures in the consolidated financial statements. A
reconciliation of the interest income, interest expense and net interest
income figures to the corresponding line items in the consolidated
financial statements is presented in the following tables.
ASSETS | ||||||||||
Interest-earning assets | ||||||||||
2025 | 2024 | 2023 | ||||||||
Average balance | Interest income | Average yield % | Average balance | Interest income | Average yield % | Average balance | Interest income | Average yield % | ||
(EUR millions) | (EUR millions) | (EUR millions) | ||||||||
Time deposits with banks | ||||||||||
domestic | 1,766 | 52 | 3.0 | 1,921 | 89 | 4.6 | 2,620 | 111 | 4.3 | |
foreign | 1,633 | 259 | 15.8 | 1,388 | 290 | 20.9 | 1,236 | 256 | 20.7 | |
Loans and advances | ||||||||||
domestic | 202,457 | 7,135 | 3.5 | 187,540 | 7,191 | 3.8 | 184,864 | 6,548 | 3.5 | |
foreign | 501,315 | 20,761 | 4.1 | 477,603 | 22,216 | 4.7 | 461,351 | 20,287 | 4.4 | |
Securities purchased with agreements to resell | ||||||||||
domestic | 31,590 | 893 | 2.8 | 10,904 | 377 | 3.5 | 17,174 | 343 | 2.0 | |
foreign | 67,388 | 4,554 | 6.8 | 67,062 | 5,867 | 8.8 | 68,727 | 4,506 | 6.6 | |
Interest-earning securities1 | ||||||||||
domestic | 38,192 | 948 | 2.5 | 35,467 | 799 | 2.3 | 32,511 | 562 | 1.7 | |
foreign | 66,668 | 2,229 | 3.3 | 62,338 | 2,039 | 3.3 | 55,670 | 1,386 | 2.5 | |
Other interest-earning assets | ||||||||||
domestic | 26,166 | 829 | 3.2 | 44,302 | 2,160 | 4.9 | 56,611 | 2,720 | 4.8 | |
foreign | 61,704 | 1,661 | 2.7 | 60,717 | 2,062 | 3.4 | 61,658 | 2,118 | 3.4 | |
Total | 998,880 | 39,319 | 3.9 | 949,242 | 43,089 | 4.5 | 942,421 | 38,839 | 4.1 | |
Non-interest earning assets | 61,298 | 65,580 | 54,850 | |||||||
Derivatives assets | 26,330 | 26,422 | 30,215 | |||||||
Total assets | 1,086,507 | 1,041,245 | 1,027,486 | |||||||
Percentage of assets applicable to foreign operations | 70.0% | 69.6% | 67.8% | |||||||
Other interest income: | ||||||||||
Interest income on derivatives | 11,633 | 15,717 | 13,112 | |||||||
Other | 375 | 352 | 448 | |||||||
Total interest income | 51,327 | 59,159 | 52,399 | |||||||
1Substantially all interest-earning securities held by the banking operations of the Company are taxable securities.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 213 |
LIABILITIES | ||||||||||
Interest-bearing liabilities | ||||||||||
2025 | 2024 | 2023 | ||||||||
Average balance | Interest expense | Average yield | Average balance | Interest expense | Average yield | Average balance | Interest expense | Averag e yield | ||
(EUR millions) | % | (EUR millions) | % | (EUR millions) | % | |||||
Time deposits from banks | ||||||||||
domestic | 5,757 | 245 | 4.3 | 5,797 | 290 | 5.0 | 19,646 | 678 | 3.4 | |
foreign | 7,280 | 187 | 2.6 | 7,806 | 288 | 3.7 | 11,881 | 308 | 2.6 | |
Current accounts | ||||||||||
domestic | 91,923 | 1,299 | 1.4 | 88,854 | 1,349 | 1.5 | 97,084 | 1,025 | 1.1 | |
foreign | 131,769 | 456 | 0.3 | 125,858 | 577 | 0.5 | 135,088 | 362 | 0.3 | |
Time deposits 1 | ||||||||||
domestic | 39,549 | 1,494 | 3.8 | 41,159 | 2,019 | 4.9 | 39,054 | 1,977 | 5.1 | |
foreign | 82,171 | 2,886 | 3.5 | 76,510 | 3,293 | 4.3 | 43,111 | 1,876 | 4.4 | |
Savings deposits | ||||||||||
domestic | 123,227 | 1,415 | 1.1 | 114,398 | 1,531 | 1.3 | 108,789 | 901 | 0.8 | |
foreign | 250,511 | 3,739 | 1.5 | 232,063 | 4,239 | 1.8 | 234,282 | 3,148 | 1.3 | |
Securities sold under agreements to repurchase | ||||||||||
domestic | 13,103 | 715 | 5.5 | 2,188 | 548 | 25.1 | 1,085 | 478 | 44.1 | |
foreign | 45,319 | 3,701 | 8.2 | 54,823 | 5,232 | 9.5 | 64,905 | 4,314 | 6.6 | |
Commercial paper | ||||||||||
domestic | 18,303 | 520 | 2.8 | 18,072 | 749 | 4.1 | 13,159 | 484 | 3.7 | |
foreign | 30,710 | 1,382 | 4.5 | 28,090 | 1,511 | 5.4 | 22,099 | 1,193 | 5.4 | |
LIABILITIES | ||||||||||
Interest-bearing liabilities | ||||||||||
2025 | 2024 | 2023 | ||||||||
Average balance | Interest expense | Average yield | Average balance | Interest expense | Average yield | Average balance | Interest expense | Averag e yield | ||
(EUR millions) | % | (EUR millions) | % | (EUR millions) | % | |||||
Short term debt | ||||||||||
domestic | 5,081 | 214 | 4.2 | 5,288 | 285 | 5.4 | 5,841 | 286 | 4.9 | |
foreign | 1,414 | 165 | 11.6 | 1,738 | 131 | 7.6 | 1,669 | 72 | 4.3 | |
Long term debt | ||||||||||
domestic | 76,783 | 2,426 | 3.2 | 72,875 | 2,281 | 3.1 | 62,233 | 1,750 | 2.8 | |
foreign | 26,508 | 722 | 2.7 | 22,835 | 685 | 3.0 | 19,106 | 549 | 2.9 | |
Subordinated liabilities | ||||||||||
domestic | 17,604 | 818 | 4.6 | 16,462 | 757 | 4.6 | 16,057 | 711 | 4.4 | |
foreign | 129 | 40 | 0.0 | 0 | 0 | 0.0 | ||||
Other interest‑bearing liabilities | ||||||||||
domestic | 4,184 | 350 | 8.4 | 5,081 | 546 | 10.7 | 4,705 | 693 | 14.7 | |
foreign | 10,261 | 433 | 4.2 | 7,632 | 266 | 3.5 | 6,639 | 253 | 3.8 | |
Total | 981,586 | 23,167 | 2.4 | 927,570 | 26,578 | 2.9 | 906,434 | 21,057 | 2.3 | |
Non-interest bearing liabilities | 27,462 | 36,419 | 37,365 | |||||||
Derivatives liabilities | 22,241 | 23,236 | 28,452 | |||||||
Total liabilities | 1,031,289 | 987,225 | 972,251 | |||||||
Group capital | 55,218 | 54,020 | 55,235 | |||||||
Total liabilities and capital | 1,086,507 | 1,041,245 | 1,027,486 | |||||||
Percentage of liabilities applicable to foreign operations | 59.8% | 59.5% | 58.8% | |||||||
Other interest expense: | ||||||||||
Interest expenses on derivatives | 12,936 | 17,030 | 14,927 | |||||||
other | 267 | 263 | 253 | |||||||
Total interest expense | 36,371 | 43,871 | 36,237 | |||||||
Total net interest result | 14,957 | 15,288 | 16,162 | |||||||
1These captions do not include deposits from banks.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 214 |
Analysis of changes in net interest income
The following table allocates changes in the Group’s operations’ interest
income and expense and net interest result between changes in average
balances and rates for the periods indicated. Changes due to a
combination of volume and rate have been allocated to changes in
average volume. The net changes in interest income, interest expense and
net interest result, as calculated in this table, have been reconciled to the
changes in interest income, interest expense and net interest result in the
consolidated financial statements. See introduction to “Average Balances
and Interest Rates” for a discussion of the differences between interest
income, interest expense and net interest result as calculated in the
following table and as set forth in the consolidated financial statements.
2025 over 2024 | 2024 over 2023 | ||||||
Increase (decrease) due to changes in | Increase (decrease) due to changes in | ||||||
Average volume | Average rate | Net change | Average volume | Average rate | Net change | ||
(EUR millions) | (EUR millions) | ||||||
Interest-earning assets | |||||||
Time deposits to banks | |||||||
domestic | -7 | -30 | -37 | -30 | 7 | -23 | |
foreign | 51 | -82 | -31 | 32 | 2 | 34 | |
Loans and advances | |||||||
domestic | 490 | -547 | -57 | 80 | 563 | 643 | |
foreign | 1,054 | -2,510 | -1,455 | 810 | 1,119 | 1,929 | |
Securities purchased with agreements to resell | |||||||
Domestic | 715 | -199 | 516 | -125 | 159 | 33 | |
foreign | 28 | -1,342 | -1,314 | -109 | 1,470 | 1,361 | |
Interest-earning securities | |||||||
Domestic | 61 | 87 | 149 | 51 | 186 | 237 | |
foreign | 142 | 48 | 190 | 166 | 486 | 652 | |
Other interest-earning assets | |||||||
domestic | -884 | -447 | -1,331 | -591 | 32 | -560 | |
foreign | 34 | -434 | -401 | -32 | -24 | -57 | |
Interest income | |||||||
domestic | 375 | -1,134 | -759 | -616 | 947 | 331 | |
foreign | 1,309 | -4,320 | -3,011 | 866 | 3,053 | 3,919 | |
Total | 1,684 | -5,454 | -3,770 | 250 | 4,000 | 4,250 | |
Other interest income | -4,062 | 2,510 | |||||
Total interest income | -7,832 | 6,760 | |||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 215 |
2025 over 2024 | 2024 over 2023 | ||||||
Increase (decrease) due to changes in | Increase (decrease) due to changes in | ||||||
Average volume | Average rate | Net change | Average volume | Average rate | Net change | ||
(EUR millions) | (EUR millions) | ||||||
Interest-bearing liabilities | |||||||
Time deposits from banks | |||||||
domestic | -2 | -43 | -45 | -478 | 90 | -388 | |
foreign | -19 | -82 | -101 | -106 | 86 | -20 | |
Current accounts | |||||||
domestic | 47 | -97 | -50 | -87 | 411 | 324 | |
foreign | 27 | -148 | -121 | -25 | 240 | 216 | |
Time deposits | |||||||
domestic | -79 | -446 | -525 | 107 | -65 | 42 | |
foreign | 244 | -651 | -407 | 1,454 | -37 | 1,416 | |
Savings deposits | |||||||
domestic | 118 | -235 | -116 | 47 | 583 | 630 | |
foreign | 338 | -837 | -500 | -30 | 1,121 | 1,091 | |
Securities sold under agreements to repurchase | |||||||
domestic | 2,737 | -2,571 | 166 | 486 | -415 | 71 | |
foreign | -907 | -624 | -1,531 | -670 | 1,588 | 917 | |
Commercial paper | |||||||
domestic | 10 | -239 | -229 | 181 | 84 | 265 | |
foreign | 141 | -270 | -129 | 323 | -6 | 318 | |
Short term debt | |||||||
domestic | -11 | -60 | -71 | -27 | 26 | -1 | |
foreign | -24 | 58 | 34 | 3 | 56 | 59 | |
Long term debt | |||||||
domestic | 122 | 23 | 145 | 299 | 232 | 531 | |
foreign | 110 | -73 | 37 | 107 | 29 | 136 | |
Subordinated liabilities | |||||||
domestic | 53 | 9 | 61 | 18 | 27 | 45 | |
foreign | |||||||
2025 over 2024 | 2024 over 2023 | ||||||
Increase (decrease) due to changes in | Increase (decrease) due to changes in | ||||||
Average volume | Average rate | Net change | Average volume | Average rate | Net change | ||
(EUR millions) | (EUR millions) | ||||||
Other interest-bearing liabilities | |||||||
domestic | -96 | -100 | -196 | 55 | -202 | -147 | |
foreign | 92 | 76 | 168 | 38 | -25 | 13 | |
Interest expense | |||||||
domestic | 2,898 | -3,758 | -861 | 601 | 772 | 1,372 | |
foreign | 0 | -2,550 | -2,550 | 1,094 | 3,052 | 4,147 | |
Total | 2,898 | -6,309 | -3,411 | 1,695 | 3,824 | 5,519 | |
Other interest expense | -4,089 | 2,114 | |||||
Total interest expense | -7,500 | 7,633 | |||||
Net interest | |||||||
domestic | -2,523 | 2,624 | 101 | -1,217 | 176 | -1,041 | |
foreign | 1,309 | -1,769 | -461 | -228 | 1 | 228 | |
Net interest | -1,214 | 855 | -359 | -1,445 | 176 | -1,269 | |
Other net interest result | 28 | 396 | |||||
Net interest result | -332 | -873 | |||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 216 |
The following table shows the interest spread and net interest margin for the past two years.
2025 | 2024 | ||
Average rate | Average rate | ||
% | % | ||
Interest spread | |||
Domestic | 0.8 | 0.8 | |
Foreign | 1.9 | 2.0 | |
Total | 1.6 | 1.7 | |
Net interest margin | |||
Domestic | 0.0 | -0.1 | |
Foreign | 2.3 | 2.5 | |
Total | 1.6 | 1.7 | |
Investments in debt securities
The following tables show the weighted average yield of ING’s investments on debt securities measured at
amortised cost and fair value through other comprehensive income. The weighted average yield is calculated as
follows:
Nominal value * coupon rate * remaining maturity
Nominal value * remaining maturity
Weighted average yield | ||||
2025 | 1 year or less | Between 1 and 5 years | Between 5 and 10 years | Over 10 years |
Fair value through other comprehensive income | ||||
Government bonds | 3.79% | 4.16% | 3.13% | 3.37% |
Central Bank bonds | ||||
Sub-sovereign, Supranationals and Agencies | 3.39% | 2.65% | 2.95% | 3.53% |
Covered bonds | 2.03% | 2.51% | 2.70% | |
Corporate bonds | 1.84% | 3.13% | ||
Financial institutions bonds | 2.87% | 5.13% | ||
ABS portfolio | 2.46% | 2.50% | 2.71% | |
1Since substantially all investment securities held by the banking operations of the Company are taxable securities, the yields are on tax-equivalent basis.
Weighted average yield | ||||
2025 | 1 year or less | Between 1 and 5 years | Between 5 and 10 years | Over 10 years |
Securities at amortised cost | ||||
Government bonds | 2.37% | 2.78% | 3.09% | 4.43% |
Central Bank bonds | —% | |||
Sub-sovereign, Supranationals and Agencies | 2.64% | 1.54% | 2.81% | 3.17% |
Covered bonds | 1.21% | 1.60% | 1.99% | |
Corporate bonds | 2.25% | 5.72% | ||
Financial institutions bonds | 0.53% | |||
ABS portfolio | 4.87% | 3.19% | 2.78% | |
1Since substantially all investment securities held by the banking operations of the Company are taxable securities, the yields are on tax-equivalent basis.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 217 |
Loan Portfolio
Loans and advances to banks and customers
Loans and advances to banks include all receivables from credit institutions, except for cash, current accounts and
deposits with other banks (including central banks). Loans and advances to customers includes lending facilities to
corporate and private customers encompass among others, loans, overdrafts and finance lease receivables.
Maturities and sensitivity of loans to changes in interest rates
The following table analyses loans and advances to banks and customers by time remaining until maturity as of
31 December 2025.
2025 | 1 year or less | 1 year to 5 years | 5 years through 15 years | After 15 years | Total |
By domestic offices: | |||||
Loans to banks | 11,311 | 874 | 177 | 0 | 12,362 |
Loans to public authorities | 325 | 463 | 2,426 | 239 | 3,452 |
Residential mortgages | 2,968 | 16,727 | 51,708 | 58,590 | 129,994 |
Other personal lending | 905 | 2,335 | 1,166 | 627 | 5,033 |
Corporate Lending | 24,238 | 33,602 | 10,350 | 602 | 68,792 |
Total domestic offices | 39,747 | 54,001 | 65,828 | 60,057 | 219,633 |
By foreign offices: | |||||
Loans to banks | 6,915 | 1,384 | 542 | 0 | 8,841 |
Loans to public authorities | 7,047 | 4,551 | 6,802 | 1,183 | 19,583 |
Residential mortgages | 15,886 | 59,817 | 111,120 | 58,280 | 245,103 |
Other personal lending | 9,904 | 17,035 | 6,148 | 1,602 | 34,690 |
Corporate Lending | 90,064 | 108,820 | 26,702 | 1,396 | 226,981 |
Total foreign offices | 129,815 | 191,608 | 151,314 | 62,461 | 535,198 |
Total gross loans and advances to banks and customers | 169,562 | 245,609 | 217,142 | 122,518 | 754,831 |
The following table analyzes loans and advances to banks and customers by interest rate sensitivity by maturity
as of 31 December 2025 for loans and advances due after one year.
2025 | Predetermined interest rates | Floating or adjustable interest rates 1 |
Loans to banks | 340 | 2,637 |
Loans to public authorities | 11,329 | 4,334 |
Residential mortgages | 247,567 | 108,676 |
Other personal lending | 23,528 | 5,386 |
Corporate Lending | 54,924 | 126,548 |
Total | 337,688 | 247,581 |
1Loans that have an interest rate that remains fixed for more than one year and which can then be changed are classified as “adjustable interest rates”.
Allowance for credit losses
The following table presents the movements in allocation of the provision for loan losses on loans accounted for as
loans and advances to banks and customers for 2025, 2024 and 2023 under IFRS-IASB.
Movements in allocation of the provision for loan losses on loans | |||
2025 | 2024 | 2023 | |
Balance on 1 January | 6,049 | 5,839 | 6,101 |
Impact of changes in accounting policies | 95 | ||
Write-offs | -937 | -1,017 | -1,111 |
Recoveries | 58 | 69 | 71 |
Net write-offs | -879 | -948 | -1,039 |
Additions and other adjustments (included in value Adjustments to receivables of the Banking operations) | 932 | 1,157 | 683 |
Balance on 31 December | 6,101 | 6,049 | 5,839 |
Average loans and advances to banks and customers | 739,101 | 690,544 | 671,424 |
Ratio of net charge‑offs to average loans and advances to banks and customers | 0.12% | 0.14% | 0.15% |
Ratio of allowance for credit losses to total loans and advances to banks and customers outstanding | 0.81% | 0.85% | 0.88% |
Additions to loan loss provisions have increased compared to 2024. Loan loss provisions are influenced by
developments in general macroeconomic conditions as well as certain individual exposures. Reference is made to
Note 1 ‘Basis of preparation and material accounting policy information’ and ‘Additional information – Risk
Management’ for detailed information on loan loss provisioning.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | 218 |
Deposits
Reference is made to ‘Additional information – Average balances and interest rates’ for detailed information on
average amount of and the average rate paid on deposit categories.
For the years ended 31 December 2025, 2024 and 2023 the aggregate amount of deposits by foreign depositors in
domestic offices was EUR 36,625 million, EUR 38,419 million and EUR 37,360 million respectively.
Uninsured deposits
For the years ended 31 December 2025 and 2024 the amount of uninsured deposits, which were not covered by
DGS, was EUR 222,384 million and EUR 202,968 million, respectively.
Deposit guarantee schemes (DGS) reimburse a limited amount to compensate depositors whose bank has failed. A
fundamental principle underlying DGS is that they are funded entirely by banks, and that no taxpayer funds are
used. Under EU rules, the Deposit Guarantee Scheme (DGS) guarantees deposits up to a maximum of EUR 100,000
per depositor in case of a bank failure.
On 31 December 2025, the amount of time deposits in excess of (local) deposit insurance regime and time
deposits which are otherwise uninsured is as follows:
Time deposits in excess on deposit insurance regime | Other uninsured Time deposits | |
(EUR millions) | (EUR millions) | |
3 months or less | 17,369 | 22,479 |
6 months or less but over 3 months | 5,119 | 5,903 |
12 months or less but over 6 months | 3,326 | 4,784 |
Over 12 months | 332 | 3,798 |
Total | 26,147 | 36,964 |
For further detailed information on deposits reference is made to Note 12 'Deposits from banks' and Note 13
'Customer deposits' of the consolidated financial statements.
Financial
statements
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-220 |
Contents
Report of Independent Registered Public Accounting Firm | F-221 |
Consolidated financial statements
Consolidated statement of financial position | F-223 |
Consolidated statement of profit or loss | F-224 |
Consolidated statement of comprehensive income | F-225 |
Consolidated statement of changes in equity | F-226 |
Consolidated statement of cash flows | F-229 |
Notes to the consolidated financial statements
1 Basis of preparation and material accounting policy information | F-231 |
Notes to the consolidated statement of financial
position
2 Cash and balances with central banks | F-249 |
3 Loans and advances to banks | F-249 |
4 Financial assets at fair value through profit or loss | F-249 |
5 Financial assets at fair value through other comprehensive income | F-251 |
6 Debt securities | F-252 |
7 Loans and advances to customers | F-253 |
8 Investment in associates and joint ventures | F-253 |
9 Property and equipment | F-255 |
10 Intangible assets | F-256 |
11 Other assets | F-257 |
12 Deposits from banks | F-258 |
13 Customer deposits | F-258 |
14 Financial liabilities at fair value through profit or loss | F-258 |
15 Provisions | F-259 |
16 Other liabilities | F-260 |
17 Debt securities in issue | F-260 |
18 Subordinated loans | F-261 |
19 Equity | F-261 |
Notes to the consolidated statement of profit or
loss
20 Net interest income | F-266 |
21 Net fee and commission income | F-267 |
22 Valuation results and net trading income | F-267 |
23 Investment income | F-268 |
24 Other net income | F-268 |
25 Staff expenses | F-268 |
26 Other operating expenses | F-270 |
27 Audit fees | F-270 |
28 Earnings per ordinary share | F-271 |
29 Dividend per ordinary share | F-271 |
Segment reporting
30 Segments | F-272 |
31 Information on geographical areas | F-277 |
Additional notes to the consolidated financial
statements
32 Potential sale of ING Bank (Eurasia) JSC | F-281 |
33 Pensions and other post-employment benefits | F-281 |
34 Taxation | F-285 |
35 Fair value of assets and liabilities | F-288 |
36 Derivatives and hedge accounting | F-298 |
37 Assets by contractual maturity | F-305 |
38 Liabilities and off-balance sheet commitments by maturity | F-306 |
39 Transfer of financial assets, assets pledged and received as collateral | F-309 |
40 Offsetting financial assets and liabilities | F-310 |
41 Commitments | F-315 |
42 Legal proceedings | F-316 |
43 Principal subsidiaries, investments in associates and joint ventures | F-318 |
44 Structured entities | F-319 |
45 Related parties | F-321 |
46 Capital management | F-323 |
47 Condensed financial information of the parent company | F-325 |
48 Subsequent events | F-330 |
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-221 |
 |
Report of Independent Registered Public Accounting Firm
To the Shareholders and the Supervisory Board of ING Groep N.V.
