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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 ING Bank 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 also includes additional disclosures beyond those required by IFRS
standards, 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 to the accounting basis of measurement. Examples of such differences include
the exclusion of accrued interest and certain costs and fees from risk data, and timing differences in
exposure values (IFRS 9 models report expected credit loss on underlying exposures). Disclosures in
accordance with Part Eight of the CRR2 and CRD V, and as required by the supervisory authority, are
published in our \u2018Additional Pillar III Report\u2019, which can be found on our corporate website ing.com.
Risk governance (*)
Effective risk management requires company-wide risk governance. ING\u2019s risk and control structure is based
on the \u2018three lines of defence\u2019 governance model. 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 MBB, the EB and the SB, and this approach is cascaded throughout ING.
The heads of ING\u2019s banking business and support functions and the heads of the country units, or their
delegates, are the first line of defence. They have primary ownership, and accountability and responsibility
for assessing, controlling and mitigating all financial and non-financial risks affecting their businesses, as
well as for the completeness and accuracy of the financial statements and risk reports with respect to their
areas of responsibility. The CTO is responsible and accountable for proper security and controls of global
applications and IT platforms servicing the bank and implementing proper processes. The COO domain
builds bridges within ING linking to almost every part of the bank. Its purpose is to drive secure and efficient
processes for customers and colleagues.
The second line of defence consists of oversight and specialised functions in risk management and
compliance. They (1) have co-responsibility for risk management, through articulating and translating the
risk appetite into methodologies and policies to support and monitor business management's control of risk,
(2) objectively challenge risk management execution and control processes and coordinate the reporting of
risks and controls by the first line of defence, (3) advise on risk management and compliance and have
decision-making power in relation to business activities that are judged to present unacceptable risks to ING
and (4) can set minimum requirements in terms of quality and quantity of global resourcing in the risk
management and compliance functions.
The internal audit function forms the third line of defence. It provides independent assurance to the Audit
Committee, the EB and the MBB on the quality and effectiveness of ING\u2019s internal control, risk management,
governance and implemented systems and processes in both the first and second lines of defence. To
protect its independent nature, decisions regarding the appointment, reappointment or dismissal from
office as well as the remuneration package of the head of the internal audit function require SB approval.
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.
\u2022The SB is, for risk management purposes, advised mainly by the Risk Committee, which assists and
advises in monitoring the risk profile and approving the overarching risk appetite of the company as well
as the structure and effective operation of the internal risk management and control systems.
\u2022The EB is responsible for managing risks associated with all activities of ING Group, whereas the MBB is
responsible for managing risks associated with all activities of ING Bank. The EB and MBB responsibilities
include ensuring that internal risk management and control systems are effective and that ING Group
and ING Bank comply with relevant legislation and regulations. On a regular basis, the EB and MBB report
on these issues and discuss the internal risk management and control systems with the SB. On a
quarterly basis, the EB and MBB report on ING\u2019s risk profile versus its risk appetite to the Risk Committee,
explaining changes in the risk profile.
As a member of the EB and the MBB, the CRO is primarily responsible for: (i) supporting the board in its
engagement with and oversight of the development of the risk appetite and risk appetite statements and
for translating the risk appetite into a risk limits structure, actively engaged in monitoring performance
relative to risk-taking and risk limit adherence; (ii) setting up the risk management framework and
overseeing the development and implementation of risk and compliance policies, processes, models,
compatible methodologies including both forward-looking and backward-looking tools, ongoing
strengthening of risk management/people capabilities and reports, as necessary to ensure the effectiveness
of robust internal control and risk systems to fully support its strategic objectives and all of its risk-taking
activities; (iii) regularly providing comprehensive information on risks to the Management Board, the Risk
Committee and other relevant functions; and (iv) advising about the current risk profile, current state of the
risk culture, utilisation against the established risk appetite, and limits, limit breaches and mitigation plans.
For more on the SB and EB roles and responsibilities see \u2018Corporate Governance\u2019.
Executive level (*)
The risk committees described below act within the overall risk policy and delegated authorities granted by
the MBB:
\u2022Global Credit and Trading Policy Committee (GCTP) discusses and approves policies, methodologies, and
procedures related to credit, trading, country, and reputation (i.e. environmental and social risk or ESR)
risks. The GCTP meets monthly. After the MBB and the GCTP, the Credit and Trading Risk Committee
(CTRC) is the highest-level body authorised to discuss and approve policies, methodologies, and
procedures related to credit and trading risk.
\u2022Global Credit Committee \u2013 Transaction Approval (GCC(TA)) discusses and approves transactions that
entail taking credit risk (including investment risk), country, legal, and environmental and social risk. The
GCC(TA) meets twice a week.
\u2022Non-Financial Risk Committee Bank (NFRC Bank) 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, measurement, mitigating and monitoring/
reporting. NFRC Bank meetings are held at least quarterly.
\u2022The Model Risk Management Committee (MoRMC) discusses and steers, on a monthly basis, the overall
model strategy. MoRMC discusses and approves policies and methodologies related to model risk
management.
\u2022Global Data Committee (GDC) oversees (identifies, measures, responds to change and monitors) the
Global\u00a0 Data function and its contribution to wider society. The GDC meets every two months.
Further, in the Asset and Liability Committee Bank (ALCO Bank) risk related topics are discussed as well.
Regional and business unit level (*)
ING\u2019s 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.
The regional and/or business unit (BU) head of risk are involved in these activities. The local (regional and BU)
head of risk is responsible for the analysis, monitoring and management of risks across the whole value
chain (from front to back office). The local risks are discussed in local risk committees that roll up to the key
risk committees at executive level. Local Client Integrity Risk Committees (CIRCs) assess client integrity risk
and they have a final decision on client acceptance or client off-boarding, from a risk-based perspective, in
the areas of financial crime, Foreign Account Tax Compliance Act (FATCA), Common Reporting Standard
(CRS) and ESR.
Organisational structure (*)
The Risk CRO function is organised along the lines of a matrix structure integrating (1) the Global Risk
functions, (2) the Regional/Country Risk functions at entity level, and (3) the Risk Segments, with a uniform
methodology and terminology, so that a holistic view of all risks is ensured. 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, ensuring a uniform taxonomy and methodology is 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 following organisation chart illustrates the reporting lines in 2022 for the risk management
organisation. The fixed lines reflect hierarchical reporting lines, whereas the dotted lines are for the
functional reporting lines:
Risk policies, procedures and standards (*)
ING has a framework of risk management policies, procedures, and minimum standards in place to create
consistency throughout the organisation, and to define requirements that are binding for all business units.
The goal of the governance framework of the local business units is to align with ING\u2019s framework and to
meet local (regulatory) requirements. Senior management is responsible for the implementation of and
adherence to policies, procedures and standards. Policies, procedures and standards are regularly reviewed
and updated via the relevant risk committees to reflect changes in requirements, markets, products and
practices.
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.
Governance (*)
ING\u2019s credit risk strategy is to maintain an internationally diversified loan and bond portfolio, while avoiding
large risk concentrations. The emphasis is on managing business developments within the business lines by
means of a top-down risk appetite framework (RAF), which sets concentration limits for countries, individual
clients, sectors, products, secondary risk (collateral/guarantees) and investment activities. The aim is to
support relationship banking activities, while maintaining internal risk/reward guidelines and controls.
A new Credit Risk department was established in 2022. This department is responsible for setting the credit
risk strategy for ING and aims to ensure credit risk and credit restructuring are managed from an
overarching point of view rather than per business line. The head of Credit Risk is supported by the following
teams within this new department:
\u2022Portfolio, Strategy & Governance team: responsible for setting up credit risk strategies and risk appetite
statements, performing analysis and monitoring of the credit risk position of ING, as well as setting and
maintaining the credit risk framework and policies.
\u2022Credit Risk Control Unit: responsible for the design or selection, implementation, oversight and
performance of the rating systems.
\u2022Global Credit Risk Restructuring: responsible for a safe, compliant and data driven credit loss process by
managing loan loss provisioning and finding solutions for business customers in financial difficulty. The
team focuses on management of the global loan loss provisioning, not only of individual WB provisions,
but also collective WB and Retail Banking provisions.
While the Credit Risk department has oversight of the Bank credit risk strategy and risk appetite across
Retail Banking risk and Wholesale Banking risk, the head of Retail/Rest of World (RoW) Risk and head of
Wholesale Banking Risk aim to ensure the management of the risk within these business lines. Also refer to
the Risk governance and organisational structure in the introductory section of the Risk management
chapter.
The credit risk function encompasses the following activities:
\u2022Measuring, monitoring and managing credit risks in the bank\u2019s portfolio, including the measures taken in
response to the war in Ukraine.
\u2022Challenging and approving new and modified transactions and borrower reviews.
\u2022Managing the levels of provisioning and risk costs, and advising on impairments.
\u2022Providing consistent credit risk policies, systems and tools to manage the credit lifecycle of all activities.
Credit risk categories (*)
In the following table the different types of credit risk categories are described and a reconciliation with the
notes in the financial statements is also included:
Reconciliation between credit risk categories and financial position (*)
Credit risk categories
Notes in the financial statements
Lending risk: is 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.
Note
2
Cash and balances with central banks
Note
3
Loans and advances to banks
Note
4
Financial assets at fair value through profit
or loss
Note
5
Financial assets at fair value through other
comprehensive income
Note
7
Loans and advances to customers
Note
41
Contingent liabilities and commitments
Investment risk: is the credit default and risk rating migration risk
that is associated with ING\u2019s 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.
Note
4
Financial assets at fair value through profit
or loss
Note
5
Financial assets at fair value through other
comprehensive income
Note
6
Securities at amortised cost
Money market risk: arises when ING places short-term deposits
with a counterparty in to manage excess liquidity. In the event of
a counterparty default, ING may lose the deposit placed.
Note
2
Cash and balances with central banks
Note
3
Loans and advances to banks
Note
7
Loans and advances to customers
Pre-settlement risk: 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).
Note
4
Financial assets at fair value through profit
or loss
Note
14
Financial liabilities at fair value through
profit or loss
Note
40
Offsetting financial assets and liabilities
Settlement risk: 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.
Note
4
Financial assets at fair value through profit
or loss
Note
11
Other assets
Note
14
Financial liabilities at fair value through
profit or loss
Note
16
Other liabilities
1 Based on credit risk measurement contained in lending, pre-settlement, money market and investment activities.
2 Based on the total amount of credit risk in the respective column using ING\u2019s internal credit risk measurement methodologies. Economic sectors (industry) below 2% are not shown separately but grouped in Other.
3 Geographical areas are based on country of residence, except for private individuals for which the geographical areas are based on the primary country of risk.
Overall portfolio (*)
During 2022, ING\u2019s portfolio size increased by \u20ac24.0 billion (+2.62%) to \u20ac937.7 billion outstandings. The net
volume growth was spread across all the business lines. Foreign exchange rate changes had a positive
impact on portfolio growth, mainly in WB, and increased total outstanding by \u20ac6.3 billion, driven by the
appreciation of the US dollar (+6.2%) against the euro, partially compensated by the British pound sterling
(-5.3%), the Polish new zloty (-1.8%), and new Turkish lira (-23.7%).
Rating distribution (*)
Overall, the rating class distribution remained stable in 2022. The share of investment grade rating classes
increased from 75.1% to 76.2%, while the share of non-investment grade decreased, from 23.2% to 21.7%.
Sub-standard grade outstandings increased from 0.4% to 0.8% of the total portfolio, whereas non-
performing loans decreased from 1.3% to 1.2%.
With respect to the rating distribution within the business lines, in WB, investment grade increased to 81.2%
(from 79.7%), where non-investment grade exposures decreased to 16.8% (from 19.1%) compared to 2021.
Substandard grade assets increased from 0.2% to 1.0% of total Wholesale Banking assets, primarily as a
result of increases in Russia, in the natural resources industry. The share of non-performing loans for WB
remained stable at 1.0% (from 0.9%).
The rating distribution for Retail Benelux improved mostly because of Dutch residential mortgages, shifting
from rating class BB/BBB to A. The share of A-rated mortgages increased from 9.3% to 24.0% of the
portfolio. In Belgium, residential mortgages showed a modest increase of BBB assets, from single A.
Substandard grade Belgium mortgage outstandings increased to 1.0% (from 0.8%).
In Retail Challengers & Growth Markets, the distribution across rating classes remained rather stable in 2022.
Overall share of investment grade decreased from 76.1% to 75.2%, NPL decreased to 1.0% (from 1.3%).
Industry (*)
In line with our objective to give stakeholders insight into the portfolio, we present the business lending
portfolio per industry breakdown in accordance with the NAICS definition. The industry composition within
Retail is concentrated in private individuals with 65.0% for Retail Benelux and 76.0% for Retail Challengers &
Growth Markets.
In Market Leaders, the overall volumes increase is mainly explained by Belgium (+4.7%), whereas the
Netherlands remained stable in 2022 (+1.1%). In C&G, the increase in volume is in private individuals,
primarily in Germany, and to a lesser extent in Australia and Spain. A decrease in France is explained by the
discontinuation of retail activities. Within WB, an increase in exposures is noted mainly in non-bank financial
institutions (NBFI) of \u20ac7.7 billion (notably in Germany, France and the US). Apart from NBFI, an increase is
observed in other industries (+\u20ac6.1 billion), compensated by a decrease in natural resources (\u20ac7.2 billion).
Outstandings by economic sectors and geographical area (*) 1
in \u20ac million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United
Kingdom
Luxembourg
France
Rest of
Europe
America
Asia
Australia
Africa
2022
Private Individuals
114,625
44,193
101,529
13,767
24,865
138
3,486
2,731
13,654
161
131
35,528
24
354,831
Central Banks
35,202
14,338
21,041
1,060
347
427
6,820
35
18,092
0
4,962
2,695
24
105,043
Natural Resources
3,084
1,356
809
746
169
4,442
2,764
470
12,154
8,771
10,398
1,028
361
46,549
Real Estate
17,586
10,112
1,388
2,374
1,391
413
3,797
3,155
3,378
3,474
1,180
4,263
2
52,513
Commercial Banks
1,359
265
3,974
551
402
4,933
4,480
4,371
6,368
9,945
12,041
1,765
409
50,863
Non-Bank Financial Institutions
2,710
1,041
5,054
2,299
99
8,229
4,489
3,220
4,495
19,636
4,091
896
0
56,258
Central Governments
3,342
7,716
1,179
6,578
4,578
46
175
1,797
8,444
13,979
333
636
551
49,356
Transportation & Logistics
3,967
2,183
608
1,300
690
1,787
583
733
7,808
3,378
6,806
531
608
30,982
Utilities
1,551
1,630
2,814
679
1,227
2,953
572
980
4,302
4,347
1,545
1,897
200
24,698
Food, Beverages & Personal Care
7,249
3,002
573
2,334
475
739
1,667
469
2,668
3,245
942
248
13
23,623
Services
4,819
8,816
1,254
1,101
67
685
808
1,066
1,120
1,821
357
632
0
22,546
General Industries
5,430
2,689
1,007
2,849
311
330
604
245
3,152
2,926
1,311
9
0
20,865
Lower Public Administration
272
5,638
5,197
644
200
0
313
3,126
402
1,310
0
4,564
0
21,666
Other
17,353
13,602
6,302
6,946
1,416
3,058
1,164
1,179
10,952
9,457
4,891
1,424
188
77,932
Total
218,548
116,580
152,730
43,229
36,237
28,179
31,720
23,576
96,989
82,450
48,989
56,116
2,381
937,725
Rating class
Investment grade
174,972
76,244
130,285
27,501
28,556
23,160
26,053
17,545
64,884
63,870
39,903
41,476
213
714,662
Non-Investment grade
40,325
36,036
20,967
14,596
7,330
4,634
5,442
5,814
27,617
17,615
7,638
13,914
1,858
203,786
Sub-standard grade
1,508
984
579
422
105
41
80
16
2,903
311
124
257
239
7,569
Non-performing loans
1,743
3,316
899
710
246
344
145
201
1,584
654
1,325
470
72
11,708
Total
218,548
116,580
152,730
43,229
36,237
28,179
31,720
23,576
96,989
82,450
48,989
56,116
2,381
937,725
1\u00a0 Geographical areas are based on country of residence, except for private individuals for which the geographical areas are based on the primary country of risk.
Outstandings by economic sectors and geographical area (*) 1
in \u20ac million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United
Kingdom
Luxembourg
France
Rest of
Europe
America
Asia
Australia
Africa
2021
Private Individuals
113,846
42,961
95,583
14,397
23,895
157
3,388
3,115
13,215
167
155
35,058
27
345,965
Central Banks
46,902
18,253
17,811
112
3,027
2,853
8,569
1,039
4,485
0
2,856
1,168
18
107,094
Natural Resources
3,734
1,180
1,208
722
291
4,487
2,497
405
15,471
9,473
12,593
1,013
780
53,855
Real Estate
17,426
10,011
1,520
2,357
1,528
436
4,201
3,254
3,461
3,521
935
4,045
4
52,699
Commercial Banks
1,378
318
3,887
707
392
4,156
3,205
5,520
6,353
7,089
13,526
2,265
413
49,208
Non-Bank Financial Institutions
3,043
921
3,146
1,718
72
7,764
4,798
1,790
3,947
17,772
3,209
411
0
48,590
Central Governments
4,911
7,396
1,179
7,473
4,417
67
203
2,065
7,695
10,927
299
533
477
47,642
Transportation & Logistics
4,572
2,209
506
1,177
723
1,760
582
982
6,837
3,410
5,682
645
514
29,597
Utilities
1,545
1,213
3,024
822
1,270
2,980
397
1,433
4,202
4,106
1,355
1,368
220
23,935
Food, Beverages & Personal Care
6,581
2,869
616
2,146
489
711
1,600
1,232
2,580
3,131
1,140
235
12
23,340
Services
4,615
9,115
1,105
866
119
523
450
1,470
861
1,539
479
565
36
21,743
General Industries
5,389
2,891
1,011
2,612
381
395
532
271
3,363
2,116
1,151
15
0
20,127
Lower Public Administration
343
5,158
5,787
636
0
0
296
2,732
467
1,197
46
2,608
0
19,271
Other
15,485
13,424
5,573
6,319
940
2,277
1,168
1,210
9,297
8,803
4,732
1,454
0
70,682
Total
229,771
117,919
141,956
42,063
37,542
28,567
31,887
26,517
82,233
73,251
48,159
51,382
2,501
913,749
Rating class
Investment grade
180,787
78,195
119,311
26,856
29,522
22,820
26,150
20,622
52,875
53,725
36,777
38,200
79
685,920
Non-Investment grade
45,530
35,600
21,250
14,148
7,647
5,234
5,568
5,774
27,993
18,184
10,534
11,998
2,259
211,721
Sub-standard grade
1,230
868
390
290
89
56
81
2
308
203
191
217
58
3,985
Non-performing loans
2,224
3,256
1,006
768
284
458
87
119
1,056
1,139
656
966
105
12,124
Total
229,771
117,919
141,956
42,063
37,542
28,567
31,887
26,517
82,233
73,251
48,159
51,382
2,501
913,749
Risk management at ING Bank'. Apart from Russia, noticeable
moves occurred in France, where NPL increased from 0.4% to 0.9% impacted by the decommissioning of
the Retail business in France. And in the UK, where NPL decreased from 1.6% to 1.2%.
The increase in exposure in the Americas region was mainly driven by FX impact. In terms of rating
distribution for America region, an increase in investment grade is observed to 77.6% (from 73.0%), non-
investment grade decreased to 21.3% from 25.1%. Sub-standard grade increased to 0.4%, while NPL
improved to 0.8% (from 1.5%). Australia\u2019s rating distribution improved with a decrease of NPL\u2019s from 1.9% to
0.8% of the portfolio.
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 \u2018cover\u2019. While a cover may be an important mitigant of credit risk and an
alternative source of repayment, generally it is ING\u2019s practice to lend on the basis of the customer\u2019s
creditworthiness rather than exclusively 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
on 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 to ensure 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\u2019s 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 increased the haircuts applied to collateral values used in stage 3 individual provisions as at
31 December 2021 and 31 December 2022 to reflect the increased risk of inflated asset prices in certain
sectors of the economy. The haircut is applied on real estate, shipping and aviation collateral values 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, financial collateral (cash
and securities) and guarantees. ING obtains cover that is eligible for credit risk mitigation under CRR/CRDIV,
as well as cover that is not eligible. Collateral covering financial market transactions is valued on a daily
basis, and 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 performing and non-performing
portfolio. Our definition of non-performing is explained in detail in \u2018Credit restructuring\u2019 (below). For
additional insight, a breakdown of ING\u2019s portfolio by industry and geography is provided.
The next table gives an overview of the collateralisation of the ING\u2019s total portfolio.
Cover values including guarantees received (*)
in \u20ac million
Cover type
Collateralisation
2022
Outstandings
Mortgages
Financial
Collateral
Guarantees
Other covers
No Cover
Partially
covered
Fully covered
Consumer lending
353,323
700,961
5,626
24,231
42,817
6.2%
7.6%
86.2%
Business lending
379,070
167,122
29,501
118,294
438,864
37.5%
22.3%
40.2%
Investment and money market
141,432
0
5
1,213
2
99.1%
0.6%
0.3%
Total lending, investment and money market
873,824
868,083
35,132
143,738
481,683
34.8%
12.9%
52.3%
Pre-settlement
63,901
Total Bank
937,725
Cover values including guarantees received (*)
in \u20ac million
Cover type
Collateralisation
2021
Outstandings
Mortgages
Financial
Collateral
Guarantees
Other covers
No Cover
Partially
covered
Fully covered
Consumer lending
344,188
690,752
6,533
25,688
40,618
6.3%
7.6%
86.1%
Business lending
413,670
160,694
23,454
112,095
332,989
44.2%
20.2%
35.5%
Investment and money market
112,360
43
63
1,100
167
98.9%
0.8%
0.3%
Total lending, investment and money market
870,218
851,490
30,050
138,882
373,774
36.0%
12.8%
51.2%
Pre-settlement
43,531
Total Bank
913,749
Excluding the pre-settlement portfolio, 52.3% (2021: 51.2%) of ING\u2019s outstandings were fully collateralised in
2022. Since investments traditionally do not require covers, the percentage for \u2018no covers\u2019 in this portfolio is
above 95%. However, 99% of the investment outstanding is investment grade. Improved economic
conditions in ING\u2019s main markets contributed to improved collateral valuations, observed in consumer
lending. Relative to the overall developments in the housing markets and the impact on provisioning, note
the paragraphs on \u2018management adjustments\u2019 in the Loan Loss provisioning section, that were made to
reflect potential impact of higher inflation, higher rates and market uncertainty.
Consumer lending portfolio (*)
The consumer lending portfolio accounts for 37.7% (2021: 37.7%) of ING\u2019s total outstanding, primarily
consisting of residential mortgage loans and other consumer lending loans. As a result, 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\u2019s residential mortgage portfolio is in
the Netherlands (34.4%), Germany (28.0%), Belgium and Luxembourg (13.2%) and Australia (10.7%).
Relative to the overall developments in the housing markets and loan loss provisions for the mortgage
portfolio\u2019s, note that management adjustments are recognised to maintain an appropriate level of
provisions. See paragraph on \u2018management adjustments\u2019 in the loan loss provisioning section.
Business lending portfolio (*)
Business lending accounts for 40.4% (2021: 45.3%) of ING\u2019s total outstanding. Business lending presented in
this section does not include pre-settlement, investment and money market exposures.
Credit quality (*)
Credit risk categories (*)
Regular
Watch List
Restructuring1
Non-performing1
Possible ratings
1\u201319
1\u201319
11\u201320
20-22
Typical ratings
1\u201314
15\u201317
18\u201320
20-22
Deterioration in risk
Not significant
Significant
Significant
Significant
Significant intervention
Not required
Not required
Required
Required
Account Ownership
Front Office
Front Office
Front Office
Front Office
Credit Risk Management
Regular
Regular
Credit Restructuring
Credit Restructuring
Primary Manager
Front Office
Front Office
Credit Restructuring
Credit Restructuring
Accounting provisioning
Stage 1/2
Stage 1/2
Stage 2/3
Stage 3
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 is applicable to private
individuals, as well as business lending. An obligation is considered \u2018past due\u2019 if a payment of interest or
principal is more than one day late. ING aims to help its customers as soon as they are past due by
reminding them of their payment obligations. In its contact with the 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 cured, for example because the customer is unable or unwilling to pay, the contract
is sent to the recovery unit. The facility is downgraded to risk rating 20 (non-performing) when the facility or
obligor \u2013 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.
ING has aligned the regulatory concept of non-performing with that of the definition of default. Hence, in
WB, obligors are classified as non-performing when a default trigger occurs:
\u2022ING 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:
\u2022The borrower (or third party) has started insolvency proceedings.
\u2022A group company/co-borrower has NPL status.
\u2022Indication of fraud (affecting the company\u2019s ability to service its debt).
\u2022There is doubt as to the borrower\u2019s ability to generate stable and sufficient cash flows to service its
debt.
\u2022Restructuring of debt.
\u2022ING has granted concessions relating to the borrower\u2019s financial difficulty, the effect of which is a
reduction in expected future cash flows of the financial asset below current carrying amount.
\u2022The 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.
Further, WB has an individual name approach, using early warnings indicators to signal possible future
issues in debt service.\u00a0
Ageing analysis (past due but performing): Consumer lending portfolio by geographic area, outstandings (*)1,2
in \u20ac million
2022
2021
Region
Past due for
1\u201330 days
Past due for
31\u201360 days
Past due for
61\u201390 days
Past due for
>90 days
Total
Past due for
1\u201330 days
Past due for
31\u201360 days
Past due for
61\u201390 days
Past due for
>90 days
Total
Europe
Belgium
294
27
18
339
599
53
61
714
Germany
68
34
13
116
105
27
11
143
Luxembourg
43
4
2
48
73
3
1
1
78
Netherlands
36
10
5
50
31
9
3
43
Poland
59
8
4
71
35
5
3
43
Spain
13
9
5
27
13
7
5
26
France
2
2
2
2
United Kingdom
1
Rest of Europe
60
15
8
83
52
9
5
66
America
1
1
Australia
29
11
2
42
17
7
1
25
Total
604
119
57
780
927
123
91
1
1,142
1 Based on consumer lending. The amount of past due but performing financial assets in respect of non-lending activities was not significant.
2 The absolute and relative materiality thresholds used for determining a defaulted status do not apply for the purposes of classification as past due. Below these thresholds, arrears of more than 90 days are reported as past due.
The past due but performing outstanding of consumer lending decreased by \u20ac362 million. The largest
decrease was observed in Belgium (-\u20ac375 million), in term loans (-\u20ac188 million) and in Residential Mortgage
(-\u20ac113 million). Moderate increase was seen in Poland (+\u20ac28 million), Rest of Europe (+\u20ac17 million) and
Australia (+\u20ac16 million), with each mainly visible in the 1\u201330 days past due bucket.
Ageing analysis (past due but performing): Business lending portfolio by geographic area, outstandings (*)1
in \u20ac million
2022
2021
Region
Past due for
1\u201330 days
Past due for
31\u201360 days
Past due for
61\u201390 days
Past due for
>90 days
Total
Past due for
1\u201330 days
Past due for
31\u201360 days
Past due for
61\u201390 days
Past due for
>90 days
Total
Europe
Belgium
579
49
10
639
1,676
178
8
1,863
United
Kingdom
1,147
77
512
1,736
1,036
108
16
1,159
Luxembourg
302
1
303
586
270
1
856
Netherlands
730
30
15
775
553
16
4
574
Poland
279
35
14
329
94
5
2
1
102
Spain
95
1
96
France
83
6
90
36
5
41
Germany
44
16
60
5
2
7
Rest of Europe
474
239
1
1
715
571
57
1
1
629
America
1,901
67
19
1,986
2,076
71
2,146
Asia
553
48
601
276
25
302
Australia
359
61
4
2
426
327
17
1
345
Total
6,452
629
575
4
7,659
7,331
727
60
3
8,121
1 The absolute and relative materiality thresholds used for determining a defaulted status do not apply for the purposes of classification as past due. Below these thresholds, arrears of more than 90 days are reported as past due.
Total past due but performing outstanding of business lending decreased by \u20ac462 million. These were
mainly contributed by decreased outstanding in the 1-30 days (\u20ac879 million) past due bucket, partly offset
by increased outstanding in 61\u201390 days past due bucket (\u20ac515 million). The top three areas of decrease in
the 1-30 days bucket were Belgium (\u20ac1,097 million), Luxembourg (\u20ac284 million) and America (\u20ac175 million).
The top three areas of increase in the 1-30 days bucket were Asia (\u20ac277 million), Poland (\u20ac185 million) and
the Netherlands (\u20ac177 million).
Credit restructuring (*)
Global Credit Restructuring (GCR) is the dedicated and independent department that deals with non-
performing loans and loans that hold a reasonable probability that ING will end up with a loss, if no specific
action is taken. GCR handles accounts or portfolios requiring an active approach, which may include
renegotiation of terms and conditions and business or financial restructuring. The loans are managed by
GCR or by units in the various regions and business units. ING uses three distinct statuses to categorise the
management of clients with (perceived) deteriorating credit risk profiles, i.e. there is increasing doubt as to
the performance and the collectability of the client\u2019s contractual obligations:
\u2022Watch list: Usually, a client is first classified as watch list when there are concerns of any potential or
material deterioration in credit risk profile that may affect the ability of the client to adhere to its debt
service obligations or to refinance its existing loans. Watch List status requires more than usual
attention, increased monitoring and quarterly reviews. Some clients with a Watch List status may
develop into a Restructuring status or even a Recovery status.
\u2022Restructuring: A client is classified in restructuring when there are concerns about the client\u2019s financial
stability, credit worthiness, and/or ability to repay, but where the situation does not require the
termination or acceleration of facilities or the liquidation of collateral. ING\u2019s actions aim to maintain the
going concern status of the client by:
\u2022restoring the client\u2019s financial stability;
\u2022supporting the client\u2019s turnaround;
\u2022restoring the balance between debt and equity; and
\u2022restructuring the debt to a sustainable situation.
\u2022Recovery: A client is classified as in recovery when ING and/or the client concludes that the client\u2019s
financial situation cannot be restored and a decision is made to terminate the (credit) relationship or
even to enter into bankruptcy. ING prefers an amicable exit, but will enforce and liquidate the collateral
or claim under the guarantees if deemed necessary.
Watch list, restructuring and recovery accounts are reviewed at least quarterly by the front office, GCR and
the relevant credit risk management executives.
Forbearance (*)
Forbearance occurs when a client is unable to meet their financial commitments due to financial difficulties
they face or are about to face and ING grants concessions towards them. Forborne assets are assets in
respect of 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 with the aim of maximising the client\u2019s
repayment ability and therewith avoiding a default situation or helping the client to return to a performing
situation.
For ING retail units, clear criteria has 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
on a portfolio (retail) basis.
All exposures are eligible for forbearance measures, i.e. both performing (Risk ratings 1-19) and non-
performing (risk ratings 20-22) exposures. 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 \u20ac million
2022
2021
Business line
Outstanding
s
Of which:
performin
g
Of which:
non-
performing
% of total
portfolio
Outstanding
s
Of which:
performin
g
Of which:
non-
performing
% of total
portfolio
Wholesale Banking
8,359
5,880
2,478
2.7%
9,798
7,455
2,343
3.1%
Retail Banking
8,080
4,973
3,107
1.6%
10,018
6,339
3,679
2.1%
Total
16,438
10,853
5,585
2.0%
19,816
13,793
6,022
2.5%
Wholesale Banking: Forborne portfolio by economic sector (*)
in \u20ac million
2022
2021
Industry
Outstandings
Of which:
performing
Of which: non-
Outstandings
Of which:
performing
Of which: non-
performing
performing
Natural Resources
1,239
603
636
2,047
1,177
870
Real Estate
2,000
1,917
84
1,665
1,570
95
Transportation & Logistics
1,073
868
205
1,336
1,061
274
Food, Beverages & Personal Care
1,082
543
539
1,202
749
452
Services
697
665
32
793
687
106
Automotive
172
125
46
581
535
46
Utilities
469
255
214
407
271
136
General Industries
255
176
80
366
321
45
Retail
302
227
76
361
304
57
Chemicals, Health &
Pharmaceuticals
191
168
23
347
324
22
Builders & Contractors
168
94
74
177
135
41
Other
710
240
469
516
318
197
Total
8,359
5,880
2,478
9,798
7,455
2,343
The main concentration of forborne assets in a single country was in the United Kingdom with 12% (2021:
14%) of the total WB forborne assets and 13% (2021: 18%) of the total non-performing forborne assets.
WB forborne assets decreased by \u20ac1.44 billion compared to 2021, of which the performing forborne assets
decreased by \u20ac1.58 billion. This was visible across all industries (except for Real estate) and locations (except
for Belgium and Poland).
WB's forborne assets were mainly concentrated in natural resources, real estate, transportation & logistics
and food beverages & personal care. These four economic sectors accounted for 65% of the total WB
forborne outstandings. During 2022, an increase in forborne assets was visible in the real estate industry (+\u20ac
0.3 billion), offset by a decrease in Natural Resources (-\u20ac0.8 billion), Automotive (-\u20ac 0.4 billion), Food,
Beverages & Personal Care (-\u20ac0.1 billion) and Transportation & Logistics (-\u20ac0.2 billion).
Retail Banking (*)
As of the end of December 2022, Retail Banking forborne assets totalled \u20ac8.1 billion, which represented 1.6%
of the total Retail Banking portfolio.
Retail Banking: Forborne portfolio by geographical area (*)
in \u20ac million
2022
2021
Region
Outstandings
Of which:
performing
Of which: non-
Outstandings
Of which:
performing
Of which: non-
performing
performing
Europe
Netherlands
2,832
2,043
789
4,171
3,224
947
Belgium
2,644
1,331
1,314
3,319
2,035
1,284
Germany
804
610
194
497
306
191
Poland
588
309
279
450
152
298
Turkey
64
31
32
146
97
49
Italy
131
52
79
129
47
82
Romania
124
53
71
115
49
66
Spain
35
15
20
35
11
23
Rest of Europe
73
48
25
99
68
30
America
13
12
9
7
2
Asia
3
1
1
3
1
1
Australia
768
467
302
1,045
340
705
Africa
1
1
Total
8,080
4,973
3,107
10,018
6,339
3,679
The main concentration of forborne assets in a single country was in the Netherlands with 35% (2021: 42%)
of total Retail Banking forborne assets and 25% (2021: 26%) of the non-performing forborne assets. Next to
that, Belgium had to 33% (2021: 33%) of the total Retail forborne assets.