Opinion on the Consolidated Financial Statements
We have audited the accompanying consolidated statements of
financial position of ING Groep N.V. and subsidiaries (‘the Company’)
as of December 31, 2025 and 2024, the related consolidated
statements of profit or loss, comprehensive income, changes in equity,
and cash flows for each of the years in the three year period ended
December 31, 2025, and the related notes and specific disclosures
described in Note 1 as being part of the consolidated financial
statements (collectively, the consolidated financial statements).
In our opinion, the consolidated financial statements present fairly, in all
material respects, the financial position of the Company as of
December 31, 2025 and 2024, and the results of its operations and its
cash flows for each of the years in the three year period ended
December 31, 2025, in conformity with International Financial Reporting
Standards as issued by the International Accounting Standards Board.
We also have audited, in accordance with the standards of the Public
Company Accounting Oversight Board (United States) (PCAOB), the
Company’s internal control over financial reporting as of December 31,
2025, based on criteria established in Internal Control – Integrated
Framework (2013) issued by the Committee of Sponsoring
Organizations of the Treadway Commission, and our report dated
February 23, 2026 expressed an unqualified opinion on the
effectiveness of the Company’s internal control over financial reporting.
Basis for Opinion
These consolidated financial statements are the responsibility of the
Company’s management. Our responsibility is to express an opinion on
these consolidated financial statements based on our audits.
We are a public accounting firm registered with the PCAOB and are
required to be independent with respect to the Company in accordance
with the U.S. federal securities laws and the applicable rules and
regulations of the Securities and Exchange Commission and the
PCAOB.
We conducted our audits in accordance with the standards of the
PCAOB. Those standards require that we plan and perform the audit to
obtain reasonable assurance about whether the consolidated financial
statements are free of material misstatement, whether due to error or
fraud. Our audits included performing procedures to assess the risks of
material misstatement of the consolidated financial statements, whether
due to error or fraud, and performing procedures that respond to those
risks. Such procedures included examining, on a test basis, evidence
regarding the amounts and disclosures in the consolidated financial
statements. Our audits also included evaluating the accounting
principles used and significant estimates made by management, as well
as evaluating the overall presentation of the consolidated financial
statements. We believe that our audits provide a reasonable basis for
our opinion.
Critical Audit Matter
The critical audit matter communicated below is a matter arising from
the current period audit of the consolidated financial statements that
was communicated or required to be communicated to the audit
committee and that: (1) relates to accounts or disclosures that are
material to the consolidated financial statements and (2) involved our
especially challenging, subjective, or complex judgements. The
communication of a critical audit matter does not alter in any way our
opinion on the consolidated financial statements, taken as a whole, and
we are not, by communicating the critical audit matter below, providing
a separate opinion on the critical audit matter or on the accounts or
disclosures to which it relates.
Assessment of expected credit losses on loans and
advances to customers and loans and advances to
banks
As discussed in the Credit Risk section on pages 160 - 187 and in Note
3 and Note 7 in the consolidated financial statements, the loans and
advances to customers amount to EUR 728 billion and loans and
advances to banks amount to EUR 21 billion as at December 31, 2025.
These loans and advances are measured at amortised cost, less
expected credit losses (‘ECL’) of EUR 5.9 billion. For collectively
determined ECL, management uses models that estimate expected
credit losses using three components: probability of default (‘PD’), loss
given default (‘LGD’) and exposure at default (‘EAD’). Management also
applied forward looking economic scenarios with associated weights.
Relevant macroeconomic factors include the gross domestic product
(‘GDP’), house price index (‘HPI’) and unemployment rate. The recent
economic conditions are outside the bounds of historical experience
used to develop ECL model methodologies and result in greater
uncertainties to estimate ECLs. These uncertainties are considered by
management in their assessment of whether judgemental overlays to
model-based provisions need to be applied. For individually determined
provisions, management estimates ECL using the amount and timing of
future expected recovery scenarios and applying probability weights if
more than one recovery scenario is present.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-222 |
|
We identified the assessment of ECL on loans and advances to
customers and loans and advances to banks as a critical audit matter
because of the significant and complex auditor judgement and
specialized skills and knowledge required to evaluate the following
elements of the overall ECL estimate:
•The judgements used to develop the model-driven PD and LGD
parameters.
•The use of forward-looking macroeconomic forecasts in ECL,
including determining macroeconomic factors such as GDP, HPI and
unemployment rate.
•The consistent identification and application of criteria for significant
increase in credit risk (‘SICR’).
•The determination of management overlays to the modelled ECL
considering the volatility and uncertainty in the economic
environment combined with the delay in which the models capture
emerging risks.
•The determination of the amount and timing of expected future
recovery cash flows for individual loan provision assessments for
impaired loans and advances and the probability weights applied in
the presence of more than one recovery scenario.
The following are the primary procedures we performed to address this
critical audit matter.
•We evaluated the design and tested the operating effectiveness of
certain internal controls related to the estimation of ECL for loans
and advances to customers and loans and advances to banks. This
included controls relating to the selection of key assumptions
(including PD, LGD and macroeconomic forecasts), review and
authorization of model outputs, governance and monitoring of the
ECL process, determination of credit risk ratings, the estimation of
future recovery cash flows of individual loan loss provisions and
associated scenario weights assigned and the determination of
management overlays to the modelled ECL.
•We involved credit risk professionals with specialized skills and
knowledge who assisted in evaluating the assumptions used to
determine the PD and LGD parameters in models used by the
Company to determine the collective provisions, including the
evaluation of the recalibrated and redeveloped credit risk models.
This included reperforming back-testing of certain models to
evaluate the current model performance and evaluation of the
identification of SICR in loans and advances by challenging the
scope of management’s criteria used in staging assessments,
consistent application of the thresholds applied within each criterion,
and the ability of staging criteria to identify SICR prior to loans and
advances being credit impaired. In addition, the credit risk
professionals assisted in testing management overlays recorded.
•We involved economic professionals with specialized skills and
knowledge, who assisted in assessing the Company’s methodology
to determine the macroeconomic forecasts used in determining the
ECL. We tested the reasonableness of management’s forecasts
against other external benchmarks and our own internal forecasts.
•We involved valuation and credit risk professionals with specialized
skills and knowledge, who assisted in assessing the methodologies,
cash flows and collateral values used in expected future recovery
cash flow assessments of individual loan loss provisions for impaired
loans and advances and in challenging management’s use of
recovery scenarios and expected cash flows by comparing against
industry trends and comparable benchmarks and recalculating
recovery amounts.
/s/ KPMG Accountants N.V.
We have served as the Company’s auditor since 2016.
Utrecht, The Netherlands
February 23, 2026
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-223 |
Consolidated statement of financial position
As at 31 December
in EUR million | 2025 | 2024 | 2025 | 2024 | ||
Assets | Liabilities | |||||
Cash and balances with central banks 2 | Deposits from banks 12 | |||||
Loans and advances to banks 3 | Customer deposits 13 | |||||
Financial assets at fair value through profit or loss 4,6 | Financial liabilities at fair value through profit or loss 14 | |||||
– Trading assets | – Trading liabilities | |||||
– Non-trading derivatives | – Non-trading derivatives | |||||
– Designated as at fair value through profit or loss | – Designated as at fair value through profit or loss | |||||
– Mandatorily at fair value through profit or loss | Current tax liabilities | |||||
Financial assets at fair value through other comprehensive income 5,6 | Deferred tax liabilities 34 | |||||
Securities at amortised cost 6 | Provisions 15 | |||||
Loans and advances to customers 7 | Other liabilities 16 | |||||
Investments in associates and joint ventures 8 | Debt securities in issue 17 | |||||
Property and equipment 9 | Subordinated loans 18 | |||||
Intangible assets 10 | Total liabilities | |||||
Current tax assets | ||||||
Deferred tax assets 34 | Equity 19 | |||||
Other assets 11 | Share capital and share premium | |||||
Other reserves | - | - | ||||
Retained earnings | ||||||
Shareholders’ equity (parent) | ||||||
Non-controlling interests | ||||||
Total equity | ||||||
Total assets | Total liabilities and equity | |||||
References relate to the accompanying notes. These are an integral part of the Consolidated financial statements.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-224 |
Consolidated statement of profit or loss
For the years ended 31 December
in EUR million | 2025 | 2024 | 2023 | 2025 | 2024 | 2023 | ||
Interest income using effective interest rate method | Addition to loan loss provisions | |||||||
Other interest income | Staff expenses 25 | |||||||
Total interest income | Other operating expenses 26 | |||||||
Total expenses | ||||||||
Interest expense using effective interest rate method | - | - | - | |||||
Other interest expense | - | - | - | Result before tax | ||||
Total interest expense | - | - | - | |||||
Taxation 34 | ||||||||
Net interest income 20 | Net result | |||||||
Fee and commission income | Net result attributable to: | |||||||
Fee and commission expense | - | - | - | Non-controlling interests | ||||
Net fee and commission income 21 | Shareholders of the parent | |||||||
Valuation results and net trading income 22 | - | |||||||
Investment income 23 | ||||||||
Share of result from associates and joint ventures 8 | ||||||||
Impairment of associates and joint ventures 8 | - | - | - | in EUR | ||||
Net result on derecognition of financial assets measured at amortised cost | - | Earnings per ordinary share 28 | ||||||
Other net income 24 | - | - | Basic earnings per ordinary share | |||||
Total income | Diluted earnings per ordinary share | |||||||
References relate to the accompanying notes. These are an integral part of the Consolidated financial statements.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-225 |
Consolidated statement of comprehensive income
For the years ended 31 December
in EUR million | 2025 | 2024 | 2023 |
Net result | |||
Other comprehensive income | |||
Items that will not be reclassified to the statement of profit or loss: | |||
Unrealised revaluations property in own use | |||
Remeasurement of the net defined benefit asset/liability | - | - | - |
Change in fair value of equity instruments at fair value through other comprehensive income | - | - | |
Changes in fair value related to changes in own credit risk for financial liabilities designated at fair value through profit or loss | - | - | - |
Items that may subsequently be reclassified to the statement of profit or loss: | |||
Change in fair value of debt instruments at fair value through other comprehensive income | - | ||
Realised gains/losses on debt instruments at fair value through other comprehensive income reclassified to the statement of profit or loss | - | ||
Changes in cash flow hedge reserve | |||
Exchange rate differences | - | - | |
Total other comprehensive income | |||
Total comprehensive income | |||
Total comprehensive income attributable to: | |||
Non-controlling interests | |||
Shareholders of the parent | |||
Each component of the other comprehensive income is presented after taxation. For the disclosure on the income tax effects on each component, reference is made to Note 34 'Taxation'.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-226 |
Consolidated statement of changes in equity
in EUR million | Share capital and share premium | Other reserves | Retained earnings | Shareholders' equity (parent) | Non-controlling interests | Total equity | |||
Balance as at 31 December 2024 | - | ||||||||
Net result | |||||||||
Other comprehensive income | - | - | |||||||
Total comprehensive income net of tax | - | ||||||||
Dividends and other cash distributions 29 | - | - | - | - | |||||
Share buyback programmes, commitment | - | - | - | ||||||
Share buyback programmes, repurchases of shares | - | - | - | ||||||
Share buyback programmes, cancellation of shares | - | - | |||||||
Employee share-based compensation plans | - | ||||||||
Other changes in treasury shares | |||||||||
Transfers | - | ||||||||
Other changes | - | ||||||||
Balance as at 31 December 2025 | - | ||||||||
References relate to the accompanying notes. These are an integral part of the Consolidated financial statements. Changes in individual Reserve components are presented in Note 19 'Equity'.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-227 |
Consolidated statement of changes in equity - continued
in EUR million | Share capital and share premium | Other reserves | Retained earnings | Shareholders' equity (parent) | Non-controlling interests | Total equity | |||
Balance as at 31 December 2023 | - | ||||||||
Net result | |||||||||
Other comprehensive income | |||||||||
Total comprehensive income net of tax | |||||||||
Dividends and other cash distributions 29 | - | - | - | - | |||||
Share buyback programmes, commitment | - | - | - | ||||||
Share buyback programmes, repurchases of shares | - | - | - | ||||||
Share buyback programmes, cancellation of shares | - | - | |||||||
Employee share-based compensation plans | |||||||||
Other changes in treasury shares | |||||||||
Transfers | - | ||||||||
Other changes | - | - | - | ||||||
Balance as at 31 December 2024 | - | ||||||||
References relate to the accompanying notes. These are an integral part of the Consolidated financial statements. Changes in individual Reserve components are presented in Note 19 'Equity'.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-228 |
Consolidated statement of changes in equity - continued
in EUR million | Share capital and share premium | Other reserves | Retained earnings | Shareholders' equity (parent) | Non-controlling interests | Total equity | |||
Balance as at 31 December 2022 | - | ||||||||
Impact of changes in accounting policies 1 | - | - | - | - | |||||
Balance as at 1 January 2023 | - | ||||||||
Net result | |||||||||
Other comprehensive income | |||||||||
Total comprehensive income net of tax | |||||||||
Dividends 29 | - | - | - | - | |||||
Share buyback programmes, commitment | - | - | - | ||||||
Share buyback programmes, repurchases of shares | - | - | - | ||||||
Share buyback programmes, cancellation of shares | - | - | |||||||
Employee share-based compensation plans | - | ||||||||
Other changes in treasury shares | - | - | - | ||||||
Transfers | - | ||||||||
Other changes | - | - | - | ||||||
Balance as at 31 December 2023 | - | ||||||||
1Changes in policy following the adoption of IFRS 17 and change in policy for non-financial guarantees.
References relate to the accompanying notes. These are an integral part of the Consolidated financial statements. Changes in individual Reserve components are presented in Note 19 'Equity'.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-229 |
Consolidated statement of cash flows
in EUR million, for the years ended 31 December | 2025 | 2024 | 2023 | |
Cash flows from operating activities | ||||
Result before tax | ||||
Adjusted for: | – Depreciation and amortisation | |||
– Addition to loan loss provisions | ||||
– Revaluations | ||||
– Exchange rate differences and other | - | |||
Taxation paid | - | - | - | |
Changes in: | – Loans and advances to banks, not available on demand | - | ||
– Deposits from banks, not payable on demand | - | - | ||
– Trading assets | - | - | ||
– Trading liabilities | - | - | - | |
– Loans and advances to customers | - | - | - | |
– Customer deposits | ||||
– Non–trading derivatives | - | |||
– Assets designated at fair value through profit or loss | ||||
– Assets mandatorily at fair value through profit or loss | - | - | ||
– Other assets | - | |||
– Other financial liabilities at fair value through profit or loss | - | |||
– Provisions and other liabilities | - | |||
Net cash flow from/(used in) operating activities | - | - | - | |
Cash flows from investing activities | ||||
Investments and advances: | - Associates and joint ventures | - | - | - |
- Financial assets at fair value through other comprehensive income | - | - | - | |
– Securities at amortised cost1 | - | - | - | |
– Property and equipment | - | - | - | |
2025 | 2024 | 2023 | ||
– Other investments | - | - | - | |
Disposals and redemptions: | – Associates and joint ventures | |||
- Financial assets at fair value through other comprehensive income | ||||
– Securities at amortised cost1 | ||||
– Property and equipment | ||||
– Other investments | ||||
Net cash flow from/(used in) investing activities | - | - | - | |
Cash flows from financing activities | ||||
Proceeds from debt securities1 | ||||
Repayments of debt securities1 | - | - | - | |
Proceeds from issuance of subordinated loans | ||||
Repayments of subordinated loans | - | - | - | |
Repayments of principal portion of lease liabilities | - | - | - | |
Purchases of treasury shares | - | - | - | |
Dividends and other cash distributions paid | - | - | - | |
Net cash flow from/(used in) financing activities | ||||
Net cash flow | - | - | - | |
Cash and cash equivalents at beginning of year | ||||
Effect of exchange rate changes on cash and cash equivalents | - | - | - | |
Cash and cash equivalents at end of year | ||||
1 Cash flows are reported on a gross basis and include investments and borrowings of short term securities .
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-230 |
Consolidated statement of cash flows - continued
Cash and cash equivalents | |||
in EUR million | 2025 | 2024 | 2023 |
Treasury bills and other eligible bills included in securities at AC | |||
Deposits from banks | - | - | - |
Loans and advances to banks | |||
Cash and balances with central banks | |||
Cash and cash equivalents at end of year | |||
Cash and cash equivalents includes only deposits from banks and loans and advances to banks that are payable
on demand.
Included in cash and cash equivalents are minimum mandatory reserve deposits held at various central banks.
Reference is made to Note 39 'Transfer of financial assets, assets pledged and received as collateral' for restrictions
on cash and balances with central banks.
Changes in liabilities arising from financing activities | |||||||||
Debt securities in issue | Subordinated Loans | Lease liabilities | |||||||
in EUR million | 2025 | 2024 | 2023 | 2025 | 2024 | 2023 | 2025 | 2024 | 2023 |
Opening balance | |||||||||
Cash flows: | |||||||||
Additions | |||||||||
Redemptions / Disposals | - | - | - | - | - | - | - | - | - |
Non cash changes: | |||||||||
Amortisation | |||||||||
Other | - | ||||||||
Changes in unrealised revaluations | |||||||||
Foreign exchange movement | - | - | - | - | - | - | |||
Closing balance | |||||||||
Part of Debt securities in issue and subordinated loans are subject to fair value hedge accounting. Hence, changes
in unrealised revaluations represent fair value adjustments to the hedged item attributable to the hedged interest
rate risk. Reference is made to the paragraph 'fair value hedge accounting' in Note 36 'Derivatives and hedge
accounting'.
The table below presents the interest and dividend received and paid.
in EUR million | 2025 | 2024 | 2023 |
Interest received | |||
Interest paid | - | - | - |
Dividend received | |||
Dividends and other cash distributions paid | - | - | - |
Dividends received from associates and joint ventures are included in investing activities; interest received, interest
paid and other dividends received are included in operating activities; and dividend paid is included in financing
activities in the Consolidated statement of cash flows.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-231 |
1 Basis of preparation and material accounting policy information
1.1 Reporting entity and authorisation of the Consolidated financial statements
ING Groep N.V. (Naamloze Vennootschap) is a company domiciled in Amsterdam, the Netherlands. Commercial
Register of Amsterdam, number 33231073. These Consolidated financial statements, as at and for the year ended
31 December 2025, comprise ING Groep N.V. (the Parent company) and its subsidiaries, together referred to as
ING Group. ING Group is a global financial institution with a strong European base, offering a wide range of retail
and wholesale banking services to customers.
The ING Group Consolidated financial statements, as at and for the year ended 31 December 2025, were
authorised for issue in accordance with a resolution of the Executive Board on 23 February 2026. The Executive
Board has the power to amend the financial statements as long as these are not adopted by the General Meeting
of Shareholders. The General Meeting of Shareholders may decide not to adopt the financial statements, but may
not amend these.
The ING Group Consolidated financial statements have been prepared in accordance with International Financial
Reporting Standards as issued by the International Accounting Standards Board for purposes of reporting with the
U.S. Securities and Exchange Commission (SEC), including financial information contained in this Annual report on
Form 20-F. The term ‘IFRS-IASB’ is used to refer to IFRS Accounting Standards as issued by the International
Accounting Standards Board, including the decisions ING Group made with regard to the options available under
IFRS-IASB.
The ING Group Consolidated financial statements have been prepared on a going concern basis and there are no
significant doubts about the ability of ING Group to continue as a going concern.
The Consolidated financial statements are presented in euros and rounded to the nearest million, unless stated
otherwise. Amounts may not add up due to rounding.
To improve transparency, reduce duplication, and present related information in one place, certain disclosures on
the nature and extent of risks related to financial instruments required by IFRS 7 ‘Financial instruments:
Disclosures’ are included in the ‘Risk management’ section of the Annual Report.
These disclosures are an integral part of ING Group Consolidated financial statements and are indicated in the ‘Risk
management’ section by the symbol (*). Chapters, paragraphs, graphs or tables within the 'Risk management'
section that are indicated with this symbol in the respective headings or table header are considered to be an
integral part of the Consolidated financial statements.
The published 2025 Consolidated financial statements of ING Group are prepared in accordance with IFRS-EU. IFRS-
EU refers to International Financial Reporting Standards (‘IFRS’) as adopted by the European Union (EU), including
the decisions ING Group made with regard to the options available under IFRS as adopted by the EU. IFRS-EU differs
from IFRS-IASB in respect of certain paragraphs in IAS 39 ‘Financial Instruments: Recognition and Measurement’
regarding hedge accounting for portfolio hedges of interest rate risk.
Under IFRS-EU, ING Group applies fair value hedge accounting for portfolio hedges of interest rate risk (fair value
macro hedges) in accordance with the EU carve-out version of IAS 39. Particularly, it is applied to portfolio-based
hedging strategies for retail lending (mortgages) and core deposits. Under the EU IAS 39 carve-out, hedge
accounting may be applied, in respect of fair value macro hedges, to core deposits. In addition, and in general to
any hedge accounting relationship under the EU IAS 39 carve-out, the hedge effectiveness requirements are less
strict than under IFRS-IASB and hedge ineffectiveness is only recognised when the revised estimate of the amount
of cash flows in scheduled time buckets falls below the original designated amount of that bucket and is not
recognised when the revised amount of cash flows in scheduled time buckets is more than the original designated
amount. Under IFRS-IASB, hedge accounting for fair value macro hedges cannot be applied to core deposits and
ineffectiveness arises whenever the revised estimate of the amount of cash flows in scheduled time buckets is
either more or less than the original designated amount of that bucket.
This information under IFRS-IASB is prepared by reversing the hedge accounting impacts that are applied under
the EU ‘carve-out’ version of IAS 39. Financial information under IFRS-IASB accordingly does not take into account
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the possibility that had ING Group applied IFRS-IASB as its primary accounting framework it might have applied
alternative hedge strategies where those alternative hedge strategies could have qualified for IFRS-IASB compliant
hedge accounting. These decisions could have resulted in different shareholders’ equity and net result amounts
compared to those indicated in this Annual Report on Form 20-F.