Non-performing loans (*)
ING\u2019s loan portfolio is under constant review. Loans to obligors that are considered more than 90 days past
due and above applicable thresholds are reclassified as non-performing. For business lending portfolios,
there generally are reasons for declaring a loan non-performing prior to the obligor being 90 days past due.
These reasons include, but are not limited to, ING\u2019s assessment of the customer\u2019s perceived inability to meet
its financial obligations, or the customer filing for bankruptcy or bankruptcy protection.
The table below represents the breakdown by industry of credit risk outstandings that have been classified
as non-performing.
Non-performing Loans: outstandings by economic sector and business lines (*)1
in \u20ac million
Wholesale
Banking
Retail Benelux
Retail
Challengers &
Growth Markets
Corporate Line
Total
Industry
2022
2021
2022
2021
2022
2021
2022
2021
2022
2021
Private Individuals
2,174
2,424
1,954
2,445
4,129
4,869
Natural Resources
1,369
1,325
34
46
17
27
1,421
1,398
Food, Beverages & Personal
Care
672
681
438
428
122
130
1,233
1,239
Transportation & Logistics
367
575
165
180
51
52
583
807
Services
119
224
448
499
61
63
628
786
Real Estate
172
132
486
495
54
59
712
686
General Industries
114
66
268
272
100
123
482
461
Builders & Contractors
139
93
244
224
110
112
493
429
Retail
98
140
107
103
39
47
244
290
Utilities
387
199
7
10
7
11
401
221
Chemicals,
Health &
Pharmaceuticals
175
65
115
70
20
22
310
158
Telecom
288
28
12
1
3
3
303
31
Other
440
305
260
282
52
58
753
646
Total
4,340
3,833
4,759
5,035
2,592
3,153
11,691
12,021
1 Based on Lending and Investment outstandings.
Non-performing Loans: outstandings by economic sectors and geographical area (*)
in \u20ac million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United Kingdom
France
Luxembourg
Rest of Europe
America
Asia
Australia
Africa
2022
Private Individuals
574
1,538
739
185
194
4
11
36
470
3
4
370
1
4,129
Natural Resources
57
33
14
53
432
77
649
85
21
1,421
Food, Beverages & Personal Care
310
179
24
109
173
7
228
77
126
1,233
Transportation & Logistics
232
58
1
36
47
20
2
154
24
7
1
583
Services
136
375
2
43
5
3
2
21
40
628
Real Estate
89
376
54
84
25
19
7
47
11
712
General Industries
127
142
17
78
31
2
26
58
482
Builders & Contractors
65
187
2
86
20
101
32
493
Retail
31
85
38
26
18
1
13
22
7
2
244
Utilities
6
6
26
23
17
194
129
401
Chemicals, Health & Pharmaceuticals
51
100
2
15
14
100
28
310
Telecom
24
1
3
5
270
303
Other
40
232
48
38
50
10
79
75
130
51
753
Total
1,742
3,312
899
710
246
344
196
145
1,578
654
1,324
470
72
11,691
Non-performing Loans: outstandings by economic sectors and geographical area (*)
in \u20ac million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United Kingdom
France
Luxembourg
Rest of Europe
America
Asia
Australia
Africa
Private Individuals
776
1,578
721
206
232
8
16
35
497
3
4
791
1
4,869
Natural Resources
67
44
20
27
116
577
421
90
37
1,398
Food, Beverages & Personal Care
299
176
25
111
226
7
2
37
228
128
1
1,239
Transportation & Logistics
385
55
1
35
47
20
3
165
29
49
17
807
Services
199
385
45
5
66
4
22
52
6
1
786
Real Estate
167
303
61
88
21
21
9
16
686
General Industries
110
173
18
91
4
3
34
27
461
Builders & Contractors
43
188
4
83
2
58
50
429
Retail
40
70
34
30
56
1
21
21
14
2
290
Utilities
8
9
71
26
28
30
48
221
Chemicals, Health & Pharmaceuticals
63
48
2
16
29
158
Telecom
13
1
2
10
1
5
31
Other
42
226
129
41
2
14
15
38
37
34
1
67
646
Total
2,212
3,255
1,005
768
284
447
119
87
1,056
1,060
656
966
105
12,021
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: (1) to the economic outlook and (2) 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 \u2018credit-impaired\u2019
financial assets under IFRS 9 (Stage 3). ING has also aligned its definition of default between IFRS9 and the
regulatory technical standards (RTS) and EBA guidelines. More information can be found in section 1.7.8 of
the Consolidated financial statements.
Climate and environmental risks in IFRS 9 models (*)
ING is evolving in its credit risk management framework to further develop a better understanding of
emerging climate and environmental risks. Banks, including ING, are in the process of collecting and
analysing empirical historical data and moving towards embedding these emerging risks into their credit
risk management processes and eventually into their IFRS 9 ECL models.
In 2022, ING continued to enhance the tools used to identify and assess climate and environmental (C&E)
risks in our portfolio. We created C&E risk sector heatmaps for both WB and Retail Banking that facilitated
the identification of exposure to C&E risks by means of scores assigned to transition and physical risk
drivers. They also enabled us to understand the magnitude of the C&E risk impact on a sectoral level and
pinpointed sectors with highest C&E risk exposure. In the past two years, we have improved our
understanding of the physical risk impact of climate events on our mortgage portfolio.
The integration of quantified inputs from the heatmaps into risk modelling has not yet been implemented
for a number of reasons including a lack of data to assess C&E risks at a client level. Refer to the section
'Environmental, social and governance risk' for further details on the heatmaps and the related challenges.
At this point in time it is not possible to incorporate climate risk separately into IFRS 9 ECL models given the
lack of sufficient empirical historical data and the above-mentioned limitations in the risk assessments on
client level. Where climate and environmental factors have impacted the economy in the recent past or
present, these impacts are however currently implicitly embedded in ING's IFRS9 ECL models through the
projected macroeconomic indicators (e.g. GDP growth and unemployment rates). We note that our ECL
models are primarily sensitive to the short-term economic outlook as we use a three-year time horizon for
macroeconomic outlook, after which a mean reversion approach is applied.
With regard to our evaluation of climate-related matters, where such events have already occurred (e.g.
floods), the impact of such events are individually assessed in the calculation of Stage 3 Individual provisions
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.
As of 31 December 2022, reported ECL includes a management adjustment of \u20ac10 million to address the
increased credit risk in ING\u2019s livestock farming portfolio resulting from nitrogen reduction targets introduced
by the Dutch Government. Refer to the section 'Management overlays' for further details.
Portfolio quality (*)
The table below describes the portfolio composition over the different IFRS 9 stages and rating classes. The
Stage 1 portfolio represents 91.5% (2021: 93.5%) of the total gross carrying amounts, mainly composed of
investment grade, while Stage 2 makes up 7.3% (2021: 5.2%) and Stage 3 makes up 1.2% (2021: 1.3%) of
the total gross carrying amounts, respectively.
Gross carrying amount per IFRS 9 stage and rating class (*)1,2,3
in \u20ac million
12-month ECL (Stage 1)
Lifetime ECL not credit
impaired (Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
2022
Rating class
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Investment grade
1 (AAA)
100,885
2
284
101,169
2
2-4 (AA)
98,181
5
2,493
1
100,675
6
5-7 (A)
177,617
23
4,596
4
182,214
27
8-10 (BBB)
320,972
98
14,714
29
335,687
127
Non-Investment grade
11-13 (BB)
155,910
277
17,365
91
173,275
368
14-16 (B)
23,649
168
19,386
471
43,035
639
17 (CCC)
7,671
8
4,572
194
12,244
202
Substandard grade
18 (CC)
5,198
595
5,198
595
19 (C)
2,116
293
2,116
293
Non-performing loans
20-22 (D)
11,708
3,841
11,708
3,841
Total
884,886
581
70,725
1,679
11,708
3,841
967,319
6,101
1Compared to the credit risk portfolio, the differences are mainly undrawn committed amounts (\u20ac150.1 billion) and other positions (\u20ac4.4 billion) not included in Credit outstandings and non-IFRS 9 eligible assets (\u20ac116.1 billion, mainly guarantees, letters of credit and pre-
settlement exposures) included in Credit outstandings.
2For a reference to the Notes in the consolidated financial statements, we refer to the table \u2018Reconciliation between credit risk categories and financial position\u2019.
3IAS 37 provisions are established for non-credit replacement guarantees not in the scope of IFRS 9. Total IAS 37 provisions (\u20ac109 million) are excluded.
Gross carrying amount per IFRS 9 stage and rating class (*)1,2,3
in \u20ac million
12-month ECL (Stage 1)
Lifetime ECL not credit
impaired (Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
2021
Rating class
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Investment grade
1 (AAA)
107,788
3
107,788
3
2-4 (AA)
106,673
5
197
106,870
5
5-7 (A)
152,255
17
1,001
1
153,256
17
8-10 (BBB)
328,301
73
7,232
14
335,533
87
Non-Investment grade
11-13 (BB)
162,912
208
14,679
86
177,592
294
14-16 (B)
26,852
185
17,931
404
44,783
589
17 (CCC)
5,377
10
4,354
198
9,730
207
Substandard grade
18 (CC)
2,314
173
2,314
173
19 (C)
1,769
142
1,769
142
Non-performing loans
20-22 (D)
12,072
3,851
12,072
3,851
Total
890,158
501
49,476
1,016
12,072
3,851
951,707
5,368
1Compared to the credit risk portfolio, the differences are mainly undrawn committed amounts (\u20ac133.3 billion) not included in Credit outstandings and non-IFRS 9 eligible assets (\u20ac95.1 billion, mainly guarantees, letters of credit and pre-settlement exposures) included in Credit
outstandings.
2For a reference to the Notes in the consolidated financial statements, we refer to the table \u2018Reconciliation between credit risk categories and financial position\u2019.
3IAS 37 provisions are established for non-credit replacement guarantees not in the scope of IFRS 9. Total IAS 37 provisions (\u20ac114.4 million) are excluded.
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:
\u2022Stage 3 gross carrying amount decreased by \u20ac0.4 billion from \u20ac12.1 billion as of 31 December 2021 to\u00a0 \u00a0
\u20ac11.7 billion as of 31 December 2022, mainly as a result of write-offs and generally low inflow into NPL
(credit impaired) in 2022. Stage 3 provisions remained however flat at \u20ac3.8 billion, reflecting worsened
macroeconomic outlook.
\u2022Stage 2 gross carrying amount increased by \u20ac21.2 billion from \u20ac49.5 billion as of 31 December 2021 to\u00a0
\u20ac70.7 billion. This is mainly caused by the significant lifetime PD trigger (\u20ac14.8 billion) driven by
downgrades of the Russian portfolio and economic turmoil. Furthermore, the implementation of a
stricter PD backstop methodology has driven the increase in Stage 2 gross carrying amounts,(\u20ac11.4
billion, mainly investment grade exposures). Other Stage 2 triggers such as the 30 Days past due and
watchlist triggers (\u20ac1.2 billion and \u20ac1.1 billion respectively), were more than offset by the forbearance
trigger (-\u20ac6.4 billion). For the latter, a two-year probation period is required before a client can move back
to Stage 1 and the decrease relates to the fact that the start of the Covid-19 pandemic is now more than
two years ago.
\u2022Stage 2 provisions increased by \u20ac0.7 billion to \u20ac1.7 billion as of 31 December 2022, largely driven by the
migration of the Russian portfolio to Stage 2 and worsened macro-economic outlook. The
implementation of the threefold increase in lifetime PD backstop trigger had limited impact on provisions
as\u00a0 it mainly impacts investment grade exposures.
\u2022In 2022, the largest increases in Stage 2 by sector were in Non-bank financial institutions, Real estate,
Chemicals health & pharmaceuticals and Lower public administration of \u20ac3.5 billion, \u20ac2.8 billion, \u20ac2.5
billion and \u20ac2.1 billion respectively The increase in Stage 2 for non-bank financial institutions mainly
resulted from the implementation of the threefold increase in lifetime PD backstop trigger, that mainly
impacts investment grade exposures. Other drivers were downgrades in the Russian portfolio and
economic turmoil. The largest decreases were in Automotive and Transportation & logistics with \u20ac0.9
billion and \u20ac0.6 billion releases respectively. The largest Stage 2 outstandings per economic sector as of
31 December 2022 are Real estate, Services, Natural resources and Non-bank financial institutions
representing 10%, 7%, 7% and 7% of the total Stage 2 gross carrying amounts respectively.
Additional information on macroeconomic scenarios is included in the section \u2018Macroeconomic scenarios
and sensitivity analysis of key sources of estimation uncertainty\u2019.
Changes in gross carrying amounts and loan loss provisions (*)1, 2
in \u20ac million
12-month ECL (Stage 1)
Lifetime ECL not credit
impaired (Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
2022
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Opening balance
890,158
501
49,476
1,016
12,072
3,851
951,707
5,368
Transfer into 12-month ECL (Stage 1)
8,513
21
-8,105
-142
-408
-47
-168
Transfer into lifetime ECL not credit impaired (Stage 2)
-42,439
-76
43,222
730
-784
-90
564
Transfer into lifetime ECL credit impaired (Stage 3)
-3,524
-8
-1,216
-82
4,740
1,234
1,144
Net remeasurement of loan loss provisions
8
223
199
430
New financial assets originated or purchased
248,443
228
248,443
228
Financial assets that have been derecognised
-138,250
-70
-11,312
-94
-2,805
-215
-152,366
-379
Net drawdowns and repayments
-78,015
-1,340
21
-79,334
Changes in models/risk parameters
-8
13
25
30
Increase in loan loss provisions
95
648
1,106
1,849
Write-offs
-1
-1,129
-1,129
-1,130
-1,130
Recoveries of amounts previously written off
71
71
Foreign exchange and other movements
-15
16
-58
-57
Closing balance
884,886
581
70,725
1,679
11,708
3,841
967,319
6,101
1Stage 3 Lifetime credit impaired provision includes \u20ac4 million on Purchased or Originated Credit Impaired.
2The addition to the loan provision (in the consolidated statement of profit or loss) amounts to \u20ac1.861 million of which \u20ac1.850 million related to IFRS 9 eligible financial assets, -\u20ac3 million related to non-credit replacement guarantees and \u20ac14 million to modification gains and
losses on restructured financial assets.
Changes in gross carrying amounts and loan loss provisions (*)1,2
in \u20ac million
12-month ECL (Stage 1)
Lifetime ECL not credit
impaired (Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
2021
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Opening balance
844,020
581
59,313
1,476
13,398
3,797
916,732
5,854
Transfer into 12-month ECL (Stage 1)
15,157
20
-14,322
-279
-835
-54
-313
Transfer into lifetime ECL not credit impaired (Stage 2)
-19,737
-32
20,537
206
-800
-74
100
Transfer into lifetime ECL credit impaired (Stage 3)
-2,166
-13
-1,589
-96
3,755
820
712
Net remeasurement of loan loss provisions
-130
-228
404
46
New financial assets originated or purchased
208,501
149
208,501
149
Financial assets that have been derecognised
-125,819
-73
-11,935
-104
-1,898
-237
-139,652
-414
Net drawdowns and repayments
-29,799
-2,526
-694
-33,019
Changes in models/risk parameters
12
41
130
184
Increase in loan loss provisions
-67
-460
989
462
Write-offs
-854
-854
-854
-854
Recoveries of amounts previously written off
45
45
Foreign exchange and other movements
-13
1
-125
-138
Closing balance
890,158
501
49,476
1,016
12,072
3,851
951,707
5,368
Macroeconomic scenarios and sensitivity analysis of key sources of estimation
uncertainty (*)
Methodology (*)
Our methodology in relation to the adoption and generation of macroeconomic scenarios is described in
this section. We continue to follow this methodology in generating our probability-weighted ECL, with
consideration of alternative scenarios and management adjustments supplementing this ECL where, in
management's opinion, 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\u2019s 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). The Oxford Economics\u2019 Global Economic Model (OEGEM) is used to complement the consensus with
consistent projections for variables for which there are no consensus estimates available (most notably
house prices and \u2013 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 two panels of ING experts. The first panel
consists of economic experts from Global Markets Research and risk and modelling specialists, while the
second panel consists of relevant senior managers.
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 OEGEM.
To understand the baseline level of uncertainty around any forecast, Oxford Economics keeps track of all its
deviations (so called forecast errors) of the past 20 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, Oxford Economics 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 for the 90th percentile of that distribution because this
corresponds with the way risk management earnings-at-risk is defined within the Bank. The upside scenario
is represented by the 10th percentile of the distribution. The applicable percentiles of the distribution imply
a 20% probability for each alternative scenario. Consequently, the baseline scenario has a 60% probability
weighting. Please note that, given their technical nature, the downside and upside scenarios are not based
on an explicit specific narrative.
Macroeconomic scenarios applied (*)
The loan loss provisions are based on the December 2022 consensus forecasts.
Baseline assumptions (*)
The general picture that the consensus conveys is that global economic growth is being challenged by
persistent inflationary pressures which are being met by central banks lifting interest rates. The consensus
expects recession to occur in many European countries in 2022-2023, while the US economy is anticipated
to stagnate. Economic growth is expected to resume in the years thereafter as inflation normalises and
monetary conditions become less tight. In economies that have experienced a notable surge in house prices
during the pandemic and its aftermath, affordability pressures amid the higher interest rate environment
are expected to lead to a moderation of growth or price declines in the near to medium-term.
The December 2022 consensus expects global output (as measured by the weighted average GDP growth
rate of ING's 25 main markets) to slow further from 6.0% in 2021, to 2.5% in 2022 and 1.3% in 2023. For
2024-2025, economic growth is expected to pick up again to 2.4%.
The US economy is expected to stagnate in 2023 as high inflation, rising interest rates, supply chain
difficulties, softer labour market dynamics, and global headwinds weaken demand. Consumer spending
growth is under downward pressure as slower employment gains curb income growth and pandemic-
related savings have diminished. With the headwinds seen fading slowly, the US economy is expected to
gather strength again in 2024. The consensus expects the growth rate of the US economy to fall from 1.9%
in 2022 to 0.2% in 2023 and to recover to on average 1.7% in 2024-2025.
Eurozone economies are dealing with the consequences of the ongoing war in Ukraine, broadening
inflationary pressures and a general deterioration of sentiment across industries and consumers.
The ECB has shifted to a hawkish tilt but government fiscal support targeting higher energy prices is
softening the economic pain in many countries. Overall, the eurozone economy is forecasted to stagnate in
2023, but Germany \u2013 as well as some other countries \u2013 faces recession reflecting its large exposure to gas
supply cuts, relatively large manufacturing sector and exposure to a slower growing Chinese economy.
Elsewhere in Europe, the outlook is equally bleak. In Poland, economic fallout from the war in Ukraine and
the related energy price shock point to a significant economic slowdown from 5.0% in 2022 to 1.0% in 2023.
However, the scope for a rise in unemployment is seen to be limited as the Polish labour market remains
tight, partially due to population ageing. As in the eurozone, the central bank is tightening monetary policy,
but fiscal policy remains expansive. The consensus expectation for Turkey is also for economic growth to
ease as the economic slowdown in Europe weighs on external demand and high inflation persists. The
consensus sees economic growth in Turkey slowing from 5.2% in 2022, to on average 2.4% in 2023-2024
and increasing again to 3.0% in 2025.
After a weak growth rate of 3.1% in 2022, economic growth in China is expected to pick-up to on average
4.7% in 2023-2025. The drag exerted by the authorities\u2019 Covid-19 policies is assumed to moderate, while
state investment will support demand. However, the real estate downturn continues to weigh on the
outlook.
The global economic slowdown, together with tighter monetary policy and high inflation is weighing on
economic growth in Australia. After growing by 3.8% in 2022, the outlook sees a growth rate of 1.8% for
2023-2024 and some pick-up to 2.6% for 2025. However, despite the economic slowdown, conditions in the
labour market are expected to remain tight.
When compared to the December 2021 consensus forecast, used for the 2021 Annual Report, the December
2022 forecast assumes much weaker economic circumstances. Global GDP was expected to increase by
2.5% in 2022 (compared to 4.1% assumed before) and 1.3% in 2023 (3.1% assumed before). The downgrade
reflects the economic impacts of the war in Ukraine and tighter monetary conditions.
Alternative scenarios and risks (*)
Because of the possible consequences of the war in Ukraine, uncertainty surrounding the forecasts is higher
than usual. This relates in particular to uncertainty about European energy supplies and worries about more
persistent high inflation. To take the general increase of uncertainty surrounding the forecasts into account,
the dispersion of the alternative scenarios has been set again at the widened level used for year-end 2021
provisioning (the half-widened dispersion). As a result, the near-term dispersion of the forward-looking
distributions (from which the alternative scenarios are derived) is larger than in normal times. Meanwhile, at
the end of the scenario horizon the dispersion has remained unchanged and hence is comparable to
scenarios generated prior to the war in Ukraine.
The baseline scenario assumes a significant easing of inflation in 2023 and relatively resilient labour
markets. However, a longer period of weakness, due to stickier inflation and more aggressive monetary
policy tightening that triggers a more notable softening of the labour market and greater falls in financial
asset and property prices, could lead to a more protracted and deeper economic slowdown. As such, the
balance of risks to the baseline outlook is negative and the alternative scenarios have a downward skew in
line with the outcomes of Oxford Economics\u2019 Global Risk Survey. The downward skew is less negative
compared to what has been applied for year-end 2021 at which time \u2013 set against a higher baseline \u2013 apart
from higher inflation, worries about supply chain disruptions and further corona virus waves were being
seen as top near-term downside risks.
The downside scenario \u2013 though technical in nature \u2013 sees for most countries a fast deceleration of
economic growth followed by a recession. Unemployment increases strongly in this scenario and house
prices in most countries show outright falls. The downside scenario captures a possible escalation of the war
in Ukraine and a more pronounced and prolonged surge in inflation.
The upside scenario \u2013 while equally technical in nature \u2013 reflects the possibility of a better economic outturn
if the war in Ukraine ended quickly, fuelling a rebound in consumer spending. The recovery is further
supported by looser monetary policy as weaker inflation prompts central banks to hold back tightening.
Management adjustments applied this year (*)
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 can also be applied
where the impact of the updated macroeconomic scenarios is over- or under-estimated by the IFRS 9
models.
ING has internal governance frameworks and controls in place to assess the appropriateness of all
management adjustments.
Management adjustments to ECL models (*)
in \u20ac million
2022
2021
Economic sector based adjustments
71
341
Second order impact adjustments
334
Payment holiday adjustments
32
Mortgage portfolio adjustments
105
124
Other Post Model Adjustments1
-57
121
Total management adjustments
453
618
1 Prior period figure has been updated to conform to current year presentation.
December 2021 management adjustments included an economic sector-based management adjustment
of \u20ac341 million because of delays in defaults occurring in the Covid-19-related crisis, mainly as a result of
government support programmes. In determining the sector-based management adjustment, a heatmap
approach was used to adjust the probability of default for sectors where businesses are significantly
impacted by the pandemic. In 2022, as it became clearer the Covid-19 pandemic had less impact than
expected on the number of defaults, the economic sector-based management adjustment has been largely
released and while at the same time management adjustments for the second order impact of the war in
Ukraine were introduced (see below). Of the remaining economic sector based adjustments of \u20ac71 million as
of 31 December 2022, \u20ac61 million relates to Business Banking clients that have benefited from Covid-19
related government support programmes in the Netherlands such as deferral of tax payments that ended in
the second half of 2022, and \u20ac10 million relates to an overlay for livestock farming sector in the
Netherlands. In the Netherlands, nitrogen reduction targets affect the livestock farming sector mainly
because of endorsed closing activities nearby Natura 2000 areas and because of expected transition to
other business models in the sector. As these specific risks are not incorporated in the model ECL, an overlay
was recognised.
ING has performed an assessment for both WB and Retail Banking on the impact of the war in Ukraine, the
increase in energy prices and other second order macroeconomic developments such as an increase in
inflation and rising interest rates. This resulted in a second order impact overlay of \u20ac334 million in total as of
31 December 2022, of which \u20ac164 million relates to Retail Banking segments and \u20ac170 million to the
Wholesale Banking segment.
As the credit risk models assume that these second order effects materialise via other risk drivers such as
GDP and unemployment rates with a delay, an overlay approach was determined to timely estimate the
Expected Credit Losses related to reduced repayment capacity and affordability for private individuals and
business clients in the Retail Banking segment. The \u20ac164 million includes an overlay of \u20ac22 million for clients
participating in the payment holiday scheme in Belgium that was introduced in 2022 to support customers
impacted by the inflation and high energy prices.
In WB, it was assessed that the economic effects of Covid-19 was not the highest risk anymore and that
other risks have emerged \u2013 mainly high energy prices, high interest rates and inflation, supply chain issues
and staffing shortages. A heatmap approach was used to adjust the probability of default for clients that
are expected to be significantly impacted by these emerged risks.
Given Covid-19-related payment holiday programmes have generally expired, this management
adjustment has been fully released in 2022.
Model based ECL of mortgage portfolios has decreased over the past years and until the third quarter of
2022, driven by significant increase of house prices in various countries. Management adjustments of \u20ac105
million in total, mainly in Stage 2 and 3, have been recognised by ING in the Netherlands, Belgium, Germany
and Australia to maintain an appropriate level of ECL and reflecting a potential impact of market
uncertainty on the recovery value of residential real estate (impacted by higher inflation and interest rates).
The management adjustment for the Netherlands and part of the Belgian mortgage portfolio was
determined by developing three alternative macroeconomic forecast scenarios, in addition to the consensus
base, up- and down-scenarios, that reflect a correction in the house prices in the next three years bringing it
back in line with the historical growth rate. For other countries, management adjustments were determined
by calculating the impact of lower house prices on LTVs and LGDs.
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. These result
from both regular model maintenance and ING\u2019s multiyear programme to update ECL models for the new
definition of default. These adjustments will be removed once updates to the specific models have been
implemented.
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 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. ING also observes that,
in general, the WB business is more sensitive to the impact of forward-looking macroeconomic scenarios.
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.
Sensitivity analysis as at December 2022\u00a0 (*)
2023
2024
2025
Un-weighted
ECL (\u20ac mln)
Probability-
weighting
Reportable
ECL (\u20ac mln)1
Netherlands
Upside scenario
Real GDP
2.2
2.3
2.9
274
20%
381
Unemployment
4.0
3.9
3.8
HPI
13.0
11.8
2.5
Baseline Scenario
Real GDP
0.2
1.4
1.8
349
60%
Unemployment
4.5
4.8
4.9
HPI
3.7
3.7
2.4
Downside scenario
Real GDP
-4.2
0.7
0.9
583
20%
Unemployment
6.4
7.8
8.7
HPI
-8.0
-6.5
2.2
Germany
Upside scenario
Real GDP
1.7
2.3
1.8
606
20%
745
Unemployment
2.6
2.2
1.8
HPI
0.6
3.9
6.2
Baseline Scenario
Real GDP
-0.7
1.4
1.5
726
60%
Unemployment
3.2
3.1
3.1
HPI
-1.8
0.9
2.7
Downside scenario
Real GDP
-4.8
0.1
1.0
942
20%
Unemployment
4.8
5.3
5.6
HPI
-6.2
-3.3
-1.4
Belgium
Upside scenario
Real GDP
1.7
2.1
2.1
535
20%
596
Unemployment
5.5
5.5
5.3
HPI
2.3
2.6
3.1
Baseline Scenario
Real GDP
0.0
1.6
1.8
584
60%
Unemployment
6.1
6.3
6.1
HPI
1.4
2.2
2.5
Downside scenario
Real GDP
-3.2
1.0
1.5
692
20%
Unemployment
7.5
8.5
8.4
HPI
-1.2
0.9
1.2
United States
Upside scenario
Real GDP
3.0
1.5
3.4
100
20%
221
Unemployment
3.4
2.8
2.5
HPI
3.7
7.4
8.1
Baseline Scenario
Real GDP
0.2
1.1
2.3
188
60%
Unemployment
4.3
4.4
3.9
HPI
2.5
2.2
2.8
Downside scenario
Real GDP
-4.1
0.2
0.6
442
20%
Unemployment
6.4
7.7
8.2
HPI
-1.2
-3.8
-3.5
1 Excluding management adjustments.
Sensitivity analysis as at December 2021 (*)
2022
2023
2024
Un-weighted
ECL (\u20ac mln)
Probability-
weighting
Reportable
ECL (\u20ac mln)1
Netherlands
Upside scenario
Real GDP
5.1
2.9
2.7
259
20%
307
Unemployment
3.2
2.9
2.9
HPI
23.3
10.9
0.9
Baseline Scenario
Real GDP
3.4
2.0
1.7
289
60%
Unemployment
3.7
4.1
4.3
HPI
13.1
2.8
0.8
Downside scenario
Real GDP
-1.5
1.2
0.7
411
20%
Unemployment
5.6
6.8
7.8
HPI
0.3
-7.7
0.6
Germany
Upside scenario
Real GDP
6.2
3.1
1.6
457
20%
483
Unemployment
2.9
2.2
1.9
HPI
12.9
7.9
5.3
Baseline Scenario
Real GDP
4.0
2.3
1.4
475
60%
Unemployment
3.4
3.1
3.1
HPI
10.4
4.6
1.9
Downside scenario
Real GDP
-0.6
0.9
0.8
535
20%
Unemployment
5.0
5.4
5.7
HPI
5.3
0.4
-2.1
Belgium
Upside scenario
Real GDP
4.6
2.5
2.0
364
20%
393
Unemployment
5.6
5.6
5.9
HPI
3.9
2.7
2.9
Baseline Scenario
Real GDP
3.1
2.0
1.8
383
60%
Unemployment
6.1
6.3
6.3
HPI
3.0
2.3
2.3
Downside scenario
Real GDP
-0.4
1.4
1.4
451
20%
Unemployment
7.6
8.6
9.0
HPI
0.4
1.0
1.0
United States
Upside scenario
Real GDP
6.7
2.4
3.1
28
20%
75
Unemployment
3.5
2.5
2.4
HPI
10.4
8.1
8.7
Baseline Scenario
Real GDP
4.0
2.5
2.1
55
60%
Unemployment
4.0
3.7
3.7
HPI
9.1
3.0
3.3
Downside scenario
Real GDP
-0.7
1.1
0.3
183
20%
Unemployment
6.5
7.4
8.0
HPI
5.3
-3.2
-3.0
1 Excluding management adjustments.
When compared to the sensitivity analysis of 2021, the macroeconomic inputs for 2022 and 2023 are less
favourable, driven by a worsened macroeconomic outlook as a result of the war in Ukraine as well as its
indirect effects such as inflation and increasing interest rates. Both 2021 and 2022 contain half-widened
dispersion around upside and downside scenarios, for 2021. This reflects continuing but decreased short-
term uncertainty relating to the impact of Covid-19 and for 2022 reflecting short-term uncertainty around
the war in Ukraine and its indirect effects. The increase in reportable ECL compared to 2021 is mainly caused
by higher model ECL amounts as per December 2022 as a result of increased provisions for Russia-related
exposures in Stage 2.
While the table above does give a high-level indication of the sensitivity of the outputs to the different
scenarios, it does not provide insight into the interdependencies and correlations between different
macroeconomic variable inputs. On a total ING level, the unweighted ECL for all collective provisioned clients
in the upside scenario was \u20ac2,680 million, in the baseline scenario \u20ac3,177 million and in the downside
scenario \u20ac4,456 million compared to \u20ac3,209 million reportable collective provisions as at 31 December 2022
(excluding all management adjustments). This reconciles as follows to the reported ECL\u2019s:
Reconciliation of model (reportable) ECL to total ECL (*)
in \u20ac million
2022
2021
Total model ECL1
3,209
2,408
ECL from individually assessed impairments
2,439
2,342
ECL from management adjustments
453
618
Total ECL
6,101
5,368
1 Prior period figure has been updated to conform to current year presentation.
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 since initial origination or purchase. ING considers the credit risk of an asset
to have significantly increased when either a threshold for absolute change in lifetime probability of default
(PD) or a relative change in lifetime PD is reached.
It should be noted that the lifetime PD thresholds are not the only drivers of stage allocation. An asset can
also change stages as a result of other triggers, such as having over 30 days arrears, being on a watch list or
being forborne. Refer to section 1.7.8 of Note 1 \u2018Basis of preparation and significant accounting policies\u2019 for
an exhaustive list. Furthermore, this analysis is rudimentary in the sense that other parameters would
change when an asset changes stages.
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 thresholds for the absolute change in lifetime PD vary between 75bps for Retail
portfolios, 100bps for WB and 250bps for SMEs, based on the characteristics of the specific portfolio. ING is in
the process of refining the thresholds on a portfolio level. These have already been implemented for more
than 20 percent of the portfolio, resulting in deviating absolute lifetime PD thresholds.
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 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 that is optimised depending on the observed default rates and overall average riskiness
of the portfolio. While the scaling factor is associated with a whole portfolio/segment, the PD at origination
is facility-specific and, in this sense, the relative threshold may differ facility by facility.
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 said 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
In the table below 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 2021 and year-end 2022.
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.
Quantitative SICR thresholds\u00a0 (*)
2022
2021
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
2.7
2.3
2.7
2.2
Consumer Lending
2.8
1.8
2.8
1.7
Business Lending
2.8
2.1
4.0
2.2
Governments and Fin. Institutions
3.0
1.9
7.9
2.2
Other Wholesale Banking
2.8
1.9
4.5
2.0
As it is apparent from the disclosures above, as per ING\u2019s 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. In 3Q 2022, following up an ECB request, a
new backstop trigger was implemented. The new trigger forces Stage 2 classification in case the lifetime PD
at reporting date has increased more than three times with respect to the origination, regardless of the
actual staging thresholds in force for a given portfolio. The new requirement entails that the threshold ratio
in the table above is effectively capped at a threefold increase for December 2022. The effect of this trigger
is especially apparent in the average thresholds ratio for investment grade facilities when confronting 2021
and 2022 figures. Since for investment grade assets thresholds tend to be looser given the good quality of
underlying counterparties ratings, the backstop trigger is more impactful.