In 2025 forward interest rates Increased resulting in a positive EU IAS 39 carve out adjustment after tax of EUR
mainly reflected in line item 'Valuation results and net trading income' in the statement of profit or loss. A
reconciliation between IFRS-EU and IFRS-IASB is included below.
Both IFRS-EU and IFRS-IASB differ in several areas from accounting principles generally accepted in the United
States of America (US GAAP).
Reconciliation net result under IFRS-EU and IFRS-IASB | |||
in EUR million | 2025 | 2024 | 2023 |
In accordance with IFRS-EU (attributable to the shareholders of the parent) | |||
Adjustment of the EU IAS 39 carve-out | - | - | |
Tax effect of the adjustment | - | ||
Effect of adjustment after tax | - | - | |
In accordance with IFRS-IASB (attributable to the shareholders of the parent) | |||
Reconciliation shareholders’ equity under IFRS-EU and IFRS-IASB | |||
in EUR million | 2025 | 2024 | 2023 |
In accordance with IFRS-EU (attributable to the shareholders of the parent) | |||
Adjustment of the EU IAS 39 carve-out | |||
Tax effect of the adjustment | - | - | - |
Effect of adjustment after tax | |||
In accordance with IFRS-IASB Shareholders’ equity | |||
ING Group has consistently applied its accounting policies to all periods presented in these Consolidated financial
statements.
During 2025, ING Group has revised the presentation in Note 26 'Other operating expenses', to enhance its
relevance and improve comparability. Consequently, comparative figures for 2024 and 2023 have been updated
accordingly.
The following amendments to IFRS became effective in the current reporting period with no significant impact for
ING Group:
§Amendments to IAS 21 'The Effects of Changes in Foreign Exchange Rates': Lack of Exchangeability (issued in
August 2023). Amendments provide guidance on determining exchange rates when a currency lacks
exchangeability, including estimation methods and disclosure requirements.
1.3.2 Upcoming changes in IFRS after 2025
ING Group has not early adopted any of the following Standards, interpretations or amendments that have been
issued but are not yet effective:
Effective in 2026:
§Amendments to IFRS 9 'Financial Instruments' and IFRS 7 'Financial Instruments: Disclosures': Classification and
Measurement of Financial Instruments (issued in May 2024). The amendments clarify that a financial liability is
derecognised on the ‘settlement date’ and introduce an accounting policy choice to derecognise financial
liabilities settled using an electronic payment system before the settlement date. Other clarifications relate to
the classification of financial assets with ESG linked features, non-recourse loans and contractually linked
instruments. Further, additional disclosure requirements introduced for equity investments at fair value
through other comprehensive income (FVOCI) and financial instruments with contingent cash flow features.
§Amendments to IFRS 9 'Financial Instruments' and IFRS 7 'Financial Instruments: Disclosures': Contracts
Referencing Nature-dependent Electricity (issued in December 2024). Amendments clarify accounting for
renewable electricity contracts, including own-use and hedge accounting and related disclosures.
§Annual Improvements to IFRS Accounting Standards: Volume 11 (issued in July 2024). Amendments include
minor clarifications and corrections across a number of Standards to improve consistency and clarity.
The implementation of the above amendments is expected to have no significant impact on ING Group's
Consolidated financial statements as they become effective.
Effective in 2027:
§Amendments to IAS 21 'The Effects of Changes in Foreign Exchange Rates': Translation to a hyperinflationary
presentation currency (issued in November 2025). Amendments clarify accounting when translating from a
non-hyperinflationary functional currency to a hyperinflationary presentation currency. There is no impact
expected on ING Group's financial statements.
§New Standard IFRS 18 'Presentation and Disclosure in Financial Statements' (issued in April 2024). IFRS 18
replaces IAS 1 'Presentation of Financial Statements', carrying forward many of the requirements in IAS 1
unchanged and complementing them with new requirements. In addition, some paragraphs from IAS 1 have
been moved to IAS 8 'Accounting Policies, Changes in Accounting Estimates and Errors' and IFRS 7.
Furthermore, the IASB has made minor amendments to IAS 7 'Statement of Cashflows' and IAS 33 'Earnings per
Share'. IFRS 18 introduces new requirements to:
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–present specified categories (operating, investing, financing, income tax and discontinued operations) and
defined subtotals in the statement of profit or loss;
–provide disclosures on management-defined performance measures (MPMs) in the notes to the financial
statements; and
–improve aggregation and disaggregation.
The implementation of IFRS 18 is expected to have no significant impact on ING Group's consolidated financial
statements as it only affects the presentation and disclosure of items in the financial statements and does not
change the underlying recognition or measurement of assets, liabilities, income or expenses.
ING Group is currently assessing the impact the amendments will have on the Consolidated financial statements.
To date, the following potential impacts have been identified:
§IFRS 18 will not affect ING's net profit, but will reclassify income and expenses into new categories in the
statement of profit or loss and introduce a new subtotal line item 'operating profit'.
§The line items presented in the primary financial statements might change as a result of the enhanced
principles introduced on 'aggregation and disaggregation'. ING does not expect there to be a significant change
in the information that is currently disclosed in the notes because the requirements to disclose material
information remain unchanged.
§New disclosure requirements for management-defined performance measures (MPMs).
§For the statement of cash flows, the starting point for calculating cash flows from operating activities will
change to 'operating profit' as noted above.
In addition, in May 2024, the IASB also issued a new accounting Standard IFRS 19 'Subsidiaries without Public
Accountability: Disclosures'. However, it is not applicable for the consolidated financial statements of ING Group.
The preparation of the Consolidated financial statements requires management to make judgements in the
process of applying its accounting policies and to use estimates and assumptions. The estimates and assumptions
affect the reported amounts of the assets and liabilities and the amounts of the contingent assets and contingent
liabilities at the balance sheet date, as well as reported income and expenses for the year. The actual outcome
may differ from these estimates. The process of setting assumptions is subject to internal control procedures and
approvals.
ING Group has identified areas that require management to make significant judgements and use critical
accounting estimates and assumptions based on the information and financial data that may or may not change
in future periods.
These areas are:
§Loan loss provisions (financial assets) (refer to Note 1.5.6 ‘Impairment of financial assets');
§The determination of the fair values of financial assets and liabilities (refer to Note 1.5.3 for ‘Fair values of
financial assets and liabilities’);
§Investment in associate - assessment of additional impairment losses or reversal of previous impairment losses
(refer to Note 1.10 ‘Investment in associates and joint ventures');
§Investment in associate - determination of significant influence over associates (refer to Note 1.10 'Investment
in associates and joint ventures'); and
§Provisions (refer to Note 1.15 ‘Provisions, contingent liabilities and contingent assets’).
In addition, in January 2025 ING has reached an agreement on the sale of the business in Russia (ING Bank
(Eurasia) JSC), subject to several conditions, including substantive and uncertain regulatory approvals. Judgement
is required to evaluate the probability of the sale. Given the prevailing uncertainties around substantive regulatory
approvals as at 31 December 2025, no loss was recognised for the year ended 31 December 2025 and assets and
liabilities of the disposal group were not classified as held for sale. Reference is made to Note 32 'Potential sale of
ING Bank (Eurasia) JSC'.
In March 2024 ING repaid the final EUR 6 billion of its Targeted Longer-Term Refinancing Operations (TLTRO) III
participation. As a result, accounting for TLTRO is no longer an area of significant judgement in 2025 and 2024,
while it was as such in 2023.
ING Group applies IFRS 9 ‘Financial Instruments’ to the recognition, classification and measurement, and
derecognition of financial assets and financial liabilities and the impairment of financial assets. ING Group applies
the requirements of IAS 39 ‘Financial Instruments: Recognition and Measurement’ for hedge accounting purposes.
1.5.1 Recognition and derecognition of financial instruments
Recognition of financial assets
Financial assets are recognised in the balance sheet when ING Group becomes a party to the contractual
provisions of the instrument. For a regular way purchase or sale of a financial asset, trade date and settlement
date accounting is applied, depending on the classification of the financial asset.
Derecognition of financial assets
Financial assets are derecognised when the rights to receive cash flows from the financial assets have expired or
where ING Group has transferred the rights to receive the cash flows from the financial asset or assumed an
obligation to pass on the cash flows and has transferred substantially all the risks and rewards of the asset. If ING
Group neither transfers nor retains substantially all the risks and rewards of ownership of a financial asset, it
derecognises the financial asset if it no longer has control over the asset. The difference between the carrying
amount of a financial asset that has been derecognised and the consideration received is recognised in profit or
loss.
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Recognition of financial liabilities
Financial liabilities are recognised on the date that the entity becomes a party to the contractual provisions of the
instrument.
Derecognition of financial liabilities
Financial liabilities are derecognised when the obligation specified in the contract is discharged, cancelled or
expired. The difference between the carrying amount of a financial liability that has been extinguished and the
consideration paid is recognised in profit or loss.
Financial assets
ING Group classifies its financial assets in the following measurement categories:
§those to be measured subsequently at fair value (either through OCI, or through profit or loss); and
§those to be measured at amortised cost (AC).
At initial recognition, ING Group measures a financial asset at its fair value plus, in the case of a financial asset not
at FVPL, transaction costs that are directly attributable to the acquisition of the financial asset. Transaction costs
of financial assets carried at fair value through profit or loss (FVPL) are expensed in the statement of profit or loss.
Financial assets – Debt instruments
The classification depends on the entity’s business model for managing the financial assets and the contractual
terms of the cash flows at initial recognition.
Business models
Business models are classified as Hold to Collect (HtC), Hold to Collect and Sell (HtC&S) or Other depending on how
a portfolio of financial instruments as a whole is managed. ING Group’s business models are based on the existing
management structure of the bank, and refined based on an analysis of how businesses are evaluated and
reported, how their specific business risks are managed, and on historic and expected future sales. Sales are
permissible in a HtC business model when these are due to an increase in credit risk, take place close to the
maturity date (where the proceeds from the sales approximate the collection of the remaining contractual cash
flows), are insignificant in value (both individually and in aggregate) or are infrequent.
Contractual cash flows Solely Payments of Principal and Interest (SPPI)
The contractual cash flows of a financial asset are assessed to determine whether they represent SPPI. Interest
includes consideration for the time value of money, credit risk and for other basic lending risks such as
consideration for liquidity risk and costs associated with holding the financial asset for a particular period of time.
In addition, interest can include a profit margin that is consistent with a basic lending arrangement. Financial
assets with embedded derivatives are considered in their entirety when determining whether their cash flows are
SPPI.
In assessing whether the contractual cash flows are SPPI, ING Group considers the contractual terms of the
instrument. This includes assessing whether the financial asset contains a contractual term that could change the
timing or amount of contractual cash flows such that it would not meet this condition.
Based on the entity’s business model for managing the financial assets and the contractual terms of the cash
flows, there are three measurement categories into which ING Group classifies its debt instruments:
§Amortised Cost (AC):
Debt instruments that are held for collection of contractual cash flows under a HtC business model where those
cash flows represent SPPI are measured at AC. Interest income from these financial assets is included in
Interest income using the Effective Interest Rate (EIR) method. Any gain or loss arising on derecognition is
recognised directly in profit or loss. Impairment losses are presented as a separate line item in the statement of
profit or loss.
§FVOCI:
Debt instruments that are held for collection of contractual cash flows and for selling the financial assets under
a HtC&S business model, where the assets’ cash flows represent SPPI, are measured at FVOCI. Movements in
the carrying amount are recognised in OCI, except for the recognition of impairment gains or losses, interest
revenue and foreign exchange gains and losses which are recognised in profit or loss. When the financial asset
is derecognised, the cumulative gain or loss previously recognised in OCI is reclassified from equity to profit or
loss and presented in Investment income or Other net income, based on the specific characteristics of the
business model. Interest income from these financial assets is included in Interest income using the EIR
method. Impairment losses are presented as a separate line item in the statement of profit or loss.
§FVPL:
Debt instruments that do not meet the criteria for AC or FVOCI are measured at FVPL. This includes debt
instruments that are held-for-trading (presented separately as Trading assets) and all other debt instruments
that do not meet the criteria for AC or FVOCI (presented separately as Mandatorily at FVPL). ING Group may in
some cases, on initial recognition, irrevocably designate a financial asset as classified and measured at FVPL.
This is the case where doing so eliminates or significantly reduces an accounting mismatch that would
otherwise arise on assets measured at AC or FVOCI. Fair value movements on trading securities, trading loans
and deposits (mainly reverse repos) are presented fully within valuation result and net trading income. This
also includes interest. The interest arising on financial assets designated as at FVPL is recognised in profit or
loss and presented within Other interest income or Other interest expense in the period in which it arises. The
interest arising on a debt instrument that is part of a hedge relationship, but not subject to hedge accounting,
is recognised in profit or loss and presented within Other interest income or Other interest expense in the
period in which it arises.
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ING Group reclassifies debt instruments if, and only if, its business model for managing those financial assets
changes. Such changes in business models are expected to be very infrequent. There have been no
reclassifications during the reporting period.
Financial assets – Equity instruments
All equity investments are measured at fair value. ING Group applies the fair value through OCI option to
investments which are considered strategic, consisting of investments that add value to ING Group’s core banking
activities.
There is no subsequent recycling of fair value gains and losses to profit or loss following the derecognition of
investments if elected to be classified and measured as FVOCI. However, the cumulative gain or loss is transferred
within equity to retained earnings on derecognition of such equity instruments. Dividends from such investments
continue to be recognised in profit or loss as investment income when ING Group’s right to receive payments is
established. Impairment requirements are not applicable to equity investments classified and measured as FVOCI.
Other remaining equity investments are measured at FVPL. All changes in the fair value are recognised in
Valuation result and Net trading income in the Consolidated statement of profit or loss.
Financial liabilities
Financial liabilities are classified and subsequently measured at AC, except for financial guarantee contracts,
derivatives and liabilities designated at FVPL. Financial liabilities classified and measured at FVPL are presented as
follows:
§The amount of change in the fair value that is attributable to changes in own credit risk of the liability
designated at FVPL is presented in OCI. Upon derecognition this Debit Valuation Adjustment (DVA) impact does
not recycle from OCI to profit or loss; and
§The remaining amount of change in the fair value is presented in profit or loss in ‘Valuation results and net
trading income’. Interest on financial liabilities at FVPL is also recognised in the valuation result, except for
items voluntarily designated as FVPL, for which interest is presented within ‘Other interest income (expense)'.
A financial guarantee contract is a contract that requires ING Group to make specified payments to reimburse the
holder for a loss it incurs because a specified debtor fails to make payment when due in accordance with the
original or modified terms of a debt instrument. Such a contract is initially recognised at fair value and is
subsequently measured at the higher of (a) the amount determined in accordance with impairment provisions of
IFRS 9 ‘Financial instruments’ (see section 'Impairment of financial assets') and (b) the amount initially recognised
less, when appropriate, cumulative amortisation recognised in accordance with the revenue recognition principle
of IFRS 15 ‘Revenue from contracts with customers’.
Securities sold subject to repurchase agreements (repos), securities lending and similar agreements continue to be
recognised in the Consolidated statement of financial position as ING Group continues to be exposed to
substantially all risks and rewards of the transferred financial asset. The counterparty liability is designated and
measured at FVPL if the asset is measured mandatorily at FVPL. Otherwise, the counterparty liability is included in
Deposits from banks, Customer deposits, or Trading.
Securities purchased under agreements to resell (reverse repos), securities borrowings and similar agreements are
not recognised in the Consolidated statement of financial position as the counterparty continues to be exposed to
substantially all risks and rewards of the transferred security. Based on the business model assessment and
counterparty, the consideration paid to purchase securities is recognised as Loans and advances to customers,
Loans and advances to banks, financial assets mandatorily at FVPL or Trading assets.
All financial assets and liabilities are recognised initially at fair value. The fair value of a financial instrument on
initial recognition is generally its transaction price (that is, the fair value of the consideration given or received).
However, if there is a material difference between the transaction price and the fair value of financial instruments
whose fair value is based on a valuation technique using significant unobservable inputs, the entire 'day one'
difference (a ‘Day One Profit or Loss’) is deferred. ING Group defers the Day One Profit or Loss relating to financial
instruments classified as Level 3 and financial instruments with material unobservable inputs into CVA which are
not necessarily classified as Level 3. The deferred Day One Profit or Loss is recognised in the statement of profit or
loss over the life of the transaction until the transaction matures, or until the significant unobservable inputs
become observable, or until the significant unobservable inputs become non-significant. In all other cases, ING
Group recognises the difference as a gain or loss at inception.
Subsequently, except for financial assets and financial liabilities measured at amortised cost, all the other financial
assets and liabilities are measured at fair value.
Fair value is defined as the price that would be received to sell an asset or paid to transfer a liability in an orderly
transaction between market participants at the measurement date. It assumes that market participants would
use and take into account the characteristics of the asset or liability when pricing the asset or liability. Fair values
of financial assets and liabilities are based on unadjusted quoted market prices where available. Such quoted
market prices are primarily obtained from exchange prices for listed financial instruments. Where an exchange
price is not available, quoted prices in an active market may be obtained from independent market vendors,
brokers, or market makers. In general, positions are valued at the bid price for a long position and at the offer price
for a short position or are valued at the price within the bid-offer spread that is most representative of fair value in
the circumstances. In some cases where positions are marked at mid-market prices, a fair value adjustment is
calculated.
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For certain financial assets and liabilities, quoted market prices are not available. For such instruments, fair value is
determined using valuation techniques. These range from discounting of cash flows to various valuation models,
where relevant pricing factors including the market price of underlying reference instruments, market parameters
(volatilities, correlations and credit ratings), and customer behaviour are taken into account. ING Group maximises
the use of market observable inputs and minimises the use of unobservable inputs in determining the fair value. It
can be subjective dependent on the significance of the unobservable input to the overall valuation. All valuation
techniques used are subject to internal review and approval. Most data used in these valuation techniques are
validated on a daily basis when possible.
When a group of financial assets and liabilities are managed on the basis of their net risk exposures, the fair value
of a group of financial assets and liabilities are measured on a net portfolio level.
To include credit risk in fair value, ING Group applies both Credit and Debit Valuation Adjustments (CVA, DVA, also
known as Bilateral Valuation Adjustments or BVA). Own issued debt and structured notes that are designated at
FVPL are adjusted for ING Group’s own credit risk by means of a DVA. To include the funding risk, ING Group applies
an additional ‘Funding Valuation Adjustment’ (FVA) to the uncollateralised derivatives based on the market price of
funding liquidity. ING Group also applies to certain positions other valuation adjustments to arrive at the fair value,
such as Bid-Offer adjustments, Model Risk Adjustments and Collateral Valuation Adjustments (CollVA).
Significant judgements and critical accounting estimates and assumptions: §Even if market prices are available, when markets are less liquid there may be a range of prices for the same security from different price sources. Selecting the most appropriate price requires judgement and could result in different estimates of fair value. §Valuation techniques are subjective in nature and significant judgement is involved in establishing fair values for certain financial assets and liabilities. Valuation techniques involve various assumptions regarding pricing factors. The use of different valuation techniques and assumptions could produce significantly different estimates of fair value. §Price testing is performed to assess whether the process of valuation has led to an appropriate fair value of the position and to minimise the potential risks of economic losses due to incorrect or misused models. §Assessing whether a market is active, and whether an input is observable and significant, requires judgement. ING Group categorises its financial instruments that are either measured in the statement of financial position at fair value or of which the fair value is disclosed, into a three-level hierarchy based on the observability and significance of the valuation inputs. The use of different approaches to assess whether a market is active, whether an input is observable, and whether an unobservable input is significant could produce different classification within the fair value hierarchy as well as potentially different deferral of the Day One Profit or Loss. §Reference is made to Note 35 'Fair value of assets and liabilities' and to the ‘Market risk’ paragraph in the ‘Risk management’ section of the Annual Report for the basis of the determination of the fair value of financial instruments and related sensitivities. | ||
IFRS 9 includes an accounting policy choice to defer the adoption of IFRS 9 hedge accounting and to continue with
hedge accounting under IAS 39. ING Group decided to exercise this accounting policy choice and did not adopt IFRS
9 hedge accounting as of 1 January 2018.
Derivatives are initially recognised at fair value on the date on which a derivative contract is entered into and are
subsequently measured at fair value. Fair values are obtained from quoted market prices in active markets,
including market transactions and valuation techniques (such as discounted cash flow models and option pricing
models), as appropriate. All derivatives are carried as assets when their fair value is positive and as liabilities when
their fair value is negative. Fair value movements on derivatives are presented in profit or loss in 'Valuation result
and net trading income', except for derivatives in either a formal hedge relationship or so-called economic hedges
that are not in a formal hedge accounting relationship where a component is presented separately in interest
result in line with ING Group’s risk management strategy.
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Embedded derivatives are separated from financial liabilities and other non-financial contracts and accounted for
as a derivative if, and only if:
1.The economic characteristics and risks of the embedded derivative are not closely related to the economic
characteristics and risks of the host contract;
2.A separate instrument with the same terms as the embedded derivative would meet the definition of a
derivative; and
3.The combined instrument is not measured at fair value with changes in fair value reported in profit or loss.
If an embedded derivative is separated, the host contract is accounted for as a similar free-standing contract.
The method of recognising the resulting fair value gain or loss depends on whether the derivative is designated as
a hedging instrument, and if so, the nature of the item being hedged. ING Group designates certain derivatives as
hedges of the fair value of recognised assets or liabilities or firm commitments (fair value hedge), hedges of highly
probable future cash flows attributable to a recognised asset or liability or a forecast transaction (cash flow
hedge), or hedges of a net investment in a foreign operation. Hedge accounting is used for derivatives designated
in this way provided certain criteria are met.
At the inception of the transaction, ING Group documents the relationship between hedging instruments and
hedged items, its risk management objective, together with the methods selected to assess hedge effectiveness.
ING Group also documents its assessment, both at hedge inception and on an ongoing basis, of whether the
derivatives that are used in hedging transactions are highly effective in offsetting changes in fair values or cash
flows of the hedged items.
Fair value hedges
Changes in the fair value of derivatives that are designated and qualify as fair value hedges are recognised in the
statement of profit or loss, together with fair value adjustments to the hedged item attributable to the hedged
risk. If the hedge relationship no longer meets the criteria for hedge accounting, the cumulative adjustment of the
hedged item is, in the case of interest-bearing instruments, amortised through the statement of profit or loss over
the remaining term of the original hedge or recognised directly when the hedged item is derecognised. For non-
interest bearing instruments, the cumulative adjustment of the hedged item is recognised in the statement of
profit or loss only when the hedged item is derecognised.