In terms of impact on ING portfolio, the application of the new backstop trigger resulted in an increase of
Stage 2 exposure. However, since the trigger impacts mainly good quality assets for which regular staging
thresholds are typically above a threefold increase in PD, the corresponding impact in provisions was
limited.
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 Bank level, the total model ECL, which is the ECL collective-assessment without taking
management adjustments into account, is \u20ac3,209 million (2021:\u00a0 \u20ac2,408 million) of which performing assets
constitute \u20ac1,884 million (2021: \u20ac1,003 million) . To demonstrate the sensitivity of the ECL to these PD
thresholds bands, an analysis was run on all collectively-assessed assets, which assumed all assets were
below the threshold (Stage 1) and apportioned a 12-month ECL. On the same asset base, analysis was run
which assumed all performing assets were above the threshold (Stage 2) and apportioned a lifetime ECL.
This gave rise to hypothetical collective-assessment ECLs of \u20ac1,348 million (2021: \u20ac634 million) and \u20ac3,391
million (2021: \u20ac2,232 million) respectively. Please note that in this analysis, all other ECL risk parameters
(except for the stage) were kept equal.
Market risk
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\u2019s 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. This means that financial instruments in
the trading books should be free of trade restrictions. 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.
ING recognises the importance of sound market risk management and bases its market risk management
framework on the need to identify, assess, control and manage market risks. The approach consists of five
recurring activities: risk identification, risk assessment, risk control, risk monitoring and risk reporting.
Governance (*)
A governance framework has been established defining specific roles and responsibilities of business
management units, market risk management units, and internal approval bodies per activity.
Supervision of market risk falls under the responsibility of the EB/MBB and is delegated to the ALCO function,
where ALCO Bank is the highest approval authority and sets the market risk appetite. ALCO Bank monitors
ING\u2019s adherence to the risk appetite for market risk and sets additional limits where appropriate. These limits
are cascaded through the organisation through lower level ALCOs. This ALCO structure facilitates top-down
risk management, limit setting, and the monitoring and control of market risk.\u00a0
FR maintains a limit framework in line with ING\u2019s Risk Appetite Framework. The businesses are responsible
for adhering to the limits which are reviewed on an annual basis and are ultimately approved by the ALCO
Bank. Limit excesses are reported to senior management in line with the ALM Limit excess reporting
procedure upon which the business needs to act accordingly. To adhere to the established limit framework,
ING implements hedging and risk mitigation strategies that range from the use of traditional market
instruments, such as interest rate swaps, to more sophisticated hedging strategies.
The organisational structure facilitates top-down risk management by recognising that risk taking and risk
management occur to a large extent at the regional/local level. Bottom-up reporting from regional/local
units to head office units allows each management level to assess the market risks relevant at the
respective levels.
Several committees govern communication between the parties involved in market risk management:
\u2022The Market Risk Model Committee (MRMC, reporting to ALCO Bank), is the dedicated authority within ING
for the approval of all funding and liquidity risk, banking and trading risk and counterparty credit risk
models, methodologies and related parameters. This is comparable with the CTRC, which reports into the
GCTP.
\u2022The Valuation Model Committee approves pricing models for trading and banking books.
Financial Risk provides risk reporting to the EB and MBB, the ALCO Bank and the senior executive
management of related business functions.
The following sections elaborate on the various elements of the risk management framework for:
\u2022Market risk economic capital (trading and banking books).
\u2022Market risks in banking books.
\u2022Market risks in trading books.
Market risk in banking books (*)
ING makes a distinction 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 it is centrally managed. The scheme below presents the transfer and
management process of market risks in the banking books:
Risk measurement (*)
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\u2019s earnings, capital, and market
value to adverse movements in interest rates originated from positions in the banking book.
Governance (*)
The management of interest rate risk follows the Interest Rate Risk in the Banking Book (IRRBB) framework
as approved by ALCO Bank. This framework describes roles, responsibilities, risk metrics, and the policies and
procedures related to interest rate risk management. Furthermore, ALCO Bank reviews and sets the risk
appetite for interest rate risk, on an annual basis. The risk appetite is translated into limits for the interest
rate risk metrics.
As a result of this framework, 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:
\u2022Investment of own funds.
\u2022Commercial business.
\u2022Group 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. The
main objective is to maximise the economic value of the capital investment book while having stable
earnings.
Commercial activities can result in linear interest rate risk, for example, tenors and duration of new
production and re-pricing of assets differ from those of liabilities. Also, interest rate risk can arise from
customer behaviour and/or convexity risk, depending on the nature of the underlying product
characteristics.
Customer behaviour risk is defined as the potential future (value) loss due to deviations in the actual
behaviour of clients versus the modelled behaviour towards the embedded options in commercial products.
General sources of customer behaviour risk, among other things, include 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 three main product
types: funds entrusted as savings and demand deposits, mortgages and loans.
Savings and demand deposits are generally invested in such a way that both the value is hedged\u00a0 and the
sensitivity of the margin to market interest rates is minimised. Interest rate risk can arise when there is a
misalignment between the change in market rates and adjustment of savings rates, which can either have
a positive or negative impact on the income as a consequence of the potential misalignment to the related
(assumption based) investment strategy of ING\u2019s savings. Interest rate risk is modelled based on the stability
of the deposit 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. Savings volumes are typically
assumed to be relatively stable and less sensitive to rate changes.
Interest rate risk for mortgages arises due to prepayment possibilities in these mortgages. In modelling this
risk, both interest rate dependent pre-payments and constant prepayments are considered. Next to a
dependence on interest rates, modelled prepayments may include other effects such as loan-to-value,
seasonality and the reset date of the loan. In addition, the interest sensitivity of embedded offered rate
options may be considered.\u00a0
Wholesale Banking loans typically do not experience interest rate dependent prepayment behaviour, 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 research. However, the substantial change in the interest rate environment makes extensive
research more challenging than before and may increase model risk. Models are backtested and updated
when deemed necessary in an annual procedure. Model parameters and the resulting risk measures are
approved by (local) ALCO.
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 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. However, 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 transferred from the
commercial books to treasury books using cap/floor contracts.
In the following sections, the interest rate risk exposures in the banking books are presented. ING uses risk
measures based on both an earnings and a value perspective. Net interest income (NII)-at-risk is used to
provide the earnings perspective and the net present value (NPV)-at-risk figures provide the value
perspective. Please note that the expected interest rate risk coming forward from the business is assumed
to be linearly hedged but no additional corrective management actions are taken into account in the NPV-
at-Risk measure. In the NII-at-Risk measure, a more dynamic hedging process is taken into account.
During 2022, the following activities related to the risk measurement for IRRBB were performed:
\u2022Annual review of the risk appetite for Market Risks in the Banking Book including further enhancement.
\u2022Further assessment and development of sub-risk types, such as tenor basis risk, vega optionality risk and
client behaviour risk.
\u2022Set up of standardised risk measurement related to climate risk.
\u2022Annual review of the interest rates scenarios used for calculating NII-at-Risk and NPV-at-Risk.
\u2022Annual savings/current account model updates.
\u2022Annual update of parameters of prepayment models for market developments.
\u2022A specific, internal firm-wide stress test relating to climate risk.
\u2022Further enhancement of the IRRBB framework in relation to upcoming regulatory requirements (e.g.
anticipation on implementation and measurement of the upcoming regulatory metric NII SOT,
development of additional requirements coming forward from latest EBA guidelines).
\u2022Improvement of the FX framework.
Net interest income (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 are included in this risk metric. NII-at-Risk is a metric
that helps provide insight to what extent ING's NII under our Dynamic Plan deviates from the interest rates
development assumed.
In its risk management, ING monitors the NII-at-Risk under a three-year timeframe. Interest rates are
stressed during the first year versus the prevailing curve, taking gradual changes over the first year. The rate
changes considered comprise both upward and downward scenarios, as well as parallel (equal movements
across the yield curve) and non-parallel scenarios.
The impact of changing interest rates on ING\u2019s NII is predominantly caused by the following factors:
\u2022Change in returns of (re-)investments of client deposits.
\u2022Change in deposits client rates (mainly savings), (partially) tracking changes in market interest rates.
\u2022Change in funding profile of mortgages, due to an expected increase or decrease in expected
prepayments.
\u2022Higher/lower returns of (re-)investments of capital investment.
\u2022Open interest rate positions, leading to changes in return because of different market rates.
\u2022Assumed 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 to
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,
amongst others, actual interest rate and savings client rate evolution, as well as changes to ING\u2019s 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 tables below reflect a parallel, linear interest rate movement during a year
('ramped') under the assumption of balance sheet developments in line with the ING's Dynamic Plan with a
time horizon of one year.
NII-at-Risk banking books per business\u00a0 - year one (*)
in \u20ac million
2022
2021
Ramped, unfloored
Ramped, unfloored
parallel \u25bc
parallel \u25b2
parallel \u25bc
parallel \u25b2
By business
Wholesale Banking
4
-47
46
-33
Retail Banking Benelux
-88
59
-122
132
Retail Challengers & Growth Markets
-41
113
-93
75
Corporate Line Banking
-18
18
-58
58
Total
-142
142
-226
232
EUR ramped (unfloored) is at +/- 100bps in 1 year
USD ramped (unfloored) is at +/- 120bps in 1 year
The NII-at-Risk is primarily driven by the difference in sensitivity of client liabilities, mainly savings, versus
the sensitivity of client assets and investments to rate changes. The investment of own funds only impacts
the earnings sensitivity marginally, as only a relatively small part has to be (re)invested within the one-year
horizon.
NII-at-Risk banking book per currency - year one (*)
in \u20ac million
2022
2021
Ramped, unfloored
Ramped, unfloored
parallel \u25bc
parallel \u25b2
parallel \u25bc
parallel \u25b2
By currency
Euro
-119
114
-181
179
US Dollar
-1
2
-23
23
Other
-23
27
-23
30
Total
-142
142
-226
232
NII. However, the main drivers in a potential change of NII sensitivity are balance sheet developments,
specifically relating to mortgages, loans and savings. In the eurozone, mortgage production was impacted
by an increase in interest rates. Next to the impact on new production, the prepayment incentive decreased
due to the increase in interest rates. The funds entrusted volume did not change significantly, The impact of
explicit and implicit floors on both rates of client assets and savings phased out in the course of the year on
the back of the interest rate increases. Pre-existing hedges, as executed by Group Treasury, were also
adjusted continuously throughout the year to hedge any interest rate risk coming from higher interest
rates. Given that Group Treasury is included in the Wholesale Banking risk numbers, these adjustments
changed the Wholesale Banking NII-at-Risk. Furthermore, ING\u2019s investment of own funds took place against
a lower duration reducing sensitivity. Excluding Model Risk, the total NII-at-Risk remains relatively limited in
comparison to ING\u2019s total interest income.\u00a0
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. This does not include positive earnings in our commercial books. The NPV-at-Risk is defined as the
outcome of an instantaneous increase or decrease in interest rates from applying currency-specific
scenarios. The NPV-at-Risk asymmetry between the downward and upward shock is mainly caused by
convexity risk in the mortgage and savings portfolio.
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.
NPV-at-Risk banking books per business (*)
in \u20ac million
2022
2021
unfloored
unfloored
parallel \u25bc
parallel \u25b2
parallel \u25bc
parallel \u25b2
By business
Wholesale Banking
-1,474
1,299
-1,477
1,444
Retail Banking Benelux
-307
-76
-953
-202
Retail Challengers & Growth Markets
1,327
-1,373
832
-1,111
Corporate Line Banking
1,049
-1,003
1,820
-1,712
Total
594
-1,153
223
-1,580
EUR (unfloored) +/- 100bp shock scenario
USD (unfloored) +/- 120bp shock scenario \u00a0
Year-on-year variance analysis (*)
The overall NPV sensitivity for the rates-up scenario decreased in 2022. This is mainly due to the shorter
duration at which ING strategically invests its own funds. These investments are done in the Corporate Line
Banking.
The changes in NPV-at-Risk in the segments Retail Benelux and Retail Challengers & Growth Markets were
partly offsetting, whereby the higher interest rates reduced the overall convexity. The resulting impact on
retail sensitivity of the increase in interest rates was hedged by Group Treasury in line with the internal ALM
practices. The Group Treasury exposure is reported under business line Wholesale Banking.
IBOR transition (*)
In line with the recommendations from the Financial Stability Board, a fundamental review of benchmarks
for important interest rates has been undertaken. Some interest benchmarks have been reformed, while
others have or will be replaced by risk-free rates (RFR) and discontinued. Following the cessation of GBP, CHF,
JPY, and EUR LIBOR rates on 31 December 2021, USD LIBOR will cease on 30 June 2023.
In 2022, the focus shifted to USD LIBOR, with new USD lending now using the recommended alternative
rates based on SOFR. This is consistent with guidance issued to limit the use of USD LIBOR from
1 January 2022 onward. Risk reduction trades to help manage the run-off of existing USD LIBOR contracts
and positions are a permitted exception.
To enable these changes, the financial sector has issued several guidance papers and other initiatives to
help phase this transition. For example, ISDA has issued an IBOR fallback supplement to help ensure clear
fallback rates apply upon the discontinuation of key IBORs. For loans, various recommendations have been
made to help ensure the inclusion of consistent robust fallback provisions. Public authorities have also
recognised that many contracts do not contain provisions for any alternatives, contain inappropriate
alternatives, or cannot be renegotiated prior to the expected cessation date (\u2018tough legacy\u2019 contracts). For
example, the Financial Conduct Authority (FCA) is expected to ask the USD LIBOR administrator to continue
publishing a 'synthetic' LIBOR rate for 15 months beyond the cessation date to provide extra time for any
remaining contracts. A similar action was taken for GBP and JPY LIBOR. The US has also implemented the
Adjustable Interest Rate (LIBOR) Act, that will revise the contractual terms of in scope contracts to reference
a rate based on SOFR upon cessation of USD LIBOR.
Due to the discontinuation of this important rate, ING, its customers, and the financial services industry face
a number of risks. These risks include legal, financial, operational, and conduct risk. Legal risks are related to
any required changes to existing transactions. Financial risks may arise due to declining liquidity and may
impact a contract directly or the ability to hedge the risks in that contract. Operational risks arise due to the
requirement to adapt IT systems, trade reporting infrastructure and operational processes. Conduct risk also
plays a role, as renegotiation of loan contracts requires active engagement from all parties to a contract,
and may lead to negotiations concentrated in a period close to actual cessation. ING continues to reach out
to impacted clients to manage the relevant timelines.
During 2022, ING sought to ensure that a large portion of the derivative portfolio is covered by ISDA
fallbacks. Regarding the loans, many facilities have already been transitioned to alternative rates.
Additionally, for the remaining portfolio the parameters for the required changes have been communicated
to counterparties, with many now in active discussions on the remaining steps.
The ING IBOR programme has governance in place with progress being tracked by business line steering
committees reporting to a central IBOR steering committee. The programme assesses and coordinates the
actions necessary to manage the required changes to internal processes and systems, including pricing, risk
management, legal documentation, hedge arrangements, as well as the impact on customers. ING
continues to monitor market developments and reform plans for other rates, to anticipate the impact on
the programme, our customers and any related risks.
One such development concerns key Polish Zloty benchmarks. The roadmap published by the Polish
National Working Group in 2022 indicates that the plan is for the market to be ready for a cessation of
WIBOR and WIBID Reference Rates in 2025. It is expected that the reform will be completed by the end of
2024, with the offering of financial products using the new benchmark (WIRON) to progress gradually in
2023 and 2024. 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.
As at 31 December 2022, ING has exposures that have yet to transition related to USD LIBOR and WIBOR.
The tables below summarise these approximate exposures. They exclude exposures that will expire before
the transition date 30 June 2023 and 1 January 2025, respectively. The GBP LIBOR, CHF LIBOR and EONIA
contracts included as at 31 December 2021 have all transitioned or matured.
Non derivative Financial instruments to transition to alternative benchmarks (*)
in \u20ac million at 31 December 2022
Financial Assets non-
derivative
Financial Liabilities\u00a0
non-derivative
Off balance sheet
commitments
Carrying value
Carrying value
Nominal value
By benchmark rate
GBP LIBOR
USD LIBOR
30,040
1,637
7,644
CHF LIBOR
EONIA
WIBOR
22,154
1,411
Total
52,194
1,637
9,055
Non derivative Financial instruments to transition to alternative benchmarks (*)
in \u20ac million at 31 December 2021
Financial Assets non-
derivative
Financial Liabilities\u00a0
non-derivative
Off balance sheet
commitments
Carrying value
Carrying value
Nominal value
By benchmark rate1
GBP LIBOR
764
350
USD LIBOR
41,805
1,542
16,435
CHF LIBOR
1
EONIA
23
184
Total
42,570
1,565
16,969
1 WIBOR transition plans became concrete in 2022 and therefore no comparatives for 2021 are included.
For derivatives linked to USD LIBOR, the conduct risk is limited as the majority are transacted with clearing
houses, which will transition through a standardised exercise in the second quarter of 2023. For USD LIBOR
derivatives that are not centrally cleared, the main transition will occur via the ISDA IBOR fallback protocol at
30 June 2023.
Derivative Financial instruments to transition to alternative benchmarks (*)
31 December 2022
31 December 2021
in \u20ac million
Nominal value
Nominal value
By benchmark rate1
GBP LIBOR
822
USD LIBOR2
495,318
488,499
WIBOR3
136,318
Total
631,636
489,321
1 For cross-currency swaps all legs of the swap are included that are linked to a main IBOR that is significant to ING.
2 The prior period has been updated to improve consistency and comparability.
3 WIBOR transition plans became concrete in 2022 and therefore no comparatives for 2021 are included.
In addition to the amounts in the table above, ING has interest rate swaptions that refer to the USD LIBOR
ICE swap rate with a notional of \u20ac10,810 million (2021: \u20ac10,343 million) that are yet to transition. The
transition of these contracts is in general governed by a specific ISDA protocol.
Given that IBOR Reform may have various accounting implications, the International Accounting Standards
Board (IASB) has undertaken a two-phase project:
\u2022Phase 1 addresses those issues that affect financial reporting before the replacement of an existing
benchmark. Phase 1 amendments to IFRS were issued by the IASB in 2019 and were early adopted by
ING in the same year. This allows ING to apply a set of temporary exceptions to continue hedge
accounting even when there is uncertainty about contractual cash flows arising from the reform. Under
these temporary exceptions, interbank offered rates are assumed to continue unaltered for the purposes
of hedge accounting until such time as the uncertainty is resolved.
\u2022Phase 2 focuses on issues that may affect financial reporting when the existing benchmark rate is
reformed or replaced. Phase 2 amendments to IFRS were issued by the IASB in 2020 and became
effective in 2021. Phase 2 amendments to IFRS relate mainly to accounting for changes in the basis for
determining the contractual cash flows of financial assets and liabilities due to the IBOR reform and
impact on hedge accounting when an existing benchmark rate is reformed or replaced with an
alternative risk-free rate.
Specifically, Phase 2 amendments require that the effective interest rate on debt financial instruments is
adjusted, and hedge accounting continues on transition to risk free rates, but only to the extent that the
modifications made to financial instruments are those necessary to implement the IBOR Reform and that
the new basis for calculating cash flows is \u2018economically equivalent\u2019 to the previous basis. By applying these
mandatory amendments, ING avoids recognising modification gains and losses on debt instruments that
would otherwise be required in the absence of Phase 2 amendments (changes to debt instruments resulting
from IBOR Reform are treated as a reset to the instrument\u2019s variable interest rate). In addition, ING avoids
hedge accounting discontinuations when modifying both hedged items and hedging instruments (and
related hedge documentation) as a consequence of IBOR reform that would otherwise be required in the
absence of Phase 2 amendments.\u00a0
As explained above, Phase 1 and Phase 2 IBOR amendments to IFRS, amongst other changes, provide
specific hedge accounting reliefs that allow hedge accounting relationships to continue when IBOR Reform is
ongoing. Phase 1 reliefs cease to apply when uncertainty arising from IBOR Reform is no longer present with
respect to the timing and amount of the IBOR-based cash flows of the relevant instruments. It is ING\u2019s policy
to cease to apply Phase 1 reliefs when the applicable contract (either hedging instrument or hedged item) is
actually modified. As a result, for these hedge accounting relationships the applicable Phase 1 reliefs ceased
to apply and Phase 2 became applicable. For USD LIBOR exposures, and although the administrator of LIBOR
confirmed on 5 March 2021 its plans for the cessation of USD LIBOR rates at the end of June 2023, there is
still uncertainty with respect to the timing of the transition as well as the transition strategy for individual
hedged items and/or hedging instruments linked to USD LIBOR. Therefore, for USD LIBOR 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, Phase 2 reliefs will become applicable.
In addition, in 2022 ING started to apply Phase 1 reliefs to the hedge accounting relationships linked to
WIBOR as there is uncertainty arising from the WIBOR reform with respect to the timing and the amount of
the underlying cash flows to which ING is exposed.
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.
Governance \u2013 Core banking business (*)
Every business unit hedges the FX risk resulting from core banking business activities into its base currency.
Consequently, assets and liabilities are matched in terms of currency.
Governance \u2013 FX translation result (*)
ING\u2019s 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. 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 \u2013 FX translation result (*)
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 Market Risk Banking Book RAS.
Foreign currency exposures banking books (*)
in \u20ac million
Foreign Investments
Hedges
Net exposures
2022
2021
2022
2021
2022
2021
US dollar1
10,470
8,218
-2,376
-99
8,093
8,119
Pound sterling
1,364
1,593
-58
1,306
1,592
Polish zloty
2,714
2,761
-321
-142
2,393
2,620
Australian dollar
3,781
3,774
-2,673
-2,511
1,108
1,263
Turkish lira
750
729
750
729
Chinese yuan
1,871
1,976
-107
1,871
1,869
Russian rouble
391
256
-174
392
82
Other currency
5,740
5,860
-3,761
-3,453
1,979
2,407
Total
27,081
25,167
-9,189
-6,486
17,892
18,681
Hyperinflation accounting and goodwill impairment had limited impact on the Turkish lira FX exposure to the CET1 Ratio.
The structural Turkish lira exposure arising from ING Bank Turkey\u2019s assets and liabilities remains within risk limits.
Equity price risk in banking books (*)
Governance (*)
ING maintains a strategic portfolio with substantial equity exposure in its banking books. Local offices are
responsible for the management of the equity investment positions. Financial Risk is responsible for
monitoring the regulatory capital for equity investments on a monthly basis and acts independently from
ING/local management when monitoring these positions.
Risk profile (*)
Equity price risk arises from the possibility that an equity security\u2019s price will fluctuate, affecting the values
of the equity security itself as well as other instruments whose value react similarly to the particular
security, a defined basket of securities, or a securities index. ING\u2019s equity exposure mainly consists of the
investments in associates and joint ventures of \u20ac1,500 million (2021: \u20ac1,587 million) and equity securities
held at fair value through other comprehensive income (FVOCI) of \u20ac1,887 million (2021: \u20ac2,457 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.
Year-on-year variance analysis (*)
In 2022, the revaluation reserve equity securities decreased by \u20ac95 million from \u20ac1,282 million to \u20ac1,187
million. In 2022, the equity securities at fair value through OCI decreased by \u20ac570 million mainly due to
divestment of HQLA eligible equity instruments.
Revaluation reserve equity securities at fair value through other comprehensive income (*)
in \u20ac million
2022
2021
Positive re-measurement
1,190
1,291
Negative re-measurement
-4
-9
Total
1,187
1,282
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 2022, 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.
Governance (*)
The Financial Markets Risk Committee (FMRC) is the market risk committee that, within the risk appetite set
by the ALCO Bank, sets the market risk limits both on an aggregated level and on a desk level. Financial Risk/
Trading Risk Management (FR/ TRM) advises both FMRC and ALCO Bank on the market risk appetite of the
trading activities.
With respect to the trading portfolios, 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. Trading activity is
systematically reviewed and positioned against the mandates are assessed jointly by the first and second
lines of defence.
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 Event Risk (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.
As of June 2022, ING has received an official permission from the ECB to perform offsetting of positions with
the exception of Ukraine, Russia and Turkey. Hence the regulatory capital numbers reported from Q2 2022
onwards, are calculated with offsetting for all base entities excluding Ukraine, Turkey\u00a0 and Russia.
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%, 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) if 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 e.g. 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\u2019s portfolio is estimated, based on
equally weighted observed market movements of the previous year (260 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 ten-day horizon the one-day risk factor shifts are scaled by the
square root of ten 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: HVaR 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
ten 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 results (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 \u2018outlier\u2019 occurs. Based on ING\u2019s one-sided confidence level of 99%, an outlier is expected once in every
100 business days.
On an overall level in 2022, there were five outliers for hypothetical P&L and three outliers for actual P&L.
The actual and hypothetical outliers occurred during the past one year concentrated in 1Q2022 mainly due
to large moves in Russian credit default swaps and Rouble volatility.
Stressed HVaR (*)
The Stressed HVaR (SVaR) is intended to replicate the HVaR calculation that would be generated on the
bank\u2019s current portfolio with inputs calibrated to the historical data from a continuous 12-month period of
significant financial stress relevant to the bank\u2019s portfolio.
To calculate SVaR, ING uses the same model that is used for 1DHVaR, with a ten-day horizon. The data for
the historical stress period used currently includes the height of the credit crisis around the fall of Lehman
Brothers, and this choice is reviewed regularly. 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% 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 are 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.
Stress testing and event risk (*)
Stress testing and event risk are valuable risk management tools. In addition to the bank-wide stress test
framework as described in the stress-testing section, FI-FM Risk performs additional assessments, specific to
the trading book, with various frequencies: sensitivity analyses (single-risk factor and multi-risk factor), ad-
hoc stress tests (e.g. Covid-19 scenarios) and structured stressed scenario tests under the event risk
framework - to monitor market risks under extreme market conditions. Event risk evaluates the bank\u2019s
financial stability under severe but plausible stress scenarios and assists in decision-making aimed at
maintaining a financially healthy going-concern institution after a severe event occurs. Event risk is based
on historical as well as hypothetical extreme scenarios. The result is an estimate of the profit and loss
caused by a potential event and its worldwide impact for ING.
ING\u2019s event risk policy is based on a large set of possible stress scenarios per risk type. 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. For equity products, for example, both a crisis scenario
(prices decrease) as well as a bull scenario (prices increase) are assumed. Scenarios are calculated based on
events happening independently, jointly by region, or in all countries simultaneously. This way, for each risk
type, a large set of scenarios is calculated. The worst scenarios per market are combined across markets by
assessing both independent events per market, and the worst events happening in all markets at the same
time.
Sensitivities (*)
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 \u20ac million
2022
2021
Foreign exchange
Foreign exchange
US Dollar
-187
US Dollar
-160
Romanian Leu
88
Taiwan Dollar
42
Japanese Yen
86
Romanian Leu
32
Chinese Yuan
32
Japanese Yen
27
South Korean Won
28
South Korean Won
-24
Most important interest rate and credit spread sensitivities at year-end (*)
in \u20ac thousand
2022
2021
Interest Rate (BPV) 1
Interest Rate (BPV) 1
Euro
-334
Euro
-501
British Pound
-95
US Dollar
185
US Dollar
-79
British Pound
-75
Taiwan Dollar
67
Taiwan Dollar
73
Japanese Yen
63
Japanese Yen
-57
Credit Spread (CSO1) 2
Credit Spread (CSO1) 2
Netherlands
162
Netherlands
535
United States
151
Germany
408
Japan
102
United States
171
France
88
France
112
Germany
87
China
110
Funding and liquidity adequacy and risk appetite (*)
ING identifies various key drivers of future liquidity and funding needs on an ongoing basis and through the
periodic risk identification process. Taking into consideration the identified drivers, ING regularly assesses its
current and future liquidity adequacy and, if deemed necessary, takes steps to further improve ING\u2019s
liquidity position and to have sufficient counterbalancing capacity. A liquidity adequacy statement is
formulated on at least a quarterly basis to substantiate and reflect the management view on the current
funding and liquidity position as well as the potential future challenges. The quarterly liquidity adequacy
statement is an important part of ING\u2019s ILAAP process.
ING assesses its F&L adequacy through three lenses \u2013 stress, economic and normative:
\u2022Through the stress lens, ING evaluates its ability to withstand a period of prolonged F&L stress for both
normative and economic requirements or limits under idiosyncratic, market-related or a combination of
idiosyncratic and market-related scenarios, which lead to customer deposit outflows, deterioration of
access to funding markets, and lower liquidity value of counterbalancing capacity.
\u2022Through the economic lens, ING assesses the extent to which its customers, professional counterparties
and investors are comfortable in providing deposits and funding in tenors, currencies and instruments
necessary to sustainably fund the business (intraday, short-term and long-term) in a going-concern
situation.
\u2022Through the normative lens, ING ascertains that the bank is in the position to meet current and
forthcoming home and host regulatory requirements.
For each lens, ING has established a related set of risk appetite statements which define ING\u2019s risk appetite
commensurate with the principles of liquidity adequacy. These risk appetite statements are summarised in
the next graph.
The F&L risk appetite statements are translated into a number of metrics with appropriate boundaries and
instruments which are used to measure and manage ING\u2019s 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 (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\u2019s risk appetite and normative
requirements.
The macroeconomic and market environment are also important considerations in ING\u2019s funding and
liquidity framework. The macroeconomic environment comprises various exogenous factors over which ING
has no control, but which may have a material impact on ING\u2019s F&L position. The main macroeconomic
factors analysed on a regular basis include:
\u2022Global and local economic performance e.g. shifts in GDP, inflation rates, unemployment rates and public
deficit/surplus.
\u2022Changing geopolitical trends.
\u2022Monetary policy with a focus on the unconventional monetary measures employed by central banks in
recent years including the measures taken since the start of the Covid-19 crisis and the more recent
period of increased inflation.
\u2022Regulatory requirements, e.g. understanding the changing regulatory landscape as well as the impact of
ING\u2019s 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.
Liquidity stress-testing (*)
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\u2019s 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 Bank, 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 and combined (idiosyncratic and market-
wide) stress scenarios. The design of the framework is based on empirical evidence supplemented by expert
judgement. 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\u2019s F&L risk framework and F&L risk
management, including:
\u2022Risk Appetite Framework (through risk appetite statements).
\u2022Risk identification and assessment.
\u2022Monitoring of the liquidity and funding position.
\u2022Business actions (if needed).
\u2022Contingency funding plan.
\u2022Early 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\u2019s liquidity position is stress tested at least monthly 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 regular 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
2022, this included stress-test scenarios dedicated to the war in Ukraine, inflation, and the impact of
monetary tightening. The internal stress scenarios also serve as input for decision making on additional
contingency measures.
Contingent F&L risks are addressed in the Contingency Capital and Funding Plan with a focus on early
warning indicators as well as organisation and planning of liquidity management in times of stress. The
contingency funding measures are developed in conjunction with the ING Recovery Plan and are tested on a
regular basis.
Governance (*)
The head of Model Risk Management (MoRM) reports to the ING chief risk officer. The Model Risk
Management Committee (MoRMC) is the dedicated authority within ING for model risk management. It is a
committee designated by the MBB. It is chaired by the ING chief risk officer and co-chaired by the head of
MoRM.
Model lines of defence (*)
ING\u2019s model risk and control structure is based on the three model lines of defence (MLoD) approach. This
approach aims to provide a sound governance framework for model risk management by defining and
implementing three different management layers with distinct roles and oversight responsibilities.
The composition and main activities within the three model lines of defence (MLoD):
\u2022The first MLoD is composed of the model owners, model users, data management and model
development, and is accountable for the implementation of model risk controls which encompass model
development, implementation and use of the models as well as monitoring of models\u2019 performance.
\u2022The second MLoD is composed of model validation and model risk oversight, which owns the model risk
management framework, proposes the model risk appetite, provides challenge to model risk
identification and assessment and provides an independent validation of models used within ING.
\u2022The third MLoD is the internal audit, reviewing the quality of model risk management execution in all
lines of defence and providing assurance over the first and second line model risk management
activities.
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. Current model RAS metrics are focused on the most important models for ING: credit
risk and other models with elevated supervisory attention. These metrics are reported to the MBB on a
quarterly basis.
Model risk management (MoRM) (*)
The MoRM policy framework comprises the total set of measures and tools put in place to manage model
risk.To enable setting model risk management standards that are proportionate to a model\u2019s importance,
ING classifies models based on their materiality and reputational risk. The classification determines the
depth and extent of the applied model risk management activities, including model validation. During 2022,
the MoRM policy framework was updated and enhanced, incorporating ING model data-ethics principles and
integrating a risk-based approach to model validation. Next to the generic MoRM policy framework,
dedicated model validation frameworks are in place. These set the validation standards for the key model
types such as credit, market, liquidity, operational risk, IRRBB, KYC, and other model categories. These
frameworks are continuously being enhanced to keep up-to-date with regulatory and technical
developments.
On an aggregated level model risk is monitored via analysis of data from the global model inventory. The
insights, from aggregated data analysis, are reported to the MoRMC and to the MBB so that senior
management can take well-informed decisions on acceptance or further mitigation of model risk.
Model lifecycle (*)
The next figure provides a schematic overview of the model lifecycle, where orange represents the activities
of the first MLoD, grey represents the second MLoD and light grey is the third MLoD. The objectives of the
different processes are outlined below.
Initiation or change: The initiation of the development of a new model or change in an existing model can
be triggered by internal or external factors, such as business needs, regulation changes and/or model
validation findings.
Data collection is the process of defining and collecting data that meets the requirements for model
development. The process includes the definition of the data needed and assessment of data availability
and data quality.
Model development is a structured process that leads to a model that is consistent with the model owner
requirements, bank policy and relevant regulation where applicable.
Pre-approval validation is an independent assessment to determine whether a newly developed or
materially changed model is valid for its intended use. The approach to model validation is proportional to
the model risk as reflected in the ING model risk classification.
The objective of the model approval stage is to ensure models are formally approved bye the designated
approval authority prior to deployment.
During the implementation stage, the model is deployed in a production environment, after completion of
required model testing and corresponding approval.