Cash flow hedges
The effective portion of changes in the fair value of derivatives that are designated and qualify as cash flow hedges
are recognised in the Other Comprehensive Income. The gain or loss relating to the ineffective portion is
recognised immediately in the statement of profit or loss. Amounts accumulated in the Other Comprehensive
Income are recycled to the statement of profit or loss in the periods in which the hedged item affects net result.
When a hedging instrument expires or is sold, or when a hedge no longer meets the criteria for hedge accounting,
any cumulative gain or loss existing in the Other Comprehensive Income at that time remains in the Other
Comprehensive Income and is recognised when the forecast transaction is ultimately recognised in the statement
of profit or loss. When a forecast transaction is no longer expected to occur, the cumulative gain or loss that was
reported in the Other Comprehensive Income is transferred immediately to the statement of profit or loss.
Net investment hedges
Hedges of net investments in foreign operations are accounted for in a similar way to cash flow hedges. Any gain
or loss on the hedging instrument relating to the effective portion of the hedge is recognised in the Other
Comprehensive Income and the gain or loss relating to the ineffective portion is recognised immediately in the
statement of profit or loss. Gains and losses accumulated in the Other Comprehensive Income are included in the
statement of profit or loss when the foreign operation is disposed.
Benchmark rate reform – specific policies for hedges directly affected by the benchmark rate reform
As explained in the ‘Impact of the benchmark rate reform’ paragraph of the ‘Risk management’ section, a
fundamental review of important interest rate benchmarks has been carried out, and is still ongoing for some of
them (for instance, WIBOR). Interest Rate Benchmark Reform Phase 1 and Phase 2 amendments to IFRS provide
specific reliefs that allow hedge accounting relationships to continue when the benchmark rate reform is ongoing.
Phase 1 reliefs remained relevant for ING Group as at 31 December 2025 for WIBOR hedges, and will cease to apply
once uncertainty about the timing and amount of the benchmark rate-based cash flows is resolved, or when the
hedging instrument is discontinued. ING Group’s policy is to cease applying Phase 1 reliefs when the relevant
contract (hedging instrument or hedged item) is modified. When this occurs, Phase 2 reliefs become applicable still
allowing hedge accounting relationships to continue. Refer to note ‘Risk management/Impact of the benchmark
rate reform’ for further details on WIBOR transition and ING’s exposures related to WIBOR that have yet to
transition.
Non-trading derivatives that do not qualify for hedge accounting
Derivative instruments that are used by ING Group as part of its risk management strategies, but which do not
qualify for hedge accounting under ING Group’s accounting policies, are presented as non-trading derivatives. Non-
trading derivatives are measured at fair value with changes in the fair value taken to the statement of profit or
loss.
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Financial assets and financial liabilities are offset, and the net amount is reported in the statement of financial
position, when ING Group has a current legally enforceable right to set off the recognised amounts and intends to
either settle on a net basis or to realise the asset and settle the liability simultaneously. Offsetting is applied to
derivatives, repurchase and reverse repurchase agreements and cash pooling agreements. A significant portion of
offsetting is applied to derivatives and related cash margin balances, which are either directly cleared through
central clearing parties or cleared through clearing members of central clearing parties. For more information,
reference is made to Note 40 ‘Offsetting financial assets and liabilities’.
An Expected Credit Loss (ECL) model is applied to financial assets accounted for at AC or FVOCI such as loans, debt
securities and lease receivables, as well as off-balance sheet items such as undrawn loan commitments, certain
financial guarantees issued, and undrawn committed revolving credit facilities. Under the ECL model, ING Group
calculates the ECL by considering on a discounted basis the cash shortfall it would incur in case of a default and
multiplying the shortfall by the probability of a default occurring. The ECL is the sum of the probability-weighted
outcomes. The ECL estimates are unbiased and include reasonable and supportable information about past
events, current conditions, and forecasts of future economic conditions. ECL is recognised on the balance sheet as
loan loss provisions (LLP).
Three-stage approach
Financial assets are classified in one of the below three stages at each reporting date. A financial asset can move
between stages during its lifetime. The stages are based on changes in credit quality since initial recognition and
defined as follows:
§Stage 1
Financial assets that have not had a significant increase in credit risk since initial recognition (i.e. no Stage 2 or
3 triggers apply). Assets are classified as Stage 1 upon initial recognition (with the exception of purchased or
originated credit impaired (POCI) assets) and ECL is determined by the probability that a default occurs in the
next 12 months (12 months ECL);
§Stage 2
Financial assets showing a significant increase in credit risk since initial recognition. For assets in Stage 2 , ECL
reflects an estimate on the credit losses over the remaining maturity of the asset (lifetime ECL); or
§Stage 3
Financial assets that are credit-impaired. Also for these assets, ECL is determined over the remaining maturity
of the asset.
Significant increase in credit risk
ING Group established a framework, incorporating quantitative and qualitative indicators, to identify and assess
significant increases in credit risk (SICR). This is used to determine the appropriate ECL Stage for each financial
asset. Reference is made to the ‘Criteria for identifying a significant increase in credit risk (SICR)’ in the ‘Risk
management’ section of the Annual Report.
An asset that is in Stage 2 will move back to Stage 1 when none of the above criteria are in place anymore.
However, if the asset was moved to Stage 2 based on the forbearance status, then the asset stays in Stage 2 for at
least 24 months. If the asset was classified as Stage 2 due to the '30 days past due' trigger, then the asset is
moved back to Stage 1 only after three months from when the trigger no longer applies.
Credit-impaired financial assets (Stage 3)
Financial assets are assessed for credit-impairment at each reporting date and more frequently when
circumstances warrant further assessment. Evidence of credit-impairment includes arrears of over 90 days on any
material credit obligation, indications that the borrower is experiencing significant financial difficulty, a breach of
contract, bankruptcy or distressed restructuring. The definition of 'credit-impaired' under IFRS 9 (Stage 3) is aligned
with the definition of 'default' used by ING Group for internal risk management purposes, which is also the
definition used for regulatory purposes.
An asset (other than a POCI asset) that is in Stage 3 will move back to Stage 2 when, as at the reporting date, it is
no longer considered to be credit-impaired, subject to certain probation periods. The asset will migrate back to
Stage 1 when its credit risk at the reporting date is no longer considered to have increased significantly since initial
recognition.
Macroeconomic scenarios
ING Group has established a quarterly process whereby forward-looking macroeconomics scenarios and
probability weightings are developed for the purpose of ECL. ING Group applies data predominantly from a leading
service provider enriched with the internal ING Group view. A baseline, up-scenario and down-scenario are
determined to reflect an unbiased and probability-weighted ECL amount. As a baseline scenario, ING Group applies
the market-neutral view combining consensus forecasts for economic variables such as unemployment rates, GDP
growth, house prices, commodity prices, and short-term interest rates. Applying market consensus in the baseline
scenario ensures unbiased estimates of the expected credit losses.
The alternative scenarios are based on observed forecast errors in the past, adjusted for the risks affecting the
economy today and the forecast horizon. The probabilities assigned are based on the likelihoods of observing the
three scenarios and are derived from confidence intervals on a probability distribution. The forecasts for the
economic variables are adjusted on a quarterly basis.
The probability weights applied to each of the three scenarios
ING Group uses three macroeconomic scenarios when determining IFRS 9 ECL (baseline, upside and downside). The
management approach used to determine the weights of each scenario and in selecting the parts of the
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distribution of forecast errors from which the weights are derived is disclosed in the 'Alternative Scenarios and
Probability Weights' section. Additionally, this approach is detailed in the sensitivity analysis within the 'Risk
management' section of the Annual Report.
Measurement of ECL
ING Group applies a collective assessment method to measure ECL for Stage 1, Stage 2, and certain Stage 3 assets.
Other credit-impaired assets subject to ECL measurement apply the individual assessment method.
Collectively assessed assets (Stages 1 to 3)
For collective assessed assets, ING Group applies a model-based approach. ECL is determined by, expressed
simplistically, multiplying the probability of default (PD) with the loss given default (LGD) and exposure at default
(EAD), adjusted for the time value of money. Assets that are collectively assessed are grouped on the basis of
similar credit-risk characteristics, taking into account the loan type, industry, geographic location, collateral type,
past due status and other relevant factors. These characteristics are relevant to the estimation of future cash flows
for groups of such assets by being indicative of the debtors’ ability to pay all amounts due according to the
contractual terms of the assets being evaluated and the loss in case the debtor is not able to pay all amounts due.
For Stage 3 assets, the PD equals 100% and the LGD and EAD represent a lifetime view of the losses based on
characteristics of defaulted facilities.
For the measurement of ECL, ING Group’s expected credit loss models (PD, LGD, EAD) used for regulatory purposes
have been adjusted. These adjustments include removing embedded prudential conservatism (such as floors) and
converted through-the-cycle estimates to point-in-time estimates. The models assess ECL on the basis of forward-
looking macroeconomic forecasts and other inputs. For most financial assets, the expected life is limited to the
remaining maturity. For overdrafts and certain revolving credit facilities, such as credit cards, the maturity is
estimated based on historical data as these do not have a fixed term or repayment schedule.
Individually assessed assets (Stage 3)
ING Group estimates ECL for individually significant credit-impaired financial assets within Stage 3 on an individual
basis. ECL for these Individually assessed assets are determined using the discounted expected future cash flow
method. To determine expected future cash flows, one or more scenarios are used. Each scenario is analysed
based on the probability of occurrence and includes forward-looking information.
In determining the scenarios, all relevant factors impacting the future cash flows are taken into account. These
include expected developments in credit quality, business and economic forecasts, and estimates of if/when
recoveries will occur, taking into account ING Group’s restructuring/recovery strategy.
The best estimate of ECL is calculated as the weighted-average of the shortfall (gross carrying amount minus
discounted expected future cash flow using the original EIR) per scenario, based on best estimates of expected
future cash flows. Recoveries can arise from, among other things, repayment of the loan, collateral recovery and
the sale of the asset. Cash flows from collateral and other credit enhancements are included in the measurement
of ECL of the related financial asset when it is part of or integral to the contractual terms of the financial asset and
the credit enhancement is not recognised separately. For the individual assessment, with granular (company- or
asset-specific) scenarios, specific factors can have a larger impact on the future cash flows than macroeconomic
factors.
When a financial asset is credit-impaired, interest income is no longer recognised based on the gross carrying
amount of the asset. Instead, interest income is calculated by applying the original effective interest rate to the
amortised cost of the asset, which is the gross carrying amount less the related loan loss provision.
Purchased or Originated Credit Impaired (POCI) assets
POCI assets are financial assets that are credit-impaired on initial recognition. Impairment on a POCI asset is
determined based on lifetime ECL from initial recognition. POCI assets are recognised initially at an amount net of
ECL and are measured at AC using a credit-adjusted effective interest rate. In subsequent periods, any changes to
the estimated lifetime ECL are recognised in profit or loss. Favourable changes are recognised as an impairment gain
if the lifetime ECL at the reporting date is lower than the estimated lifetime ECL at initial recognition.
Write-off and debt forgiveness
Loans and debt securities are written off (either partially or in full) when there is no reasonable expectation of
recovery and/or collectability of amounts due. The following events can lead to a write-off:
§After a restructuring has been completed and there is a high improbability of recovery of part of the remaining
loan exposure (including partial debt forgiveness);
§In a bankruptcy liquidation scenario;
§After divestment or sale of a credit facility at a discount; and
§Specific fraud cases with no recourse options.
When a loan is uncollectable, it is written off against the related loan loss provision. Subsequent recoveries of
amounts previously written off are recognised in ‘Addition to loan loss provisions’ in the Consolidated statement of
profit or loss.
Debt forgiveness (or debt settlement) involves write-off, but also involves the forgiveness of a legal obligation, in
whole or in part. This means that ING Group forfeits the legal right to recover the debt. As a result, the financial
asset needs to be derecognised.
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Presentation of ECL
ECL for financial assets measured at AC is deducted from the gross carrying amount of the assets. For debt
instruments at FVOCI, the ECL is recognised in OCI, instead of deducting it from the carrying amount of the asset.
ECL also reflects any credit losses related to the portion of the loan commitment that is expected to be drawn
down over the remaining life of the instrument. The ECL on issued financial guarantee contracts, in scope of IFRS 9
and not measured at FVPL, is recognised as liabilities and presented in Other provisions. ECL are presented in profit
or loss in Addition to loan loss provision.
Significant judgements and critical accounting estimates and assumptions: The calculation of ECL requires a number of judgements and estimates. In particular: §ING Group makes various assumptions about the risk of default, the credit loss rates in case of a default and expected future cash flows. For collective provisions, ING Group applies significant judgement when estimating modelled parameters such as PD, LGD and EAD, including the selection and calibration of relevant models. For stage 3 individual provisioning, the determination and probabilities of restructuring and recovery scenarios, as well as the amount and timing of expected future cash flows, may be particularly subjective. §Forward-looking macroeconomic scenarios used in impairment assessments are uncertain in nature. The use of alternate forward-looking macroeconomic scenarios can produce significantly different estimates of ECL. This is demonstrated in the sensitivity analysis in the ‘Risk Management’ section of the annual report, where the un-weighted ECL under each of the three scenarios for some significant portfolios is disclosed. §When determining whether the credit risk on a financial asset has increased significantly (criteria for identifying a significant increase in credit risk), ING Group considers reasonable and supportable information to compare the risk of default occurring at reporting date with the risk of a default occurring at initial recognition of the financial asset. Whilst judgement is required in applying a PD rating to each financial asset, there is significant judgement used in determining the Stage allocation PD banding thresholds. The process of comparing a financial asset’s PD with the PD banding thresholds determines its ECL Stage. Assets in Stage 1 are allocated a 12-month ECL, and those in Stage 2 are allocated a lifetime ECL, and the difference is often significant. As such, the judgement made in assigning financial asset PDs and the PD banding thresholds constitutes a significant judgement. Analysis of the sensitivity associated with the assessment of a significant increase in credit risk is presented in the ‘Risk Management’ section of the Annual Report. §Judgement is exercised in management’s evaluation of whether there is objective evidence that exposures are credit-impaired. §To reflect the risks that are not properly captured by the ECL models (including climate risk), a number of management adjustments to the model-based ECL were necessary as at 31 December 2025, which required significant judgement. Reference is made to the ‘Management adjustments applied this reporting period’ paragraph in the ‘risk management’ section of the Annual Report. | ||
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In certain circumstances, ING Group grants borrowers postponement, reduction of loan principal and/or interest
payments on a temporary period of time to maximise collection opportunities, and if possible, avoid default,
foreclosure, or repossession. When such postponement, reduction of loan principal and/or interest payments are
executed based on credit concerns, they are also referred to as forbearance (refer to the ‘Risk management’
section of the Annual Report for more details) and require analysis on whether the contractual terms have been
substantially modified or not. A similar assessment is needed when contractual terms are modified for reasons
other than forbearance.
ING Group determines whether there has been a substantial modification using both quantitative and qualitative
factors. If the modification results in a substantial modification of the terms of the loan, the original loan is
derecognised and a new loan is recognised at fair value at the modification date. In case of a non-substantial
modification, a modification gain or loss is recognised in profit or loss.
ING Group participated in the Targeted Longer-Term Refinancing Operations (TLTRO III), which mainly affected
comparative periods as, in March 2024, ING repaid the final EUR 6 billion of its TLTRO III participation. ING Group
considered TLTRO funding provided by the ECB to banks to be on market terms on the basis that the ECB has
established a separate market with TLTRO programmes. They have specific terms which are different from other
sources of funding available to banks, including those provided by the ECB. Consequently, the rate under TLTRO
was considered to be a market conforming rate and TLTRO funding was recognised fully as a financial liability.
ING Group interpreted the whole rate set by the ECB under TLTRO as a floating rate on the financial liability, being
the market rate for each specific period in time. This resulted in discrete rates for discrete interest periods over the
life of TLTRO. The change in the applicable rate between interest periods was seen as a change in the floating rate
and was accounted for prospectively. Similarly, if the ECB announced changes in the rate for the amounts already
drawn under the existing TLTRO, then such changes also represented a change in a floating rate. Following this,
such changes led to the recognition of an increased/decreased interest in the relevant period of life of the
exposure, rather than by the recognition of an immediate modification gain or loss at the moment of the change
of terms by the ECB. If the change related to the periods already passed, the impact for those past periods was
recognised in profit or loss immediately. Reference is made to Note 20 ‘Net interest income’ for the presentation of
ING Group’s participation in TLTRO programmes.
When ING purchases a financial guarantee, it assesses whether the guarantee is integral or non‑integral to the
related loan.
Integral financial guarantees are not accounted for separately but included in the accounting for the loan under
IFRS 9:
§For loans measured at amortised cost or FVOCI, the guarantee is reflected in the expected credit loss (ECL)
measurement. Premiums paid are treated as transaction costs and recognised as part of Interest income using
the effective interest rate method.
§For loans measured at FVTPL, the guarantee is included in the fair value of the loan. Premiums paid are treated
as transaction costs and recognised within Fee and commission expense.
Non‑integral financial guarantees are accounted for separately, within Other assets, by analogy to
reimbursements under IAS 37 'Provisions, Contingent Liabilities and Contingent Assets':
§For loans measured at amortised cost or FVOCI, a compensation right asset is recognised and measured based
on ECL, provided recovery is virtually certain.
§Changes in compensation right assets are recognised as a reduction in risk costs within Addition to loan loss
provisions line in profit or loss. Premiums paid are recognised within Fee and commission expense.
§For loans measured at FVTPL, non‑integral financial guarantees are designated at FVTPL, with premiums
recognised within Fee and commission expense.
ING Group comprises ING Groep N.V. (the Parent Company), ING Bank N.V. and all other subsidiaries. Subsidiaries
are entities controlled by ING Groep N.V. Control exists if ING Groep N.V. is exposed to or has rights to variable
returns and has the ability to affect those returns through the power over the subsidiary.
For interests in structured entities, the existence of control requires judgement as these entities are designed so
that voting or similar rights are not the dominant factor in deciding who controls the entity. This judgement
includes, for example, the involvement in the design of the structured entity, contractual arrangements that give
rights to direct the structured entities' relevant activities and commitment to ensure that the structured entity
operates as designed.
Transactions between ING Groep N.V. and its subsidiaries are eliminated on consolidation. Reference is made to
Note 43 'Principal subsidiaries, investments in associates and joint ventures' for a list of principal subsidiaries and
their statutory place of incorporation. A description of ING’s activities involving structured entities is included in
Note 44 'Structured entities'.
A list containing the information referred to in Section 379 (1), Book 2 of the Dutch Civil Code has been filed with
the office of the Commercial Register of Amsterdam, in accordance with Section 379 (5), Book 2 of the Dutch Civil
Code.
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ING Groep N.V. and its Dutch group companies are subject to legal restrictions regarding the amount of dividends
they can pay to their shareholders. The Dutch Civil Code contains the restriction that dividends can only be paid up
to an amount equal to the excess of the company’s own funds over the sum of the paid-up capital and reserves
required by law. Certain Group companies are also subject to other restrictions in certain countries, in addition to
the restrictions on the amount of funds that may be transferred in the form of dividends, or otherwise, to the
parent company.
Furthermore, in addition to the restrictions regarding the minimum capital requirements that are imposed by
industry regulators in the countries in which the subsidiaries operate, other limitations exist in certain countries.
An operating segment is a distinguishable component of ING Group, engaged in providing products or services,
whose operating results are regularly reviewed by the Executive Board of ING Group and the Management Board
Banking (together they make up the Chief Operating Decision Maker (CODM)) who decide which resources to
allocate to the segment and assess its performance.
The CODM reviews and assesses ING Group's performance primarily by line of business. As a result, ING identified
Since the second quarter of 2022, Türkiye has been considered a hyperinflationary economy for accounting
purposes. As ING Group has a subsidiary in Türkiye, ING Group has applied IAS 29 ‘Financial Reporting in
Hyperinflationary Economies’ to its operations since then. IAS 29 continued to be relevant for ING’s operations in
Türkiye in 2023, 2024 and 2025. Under IAS 29, the results of the operations in Türkiye should be stated in terms of
the current purchasing power at the reporting date. For that, the consumer price index (CPI) as determined by the
Turkish Statistical Institute was used. The CPI for Türkiye (2003=100) at 31 December 2025 was 3,513.87 , at 31
December 2024 was 2,684.55 and at 31 December 2023 it was 1,859.38 (movement 2025: 30.89 %, 2024: 44.38 %,
2023: 64.77 %). The effect of such restatement for inflation in the current period of the statement of
comprehensive income and the balance sheet has been recognised in the statement of profit or loss within ‘Other
net income’ as a ‘Net monetary gain or loss’. The net monetary loss for the period represents the loss of
purchasing power by the net monetary position (monetary assets exceeding monetary liabilities) of ING Türkiye.
After the application of the above restatement procedures in Turkish Lira under IAS 29, the financial position and
the results for the period of ING Türkiye were translated and presented in EUR at the exchange rate on 31
December 2025. For the statement of comprehensive income this is in contrast with the usual translation
procedures where items of comprehensive income are translated at the exchange rate at the date of transaction.
Furthermore, ING Group chose to present both the restatement effect resulting from restating ING Group’s interest
in the equity of ING Türkiye as required by IAS 29, and the translation effect from translating at a closing rate that
Functional and presentation currency
Items included in the financial statements of each of ING Group’s entities are measured using the currency of the
primary economic environment in which the entity operates (the functional currency). The Consolidated financial
statements are presented in euros, which is ING Group’s presentation currency.
Transactions and balances
Foreign currency transactions are translated into the functional currency using the exchange rate prevailing at the
date of the transactions. Exchange rate differences resulting from the settlement of such transactions and from
the translation at year-end exchange rates of monetary assets and liabilities denominated in foreign currencies
are recognised in the statement of profit or loss, except when deferred in equity as part of qualifying cash flow
hedges or qualifying net investment hedges.
Non-monetary items that are measured in terms of historical cost in a foreign currency are translated using the
exchange rate at the date of the transaction.
Exchange rate differences on non-monetary items, measured at fair value through profit or loss, are reported as part
of the fair value gain or loss. Non-monetary items are retranslated at the date the fair value is determined. Exchange
rate differences on non-monetary items measured at fair value through other comprehensive income are included in
other comprehensive income and get accumulated in the revaluation reserve in equity.
Exchange rate differences in the statement of profit or loss are generally included in ‘Valuation results and net
trading income’. Reference is made to Note 22 ‘Valuation results and net trading income’, which discloses the
amounts included in the statement of profit or loss. Exchange rate differences relating to the disposal of debt and
FVPL equity securities are considered to be an inherent part of the capital gains and losses recognised in Investment
income. As mentioned below, in Group companies relating to the disposals of group companies, any exchange rate
difference deferred in equity is recognised in the statement of profit or loss in ‘Result on disposal of group companies’.
Reference is also made to Note 19 ‘Equity’, which discloses the amounts included in the statement of profit or loss.
Group companies
The results and financial positions of all group companies that have a functional currency different from the
presentation currency are translated into the presentation currency as follows:
§Assets and liabilities are translated at the closing rate at the date of the statement of financial position;
§Income and expenses are translated at average exchange rates (unless this average is not a reasonable
approximation of the cumulative effect of the rates prevailing on the transaction dates, in which case income
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and expenses are translated at the dates of the transactions). However, under hyperinflation accounting,
income and expenses of ING Türkiye are translated at the closing rate; and
§All resulting exchange rate differences are recognised in a separate component of equity.
On consolidation, exchange rate differences arising from the translation of a monetary item that forms part of the
net investment in a foreign operation, and of borrowings and other instruments designated as hedges of such
investments, are taken to shareholders’ equity. When a foreign operation is sold, the corresponding exchange rate
differences are recognised in the statement of profit or loss as part of the gain or loss on sale.
Goodwill and fair value adjustments arising from the acquisition of a foreign operation are treated as assets and
Associates are all entities over which ING Group has significant influence but not control. Significant influence is the
ability to participate in the financial and operating policies of the investee. It generally results from a shareholding
of between 20% and 50% of the voting rights or through situations including, but not limited to one or more of the
following:
§Representation on the board of directors;
§Participation in the policymaking process; and
§Interchange of managerial personnel.
Joint ventures are entities over which ING Group has joint control.
Investments in associates and joint ventures are initially recognised at cost and subsequently accounted for using
the equity method of accounting. ING Group’s investment in associates and joint ventures (net of any
accumulated impairment loss) includes goodwill identified on acquisition. ING Group’s share of its associates and
joint ventures post-acquisition profits or losses is recognised in the statement of profit or loss, and its share of
post-acquisition changes in reserves is recognised in equity. The cumulative post-acquisition changes are adjusted
against the carrying amount of the investment. When ING Group’s share of losses in an associate or joint venture
equals or exceeds its interest in the associate or joint venture, including any long-term interests in the associate
like uncollateralised loans that are neither planned nor likely to be settled in the foreseeable future, ING Group
does not recognise further losses, unless it has incurred obligations or made payments on behalf of the associate
or joint venture.
Unrealised gains on transactions between ING Group and its associates and joint ventures are eliminated to the
extent of ING Group’s interest in the associates and joint ventures. Unrealised losses are also eliminated unless
they provide evidence of an impairment of the asset transferred. Accounting policies of associates and joint
ventures have been changed where necessary to ensure consistency with the policies adopted by ING Group.
The recoverable amount, being the higher of fair value less cost of disposal and value in use, of the investment in
associate and joint venture is determined when there is an indication of potential (reversal of) impairment. In case
of an indication of potential impairment, an impairment loss is recognised when the carrying amount of the
investment exceeds its recoverable amount. Goodwill on acquisitions of interests in associates and joint ventures is
not tested separately for impairment, but is assessed as part of the carrying amount of the investment. An
impairment loss is subsequently reversed if there is indication of a reversal and there is a change in the estimates
used to determine the recoverable amount. In case of an indication of a potential reversal of impairment, an
impairment loss is reversed to the extent that the recoverable amount exceeds its carrying amount, but cannot
exceed the original impairment loss.
The reporting dates of certain associates and joint ventures can differ from the reporting date of the Group, but by
no more than three months.
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Significant judgements and critical accounting estimates and assumptions: | ||
Potential impairment and reversal assessment Identification of impairment indicators as well as indicators of potential reversal of previous impairments of ING Group’s investment in TMBThanachart Bank Public Company Limited (hereafter: TTB), an associate, requires significant judgement. When there is objective evidence of impairment or indicators that prior period impairment losses no longer exist or may have decreased, value in use (VIU) needs to be determined. Estimation of VIU involves significant estimates and management assumptions. See Note 8 ‘Investment in associates and joint ventures’. Determination of significant influence over associates It is presumed that an entity has significant influence when it holds 20% or more of the voting power of the investee. Conversely, it is presumed that an entity does not have significant influence when voting power is less than 20% in the investee. Depending on the facts and circumstances, the presumption is rebutted when ING can clearly demonstrate whether or not it has power to participate in the investee’s financial and operating policy decisions. The consideration of all relevant factors requires judgement, including, amongst others, the investment purpose, investee’s governance structure and legal regime, ability to obtain meaningful board representation and participation in policymaking decisions. Refer to Note 5 'Financial assets at fair value through other comprehensive income' regarding ING’s accounting for its investment in Van Lanschot Kempen. | ||
Property in own use
Land and buildings held for own use are stated at fair value at the balance sheet date. Depreciation is recognised
on a straight-line basis over the estimated useful life (in general 20 –50 years). On disposal, the related revaluation
reserve is transferred to retained earnings.
Equipment
Equipment is stated at cost less accumulated depreciation and any impairment losses. The cost of the assets is
depreciated on a straight line basis over their estimated useful lives, which are generally as follows: two to five
years for data processing equipment, and four to ten years for fixtures and fittings.
Disposals of property and equipment
The difference between the proceeds on disposal and net carrying value is recognised in the statement of profit or
loss under Other net income.
Right-of-use assets - ING Group as the lessee
A lessee is required to recognise a right-of-use asset representing its right to use the underlying leased asset and
a corresponding liability representing its obligation to make lease payments at the date at which the leased
asset is available for use by ING Group. Each lease payment is allocated between the repayment of the liability
and finance cost. The finance costs are charged to profit or loss over the lease period so as to produce a constant
periodic rate of interest on the remaining balance of the liability for each period. The right-of-use asset is
depreciated over the shorter of the asset’s useful life and the lease term on a straight-line basis.
Assets and liabilities arising from a lease are initially measured on a present value basis. Lease liabilities include
the net present value of the following lease payments:
§Fixed payments (including in-substance fixed payments), less any lease incentives receivable;
§Variable lease payments that are based on an index or a rate;
§Amounts expected to be payable by the lessee under residual value guarantees;
§The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and
§Payments of penalties for terminating the lease, if the lease term reflects the lessee exercising that option.
The lease payments are discounted using the interest rate implicit in the lease. If that rate cannot be readily
determined, the lessee’s incremental borrowing rate is used, being the rate that the lessee would have to pay to
borrow the funds necessary to obtain an asset of similar value in a similar economic environment with similar
terms and conditions.
Right-of-use assets are measured at cost comprising the amount of the initial measurement of the lease liability,
any lease payments made at or before the commencement date less any lease incentives received and any initial
direct costs and restoration costs.
The right-of-use asset is included in the statement of financial position line-item ‘Property and equipment’. The
lease liability is included in the statement of financial position line-item ‘Other liabilities’. Refer to Note 9 ‘Property
and equipment’ and to Note 16 ‘Other liabilities’.
Subsequent to initial recognition, the right-of-use asset amortises using a straight-line method to the income
statement over the life of the lease. The lease liability increases for the accrual of interest and decreases when
payments are made. Any remeasurement of the lease liability due to a lease modification or other reassessment
results in a corresponding adjustment to the carrying amount of the right-of-use asset.
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When ING Group acts as a lessor, a distinction should be made between finance leases and operating leases. For
ING Group as a lessor, these are mainly finance leases and are therefore not included in 'Property and equipment'.
Instead, the present value of the lease payments is recognised as a receivable under Loans and advances to
customers or Loans and advances to banks. The difference between the gross receivable and the present value of
the receivable is unearned finance lease income. Lease income is recognised over the term of the lease using the
net investment method (before tax), which reflects a constant periodic rate of return.
Impairment of goodwill and other non-financial assets
ING Group assesses at each reporting period whether there is an indication that a non-financial asset may be
impaired. Irrespective of whether there is an indication of impairment, intangible assets with an indefinite useful
life, including goodwill acquired in a business combination, and intangible assets not yet available for use, are
tested annually for impairment. Goodwill is allocated to groups of cash generating units (CGUs) for the purpose of
impairment testing. These groups of CGUs represent the lowest level at which goodwill is monitored for internal
management purposes. Goodwill is tested for impairment by comparing the carrying value of the group of CGUs to
the recoverable amount of that group of CGUs. Impairment of goodwill, if applicable, is included in the statement
of profit or loss in Other operating expenses and is not subsequently reversed.
Computer software
Computer software that has been purchased or generated internally for own use is stated at cost less amortisation
and any impairment losses. Amortisation is calculated on a straight-line basis over its useful life, which generally
Income tax on the result for the year consists of current and deferred tax. Income tax is recognised in the
statement of profit or loss but it is recognised directly in equity if the tax relates to items that are recognised
directly in equity.
Uncertain tax positions are assessed continually by ING Group and in case it is probable that there will be a cash
outflow, a current tax liability is recognised.
Deferred income tax
Deferred income tax is provided in full, using the liability method, for temporary differences arising between the
tax basis of assets and liabilities and their carrying amounts in the Consolidated statement of financial position.
Deferred income tax is determined using tax rates (and laws) that have been enacted or substantively enacted at
the balance sheet date and are expected to apply when the related deferred income tax asset is realised or the
deferred income tax liability is settled. Deferred tax assets and liabilities are not discounted.
Deferred tax assets are recognised when it is probable that future taxable profit will be available against which the
temporary differences can be utilised. Deferred income tax is provided for temporary differences arising from
investments in subsidiaries and associates, except where the timing of the reversal of the temporary difference is
controlled by ING Group and it is probable that the difference will not reverse in the foreseeable future. The tax
effects of income-tax losses available for carry forward are recognised as an asset where it is probable that future
taxable profits will be available, against which these losses can be utilised.
Fair value remeasurements of debt and equity instruments measured at FVOCI and cash flow hedges are
recognised directly in equity. Deferred tax related to this fair value remeasurement is also recognised directly in
A provision is a present obligation arising from past events, the settlement of which is expected to result in an
outflow of resources embodying economic benefits. However, the timing or the amount is uncertain. Provisions are
discounted when the effect of the time value of money is significant using a pre-tax discount rate.
Reorganisation provisions include employee termination benefits when ING Group is demonstrably committed to
either terminate the employment of current employees according to a detailed formal plan without possibility of
withdrawal, or providing termination benefits as a result of an offer made to encourage voluntary redundancy.
A liability is recognised for a levy when the activity that triggers payment, as identified by the relevant legislation,
occurs. For a levy that is triggered upon reaching a minimum threshold, the liability is recognised only upon
reaching the specified minimum threshold.
A contingent liability is a possible obligation that arises from past events and whose existence will be confirmed
only by the occurrence or non-occurrence of one or more uncertain future events not wholly within the control of
ING Group, or a present obligation that arises from past events but is not recognised because it is either not
probable that an outflow of economic benefits will be required to settle the obligation or the amount of the
obligation cannot be measured reliably. Contingent liabilities are not recognised in the statement of financial
position, but are rather disclosed in the notes unless the possibility of the outflow of economic benefits is remote.
A contingent asset is a possible asset that arises from past events and whose existence will be confirmed only by
the occurrence or non-occurrence of one or more uncertain future events not wholly within the control of ING
Group. Contingent assets are recognised in the statement of financial position only when realisation of the income
that arises from such an asset is virtually certain. Contingent assets are disclosed in the notes when an inflow of
economic benefits is probable.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-246 |
Significant judgements and critical accounting estimates and assumptions: The recognition and measurement of provisions is an inherently uncertain process, involving using judgement to determine when a present obligation exists and estimates regarding probability, amounts and timing of cash flows. ING Group may become involved in governmental, regulatory, arbitration and legal proceedings and investigations, and may be subject to third-party claims. With or without reference to the above, ING Group may also offer compensation to certain of its customers. Judgement is required to assess whether a present obligation exists and to estimate the probability of an unfavourable outcome and the amount of potential loss. The degree of uncertainty and the method of making the accounting estimate depends on the individual case, its nature and complexity. Such cases are usually one of a kind. For the assessment of related provisions, ING Group consults with internal and external legal experts. Even taking into consideration legal experts’ advice, the probability of an outflow of economic benefits can still be uncertain and the provision recognised can remain sensitive to the assumptions used. Reference is made to Note 15 'Provisions'. For proceedings where it is not possible to make a reliable estimate of the expected financial effect, that could result from the ultimate resolution of the proceedings, no provision is recognised, however disclosure is included in the financial statements, where relevant. Reference is made to Note 42 'Legal proceedings'. Critical accounting estimates and assumptions for the reorganisation provision are in estimating the amounts and timing of cash flows as the announced transformation initiatives are implemented over a period of several years. Reference is made to Note 15 'Provisions'. | ||
1.16 Irrevocable Payment Commitments on contributions to SRF and DGS
ING makes contributions to the Single Resolution Fund (SRF) and Deposit Guarantee Schemes (DGS). The annual
contributions are paid in cash or, in some cases, partly using Irrevocable Payment Commitments (IPCs) that
become payable if and when called. Cash contributions are accounted for as levies as described in section 1.15
above, while IPCs are disclosed in Note 41 'Commitments'. Cash collateral posted on IPCs to the SRF is accounted
for as an interest bearing financial asset at amortised cost. Government bonds posted as collateral on IPCs to DGS
Defined benefit plans
The net defined benefit asset or liability recognised in the statement of financial position in respect of defined
benefit pension plans is the fair value of the plan assets less the present value of the defined benefit obligation at
the balance sheet date.
Changes in plan assets include mainly:
§Return on plan assets are recognised as staff costs in the statement of profit or loss. It is determined using a
high quality corporate bond rate (identical to the discount rate used in determining the defined benefit
obligation) at the start of the reporting period; and
§Remeasurements which are recognised in Other comprehensive income.
The defined benefit obligation is calculated by internal and external independent qualified actuaries through
actuarial models and calculations using the projected unit credit method. This method considers expected future
payments required to settle the obligation resulting from employee service in the current and prior periods,
discounted using a high quality corporate bond rate. Inherent in these actuarial models are assumptions including
discount rates, rates of increase in future salary and benefit levels, mortality rates, consumer price index and the
expected level of indexation. The assumptions are based on available market data as well as management
expectations and are updated regularly.
Changes in the defined benefit obligation include mainly:
§Service cost which is recognised as staff costs in the statement of profit or loss;
§Interest expenses are recognised as staff costs in the Statement of profit or loss. It is determined using a high
quality corporate bond rate at the start of the period;
§Remeasurements which are recognised in Other comprehensive income (equity) and not recycled to the
Statement of profit or loss;
§Any past service cost relating to a plan amendment is recognised in profit or loss in the period of the plan
amendment; and
§Gains and losses on curtailments and settlements are recognised in the Statement of profit or loss when the
curtailment or settlement occurs.
The recognition of a net defined benefit asset in the Consolidated statement of financial position is limited to the
present value of any economic benefits available in the form of refunds from the plans or reductions in future
contributions to the plans.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-247 |
Defined contribution plans
For defined contribution plans, ING Group pays contributions to publicly or privately administered pension
insurance plans on a mandatory, contractual or voluntary basis. ING Group has no further payment obligations
once the contributions have been paid. The contributions are recognised as staff expenses in the profit or loss
when they are due. Prepaid contributions are recognised as an asset to the extent that a cash refund or a
reduction in the future payments is available.
Other post-employment obligations
Some group companies provide other post-employment benefits to former employees. The entitlement to these
benefits is usually conditional on the employee remaining in service up to retirement age and the completion of a
minimum service period. The expected costs of these benefits are accrued over the period of employment using an
Treasury shares (own equity instruments bought back by ING Group or its subsidiaries) are deducted from Equity
(Other reserves). No gain or loss is recognised in the statement of profit or loss when purchasing, selling or
cancelling these shares. Treasury shares are not taken into account when calculating earnings per ordinary share
or dividend per ordinary share as they are not considered to be outstanding.
Treasury shares can be purchased by ING as part of a share buyback programme. If a share buyback is executed
by a broker and the agreement with the broker is irrevocable, ING has a contractual obligation to purchase its own
shares that is unavoidable once it signs the agreement with the broker. This is the moment when ING recognises a
financial liability measured at the present value of the redemption amount with a corresponding reduction in
equity (Retained earnings). During the share buyback programme, ING settles this liability for the actual purchase
price paid for the shares bought on a daily basis. Actual shares bought back and held by ING are presented as
Treasury shares within Other reserves in equity.
Interest
Interest income and expense are recognised in the statement of profit or loss using the effective interest method.
The effective interest method is a method of calculating the amortised cost of a financial asset or a financial
liability and of allocating the interest income or interest expense over the relevant period. The effective interest
rate is the rate that exactly discounts estimated future cash payments or receipts through the expected life of the
financial instrument or, when appropriate, a shorter period to the net carrying amount of the financial asset or
financial liability. When calculating the effective interest rate, ING Group estimates cash flows considering all
contractual terms of the financial instrument (for example, prepayment options) but does not consider future
credit losses.
The calculation includes all fees and points paid or received between parties to the contract that are an integral
part of the effective interest rate, transaction costs and all other premiums or discounts. Once a financial asset or
a group of similar financial assets has been written down as a result of an impairment loss, interest income is
recognised using the rate of interest used to discount the future cash flows for the purpose of measuring the
impairment loss.
Interest results on instruments classified at Amortised Cost, assets measured at FVOCI and derivatives in a formal
hedge accounting relationship are presented in ‘Interest income (expense) using effective interest rate method’.
Interest result on financial assets and liabilities voluntarily designated as at FVPL and derivatives in so-called
economic hedges and instruments designated at fair value are presented in ‘Other interest income (expense)’.
Interest result on all other financial assets and liabilities at FVTPL is recognised in ‘Valuation results and net trading
income’.
Fees and commissions
Fees and commissions are generally recognised as the service is provided. Loan commitment fees for loans that
are likely to be drawn down are deferred (together with related direct costs) and recognised as an adjustment to
the effective interest rate on the loan. Loan syndication fees are recognised as income when the performance
obligation has been satisfied based on the particular contract and ING Group has retained no part of the loan
package for itself or has retained a part at the same effective interest rate as the other participants. Commission
and fees arising from negotiating, or participating in the negotiation of, a transaction for a third party – such as
the arrangement of the acquisition of shares or other securities or the purchase or sale of businesses – are
recognised on completion of the underlying transaction. Portfolio and other management advisory and service
fees are recognised based on the applicable service contracts as the service is provided. Asset management fees
related to investment funds and investment contract fees are recognised on a pro-rata basis over the period the
service is provided. The same principle is applied for wealth management, financial planning and custody services
that are continuously provided over an extended period of time. Fees received and paid between banks for
payment services are classified as commission income and expenses.
Lease income
The proceeds from leasing out assets under operating leases are recognised on a straight-line basis over the life of
the lease agreement. Lease payments received in respect of finance leases when ING Group is the lessor are
divided into an interest component (recognised as interest income) and a repayment component based on a
Expenses are recognised in the statement of profit or loss as incurred, or when a decrease in future economic
benefits related to a decrease in an asset or an increase in a liability has arisen that can be measured reliably. Fee
and commission expenses generally result from contracts with ING service providers, who perform their service for
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-248 |
ING Group’s customers. Costs are generally presented as ‘Commission expenses’ if they are specific, incremental,
directly attributable and identifiable to generate income.
Share-based payments
ING Group only engages in share-based payment transactions with its staff and directors. Share-based payment
expenses are recognised as a staff expense over the vesting period. A corresponding increase in equity is
recognised for equity-settled share-based payment transactions. A liability is recognised for cash-settled share-
based payment transactions. The fair value of equity-settled share-based payment transactions are measured at
the grant date, and the fair value of cash-settled share-based payment transactions are measured at each
balance sheet date. Rights granted will remain valid until the expiry date, even if the share based payment
scheme is discontinued. The rights are subject to certain conditions, including a pre-determined continuous period
Earnings per ordinary share is calculated on the basis of the weighted average number of ordinary shares
outstanding. In calculating the weighted average number of ordinary shares outstanding:
§Own shares held by group companies are deducted from the total number of ordinary shares in issue;
§The computation is based on daily averages; and
§In case of exercised warrants, the exercise date is taken into consideration.
Diluted earnings per share data are computed as if all convertible instruments outstanding at year-end were
exercised at the beginning of the period. It is also assumed that ING Group uses the assumed proceeds thus
received to buy its own shares against the average market price in the financial year. The net increase in the
number of shares resulting from the exercise is added to the average number of shares used to calculate diluted
The statement of cash flows is prepared in accordance with the indirect method, distinguishing cash flows from
operating, investing and financing activities. In the net cash flow from operating activities, the result before tax is
adjusted for those items in the statement of profit or loss and changes in items per the statement of financial
position, which do not result in actual cash flows during the year.
For the purposes of the statement of cash flows, Cash and cash equivalents include deposits from banks and loans
and advances to banks that are on demand. Furthermore, it includes treasury bills and other eligible bills shorter
than three months. Investments qualify as a cash equivalent if they are readily convertible to a known amount of
cash and are subject to an insignificant risk of changes in value.
Cash flows arising from foreign currency transactions are translated into the functional currency using the
exchange rates at the date of the cash flows.
The net cash flow shown in respect of Loans and advances to customers relates only to transactions involving
actual payments or receipts. The Addition to loan loss provision, which is deducted from the item Loans and
advances to customers in the statement of financial position, has been adjusted accordingly from the result before
tax and is shown separately in the statement of cash flows.
The difference between the Net cash flow in accordance with the statement of cash flows and the change
between the opening and closing balance of Cash and cash equivalents in the statement of financial position is
due to exchange rate differences and is presented separately in the cash flow statement.
Liabilities arising from financing activities are debt securities, lease liabilities and subordinated loans.
The condensed parent company financial statements of ING Groep N.V. are prepared using the recognition and
measurement principles as those applied in the Consolidated financial statements. Additionally, the investments in
Group companies are accounted for in the Parent company accounts according to the equity method.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-249 |
Notes to the Consolidated statement of financial position
Cash and balances with central banks | ||
in EUR million | 2025 | 2024 |
Amounts held at central banks 1 | ||
Cash and bank balances | ||
1Amounts held at central banks include an amount of EUR -17 million (2024: EUR -14 million) of Loan loss provisions.
Amounts held at central banks reflect on-demand balances. The movement reflects ING’s active liquidity
management.
Reference is made to Note 39 'Transfer of financial assets, assets pledged and received as collateral' for restrictions
on amounts held at central banks.