In the model use stage the model is applied by the users for the specific purpose for which it was designed.
The model may only be used after formal approval.
The objective of model monitoring is to determine if the model is performing as expected by regularly
assessing model accuracy and/or predictive ability, considering internal or external developments that may
influence model performance. Model performance monitoring begins when a model is deployed for use and
continues until the model has officially been decommissioned.
Periodic validation assesses, on a regular basis, whether a model is still valid for its intended use and if the
model is used as intended, taking into consideration any internal or external changes since the last
validation. The frequency of periodic validation depends on the model risk, model type and applicable
regulation.
A model that is/will no longer be used must be decommissioned.
1.2.1\u00a0 Presentation of Risk management disclosures
To improve transparency, reduce duplication and present related information in one place, certain
disclosures of the nature and extent of risks related to financial instruments required by IFRS 7 \u2018Financial
instruments: Disclosures\u2019 are included in the \u2018Risk management\u2019 section of the Annual Report.
These disclosures are an integral part of ING Bank Consolidated financial statements and are indicated in the
\u2018Risk management\u2019 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.
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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 ING Bank 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 also includes additional disclosures beyond those required by IFRS
standards, 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 to the accounting basis of measurement. Examples of such differences include
the exclusion of accrued interest and certain costs and fees from risk data, and timing differences in
exposure values (IFRS 9 models report expected credit loss on underlying exposures). Disclosures in
accordance with Part Eight of the CRR2 and CRD V, and as required by the supervisory authority, are
published in our \u2018Additional Pillar III Report\u2019, which can be found on our corporate website ing.com.
1.2\u00a0 Basis of preparation of the Consolidated financial statements
The ING Bank Consolidated financial statements have been prepared in accordance with International
Financial Reporting Standards (IFRS) as adopted by the European Union (EU) and the relevant articles of Part
9 of Book 2 of the Dutch Civil Code.
IFRS as adopted by the EU are IFRS Standards and IFRS Interpretations as issued by the International
Accounting Standards Board (IASB) and the IFRS Interpretations Committee (IFRIC) with some limited
modifications such as the temporary \u2018carve-out\u2019 from IAS 39 \u2018Financial Instruments: Recognition and
Measurement\u2019 (herein, referred to as IFRS).
Under the EU carve-out, ING Bank applies fair value hedge accounting to portfolio hedges of interest rate risk
(macro hedging). For further information, reference is made to paragraph 1.7.4 \u2018Derivatives and hedge
accounting\u2019 of this note and to Note 36 'Derivatives and hedge accounting'.
The ING Bank Consolidated financial statements have been prepared on a going concern basis and there are
no significant doubts about the ability of ING Bank 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.
1.2.1\u00a0 Presentation of Risk management disclosures
To improve transparency, reduce duplication and present related information in one place, certain
disclosures of the nature and extent of risks related to financial instruments required by IFRS 7 \u2018Financial
instruments: Disclosures\u2019 are included in the \u2018Risk management\u2019 section of the Annual Report.
These disclosures are an integral part of ING Bank Consolidated financial statements and are indicated in the
\u2018Risk management\u2019 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.
", "dimensions": { "concept": "ifrs-full:DisclosureOfBasisOfPreparationOfFinancialStatementsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8zNC9mcmFnOjcxODZmYWViNTZiOTRhYWViZTQ2ZDc3OTg1MjQ2ZDY1L3RleHRyZWdpb246NzE4NmZhZWI1NmI5NGFhZWJlNDZkNzc5ODUyNDZkNjVfMTY0OTI2NzYzNDM3MQ_c9c41653-96f6-4e54-bd59-322b8cbef359": { "value": "
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 ING Bank 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 also includes additional disclosures beyond those required by IFRS
standards, 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 to the accounting basis of measurement. Examples of such differences include
the exclusion of accrued interest and certain costs and fees from risk data, and timing differences in
exposure values (IFRS 9 models report expected credit loss on underlying exposures). Disclosures in
accordance with Part Eight of the CRR2 and CRD V, and as required by the supervisory authority, are
published in our \u2018Additional Pillar III Report\u2019, which can be found on our corporate website ing.com.
Risk governance (*)
Effective risk management requires company-wide risk governance. ING\u2019s risk and control structure is based
on the \u2018three lines of defence\u2019 governance model. 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 MBB, the EB and the SB, and this approach is cascaded throughout ING.
The heads of ING\u2019s banking business and support functions and the heads of the country units, or their
delegates, are the first line of defence. They have primary ownership, and accountability and responsibility
for assessing, controlling and mitigating all financial and non-financial risks affecting their businesses, as
well as for the completeness and accuracy of the financial statements and risk reports with respect to their
areas of responsibility. The CTO is responsible and accountable for proper security and controls of global
applications and IT platforms servicing the bank and implementing proper processes. The COO domain
builds bridges within ING linking to almost every part of the bank. Its purpose is to drive secure and efficient
processes for customers and colleagues.
The second line of defence consists of oversight and specialised functions in risk management and
compliance. They (1) have co-responsibility for risk management, through articulating and translating the
risk appetite into methodologies and policies to support and monitor business management's control of risk,
(2) objectively challenge risk management execution and control processes and coordinate the reporting of
risks and controls by the first line of defence, (3) advise on risk management and compliance and have
decision-making power in relation to business activities that are judged to present unacceptable risks to ING
and (4) can set minimum requirements in terms of quality and quantity of global resourcing in the risk
management and compliance functions.
The internal audit function forms the third line of defence. It provides independent assurance to the Audit
Committee, the EB and the MBB on the quality and effectiveness of ING\u2019s internal control, risk management,
governance and implemented systems and processes in both the first and second lines of defence. To
protect its independent nature, decisions regarding the appointment, reappointment or dismissal from
office as well as the remuneration package of the head of the internal audit function require SB approval.
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.
\u2022The SB is, for risk management purposes, advised mainly by the Risk Committee, which assists and
advises in monitoring the risk profile and approving the overarching risk appetite of the company as well
as the structure and effective operation of the internal risk management and control systems.
\u2022The EB is responsible for managing risks associated with all activities of ING Group, whereas the MBB is
responsible for managing risks associated with all activities of ING Bank. The EB and MBB responsibilities
include ensuring that internal risk management and control systems are effective and that ING Group
and ING Bank comply with relevant legislation and regulations. On a regular basis, the EB and MBB report
on these issues and discuss the internal risk management and control systems with the SB. On a
quarterly basis, the EB and MBB report on ING\u2019s risk profile versus its risk appetite to the Risk Committee,
explaining changes in the risk profile.
As a member of the EB and the MBB, the CRO is primarily responsible for: (i) supporting the board in its
engagement with and oversight of the development of the risk appetite and risk appetite statements and
for translating the risk appetite into a risk limits structure, actively engaged in monitoring performance
relative to risk-taking and risk limit adherence; (ii) setting up the risk management framework and
overseeing the development and implementation of risk and compliance policies, processes, models,
compatible methodologies including both forward-looking and backward-looking tools, ongoing
strengthening of risk management/people capabilities and reports, as necessary to ensure the effectiveness
of robust internal control and risk systems to fully support its strategic objectives and all of its risk-taking
activities; (iii) regularly providing comprehensive information on risks to the Management Board, the Risk
Committee and other relevant functions; and (iv) advising about the current risk profile, current state of the
risk culture, utilisation against the established risk appetite, and limits, limit breaches and mitigation plans.
For more on the SB and EB roles and responsibilities see \u2018Corporate Governance\u2019.
Executive level (*)
The risk committees described below act within the overall risk policy and delegated authorities granted by
the MBB:
\u2022Global Credit and Trading Policy Committee (GCTP) discusses and approves policies, methodologies, and
procedures related to credit, trading, country, and reputation (i.e. environmental and social risk or ESR)
risks. The GCTP meets monthly. After the MBB and the GCTP, the Credit and Trading Risk Committee
(CTRC) is the highest-level body authorised to discuss and approve policies, methodologies, and
procedures related to credit and trading risk.
\u2022Global Credit Committee \u2013 Transaction Approval (GCC(TA)) discusses and approves transactions that
entail taking credit risk (including investment risk), country, legal, and environmental and social risk. The
GCC(TA) meets twice a week.
\u2022Non-Financial Risk Committee Bank (NFRC Bank) 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, measurement, mitigating and monitoring/
reporting. NFRC Bank meetings are held at least quarterly.
\u2022The Model Risk Management Committee (MoRMC) discusses and steers, on a monthly basis, the overall
model strategy. MoRMC discusses and approves policies and methodologies related to model risk
management.
\u2022Global Data Committee (GDC) oversees (identifies, measures, responds to change and monitors) the
Global\u00a0 Data function and its contribution to wider society. The GDC meets every two months.
Further, in the Asset and Liability Committee Bank (ALCO Bank) risk related topics are discussed as well.
Regional and business unit level (*)
ING\u2019s 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.
The regional and/or business unit (BU) head of risk are involved in these activities. The local (regional and BU)
head of risk is responsible for the analysis, monitoring and management of risks across the whole value
chain (from front to back office). The local risks are discussed in local risk committees that roll up to the key
risk committees at executive level. Local Client Integrity Risk Committees (CIRCs) assess client integrity risk
and they have a final decision on client acceptance or client off-boarding, from a risk-based perspective, in
the areas of financial crime, Foreign Account Tax Compliance Act (FATCA), Common Reporting Standard
(CRS) and ESR.
Organisational structure (*)
The Risk CRO function is organised along the lines of a matrix structure integrating (1) the Global Risk
functions, (2) the Regional/Country Risk functions at entity level, and (3) the Risk Segments, with a uniform
methodology and terminology, so that a holistic view of all risks is ensured. 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, ensuring a uniform taxonomy and methodology is 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 following organisation chart illustrates the reporting lines in 2022 for the risk management
organisation. The fixed lines reflect hierarchical reporting lines, whereas the dotted lines are for the
functional reporting lines:
Risk policies, procedures and standards (*)
ING has a framework of risk management policies, procedures, and minimum standards in place to create
consistency throughout the organisation, and to define requirements that are binding for all business units.
The goal of the governance framework of the local business units is to align with ING\u2019s framework and to
meet local (regulatory) requirements. Senior management is responsible for the implementation of and
adherence to policies, procedures and standards. Policies, procedures and standards are regularly reviewed
and updated via the relevant risk committees to reflect changes in requirements, markets, products and
practices.
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.
Governance (*)
ING\u2019s credit risk strategy is to maintain an internationally diversified loan and bond portfolio, while avoiding
large risk concentrations. The emphasis is on managing business developments within the business lines by
means of a top-down risk appetite framework (RAF), which sets concentration limits for countries, individual
clients, sectors, products, secondary risk (collateral/guarantees) and investment activities. The aim is to
support relationship banking activities, while maintaining internal risk/reward guidelines and controls.
A new Credit Risk department was established in 2022. This department is responsible for setting the credit
risk strategy for ING and aims to ensure credit risk and credit restructuring are managed from an
overarching point of view rather than per business line. The head of Credit Risk is supported by the following
teams within this new department:
\u2022Portfolio, Strategy & Governance team: responsible for setting up credit risk strategies and risk appetite
statements, performing analysis and monitoring of the credit risk position of ING, as well as setting and
maintaining the credit risk framework and policies.
\u2022Credit Risk Control Unit: responsible for the design or selection, implementation, oversight and
performance of the rating systems.
\u2022Global Credit Risk Restructuring: responsible for a safe, compliant and data driven credit loss process by
managing loan loss provisioning and finding solutions for business customers in financial difficulty. The
team focuses on management of the global loan loss provisioning, not only of individual WB provisions,
but also collective WB and Retail Banking provisions.
While the Credit Risk department has oversight of the Bank credit risk strategy and risk appetite across
Retail Banking risk and Wholesale Banking risk, the head of Retail/Rest of World (RoW) Risk and head of
Wholesale Banking Risk aim to ensure the management of the risk within these business lines. Also refer to
the Risk governance and organisational structure in the introductory section of the Risk management
chapter.
The credit risk function encompasses the following activities:
\u2022Measuring, monitoring and managing credit risks in the bank\u2019s portfolio, including the measures taken in
response to the war in Ukraine.
\u2022Challenging and approving new and modified transactions and borrower reviews.
\u2022Managing the levels of provisioning and risk costs, and advising on impairments.
\u2022Providing consistent credit risk policies, systems and tools to manage the credit lifecycle of all activities.
Credit risk categories (*)
In the following table the different types of credit risk categories are described and a reconciliation with the
notes in the financial statements is also included:
Reconciliation between credit risk categories and financial position (*)
Credit risk categories
Notes in the financial statements
Lending risk: is 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.
Note
2
Cash and balances with central banks
Note
3
Loans and advances to banks
Note
4
Financial assets at fair value through profit
or loss
Note
5
Financial assets at fair value through other
comprehensive income
Note
7
Loans and advances to customers
Note
41
Contingent liabilities and commitments
Investment risk: is the credit default and risk rating migration risk
that is associated with ING\u2019s 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.
Note
4
Financial assets at fair value through profit
or loss
Note
5
Financial assets at fair value through other
comprehensive income
Note
6
Securities at amortised cost
Money market risk: arises when ING places short-term deposits
with a counterparty in to manage excess liquidity. In the event of
a counterparty default, ING may lose the deposit placed.
Note
2
Cash and balances with central banks
Note
3
Loans and advances to banks
Note
7
Loans and advances to customers
Pre-settlement risk: 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).
Note
4
Financial assets at fair value through profit
or loss
Note
14
Financial liabilities at fair value through
profit or loss
Note
40
Offsetting financial assets and liabilities
Settlement risk: 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.
Note
4
Financial assets at fair value through profit
or loss
Note
11
Other assets
Note
14
Financial liabilities at fair value through
profit or loss
Note
16
Other liabilities
1 Based on credit risk measurement contained in lending, pre-settlement, money market and investment activities.
2 Based on the total amount of credit risk in the respective column using ING\u2019s internal credit risk measurement methodologies. Economic sectors (industry) below 2% are not shown separately but grouped in Other.
3 Geographical areas are based on country of residence, except for private individuals for which the geographical areas are based on the primary country of risk.
Overall portfolio (*)
During 2022, ING\u2019s portfolio size increased by \u20ac24.0 billion (+2.62%) to \u20ac937.7 billion outstandings. The net
volume growth was spread across all the business lines. Foreign exchange rate changes had a positive
impact on portfolio growth, mainly in WB, and increased total outstanding by \u20ac6.3 billion, driven by the
appreciation of the US dollar (+6.2%) against the euro, partially compensated by the British pound sterling
(-5.3%), the Polish new zloty (-1.8%), and new Turkish lira (-23.7%).
Rating distribution (*)
Overall, the rating class distribution remained stable in 2022. The share of investment grade rating classes
increased from 75.1% to 76.2%, while the share of non-investment grade decreased, from 23.2% to 21.7%.
Sub-standard grade outstandings increased from 0.4% to 0.8% of the total portfolio, whereas non-
performing loans decreased from 1.3% to 1.2%.
With respect to the rating distribution within the business lines, in WB, investment grade increased to 81.2%
(from 79.7%), where non-investment grade exposures decreased to 16.8% (from 19.1%) compared to 2021.
Substandard grade assets increased from 0.2% to 1.0% of total Wholesale Banking assets, primarily as a
result of increases in Russia, in the natural resources industry. The share of non-performing loans for WB
remained stable at 1.0% (from 0.9%).
The rating distribution for Retail Benelux improved mostly because of Dutch residential mortgages, shifting
from rating class BB/BBB to A. The share of A-rated mortgages increased from 9.3% to 24.0% of the
portfolio. In Belgium, residential mortgages showed a modest increase of BBB assets, from single A.
Substandard grade Belgium mortgage outstandings increased to 1.0% (from 0.8%).
In Retail Challengers & Growth Markets, the distribution across rating classes remained rather stable in 2022.
Overall share of investment grade decreased from 76.1% to 75.2%, NPL decreased to 1.0% (from 1.3%).
Industry (*)
In line with our objective to give stakeholders insight into the portfolio, we present the business lending
portfolio per industry breakdown in accordance with the NAICS definition. The industry composition within
Retail is concentrated in private individuals with 65.0% for Retail Benelux and 76.0% for Retail Challengers &
Growth Markets.
In Market Leaders, the overall volumes increase is mainly explained by Belgium (+4.7%), whereas the
Netherlands remained stable in 2022 (+1.1%). In C&G, the increase in volume is in private individuals,
primarily in Germany, and to a lesser extent in Australia and Spain. A decrease in France is explained by the
discontinuation of retail activities. Within WB, an increase in exposures is noted mainly in non-bank financial
institutions (NBFI) of \u20ac7.7 billion (notably in Germany, France and the US). Apart from NBFI, an increase is
observed in other industries (+\u20ac6.1 billion), compensated by a decrease in natural resources (\u20ac7.2 billion).