Loans and advances to banks | ||||||
Netherlands | Rest of the world | Total | ||||
in EUR million | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 |
Loans and advances to banks1 | ||||||
1 Loans and advances to banks include EUR -18 million (2024: EUR -22 million) of Loan loss provisions.
Loans and advances include balances of reverse repurchase transactions. For more information, refer to Note 4
'Financial assets at fair value through profit or loss'. Furthermore, it includes on-demand and term loans, and cash
collateral transactions. Reference is made to Note 7 'Loans and advances to customers' for information on finance
lease receivables included in Loans and advances to banks.
As at 31 December 2025 and at 31 December 2024, all loans and advances to banks are non-subordinated.
Financial assets at fair value through profit or loss | ||
in EUR million | 2025 | 2024 |
Trading assets | ||
Non-trading derivatives | ||
Designated at fair value through profit or loss | ||
Mandatorily measured at fair value through profit or loss | ||
(Reverse) repurchase transactions
Financial assets at fair value through profit or loss include securities lending and sales and repurchase transactions
with securities. At ING, these types of transactions are recognised in several lines in the statement of financial
position depending on business model assessment and counterparty. Netting is applicable to repurchase
agreements that are governed by an established Global Master Repurchase Agreement (GMRA) when ING Group
has the intention to settle net. This netting is restricted to transactions involving the same currency and maturity
date, and must occur within the same legal entity. Reference is made to Note 40 'Offsetting financial assets and
liabilities'.
Securities purchased under agreements to resell (reverse repos), securities borrowings and similar agreements are
not recognised in the consolidated statement of financial position as the counterparty continues to be exposed to
substantially all risks and rewards of the transferred security. Based on the business model assessment and
counterparty, the consideration paid to purchase securities is recognised as Loans and advances to customers,
Loans and advances to banks, financial assets mandatorily at FVPL or Trading assets.
Securities sold subject to repurchase agreements (repos), securities lending and similar agreements continue to be
recognised in the consolidated statement of financial position as ING Group continues to be exposed to
substantially all risks and rewards of the transferred financial asset. The counterparty liability is designated and
measured at FVPL if the asset is measured mandatorily at FVPL. Otherwise, the counterparty liability is included in
Deposits from banks, Customer deposits or Trading. Furthermore, for repurchase agreements, the gross amount of
assets must be considered together with the gross amount of related liabilities, which are presented separately on
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-250 |
the statement of financial position since IFRS does not always allow the netting of these positions in the statement
of financial position.
Reference is made to Note 39 'Transfer of financial assets, assets pledged and received as collateral' for
information on transferred assets which were not derecognised.
financial position:
Exposure to (reverse) repurchase agreements | ||
in EUR million | 2025 | 2024 |
Reverse repurchase transactions | ||
Loans and advances to banks | ||
Loans and advances to customers | ||
Trading assets, loans and receivables | ||
Loans and receivables mandatorily measured at fair value through profit or loss | ||
Repurchase transactions | ||
Deposits from banks | ||
Customer deposits | ||
Trading liabilities, funds on deposit | ||
Funds entrusted designated and measured at fair value through profit or loss | ||
Trading assets
Trading assets by type | ||
in EUR million | 2025 | 2024 |
Equity securities | ||
Debt securities | ||
Derivatives | ||
Loans and receivables | ||
Trading assets include assets that are closely related to servicing the needs of the clients of ING Group. ING offers
institutional clients, corporate clients, and governments products that are traded on the financial markets. A
significant part of the derivatives in the trading portfolio is related to servicing corporate clients in their risk
management to hedge, for example, currency or interest rate exposures. In addition, ING provides its customers
access to equity and debt markets for issuing their own equity or debt securities (securities underwriting).
Reference is made to Note 14 'Financial liabilities at fair value through profit or loss' for information on trading
liabilities.
Non-trading derivatives
Non-trading derivatives by type | ||
in EUR million | 2025 | 2024 |
Derivatives used in | ||
- fair value hedges | ||
- cash flow hedges | ||
- hedges of net investments in foreign operations | ||
Other non-trading derivatives | ||
Reference is made to Note 36 'Derivatives and hedge accounting' for information on derivatives designated in
hedge accounting.
Other non-trading derivatives mainly includes interest-rate swaps, foreign exchange swaps, and cross currency
swaps for which no hedge accounting is applied.
Designated at fair value through profit or loss
Designated at fair value through profit or loss by type | ||
in EUR million | 2025 | 2024 |
Debt securities | ||
Loans and receivables | ||
‘Financial assets designated at fair value through profit or loss’ is partly economically hedged by credit derivatives.
The hedges do not meet the criteria for hedge accounting and the loans and debt securities are recorded at fair
value to avoid an accounting mismatch. The maximum credit exposure of the loans and receivables and debt
securities included in ‘Financial assets designated at fair value through profit or loss’ approximates its carrying
value and amounts to EUR 3,448 million (2024: EUR 5,740 million). In 2025, the change in fair value of these loans
and debt securities amounts to EUR -177 million (2024: EUR 5 million).
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-251 |
ING has mitigated the credit risk exposure on part of the portfolio. The cost at initial recognition of the financial
assets designated at fair value through profit or loss that are economically hedged by credit derivatives is EUR
for the financial asset economically hedged is EUR 85 million (2024: EUR 173 million) and the change for the
current year is EUR -88 million (2024: EUR 24 million). The cumulative change in fair value attributable to changes
in credit risk for the financial assets non-economically hedged with credit derivatives is EUR 513 million (2024: EUR
The notional value of the related credit derivatives is EUR 2,486 million (2024: EUR 3,807 million). The cumulative
change in fair value of the credit derivatives since the financial assets were first designated, amounts to EUR
-85 million (2024: EUR -214 million) and the change for the current year is EUR 128 million (2024: EUR -95 million).
The changes in fair value attributable to changes in credit risk have been calculated by determining the changes in
credit spread implicit in the fair value of loans and bonds issued by entities with similar credit characteristics.
Mandatorily at fair value through profit or loss
Mandatorily at fair value through profit or loss by type | ||
in EUR million | 2025 | 2024 |
Equity securities | ||
Debt securities | ||
Loans and receivables | ||
Equity securities are individually insignificant for ING Group. For total exposure to debt securities, reference is made
to Note 6 'Debt securities'. Loans and receivables include mainly reverse repurchase agreements.
Financial assets at fair value through other comprehensive income by type | ||
in EUR million | 2025 | 2024 |
Equity securities | ||
Debt securities 1 | ||
Loans and advances 1 | ||
1 Debt securities includes an amount of EUR -15 million (2024: EUR -12 million) and Loans and advances includes EUR -6 million (2024: EUR -7 million) of
Loan loss provisions.
Exposure to equity securities
Equity securities designated as at fair value through other comprehensive income | ||||
Carrying value | Carrying value 1 | Dividend income | Dividend income 1 | |
in EUR million | 2025 | 2024 | 2025 | 2024 |
Investment in Bank of Beijing | ||||
Investment in Van Lanschot Kempen | ||||
Other Investments | ||||
1 The table has been updated to present the increased stake in Van Lanschot Kempen separately from other investments.
As at 31 December 2025 ING holds 13 % (2024: 13 %) of the shares of Bank of Beijing, a bank listed on the Shanghai
Stock Exchange. The stake in Bank of Beijing is part of the Corporate Line. As per regulatory requirements set by
the China Banking and Insurance Regulatory Commission, ING, as a shareholder holding more than 5% of the
shares, is required to supply additional capital when necessary. No request for additional capital was received in
2025 (2024: nil).
In 2025 ING increased its ownership in Van Lanschot Kempen by acquiring an additional 17.6 % stake, raising its
total interest based on the issued share capital from 2.7 % to 20.3 %. Despite ING holding over 20% voting rights in
VLK (a presumption of significant influence in IFRS), this presumption is rebutted given that ING holds rights similar
to other ordinary shareholders where voting does not include financial and operating policy decisions and ING
does not have the rights or ability to obtain board representation. Therefore, the increased investment in VLK is
designated at fair value through other comprehensive income consistent with ING’s passive investment purpose.
The stake is part of the Corporate Line.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-252 |
Changes in fair value through other comprehensive income
The following table presents changes in financial assets at fair value through other comprehensive income:
Changes in fair value through other comprehensive income financial assets | ||||||
FVOCI equity securities | FVOCI debt instruments 1 | Total | ||||
in EUR million | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 |
Opening balance as at 1 January | ||||||
Additions | ||||||
Amortisation | ||||||
Transfers | ||||||
Changes in unrealised revaluations 2 | - | - | ||||
Impairments | - | - | ||||
Reversals of impairments | - | - | ||||
Disposals and redemptions | - | - | - | - | - | - |
Exchange rate differences | - | - | - | |||
Other changes | - | |||||
Closing balance | ||||||
1Fair value through other comprehensive income debt instruments includes both debt securities and loans and advances.
2Changes in unrealised revaluations of FVOCI debt instruments include changes on hedged items which are recognised in the statement of profit or loss.
Reference is made to Note 19 'Equity' for details on the changes in the revaluation reserve.
FVOCI equity securities
Exchange rate differences of EUR -178 million (31 December 2024: EUR 62 million) are mainly related to the stake
in Bank of Beijing following the depreciation of CNY versus EUR. In 2025, changes in unrealised revaluations of
equity securities are mainly related to a revaluation of the stake in Bank of Beijing of EUR -225 million (31
December 2024: EUR 590 million) following a change in the share price.
FVOCI debt instruments
In 2025, changes in interest rates and portfolio composition resulted in changes in unrealised revaluations of debt
securities of EUR 322 million (31 December 2024: EUR -96 million).
Reference is made to Note 6 'Debt securities' for details on ING Group’s total exposure to debt securities.
Exposure to debt securities | ||
in EUR million | 2025 | 2024 |
Debt securities at fair value through other comprehensive income | ||
Debt securities at amortised cost | ||
Total debt securities at fair value through other comprehensive income and amortised cost | ||
Trading assets | ||
Debt securities designated and measured at fair value through profit or loss | ||
Debt securities mandatorily measured at fair value through profit or loss | ||
Total debt securities at fair value through profit or loss | ||
million (31 December 2024: EUR 97,999 million) is specified as follows:
Debt securities by type of exposure | ||||||||
Debt Securities at FVPL 1 | Debt Securities at FVOCI | Debt Securities at AC | Total | |||||
in EUR million | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 |
Government bonds | ||||||||
Central bank bonds | ||||||||
Sub-sovereign, Supranationals and Agencies | ||||||||
Covered bonds | ||||||||
Corporate bonds | ||||||||
Financial institutions' bonds | ||||||||
ABS portfolio | ||||||||
Loan loss provisions | - | - | - | - | - | - | ||
Debt securities portfolio | ||||||||
1Debt securities at FVPL includes both debt securities designated - and mandatorily measured at fair value through profit or loss.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-253 |
Loans and advances to customers by type | ||||||
Netherlands | Rest of the world | Total | ||||
in EUR million | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 |
Loans and advances to public authorities | ||||||
Residential mortgages | ||||||
Other personal lending | ||||||
Corporate Lending | ||||||
Loan loss provisions | - | - | - | - | - | - |
For details on credit quality and loan loss provisioning, refer to ‘Risk management – Credit risk’ – paragraphs ‘Credit
quality’ and 'Loan loss provisioning'.
As at 31 December 2025 EUR 727,498 million (2024: EUR 683,398 million) of loans and advances to customers are
non-subordinated.
detailed as follows:
Finance lease receivables 1 | ||
in EUR million | 2025 | 2024 |
Maturities of gross investment in finance lease receivables | ||
- within 1 year | ||
- between 1-2 years | ||
- between 2-3 years | ||
- between 3-4 years | ||
- between 4-5 years | ||
- more than 5 years | ||
Unearned future finance income on finance leases | - | - |
Net investment in finance leases | ||
Included in Loans and advances to banks | ||
Included in Loans and advances to customers | ||
The finance lease receivables mainly relate to the financing of equipment and real estate for third parties where
ING is the lessor and are mainly part of corporate lending. Interest income in 2025 on finance lease receivables
amounts to EUR 513 million (2024: EUR 522 million).
Investments in associates and joint ventures | ||||||
2025 | 2024 | |||||
in EUR million | Interest held (%) | Fair value of listed investments | Balance sheet value | Interest held (%) | Fair value of listed investments | Balance sheet value |
TMBThanachart Bank Public Company Limited | ||||||
Other investments in associates and joint ventures | ||||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-254 |
TMBThanachart Bank Public Company Limited
ING Group has an 23 % investment in TMBThanachart Bank Public Company Limited (hereafter: TTB), a bank listed
on the stock exchange of Thailand. TTB is providing products and services to wholesale, small and medium
enterprise (SME), and retail customers. TTB is accounted for as an investment in associate based on the size of
ING's shareholding and representation on the Board. The investment in TTB is reflected in the Corporate Line.
A summary of the unaudited financial information of TTB as of the end of September 2025 based on the data
available at the time the consolidated financial statements were prepared is presented below. TTB’s statutory
reporting date is 31 December. For the year ending 31 December 2025, ING recognised the associate’s results
using TTB’s financial statements for the 12‑month period ending 30 September 2025.
Selected balance sheet information TMBThanachart Bank Public Company Limited | ||
As at 30 September in EUR million | 2025 | 2024 |
Loans to customers and accrued interest receivables, net | ||
Interbank and money market items, net | ||
Investments, net | ||
Other | ||
Total assets | ||
Deposits | ||
Interbank and money market items | ||
Debts issued and borrowings | ||
Other | ||
Total liabilities | ||
Equity | ||
Selected profit or loss information TMBThanachart Bank Public Company Limited | ||
For the 12 months ended 30 September | ||
in EUR million | 2025 | 2024 |
Total operating income | ||
Total expenses | ||
Profit for the period | ||
Total other comprehensive income for the period | ||
Other investments in associates and joint ventures
Included in Other investments in associates and joint ventures are mainly financial services and (non-) financial
technology funds or vehicles operating predominantly in Europe, and are individually not significant to ING Group.
Significant influence for associates in which the interest held is below 20%, is based on the combination of ING
Group’s financial interest and other arrangements, such as participation in the Board of Directors.
The associates and joint ventures of ING are subject to legal and regulatory restrictions regarding the amount of
dividends they can pay to ING. These restrictions are, for example, dependent on the laws in the country of
incorporation for declaring dividends or as a result of minimum capital requirements that are imposed by industry
regulators in the countries in which the associates and joint ventures operate.
In addition, the associates and joint ventures also consider other factors in determining the appropriate levels of
equity needed. These factors and limitations include, but are not limited to, the rating agency and regulatory
views, which can change over time.
Changes in Investments in associates and joint ventures | ||
in EUR million | 2025 | 2024 |
Opening balance as at 1 January | ||
Additions | ||
Transfers | - | - |
Revaluations | ||
Share of results | ||
Dividends received | - | - |
Disposals | - | - |
Impairments | - | - |
Exchange rate differences | - | |
Closing balance | ||
Share of results from associates and joint ventures of EUR 209 million (2024: EUR 205 million) as included in the
table above is mainly attributable to our share in the results of TTB of EUR 136 million (2024: EUR 123 million)
and a EUR 44 million gain from the sale of an associate in Belgium, while 2024 included EUR 77 million as our
share in the result of an associate in Belgium following a one-off profit.
Impairments and reversal thereof on the investment in TTB
Accumulated impairments on the investment in TTB of EUR 395 million (2024: EUR 395 million) were recognised in
previous years. There is no impairment trigger observed as per 31 December 2025. A Value in Use ('VIU') was
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-255 |
estimated following the prolonged increase of the quoted TTB share price over the original cost price of the
investment and the sustained improved broker consensus outlook. As the VIU did not significantly exceed the
carrying amount of the investment in TTB, no reversal of impairment was recognised.
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and VIU. Fair value less
costs of disposal is based on observable share price. The VIU calculation uses discounted cash flow projections
based on management’s best estimates. VIU is derived using a Dividend Discount Model (DDM) where distributable
equity, i.e. future earnings available to ordinary shareholders, is used as a proxy for future cash flows. The
valuation looks at expected cash flows into perpetuity resulting in two main components to the VIU calculation:
§The estimation of future earnings over a 5-year forecast period; and
§The terminal value being the extrapolation of earnings into perpetuity applying a long-term growth rate. The
earnings that are used for extrapolation represent the stable long-term financial results and position of TTB, i.e.
a steady state. The terminal value comprises the majority of the total VIU.
Key assumptions used in the VIU calculation as at 31 December 2025
The VIU is determined using a valuation model which is subject to multiple management assumptions. The key
assumptions, i.e. those to which the overall result is most sensitive to, are the following:
•Expected future earnings of TTB: Short- to medium-term expectations are based on forecasts derived from
broker consensus. Longer-term and steady-state expectations into perpetuity are derived using reasonable
and supportable assumptions capturing a combination of TTB specific and market data points; A capital
maintenance charge is applied, which is management’s forecast of the earnings that need to be withheld in
order for TTB to meet target regulatory requirements over the forecast period;
•Discount rate (cost of equity): 10.17 % (2024: 10.96 %), based on the capital asset pricing model (CAPM)
calculated for TTB using current market data and expert judgement; and
•Terminal growth rate: 2.41 % (2024: 2.74 %) consistent with current long term government bond yield in
Thailand as a proxy for a risk-free rate.
The model was evaluated for reasonably possible changes to key assumptions in the model. This reflects the
sensitivity of the VIU to each key assumption on its own and it is possible that more than one favourable and/or
unfavourable change may occur at the same time. The selected rates of reasonably possible changes to key
assumptions are based on external analysts’ forecasts and other relevant external data sources, which can change
period to period. The sensitivity of the VIU to each key assumption is as follows:
•A favourable change of 10 % in the cash flows would result in an increase in VIU of EUR 89 million (2024: EUR
EUR -59 million);
•A favourable change of 1 % in the discount rate would result in an increase in VIU of EUR 159 million (2024: EUR
EUR -75 million);
•A favourable change of 1 % in the terminal growth rate would result in an increase in VIU of EUR 118 million
(2024: EUR 68 million), while an unfavourable change of -1 % would result in a decrease in VIU of EUR -90
Property and equipment by type | ||
in EUR million | 2025 | 2024 |
Property in own use | ||
Equipment: | ||
- Data processing equipment | ||
- Other equipment | ||
Right- of- use assets: | ||
- ROU property | ||
- ROU cars | ||
- ROU other leases | ||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-256 |
Changes in property and equipment | ||||||||
Property in own use | Equipment | Right-of-use assets | Total | |||||
in EUR million | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 |
Opening balance as at 1 January | ||||||||
Additions | ||||||||
Transfers | - | - | - | - | ||||
Depreciation | - | - | - | - | - | - | - | - |
Impairments1 | - | - | - | - | - | - | - | - |
Reversals of impairments 1 | ||||||||
Remeasurements | ||||||||
Disposals | - | - | - | - | - | - | - | - |
Exchange rate differences | - | - | - | - | ||||
Closing balance | ||||||||
Cost price | ||||||||
Accumulated depreciation | - | - | - | - | - | - | - | - |
Accumulated impairments | - | - | - | - | - | - | - | - |
Accumulated revaluation surplus | ||||||||
Accumulated remeasurement | ||||||||
Net carrying value | ||||||||
1Impairments and reversals of impairments of property and equipment are presented as Other operating expenses in the statement of Profit or Loss.
ING considers valuations from third-party experts in determining the fair values of property in own use. The vast
majority of the land and buildings were appraised during 2025. Property in own use purchase costs amounted to
EUR 994 million (2024: EUR 871 million). Cost or the purchase price less accumulated depreciation and
impairments would have been EUR 599 million (2024: EUR 476 million) had property in own use been valued at
cost instead of at fair value.
Changes in intangible assets | ||||||||
Goodwill | Software | Other | Total | |||||
in EUR million | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 |
Opening balance as at 1 January | ||||||||
Additions | ||||||||
Capitalised expenses | ||||||||
Amortisation | - | - | - | - | ||||
Impairments 1 | - | - | - | - | ||||
Exchange rate differences | - | - | ||||||
Disposals | - | - | - | - | ||||
Other changes | - | - | ||||||
Closing balance | ||||||||
Gross carrying amount | ||||||||
Accumulated amortisation | - | - | - | - | - | - | ||
Accumulated impairments | - | - | - | - | - | - | ||
Net carrying value | ||||||||
1 Impairments of intangible assets are presented within Other operating expenses in the statement of Profit or Loss.
Goodwill
Goodwill allocation to group of CGUs | |||||||
in EUR million | Method used for recoverable amount | Discount rate | Terminal growth rate | Goodwill | |||
Group of CGUs | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | |
Retail Netherlands | Value in use | ||||||
Retail Germany | Value in use | ||||||
Retail Poland | Value in use | ||||||
Retail Romania | Value in use | ||||||
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-257 |
Impairment testing
Goodwill is tested for impairment annually in the fourth quarter by comparing the recoverable amount of each
goodwill-carrying CGU with its carrying amount. The key assumptions used in the calculation of the recoverable
amounts are included in the table above. Furthermore, ING Group tests goodwill whenever a triggering event is
identified. In 2025, no triggering events were identified.
At the annual impairment test in the fourth quarter, the recoverable amount exceeds the carrying value of the
CGUs as at 31 December 2025 and therefore no impairment is required (31 December 2024: nil ).
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and Value in Use (VIU).
The VIU calculation is based on a Dividend Discount model using three-year management-approved plans,
updated for expected changes in the macroeconomic environment. When estimating the VIU of a CGU, local
conditions and requirements determine the capital requirements, discount rates, and terminal growth rates. These
local conditions and requirements determine the ability to upstream excess capital and profits to ING Group. The
discount rate calculation includes other inputs such as equity market premium, country risk premium, and long-
term inflation which are based on market sources and management’s judgement. The long-term growth rate is
based on the long-term inflation rate obtained from market sources. The impacts of climate risk are included to
the extent that they are observable in discount rates and assets prices.
Sensitivity of key assumptions
Key assumptions in the goodwill impairment test model are the projected locally available cash flows (based on
local capital requirements and projected profits), discount rates (cost of equity), and long-term growth rates.
The recoverable amounts of the CGUs are sensitive to the above key assumptions. A decrease in the available cash
flows of 10 %, an increase in the discount rate of 1 percent point or a reduction of the future growth rate to zero
are considered reasonably possible changes in key assumptions. If the aforementioned changes occur to one of
the above key assumptions holding the other key assumptions constant, goodwill of the remaining CGUs will
continue to be recoverable.
Software
Software includes internally developed software amounting to EUR 956 million (2024: EUR 768 million). Software
capitalisation amounts increased in 2025 following the significant IT-platform investments in our Retail business.
Software is reviewed for indicators of impairment. Irrespective of whether there is an indication of impairment,
software under development is tested annually for impairment.
Other assets by type | ||
in EUR million | 2025 | 2024 |
Assets held for sale | ||
Net defined benefit assets | ||
Investment properties | ||
Property development and obtained from foreclosures | ||
Prepayments | ||
Accrued assets | ||
Amounts to be settled | ||
Other | ||
Disclosures in respect of Net defined benefit assets are provided in Note 33 'Pensions and other post-employment
benefits'.
Amounts to be settled include primarily transactions not settled at the balance sheet date. The nature of these
transactions is short term and they are expected to settle shortly after the closing date of the balance sheet. Other
relates to various receivables in the normal course of business, including short-term receivables from mortgages
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-258 |
Deposits from banks by type | ||||||
Netherlands | Rest of the world | Total | ||||
in EUR million | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 |
Non-interest bearing | ||||||
Interest bearing | ||||||
Deposits from banks includes non-subordinated deposits and, to a lesser extent, repurchase transactions. For more
information on reverse repurchase transactions, refer to Note 4 'Financial assets at fair value through profit or loss'.
Customer deposits | ||
in EUR million | 2025 | 2024 |
Current accounts / Overnight deposits | ||
Savings accounts | ||
Time deposits | ||
Other | ||
Current accounts / Overnight deposits, Savings accounts and Time deposits include balances with individuals,
respectively EUR 113,586 million (2024: EUR 107,068 million), EUR 347,234 million (2024: EUR 324,135 million)
and EUR 50,033 million (2024: EUR 56,599 million).
Customer deposits by type | ||||||
Netherlands | Rest of the world | Total | ||||
in EUR million | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 |
Non-interest bearing | ||||||
Interest bearing 1 | ||||||
1 Interest bearing includes current accounts which are not remunerated. However, ING holds the contractual right to revise the rates.
Financial liabilities at fair value through profit or loss | ||
in EUR million | 2025 | 2024 |
Trading liabilities | ||
Non-trading derivatives | ||
Designated at fair value through profit or loss | ||
Trading liabilities
Trading liabilities by type | ||
in EUR million | 2025 | 2024 |
Equity securities | ||
Debt securities | ||
Funds on deposit | ||
Derivatives | ||
Non-trading derivatives
Non-trading derivatives by type | ||
in EUR million | 2025 | 2024 |
Derivatives used in: | ||
- fair value hedges | ||
- cash flow hedges | ||
- hedges of net investments in foreign operations | ||
Other non-trading derivatives | ||
Reference is made to Note 36 'Derivatives and hedge accounting' for information on derivatives used for hedge
accounting.
Other non-trading derivatives mainly include interest-rate swaps, foreign-exchange swaps and cross-currency
swaps for which no hedge accounting is applied.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-259 |
Designated at fair value through profit or loss
Designated at fair value through profit or loss by type | ||
in EUR million | 2025 | 2024 |
Debt securities | ||
Funds entrusted | ||
Subordinated liabilities | ||
As at 31 December 2025, the change in the fair value of financial liabilities designated at fair value through profit
or loss attributable to changes in credit risk is EUR 57 million on a cumulative basis (2024: EUR 17 million). This
change has been determined as the amount of change in fair value of the financial liability that is not attributable
to changes in market conditions that gave rise to market risk (i.e. mainly interest-rate risk based on yield curves).
The amount that ING Group is contractually required to pay at maturity to the holders of financial liabilities
designated at fair value through profit or loss excluding repurchase agreements (part of funds entrusted) is EUR
Funds entrusted include mainly repurchase agreements. For more information on repurchase transactions, refer
to Note 4 'Financial assets at fair value through profit or loss'.
Provisions by type | ||
in EUR million | 2025 | 2024 |
Reorganisation provisions | ||
Litigation provisions | ||
Other provisions | ||
Loan loss provisions for guarantees and loan commitments | ||
For details and changes on loan loss provisioning for guarantees and loan commitments, refer to ‘Risk
management – Credit risk’ paragraph 'Loan loss provisioning'.
Changes in provisions | ||||||||
Reorganisation | Litigation | Other provisions | Total | |||||
in EUR million | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 |
Opening balance as at 1 January | ||||||||
Additions 1 | ||||||||
Releases 1 | - | - | - | - | - | - | - | - |
Utilised | - | - | - | - | - | - | - | - |
Exchange rate differences | - | - | - | - | ||||
Other changes | - | - | - | - | ||||
Closing balance | ||||||||
1Additions to provisions and unused amounts released are presented in Note 26 'Other operating expenses' in the Statement of Profit
or Loss.
As at 31 December 2025, amounts expected to be settled within 12 months in provisions amount to EUR
and timing of cash flows required to settle the obligation.
Reorganisation provisions
Reorganisation initiatives are implemented over a period of several years and the estimate of the reorganisation
provisions is inherently uncertain.
Litigation provisions
Furthermore, we refer to Note 42 'Legal proceedings' for any contingent liabilities in respect of legal proceedings.
Other provisions
In 2024, the utilisations in the Other provisions mainly relate to the provision for the compensation of Dutch retail
customers for past interest charges that did not sufficiently track market rates.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-260 |
Other liabilities by type | ||
In EUR million | 2025 | 2024 |
Net defined benefit liability | ||
Other post-employment benefits | ||
Other staff-related liabilities | ||
Other taxation and social security contributions | ||
Rents received in advance | ||
Costs payable | ||
Amounts to be settled | ||
Lease liabilities | ||
Other | ||
Disclosures in respect of Net defined benefit liabilities are provided in Note 33 'Pensions and other post-
employment benefits'. Other staff-related liabilities comprise provisions for vacation leave, jubilee, disability and
illness, as well as liabilities for variable compensations.
Lease liabilities relate to right-of-use assets. Disclosures regarding right-of-use assets are provided in Note 9
'Property and equipment'. The total cash outflow for leases in 2025 was EUR 282 million (2024: EUR 290 million).
Amounts to be settled include primarily transactions not settled at the balance sheet date. The nature of these
transactions is short term and have settled after the closing date of the balance sheet. The line Other relates
mainly to amounts payable to suppliers. It also includes the remaining EUR 732 million (2024: EUR 1,275 million)
obligation related with share buyback programme.
Debt securities in issue relate to debentures and other issued debt securities with either fixed interest rates or
interest rates based on floating interest rate levels, such as certificates of deposit and accepted bills issued by ING
Group, except for subordinated items. Debt securities in issue do not include debt securities presented as Financial
liabilities at fair value through profit or loss. ING Group does not have debt securities that are issued on terms other
than those available in the normal course of business.
Debt securities in issue – maturities | ||
In EUR million | 2025 | 2024 |
Fixed rate debt securities | ||
Within 1 year | ||
More than 1 year but less than 2 years | ||
More than 2 years but less than 3 years | ||
More than 3 years but less than 4 years | ||
More than 4 years but less than 5 years | ||
More than 5 years | ||
Total fixed rate debt securities | ||
Floating rate debt securities | ||
Within 1 year | ||
More than 1 year but less than 2 years | ||
More than 2 years but less than 3 years | ||
More than 3 years but less than 4 years | ||
More than 4 years but less than 5 years | ||
More than 5 years | ||
Total floating rate debt securities | ||
Total debt securities | ||
Reference is made to the Consolidated statement of cash flows for more information on issuances, redemptions
and non-cash movements.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-261 |
Subordinated loans | ||
In EUR million | 2025 | 2024 |
Subordinated loans | ||
Subordinated loans are bonds issued by ING Groep N.V. and its subsidiaries to raise Tier 1 and Tier 2 (CRR-eligible)
capital. Under IFRS these securities are classified as liabilities, and for regulatory purposes they are considered as
capital.
In 2025 ING Groep N.V. issued EUR 1.25 billion 4.13 % Fixed Rate Subordinated Green Tier 2 Notes in May, EUR
Contingent Convertible Capital Securities in September.
In 2025 ING Groep N.V. redeemed EUR 750 million 2.00 % Fixed Subordinated Tier 2 notes in March, USD 1.25
billion 6.50 % Perpetual AT1 Contingent Convertible Capital Securities in April and EUR 1 billion 1.00 % Fixed
Subordinated Tier 2 notes in November.
Reference is made to the Consolidated statement of cash flows for further information on issuances and
redemptions.
Total equity | |||
In EUR million | 2025 | 2024 | 2023 |
Share capital and share premium | |||
- Share capital | |||
- Share premium | |||
Other reserves | |||
- Revaluation reserve: Equity securities at FVOCI | |||
- Revaluation reserve: Debt instruments at FVOCI | - | - | - |
- Revaluation reserve: Cash flow hedge | - | - | - |
- Revaluation reserve: Credit liability | - | - | |
- Revaluation reserve: Property in own use | |||
- Net defined benefit asset/liability remeasurement reserve | - | - | - |
- Currency translation reserve | - | - | - |
- Share of associates and joint ventures and other reserves | |||
- Treasury shares | - | - | - |
- | - | - | |
Retained earnings | |||
Shareholders’ equity (parent) | |||
Non-controlling interests | |||
Total equity | |||
Adjustments for hyperinflation
ING applies IAS 29 ‘Hyperinflation’ on its investment in Türkiye since 2022. The IAS 29 indexation impact on equity
was EUR 34 million (2024: EUR 50 million; 2023: EUR 54 million) of which EUR 123 million (2024: EUR 202 million;
2023: EUR 284 million) in the currency translation reserve, EUR 0 million (2024: EUR 4 million; 2023: EUR 3 million)
in revaluation reserves and EUR -89 million (2024: EUR -156 million; 2023: EUR -234 million) in profit or loss.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-262 |
Share capital and share premium
Share capital | ||||||
Ordinary shares (par value EUR | ||||||
Number x 1,000 | In EUR million | |||||
2025 | 2024 | 2023 | 2025 | 2024 | 2023 | |
Authorised share capital | ||||||
Unissued share capital | ||||||
Issued share capital | ||||||
Changes in issued share capital | ||
Ordinary shares (par value EUR | ||
Number x 1,000 | In EUR million | |
Issued share capital as at 31 December 2022 | ||
Issue of shares | ||
Cancellation of shares | - | - |
Issued share capital as at 31 December 2023 | ||
Cancellation of shares | - | - |
Issued share capital as at 31 December 2024 | ||
Cancellation of shares | - | - |
Issued share capital as at 31 December 2025 | ||
In 2022, shares were issued in order to fund obligations arising from share-based employee incentive
programmes. As from 2023 these shares are repurchased from the market. The cancellation of shares relates to
the shares purchased under the share buyback programme which was completed in October 2025. For further
information, reference is made to 'Ordinary shares held by ING Group (treasury shares)'.
As at 31 December 2025 ING Groep N.V. has issued USD 9,000 million (2024: USD 8,750 million; 2023: USD 7,750
million) Perpetual Additional Tier 1 Contingent Convertible Capital Securities which can, in accordance with their
terms and conditions, convert by operation of law into ordinary shares if the conditions (when the Group CET1
ratio has fallen below 7.00 %) to such a conversion are fulfilled. As a result of this conversion, the issued share
capital can increase by up to 1,014 million (2024: 982 million; 2023: 864 million) ordinary shares. Reference is
made to Note 18 'Subordinated loans'.
Ordinary shares
All ordinary shares are registered. No share certificates have been issued. The par value of ordinary shares is EUR
at 31 December 2025, 3,022 million ordinary shares were issued and fully paid.
Ordinary shares held by ING Group (Treasury shares)
As at 31 December 2025, 119.1 million ordinary shares (2024: 51.1 million; 2023: 154.6 million) of ING Groep N.V.
with a par value of EUR 0.01 are held by ING Groep N.V. or its subsidiaries.
Share premium
No changes in 2025, 2024 and 2023.
Revaluation reserves
Changes in revaluation reserve: Equity securities and Debt instruments at FVOCI | ||||||
Equity securities at FVOCI | Debt instruments at FVOCI | |||||
In EUR million | 2025 | 2024 | 2023 | 2025 | 2024 | 2023 |
Opening balance | - | - | - | |||
Unrealised revaluations | - | - | - | |||
Realised gains/losses transferred to the statement of profit or loss | - | |||||
Realised revaluations transferred to retained earnings | - | |||||
Closing balance | - | - | - | |||
Equity securities at FVOCI
In 2025, the unrealised revaluation of EUR -366 million (2024: EUR 664 million; 2023: EUR -35 million) includes
revaluation of shares in Bank of Beijing for EUR -403 million (2024: EUR 652 million; 2023: EUR -24 million).
Changes in cash flow hedge and credit liability reserve | ||||||
Cash flow hedge | Credit liability | |||||
In EUR million | 2025 | 2024 | 2023 | 2025 | 2024 | 2023 |
Opening balance | - | - | - | - | ||
Changes in credit liability reserve | - | - | - | |||
Unrealised revaluations | ||||||
Closing balance | - | - | - | - | - | |
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-263 |
Cash flow hedge
The increase in the cash flow hedge reserve, primarily related to floating rate lending with interest rate swaps, in
2025 (EUR 597 million) reflects the impact of changes in interest rates, pull-to-par effect and amortisation of de-
designated hedges. Reference is made to Note 36 'Derivatives and hedge accounting'.
Changes in Property in own use reserve | |||
In EUR million | 2025 | 2024 | 2023 |
Opening balance | |||
Unrealised revaluations | |||
Realised revaluations transferred to retained earnings | - | - | - |
Closing balance | |||
Net defined benefit asset/liability remeasurement reserve
Reference is made to Note 33 'Pensions and other post-employment benefits'.
Currency translation reserve
Changes in currency translation reserve | |||
In EUR million | 2025 | 2024 | 2023 |
Opening balance | - | - | - |
Unrealised revaluations | - | ||
Realised gains/losses transferred to the statement of profit or loss | |||
Exchange rate differences | - | - | |
Closing balance | - | - | - |
Unrealised revaluations relates to changes in the value of hedging instruments that are designated as net
investment hedges. The hedging strategy is to protect the CET1 ratio against adverse impact from exchange rate
fluctuations. The net decrease of unrealised revaluations and Exchange rate differences of EUR -789 million is
related to several currencies including USD (EUR -664 million), TRY (EUR -21 million including EUR 123 million IAS
29 indexation effect), GBP (EUR -64 million), PLN (EUR 29 million), UAH (EUR -16 million), AUD (EUR -69 million),
RUB (EUR 87 million), THB (EUR -19 million), RON (EUR -13 million) and other currencies (EUR -39 million).
Share of associates and joint ventures and other reserves
Changes in share of associates, joint ventures and other reserves | |||
In EUR million | 2025 | 2024 | 2023 |
Opening balance | |||
Result for the year | |||
Transfer to/from retained earnings | - | - | - |
Closing balance | |||
The Share of associates, joint ventures and other reserves includes non-distributable profits from associates and
joint ventures of EUR 962 million (2024: EUR 940 million; 2023: EUR 815 million). Other reserves includes a
statutory reserve of EUR 108 million (2024: EUR 897 million; 2023: EUR 1,602 million) related to the former
Stichting Regio Bank and the former Stichting Vakbondsspaarbank SPN and a legal reserve of EUR 956 million
(2024: EUR 768 million; 2023: EUR 628 million) related to internally developed software. The transfer to retained
earnings of EUR -590 million includes the release of the Regio bank and Vakbondsspaarbank SPN reserve of EUR
-802 million (2024: EUR -830 million; 2023: EUR -998 million) against regulatory expenses which are recognised in
the statement of profit or loss.
Treasury shares
Changes in treasury shares | ||||||
In EUR million | Number x 1,000 | |||||
2025 | 2024 | 2023 | 2025 | 2024 | 2023 | |
Opening balance | - | - | - | |||
Purchased/sold for trading purposes | - | - | - | |||
Purchased under staff share plans | - | - | - | |||
Distributed under staff share plans | - | - | - | |||
Purchased under Share buyback programme | - | - | - | |||
Cancelled under Share buyback programme | - | - | - | |||
Closing balance | - | - | - | |||
In 2025 ING Group initiated three share buyback programmes and completed one from 2024:
§EUR 2,000 million, commencing on 31 October 2024 and completed by 30 April 2025. A total of 126 million
shares have been repurchased at an average effective price of EUR 15.89 per share. The shares have been
cancelled in July 2025;
§EUR 70 million, commencing on 3 March 2025 and completed by 4 March 2025. A total of 4 million shares have
been repurchased at an average price of EUR 17.44 per share and for a total consideration of EUR 64 million.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-264 |
The purpose of the share repurchase programme was to meet obligations under the share-based
compensation plans;
§EUR 2,000 million, commencing on 2 May 2025 and completed by 27 October 2025. A total of 101 million
shares have been repurchased at an average effective price of EUR 19.76 per share. The shares have been
cancelled in January 2026;
§EUR 1,100 million, commencing on 30 October 2025 and expected to be completed before 27 April 2026. As per
31 December 2025 a total of 18 million shares have been repurchased at an average price of EUR 22.62 per
share and for a total consideration of EUR 397 million. ING has the intention to cancel these shares in June
2026.
Retained earnings
Changes in retained earnings | |||
In EUR million | 2025 | 2024 | 2023 |
Opening balance | |||
Impact on opening balance1 | - | ||
Transfer to/from other reserves | |||
Result for the year | |||
Dividend and other distributions | - | - | - |
Employee share plans | - | - | |
Share buybacks and other changes | - | - | - |
Closing balance | |||
1In 2023, changes in policy following the adoption of IFRS 17 and change in policy for non-financial guarantees.
Dividend and other distributions
In 2025, a cash dividend of EUR 3,191 million (2024: EUR 3,626 million; 2023: EUR 2,668 million) and in January
2026 an additional cash distribution of EUR 500 million (2024: EUR 498 million; 2023: EUR 0 million) were paid to
the shareholders of ING Group. For further information, reference is made to Note 29 'Dividend per ordinary share'.
Share buybacks and other changes
Share buybacks and other changes includes an amount of EUR -1,458 million (2024: EUR -5,723 million; 2023: EUR
-3,217 million), which corresponds to the purchase and cancellation of treasury shares purchased under the share
buyback programmes.
Ordinary shares - Restrictions with respect to dividend and repayment of capital
The following equity components cannot be freely distributed: Revaluation reserves, Net defined benefit asset/
liability remeasurement reserve, Currency translation reserve, Share of associates and joint ventures reserve and
Other reserves including the reserve related to the former Stichting Regio Bank and the former Stichting
Vakbondsspaarbank SPN.
ING Groep N.V. is subject to legal restrictions regarding the amount of dividends it can pay to the holders of its
ordinary shares. Pursuant to the Dutch Civil Code, dividends can only be paid up to an amount equal to the excess
of the company’s own funds over the sum of the paid-up capital and reserves required by law.
Moreover, ING Groep N.V.’s ability to pay dividends is dependent on the dividend payment ability of its subsidiaries,
associates and joint ventures. ING Groep N.V. is legally required to create a non-distributable reserve insofar as
profits of its subsidiaries, associates and joint ventures are subject to dividend payment restrictions which apply to
those subsidiaries, associates and joint ventures themselves.
Non-distributable reserves, determined in accordance with the financial reporting requirements included in Part 9
of Book 2 of the Dutch Civil Code, from ING Group’s subsidiaries, associates and joint ventures are as follows:
Non-distributable reserves | |||
In EUR million | 2025 | 2024 | 2023 |
ING Bank | |||
Other | |||
Non-distributable reserves | |||
In addition to the legal and regulatory restrictions on distributing dividends from subsidiaries, associates and joint
ventures to ING Groep N.V. there are various other considerations and limitations that are taken into account in
determining the appropriate levels of equity in the Group’s subsidiaries, associates and joint ventures. These
considerations and limitations include, but are not restricted to, minimum capital requirements that are imposed
by industry regulators in the countries in which the subsidiaries, associates and joint ventures operate, or other
limitations which may exist in certain countries and may or may not be temporary in nature. It is not possible to
disclose a reliable quantification of these limitations. Without prejudice to the authority of the Executive Board to
allocate profits to reserves and to the fact that the ordinary shares are the most junior securities issued by ING
Groep N.V., no specific dividend payment restrictions with respect to ordinary shares exist.
Furthermore, ING Groep N.V. is subject to legal restrictions with respect to repayment of capital to holders of
ordinary shares. Pursuant to the Dutch Civil Code, capital may only be repaid if none of ING Groep N.V.’s creditors
opposes such a repayment within two months following the announcement of a resolution to that effect.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-265 |
Cumulative preference shares (not issued)
Pursuant to the Articles of Association of ING Groep N.V. the authorised cumulative preference share capital
consists of 4.6 billion cumulative preference shares, of which none have been issued. The par value of these
cumulative preference shares is EUR 0.01 . A right to acquire cumulative preference shares has been granted to
Stichting Continuïteit ING (ING Continuity Foundation).
The cumulative preference shares rank before the ordinary shares in entitlement to dividend and to distributions
upon liquidation of ING Groep N.V.
The dividend on the cumulative preference shares will be equal to a percentage, calculated on the amount
compulsorily paid up or yet to be paid up. This percentage shall be equal to the average of the euro short-term
rate (€STR) as calculated by the European Central Bank during the financial year for which the distribution is made;
this percentage being weighted on the basis of the number of days for which it applies, and increased by 2.585
percentage points.
If, and to the extent that, the profit available for distribution is not sufficient to pay the dividend referred to above
in full, the shortfall will be made up from the reserves insofar as possible. If, and to the extent that, the dividend
distribution cannot be made from the reserves, the profits earned in subsequent years shall first be used to make
up the shortfall before any distribution may be made on shares of any other category.
ING Groep N.V.’s Articles of Association make provision for the cancellation of cumulative preference shares. Upon
cancellation of cumulative preference shares and upon liquidation of ING Groep N.V., the amount paid up on the
cumulative preference shares will be repaid together with the accrued dividend as well as any dividend shortfall in
preceding years, insofar as this shortfall has not yet been made up. No specific dividend payment restrictions with
respect to the cumulative preference shares exist.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-266 |
Notes to the Consolidated statement of profit or loss
Net interest income | ||||||||
in EUR million | 2025 | 2024 | 2023 | 2025 | 2024 | 2023 | ||
Interest income on loans1 | Interest expense on deposits2 | |||||||
Interest income on debt securities at amortised cost | Interest expense on debt securities in issue | |||||||
Interest income on financial assets at fair value through OCI | Interest expense on subordinated loans | |||||||
Interest income on non-trading derivatives (hedge accounting) | Interest expense on non-trading derivatives (hedge accounting) | |||||||
Total interest income using effective interest rate method | Total interest expense using effective interest rate method | |||||||
Interest income on financial assets at fair value through profit or loss | Interest expense on financial liabilities at fair value through profit or loss | |||||||
Interest income on non-trading derivatives (no hedge accounting) | Interest expense on non-trading derivatives (no hedge accounting) | |||||||
Interest income other | Interest expense on lease liabilities | |||||||
Total other interest income | Interest expense other | |||||||
Total other interest expense | ||||||||
Total interest income | Total interest expense | |||||||
Net interest income | ||||||||
1Includes interest income on loans to customers and banks, cash balances as well as negative interest on liabilities. Negative interest on liabilities amounted to EUR 11 million (2024: EUR 7 million; 2023: EUR 19 million).
2Includes interest paid on deposits from customers and banks, and negative interest on assets. Negative interest on assets amounted to EUR 12 million (2024: EUR 1 million; 2023: nil ).
Net interest income was affected by reversing the hedge accounting impacts that are applied under EU ‘IAS 39
carve-out’ with an impact of EUR 276 million (2024: EUR 265 million; 2023: EUR 187 million). The net decrease,
without the IAS 39 carve out impact, is EUR 342 million.
For 2024 Interest expense on deposits includes interest paid under the TLTRO III programme of EUR 59 million
(2023: EUR 557 million). The funding under this programme was fully repaid during the first quarter of 2024.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-267 |
Net fee and commission income | |||
in EUR million | 2025 | 2024 | 2023 |
Fee and commission income | |||
Payment Services | |||
Securities business | |||
Insurance and other broking | |||
Portfolio management | |||
Lending business | |||
Financial guarantees and other commitments | |||
Other fee and commission income | |||
Total fee and commission income | |||
Fee and commission expenses | |||
Payment Services | |||
Securities business | |||
Distribution of products | |||
Other fee and commission expenses | |||
Total fee and commission expenses | |||
Net fee and commission income |
Payment services fees are earned for providing services for deposit accounts and cards, cash management and
transaction processing including interchange. Securities fees and commissions are fees for securities brokerage
and securities underwriting. Portfolio management fees include fees earned for asset management activities,
fiduciary and related activities in which ING holds or invests assets on behalf of its customers. Fees and
commissions from lending (syndication) business include income earned for lending advisory, origination,
underwriting and loan commitments which are not part of the effective interest rate. Financial guarantees and
other commitments fees and commissions are earned from bank guarantees, letters of credit and other trade
finance related products, factoring and leasing. Fees paid for distribution of products are all fees paid for the
distribution of ING’s products and services through external providers.
Reference is made to Note 30 'Segments', which includes net fee and commission income, as reported to the
Executive Board and the Management Board Banking, disaggregated by segment.
Valuation results and net trading income | |||
in EUR million | 2025 | 2024 | 2023 |
Securities trading results | |||
Derivatives trading results | - | ||
Other trading results | |||
Change in fair value of derivatives relating to | |||
– fair value hedges | |||
– cash flow hedges (ineffective portion) | |||
– other non-trading derivatives | - | ||
Change in fair value of assets and liabilities (hedged items) | - | - | - |
Valuation results on assets and liabilities designated at FVPL (excluding trading) | - | ||
Foreign exchange transactions results | - | ||
- | |||
In general, the fair value movements are influenced by changes in the market conditions, such as stock prices,
credit spreads, interest rates and currency exchange rates. In 2025, the interest rate volatility resulted in a
positive EU IAS39 carve out adjustment of EUR 2,367 million (2024: EUR -1,793 million; 2023: EUR -4,642 million).
Net trading income relates to trading assets and trading liabilities which include assets and liabilities that are
classified under IFRS as Trading but are closely related to servicing the needs of the clients of ING. ING offers
products that are traded on the financial markets to institutional clients, corporate clients, and governments. ING’s
trading books are managed based on internal limits and comprise a mix of products whose results may neutralise
one another. A significant part of the derivatives in the trading portfolio are related to servicing corporate clients in
their risk management to hedge for example currency or interest rate exposures. From a risk perspective, the
gross amount of trading assets must be considered together with the gross amount of trading liabilities, which are
presented separately on the statement of financial position. However, IFRS does not always allow the netting of
these positions in the statement of financial position. Reference is made to Note 4 'Financial assets at fair value
through profit or loss' and Note 14 'Financial liabilities at fair value through profit or loss' for information on trading
assets and trading liabilities respectively.
Securities trading results include the results of market making in instruments such as government securities,
equity securities, corporate debt securities, and money-market instruments. The majority of the risks involved in
security and currency trading are economically hedged with derivatives. The securities trading results are partly
offset by results on these derivatives. Derivatives trading results include the results of derivatives such as interest
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-268 |
rate swaps, options, futures, and forward contracts. Trading gains and losses relating to trading securities still held
as at 31 December 2025 amount to EUR 1,219 million (2024: EUR 20 million; 2023: EUR 160 million).
Other trading results include the results of trading loans and funds entrusted.
Foreign-exchange transactions results include gains and losses from spot, options, futures, and translated foreign
currency assets and liabilities. The result on currency trading is included in foreign exchange transactions results.
Valuation results and net trading income include the fair value movements on derivatives (used for both hedge
accounting and economically hedging exposures) as well as the changes in the fair value of assets and liabilities
included in hedging relationships as hedged items. In 2025, fluctuations in interest rate had a significant impact on
the fair value changes of both the derivatives and the hedged items designated in fair value hedges. Reference is
made to Note 36 'Derivatives and hedge accounting' for information on derivatives used for hedge accounting.
Furthermore, derivatives trading results are also impacted by fair value movements arising from changes in credit
spreads (CVA and DVA), bid offer spreads, model risk and incremental cost of funding on derivatives (FVA and
Investment income | |||
in EUR million | 2025 | 2024 | 2023 |
Dividend income | |||
Realised gains/losses on disposal of debt instruments measured at FVOCI | - | - | |
Other investment income | - | ||
Dividend income mainly consists of dividend received from ING’s equity stake in Bank of Beijing.
Other net income | |||
in EUR million | 2025 | 2024 | 2023 |
Net monetary loss reflecting IAS 29 hyperinflation impact | - | - | - |
Income related to a prior insolvency of a financial institution in the Netherlands | |||
Sale of the remaining NNHB mortgages | |||
Other | |||
- | - | ||
The net monetary loss, reflecting the IAS 29 hyperinflation impact, is fully related to the indexation of ING Türkiye's
statement of financial position and statement of profit or loss with an offsetting effect in the currency translation
reserve.
Staff expenses | |||
in EUR million | 2025 | 2024 | 2023 |
Salaries | |||
Pension costs and other staff-related benefit costs | |||
Social security costs | |||
Share-based compensation arrangements | |||
External employees | |||
Education | |||
Other staff costs | |||
Share-based compensation arrangements include EUR 52 million (2024: EUR 45 million; 2023: EUR 31 million)
relating to equity-settled share-based payment arrangements.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-269 |
Number of employees | |||||||||
Netherlands | Rest of the world | Total | |||||||
2025 | 2024 | 2023 | 2025 | 2024 | 2023 | 2025 | 2024 | 2023 | |
Total average number of internal employees at full time equivalent basis | |||||||||
Remuneration of senior management, Executive Board and Supervisory Board
Reference is made to Note 45 'Related parties'.
Share plans
ING grants various types of share awards, namely deferred and upfront shares, which form part of the variable
remuneration offering via the Long-term Sustainable Performance Plan (LSPP). The entitlement to the LSPP share
awards is granted conditionally. If the participant remains in employment for an uninterrupted period between the
grant date and the vesting date, the entitlement becomes unconditional, with the exception of the upfront shares
which are immediately vested upon grant. Upfront and deferred shares awarded to the Executive Board and
Management Board members of ING Group as well as identified staff, have a retention obligation that must be
adhered to upon vesting, typically a minimum retention of 12 months applies for staff and up to 60 months for
Board. ING has the authority to apply a holdback to awarded but unvested shares and a clawback to vested
shares.
The share awards granted in 2025 relate to the performance year 2024. In 2025, 48,224 share awards (2024:
awards (2024: 121,504 ; 2023: 172,103 ) were granted to the Management Board Banking. To senior management
and other employees 3,876,388 share awards (2024: 4,248,400 ; 2023: 3,244,951 ) were granted.
The shares granted under the Share Based Compensation Plans create obligations for ING Group that require
funding. Starting in 2023, shares are purchased from the market to fund the obligations arising out of the awards
granted under the share plans.
Changes in share awards | ||||||
Share awards (in numbers) | Weighted average grant date fair values (in euros) | |||||
2025 | 2024 | 2023 | 2025 | 2024 | 2023 | |
Opening balance as at 1 January | ||||||
Granted | ||||||
Vested | - | - | - | |||
Forfeited | - | - | - | |||
Closing balance | ||||||
As at 31 December 2025, there were 5,290,115 share awards outstanding (2024: 4,855,542 ; 2023: 3,897,800 ).
These all are related to equity-settled share-based payment arrangements, as cash-settled share-based payment
arrangements were terminated in 2023.
The fair value of share awards granted is recognised as an expense under Staff expenses and is allocated over the
vesting period of the share awards. The fair value calculation takes into account the current share prices, expected
volatilities and the dividend yield of ING shares.
As at 31 December 2025, total unrecognised compensation costs related to share awards amount to EUR 33
million (2024: EUR 25 million; 2023: EUR 15 million). These costs are expected to be recognised over a weighted
average period of 2.0 years (2024: 2.0 years; 2023: 2.0 years).
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-270 |
Other operating expenses | |||
in EUR million | 2025 | 2024 1 | 2023 1 |
Promotional and clients acquisition costs | |||
IT related expenses (excluding outsourcing and subcontracting) | |||
Outsourcing and subcontracting | |||
Facilities | |||
Market data services | |||
Advisory fees | |||
Audit and supervisory fees | |||
Indirect taxes | |||
Regulatory costs | |||
Depreciation and impairment of property and equipment 9 | |||
Amortisation and impairment of intangible assets 10 | |||
Additions and releases of provisions 15 | |||
Other | |||
1ING changed the presentation of Other operating expenses as of 2025. The comparative figures for 2024 and 2023 have been updated accordingly. The
reclassifications do not affect the total amount of Other operating expenses.
Reference is made to Note 9 'Property and equipment' for (reversals of) impairments of property and equipment
and Note 10 'Intangible assets' for (reversals of) impairments of intangible assets.
For more information on addition to (unused amounts reversed of) provision for reorganisations refer to Note 15
'Provisions' and for more information on addition to (unused amounts reversed of) other provisions refer to Note
15 'Provisions' and Note 42 'Legal proceedings'.
Regulatory costs
Regulatory costs represent contributions to the Deposit Guarantee Schemes (DGS), the Single Resolution Fund
(SRF), local bank taxes and local resolution funds. Included in Regulatory costs for 2025, are contributions to DGS of
EUR 167 million (2024: EUR 230 million; 2023: EUR 320 million) mainly related to Belgium, Poland, Germany and
the Netherlands and contributions to the SRF and local resolution funds of EUR 41 million (2024: EUR 35 million;
2023: EUR 251 million). In 2025 local bank taxes increased by EUR 41 million from EUR 617 million in 2024 to EUR
Total audit and non-audit services include the following fees for services provided by the Group’s auditor.
Fees of Group’s auditor | |||
in EUR million | 2025 | 2024 | 2023 |
Audit fees | |||
Audit related fees | |||
Total1 | |||
1The Group’s auditor did not provide any non-audit services.
Fees as disclosed in the table above relate to the network of the Group’s auditors and are the total fees charged for
the period excluding VAT.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-271 |
Earnings per ordinary share | |||||||||
Weighted average number | |||||||||
of ordinary shares outstanding | |||||||||
Amount | during the period | Per ordinary share | |||||||
(in EUR million) | (in millions) | (in EUR) | |||||||
2025 | 2024 | 2023 | 2025 | 2024 | 2023 | 2025 | 2024 | 2023 | |
Basic earnings | |||||||||
Basic earnings from continuing operations | |||||||||
Effect of dilutive instruments: | |||||||||
Share plans | |||||||||
Diluted earnings | |||||||||
Diluted earnings from continuing operations | |||||||||
Earnings per ordinary share is calculated on the basis of the weighted average number of ordinary shares
outstanding. In calculating the weighted average number of ordinary shares outstanding, own shares held by group
companies (including share buyback programmes) are deducted from the total number of ordinary shares in issue.
Dilutive instruments
Diluted earnings per share is calculated as if the share plans outstanding at the end of the period had been
exercised at the beginning of the period and assuming that the cash received from dilutive instruments (if any) is
used to buy own shares against the average market price during the period. The net increase in the number of
shares resulting from exercising share plans is added to the average number of shares used for the calculation of
diluted earnings per share.
Dividends to shareholders of the parent | ||
Per ordinary share (in EUR) | Total (in EUR million) | |
Dividends on ordinary shares: | ||
In respect of 2023 | ||
- Interim dividend, paid August 2023 | ||
- Final dividend, paid May 2024 | ||
Total dividend in respect of 2023 | ||
In respect of 2024 | ||
- Interim dividend, paid August 2024 | ||
- Final dividend, paid May 2025 | ||
Total dividend in respect of 2024 | ||
In respect of 2025 | ||
- Interim dividend, paid August 2025 | ||
- Final dividend declared | ||
Total dividend for the period ending 31 December 2025 | ||
On 22 April 2025, the Annual General Meeting of shareholders ratified the total dividend of EUR 1.06 per ordinary
share of which EUR 0.35 per share was paid as an interim cash dividend during August 2024. The final dividend of
EUR 0.71 per ordinary share was paid entirely in cash on 2 May 2025.
In October 2025 an additional cash distribution of EUR 0.172 per share was declared to shareholders of ING Group
and EUR 500 million was paid in January 2026 (2024: EUR 498 million, EUR 0.161 per share 2023: nil ).
The Board has proposed to pay a final cash dividend over 2025 of EUR 0.736 per share. This is subject to approval
by shareholders at the Annual General Meeting in April 2026.
ING Groep N.V. is required to withhold tax of 15 % on dividends paid. Reference is made to Note 19 'Equity' for more
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-272 |
Segment reporting
ING Group’s segments are based on the internal reporting structure by lines of business.
The Executive Board of ING Group and the Management Board Banking (together the Chief Operating Decision
Maker or CODM) set the performance targets, and approve and monitor the budgets prepared by the business
lines. Business lines formulate strategic, commercial, and financial plans in conformity with the strategy and
performance targets set by the CODM.
'Basis of preparation and material accounting policy information'. The results for the period for each reportable
segment are after intercompany and intersegment eliminations and are those reviewed by the CODM to assess
performance of the segments. Corporate expenses are allocated to business lines based on time spent by head
office personnel, the relative number of staff, or on the basis of income, expenses and/or assets of the segment.
Interest income per segment is reported as net interest income because management relies primarily on net
segments:
Specification of the main sources of income of each of the segments by line of business | |
Segments by line of business | Main source of income |
Retail Netherlands | Income from products and services provided to private individuals, business banking clients and private banking clients in the Netherlands. The main products and services offered are daily banking, lending, savings, investments and insurance. |
Retail Belgium | Income from products and services provided to private individuals, business banking clients and private banking clients in Belgium and Luxembourg. The main products and services offered are similar to those in the Netherlands. |
Retail Germany | Income from products and services provided to private individuals, business banking clients and private banking clients in Germany. The main products and services offered are similar to those in the Netherlands. |
Retail Other | Income from products and services provided to private individuals, business banking clients and private banking clients in the other retail countries. The main products and services offered are similar to those in the Netherlands. |
Wholesale Banking | Income from wholesale banking activities, of which the main products are lending, payments & cash management, working capital solutions, trade finance, financial markets, corporate finance and treasury. |
Specification of geographical split of the segments | |
Geographical split of the segments | Main countries |
The Netherlands | |
Belgium | Including Luxembourg |
Germany | |
Other Challengers | Australia, Italy, Spain and Portugal |
Growth Markets | Poland, Romania and Türkiye |
Wholesale Banking Rest of World | Other countries in Europe & Middle East, Americas, Asia |
Other | Corporate Line |
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-273 |
ING Group monitors and evaluates the performance of ING Group at a consolidated level and by segment. The
Executive Board and the Management Board Banking consider this to be relevant to an understanding of the
Group’s financial performance, because it allows investors to understand the primary method used by
management to evaluate the Group’s operating performance and make decisions about allocating resources.
In addition, ING Group believes that the presentation of results in accordance with IFRS-EU helps investors compare
its segment performance on a meaningful basis by highlighting result before tax attributable to ongoing
operations and the profitability of the segment businesses. IFRS-EU result is derived by including the impact of the
IFRS-EU ‘IAS 39 carve out’ adjustment.
The IFRS-EU ‘IAS 39 carve-out’ adjustment relates to fair value portfolio hedge accounting strategies for the
mortgage and savings portfolios in the Benelux, Germany, France, Spain, Italy and Romania that are not eligible
under IFRS-IASB. As no hedge accounting is applied to these mortgage and savings portfolios under IFRS-IASB, the
fair value changes of the derivatives are not offset by fair value changes of the hedge items (mortgages and
savings).
The segment reporting in the annual report on Form 20-F has been prepared in accordance with International
Financial Reporting Standards as issued by the EU (IFRS-EU) and reconciled to International Financial Reporting
Standards as issued by the International Accounting Standards Board (IFRS-IASB) for consistency with the other
financial information contained in this report. The difference between the accounting standards is reflected in the
Wholesale Banking segment, and in the geographical split of the segments in the Netherlands, Belgium, Germany,
Other Challengers, Growth Markets and Wholesale Banking Rest of World.
Reference is made to Note 1 'Basis of preparation and material accounting policy information' for a reconciliation
between IFRS-EU and IFRS-IASB. Corporate expenses are allocated to business lines based on time spent by head
office personnel, the relative number of staff, or on the basis of income, expenses and/or assets of the segment.
ING Group reconciles the total segment results to the total result using Corporate Line. The Corporate Line includes
capital management activities, as ING Group applies a system of capital charging for its banking operations in
order to create a comparable basis for the results of business units globally, irrespective of the business units’ book
equity and the currency they operate in.
Corporate Line also includes certain other income and expenses that are not allocated to the banking businesses,
such as our investments in Bank of Beijing and TMBThanachart Bank (Asian stakes) as well as our stake in Van
Lanschot Kempen (which in 2025 was increased to 20.3 %). Furthermore, as from 2022, results in the Corporate
Line have been impacted by the application of hyperinflation accounting in the consolidation of our subsidiary in
Türkiye (IAS 29).
Total income within the Corporate Line increased 28 % to EUR 484 million, up from EUR 378 million in the previous
year. This growth was driven by higher income from foreign currency ratio hedging (up EUR 70 million year-on-
year), increased results from our financial stakes (EUR 49 million, including a favourable revaluation of the
derivative related to the forward purchase of a stake in Van Lanschot Kempen), and a diminished impact from IAS
29 (reflecting lower inflation in Türkiye). In both years, results also included a receivable related to the prior
insolvency of a financial institution in the Netherlands: EUR 16 million in 2025 and EUR 53 million in 2024.
Operating expenses for the Corporate Line decreased to EUR 512 million, compared with EUR 533 million in 2024.
The 2025 figure comprised a hyperinflation impact of EUR 12 million and EUR 73 million in restructuring costs. In
2024, expenses included a EUR 35 million hyperinflation impact, EUR 25 million in restructuring costs, a EUR 22
million one-off CLA-related payment to staff in the Netherlands, and a EUR 21 million litigation provision. Expenses
excluding the aforementioned items declined year-on-year due to a higher VAT refund.
The information presented in this note is in line with the information presented to the Executive Board of ING
Group and Management Board Banking.
This note does not provide information on the types of products and services from which each reportable segment
derives its revenues, as this is not reported internally.
ING Group Annual Report on Form 20-F | Contents | Part I | Part II | Part III | Additional information | Financial statements | F-274 |
Reconciliation between IFRS-IASB and IFRS-EU income, expense and net result | |||||||||||||||
12 month period | 2025 | 2024 | 2023 | ||||||||||||
in EUR million | Income | Expenses | Taxation | Non-controlling interests | Net result 1 | Income | Expenses | Taxation | Non-controlling interests | Net result1 | Income | Expenses |
|||
FAQ
What does ING (ING) describe in its 2025 Form 20-F?
ING’s 2025 Form 20-F outlines its global banking operations, risk profile and accounting frameworks. It details business lines, geographic reach, extensive risk factors, regulatory environment, and explains its dual reporting under IFRS-IASB for SEC purposes and IFRS‑EU for statutory accounts.
How many ING (ING) ordinary shares were outstanding at year-end 2025?
ING reports 2,902,437,688 ordinary shares outstanding, each with a nominal value of EUR 0.01. This figure reflects the company’s equity base at the close of the fiscal year and is relevant for ownership, earnings-per-share calculations and potential dilution considerations.
Which accounting standards does ING (ING) use in its 20-F financials?
ING prepares financial information for SEC reporting under IFRS-IASB, while its published financial statements follow IFRS‑EU. The report explains differences driven mainly by the EU IAS 39 hedge accounting carve‑out and provides reconciliations for shareholders’ equity and net result between the two bases.
What key macro and market risks does ING (ING) highlight?
ING cites risks from global economic volatility, inflation or deflation, interest-rate changes, market contagion and political instability. It notes potential impacts on loan quality, capital markets exposure, liquidity, funding costs, and earnings, particularly in its core Benelux and German markets and wider international portfolio.
How is ING (ING) affected by Russia and Ukraine exposures?
ING has wholesale banking activities in Russia and Ukraine and investments in Russia, some in local currency. It states that sanctions and related measures have significantly affected its Russian activities and global markets, and notes an intention to sell its Russian business, subject to approvals and uncertain timing.
What ESG and climate-related risks does ING (ING) discuss?
ING details transition and physical climate risks, evolving ESG regulation, and stakeholder expectations on sustainability and diversity. It highlights potential impacts on portfolios, collateral values, reputation, litigation exposure, and operational costs as it builds data, models and governance to meet emerging disclosure and risk-management requirements.
What technology and cybersecurity risks does ING (ING) emphasize?
ING warns of operational and IT risks from system failures, cyber-attacks, data breaches and increased digitalisation, including AI-related vulnerabilities. It notes rising regulatory requirements such as GDPR, PSD2, DORA and the EU AI Act, where non-compliance or successful attacks could harm operations, finances and reputation.
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Jun 4, 2025
Cambrian and ING Announce $150 Million Facility
ING Latest SEC Filings
Feb 27, 2026
[6-K] ING GROEP NV Current Report (Foreign Issuer)
Feb 26, 2026
[6-K] ING GROEP NV Current Report (Foreign Issuer)
Feb 26, 2026
[6-K] ING GROEP NV Current Report (Foreign Issuer)
Feb 26, 2026
[IRANNOTICE] ING GROEP NV SEC Filing
Feb 24, 2026
[6-K] ING GROEP NV Current Report (Foreign Issuer)