Outstandings by economic sectors and geographical area (*) 1
in \u20ac million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United
Kingdom
Luxembourg
France
Rest of
Europe
America
Asia
Australia
Africa
2022
Private Individuals
114,625
44,193
101,529
13,767
24,865
138
3,486
2,731
13,654
161
131
35,528
24
354,831
Central Banks
35,202
14,338
21,041
1,060
347
427
6,820
35
18,092
0
4,962
2,695
24
105,043
Natural Resources
3,084
1,356
809
746
169
4,442
2,764
470
12,154
8,771
10,398
1,028
361
46,549
Real Estate
17,586
10,112
1,388
2,374
1,391
413
3,797
3,155
3,378
3,474
1,180
4,263
2
52,513
Commercial Banks
1,359
265
3,974
551
402
4,933
4,480
4,371
6,368
9,945
12,041
1,765
409
50,863
Non-Bank Financial Institutions
2,710
1,041
5,054
2,299
99
8,229
4,489
3,220
4,495
19,636
4,091
896
0
56,258
Central Governments
3,342
7,716
1,179
6,578
4,578
46
175
1,797
8,444
13,979
333
636
551
49,356
Transportation & Logistics
3,967
2,183
608
1,300
690
1,787
583
733
7,808
3,378
6,806
531
608
30,982
Utilities
1,551
1,630
2,814
679
1,227
2,953
572
980
4,302
4,347
1,545
1,897
200
24,698
Food, Beverages & Personal Care
7,249
3,002
573
2,334
475
739
1,667
469
2,668
3,245
942
248
13
23,623
Services
4,819
8,816
1,254
1,101
67
685
808
1,066
1,120
1,821
357
632
0
22,546
General Industries
5,430
2,689
1,007
2,849
311
330
604
245
3,152
2,926
1,311
9
0
20,865
Lower Public Administration
272
5,638
5,197
644
200
0
313
3,126
402
1,310
0
4,564
0
21,666
Other
17,353
13,602
6,302
6,946
1,416
3,058
1,164
1,179
10,952
9,457
4,891
1,424
188
77,932
Total
218,548
116,580
152,730
43,229
36,237
28,179
31,720
23,576
96,989
82,450
48,989
56,116
2,381
937,725
Rating class
Investment grade
174,972
76,244
130,285
27,501
28,556
23,160
26,053
17,545
64,884
63,870
39,903
41,476
213
714,662
Non-Investment grade
40,325
36,036
20,967
14,596
7,330
4,634
5,442
5,814
27,617
17,615
7,638
13,914
1,858
203,786
Sub-standard grade
1,508
984
579
422
105
41
80
16
2,903
311
124
257
239
7,569
Non-performing loans
1,743
3,316
899
710
246
344
145
201
1,584
654
1,325
470
72
11,708
Total
218,548
116,580
152,730
43,229
36,237
28,179
31,720
23,576
96,989
82,450
48,989
56,116
2,381
937,725
1\u00a0 Geographical areas are based on country of residence, except for private individuals for which the geographical areas are based on the primary country of risk.
Outstandings by economic sectors and geographical area (*) 1
in \u20ac million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United
Kingdom
Luxembourg
France
Rest of
Europe
America
Asia
Australia
Africa
2021
Private Individuals
113,846
42,961
95,583
14,397
23,895
157
3,388
3,115
13,215
167
155
35,058
27
345,965
Central Banks
46,902
18,253
17,811
112
3,027
2,853
8,569
1,039
4,485
0
2,856
1,168
18
107,094
Natural Resources
3,734
1,180
1,208
722
291
4,487
2,497
405
15,471
9,473
12,593
1,013
780
53,855
Real Estate
17,426
10,011
1,520
2,357
1,528
436
4,201
3,254
3,461
3,521
935
4,045
4
52,699
Commercial Banks
1,378
318
3,887
707
392
4,156
3,205
5,520
6,353
7,089
13,526
2,265
413
49,208
Non-Bank Financial Institutions
3,043
921
3,146
1,718
72
7,764
4,798
1,790
3,947
17,772
3,209
411
0
48,590
Central Governments
4,911
7,396
1,179
7,473
4,417
67
203
2,065
7,695
10,927
299
533
477
47,642
Transportation & Logistics
4,572
2,209
506
1,177
723
1,760
582
982
6,837
3,410
5,682
645
514
29,597
Utilities
1,545
1,213
3,024
822
1,270
2,980
397
1,433
4,202
4,106
1,355
1,368
220
23,935
Food, Beverages & Personal Care
6,581
2,869
616
2,146
489
711
1,600
1,232
2,580
3,131
1,140
235
12
23,340
Services
4,615
9,115
1,105
866
119
523
450
1,470
861
1,539
479
565
36
21,743
General Industries
5,389
2,891
1,011
2,612
381
395
532
271
3,363
2,116
1,151
15
0
20,127
Lower Public Administration
343
5,158
5,787
636
0
0
296
2,732
467
1,197
46
2,608
0
19,271
Other
15,485
13,424
5,573
6,319
940
2,277
1,168
1,210
9,297
8,803
4,732
1,454
0
70,682
Total
229,771
117,919
141,956
42,063
37,542
28,567
31,887
26,517
82,233
73,251
48,159
51,382
2,501
913,749
Rating class
Investment grade
180,787
78,195
119,311
26,856
29,522
22,820
26,150
20,622
52,875
53,725
36,777
38,200
79
685,920
Non-Investment grade
45,530
35,600
21,250
14,148
7,647
5,234
5,568
5,774
27,993
18,184
10,534
11,998
2,259
211,721
Sub-standard grade
1,230
868
390
290
89
56
81
2
308
203
191
217
58
3,985
Non-performing loans
2,224
3,256
1,006
768
284
458
87
119
1,056
1,139
656
966
105
12,124
Total
229,771
117,919
141,956
42,063
37,542
28,567
31,887
26,517
82,233
73,251
48,159
51,382
2,501
913,749
Risk management at ING Bank'. Apart from Russia, noticeable
moves occurred in France, where NPL increased from 0.4% to 0.9% impacted by the decommissioning of
the Retail business in France. And in the UK, where NPL decreased from 1.6% to 1.2%.
The increase in exposure in the Americas region was mainly driven by FX impact. In terms of rating
distribution for America region, an increase in investment grade is observed to 77.6% (from 73.0%), non-
investment grade decreased to 21.3% from 25.1%. Sub-standard grade increased to 0.4%, while NPL
improved to 0.8% (from 1.5%). Australia\u2019s rating distribution improved with a decrease of NPL\u2019s from 1.9% to
0.8% of the portfolio.
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 \u2018cover\u2019. While a cover may be an important mitigant of credit risk and an
alternative source of repayment, generally it is ING\u2019s practice to lend on the basis of the customer\u2019s
creditworthiness rather than exclusively 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
on 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 to ensure 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\u2019s 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 increased the haircuts applied to collateral values used in stage 3 individual provisions as at
31 December 2021 and 31 December 2022 to reflect the increased risk of inflated asset prices in certain
sectors of the economy. The haircut is applied on real estate, shipping and aviation collateral values 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, financial collateral (cash
and securities) and guarantees. ING obtains cover that is eligible for credit risk mitigation under CRR/CRDIV,
as well as cover that is not eligible. Collateral covering financial market transactions is valued on a daily
basis, and 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 performing and non-performing
portfolio. Our definition of non-performing is explained in detail in \u2018Credit restructuring\u2019 (below). For
additional insight, a breakdown of ING\u2019s portfolio by industry and geography is provided.
The next table gives an overview of the collateralisation of the ING\u2019s total portfolio.
Cover values including guarantees received (*)
in \u20ac million
Cover type
Collateralisation
2022
Outstandings
Mortgages
Financial
Collateral
Guarantees
Other covers
No Cover
Partially
covered
Fully covered
Consumer lending
353,323
700,961
5,626
24,231
42,817
6.2%
7.6%
86.2%
Business lending
379,070
167,122
29,501
118,294
438,864
37.5%
22.3%
40.2%
Investment and money market
141,432
0
5
1,213
2
99.1%
0.6%
0.3%
Total lending, investment and money market
873,824
868,083
35,132
143,738
481,683
34.8%
12.9%
52.3%
Pre-settlement
63,901
Total Bank
937,725
Cover values including guarantees received (*)
in \u20ac million
Cover type
Collateralisation
2021
Outstandings
Mortgages
Financial
Collateral
Guarantees
Other covers
No Cover
Partially
covered
Fully covered
Consumer lending
344,188
690,752
6,533
25,688
40,618
6.3%
7.6%
86.1%
Business lending
413,670
160,694
23,454
112,095
332,989
44.2%
20.2%
35.5%
Investment and money market
112,360
43
63
1,100
167
98.9%
0.8%
0.3%
Total lending, investment and money market
870,218
851,490
30,050
138,882
373,774
36.0%
12.8%
51.2%
Pre-settlement
43,531
Total Bank
913,749
Excluding the pre-settlement portfolio, 52.3% (2021: 51.2%) of ING\u2019s outstandings were fully collateralised in
2022. Since investments traditionally do not require covers, the percentage for \u2018no covers\u2019 in this portfolio is
above 95%. However, 99% of the investment outstanding is investment grade. Improved economic
conditions in ING\u2019s main markets contributed to improved collateral valuations, observed in consumer
lending. Relative to the overall developments in the housing markets and the impact on provisioning, note
the paragraphs on \u2018management adjustments\u2019 in the Loan Loss provisioning section, that were made to
reflect potential impact of higher inflation, higher rates and market uncertainty.
Consumer lending portfolio (*)
The consumer lending portfolio accounts for 37.7% (2021: 37.7%) of ING\u2019s total outstanding, primarily
consisting of residential mortgage loans and other consumer lending loans. As a result, 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\u2019s residential mortgage portfolio is in
the Netherlands (34.4%), Germany (28.0%), Belgium and Luxembourg (13.2%) and Australia (10.7%).
Relative to the overall developments in the housing markets and loan loss provisions for the mortgage
portfolio\u2019s, note that management adjustments are recognised to maintain an appropriate level of
provisions. See paragraph on \u2018management adjustments\u2019 in the loan loss provisioning section.
Business lending portfolio (*)
Business lending accounts for 40.4% (2021: 45.3%) of ING\u2019s total outstanding. Business lending presented in
this section does not include pre-settlement, investment and money market exposures.
Credit quality (*)
Credit risk categories (*)
Regular
Watch List
Restructuring1
Non-performing1
Possible ratings
1\u201319
1\u201319
11\u201320
20-22
Typical ratings
1\u201314
15\u201317
18\u201320
20-22
Deterioration in risk
Not significant
Significant
Significant
Significant
Significant intervention
Not required
Not required
Required
Required
Account Ownership
Front Office
Front Office
Front Office
Front Office
Credit Risk Management
Regular
Regular
Credit Restructuring
Credit Restructuring
Primary Manager
Front Office
Front Office
Credit Restructuring
Credit Restructuring
Accounting provisioning
Stage 1/2
Stage 1/2
Stage 2/3
Stage 3
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 is applicable to private
individuals, as well as business lending. An obligation is considered \u2018past due\u2019 if a payment of interest or
principal is more than one day late. ING aims to help its customers as soon as they are past due by
reminding them of their payment obligations. In its contact with the 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 cured, for example because the customer is unable or unwilling to pay, the contract
is sent to the recovery unit. The facility is downgraded to risk rating 20 (non-performing) when the facility or
obligor \u2013 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.
ING has aligned the regulatory concept of non-performing with that of the definition of default. Hence, in
WB, obligors are classified as non-performing when a default trigger occurs:
\u2022ING 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:
\u2022The borrower (or third party) has started insolvency proceedings.
\u2022A group company/co-borrower has NPL status.
\u2022Indication of fraud (affecting the company\u2019s ability to service its debt).
\u2022There is doubt as to the borrower\u2019s ability to generate stable and sufficient cash flows to service its
debt.
\u2022Restructuring of debt.
\u2022ING has granted concessions relating to the borrower\u2019s financial difficulty, the effect of which is a
reduction in expected future cash flows of the financial asset below current carrying amount.
\u2022The 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.
Further, WB has an individual name approach, using early warnings indicators to signal possible future
issues in debt service.\u00a0
Ageing analysis (past due but performing): Consumer lending portfolio by geographic area, outstandings (*)1,2
in \u20ac million
2022
2021
Region
Past due for
1\u201330 days
Past due for
31\u201360 days
Past due for
61\u201390 days
Past due for
>90 days
Total
Past due for
1\u201330 days
Past due for
31\u201360 days
Past due for
61\u201390 days
Past due for
>90 days
Total
Europe
Belgium
294
27
18
339
599
53
61
714
Germany
68
34
13
116
105
27
11
143
Luxembourg
43
4
2
48
73
3
1
1
78
Netherlands
36
10
5
50
31
9
3
43
Poland
59
8
4
71
35
5
3
43
Spain
13
9
5
27
13
7
5
26
France
2
2
2
2
United Kingdom
1
Rest of Europe
60
15
8
83
52
9
5
66
America
1
1
Australia
29
11
2
42
17
7
1
25
Total
604
119
57
780
927
123
91
1
1,142
1 Based on consumer lending. The amount of past due but performing financial assets in respect of non-lending activities was not significant.
2 The absolute and relative materiality thresholds used for determining a defaulted status do not apply for the purposes of classification as past due. Below these thresholds, arrears of more than 90 days are reported as past due.
The past due but performing outstanding of consumer lending decreased by \u20ac362 million. The largest
decrease was observed in Belgium (-\u20ac375 million), in term loans (-\u20ac188 million) and in Residential Mortgage
(-\u20ac113 million). Moderate increase was seen in Poland (+\u20ac28 million), Rest of Europe (+\u20ac17 million) and
Australia (+\u20ac16 million), with each mainly visible in the 1\u201330 days past due bucket.
Ageing analysis (past due but performing): Business lending portfolio by geographic area, outstandings (*)1
in \u20ac million
2022
2021
Region
Past due for
1\u201330 days
Past due for
31\u201360 days
Past due for
61\u201390 days
Past due for
>90 days
Total
Past due for
1\u201330 days
Past due for
31\u201360 days
Past due for
61\u201390 days
Past due for
>90 days
Total
Europe
Belgium
579
49
10
639
1,676
178
8
1,863
United
Kingdom
1,147
77
512
1,736
1,036
108
16
1,159
Luxembourg
302
1
303
586
270
1
856
Netherlands
730
30
15
775
553
16
4
574
Poland
279
35
14
329
94
5
2
1
102
Spain
95
1
96
France
83
6
90
36
5
41
Germany
44
16
60
5
2
7
Rest of Europe
474
239
1
1
715
571
57
1
1
629
America
1,901
67
19
1,986
2,076
71
2,146
Asia
553
48
601
276
25
302
Australia
359
61
4
2
426
327
17
1
345
Total
6,452
629
575
4
7,659
7,331
727
60
3
8,121
1 The absolute and relative materiality thresholds used for determining a defaulted status do not apply for the purposes of classification as past due. Below these thresholds, arrears of more than 90 days are reported as past due.
Total past due but performing outstanding of business lending decreased by \u20ac462 million. These were
mainly contributed by decreased outstanding in the 1-30 days (\u20ac879 million) past due bucket, partly offset
by increased outstanding in 61\u201390 days past due bucket (\u20ac515 million). The top three areas of decrease in
the 1-30 days bucket were Belgium (\u20ac1,097 million), Luxembourg (\u20ac284 million) and America (\u20ac175 million).
The top three areas of increase in the 1-30 days bucket were Asia (\u20ac277 million), Poland (\u20ac185 million) and
the Netherlands (\u20ac177 million).
Credit restructuring (*)
Global Credit Restructuring (GCR) is the dedicated and independent department that deals with non-
performing loans and loans that hold a reasonable probability that ING will end up with a loss, if no specific
action is taken. GCR handles accounts or portfolios requiring an active approach, which may include
renegotiation of terms and conditions and business or financial restructuring. The loans are managed by
GCR or by units in the various regions and business units. ING uses three distinct statuses to categorise the
management of clients with (perceived) deteriorating credit risk profiles, i.e. there is increasing doubt as to
the performance and the collectability of the client\u2019s contractual obligations:
\u2022Watch list: Usually, a client is first classified as watch list when there are concerns of any potential or
material deterioration in credit risk profile that may affect the ability of the client to adhere to its debt
service obligations or to refinance its existing loans. Watch List status requires more than usual
attention, increased monitoring and quarterly reviews. Some clients with a Watch List status may
develop into a Restructuring status or even a Recovery status.
\u2022Restructuring: A client is classified in restructuring when there are concerns about the client\u2019s financial
stability, credit worthiness, and/or ability to repay, but where the situation does not require the
termination or acceleration of facilities or the liquidation of collateral. ING\u2019s actions aim to maintain the
going concern status of the client by:
\u2022restoring the client\u2019s financial stability;
\u2022supporting the client\u2019s turnaround;
\u2022restoring the balance between debt and equity; and
\u2022restructuring the debt to a sustainable situation.
\u2022Recovery: A client is classified as in recovery when ING and/or the client concludes that the client\u2019s
financial situation cannot be restored and a decision is made to terminate the (credit) relationship or
even to enter into bankruptcy. ING prefers an amicable exit, but will enforce and liquidate the collateral
or claim under the guarantees if deemed necessary.
Watch list, restructuring and recovery accounts are reviewed at least quarterly by the front office, GCR and
the relevant credit risk management executives.
Forbearance (*)
Forbearance occurs when a client is unable to meet their financial commitments due to financial difficulties
they face or are about to face and ING grants concessions towards them. Forborne assets are assets in
respect of 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 with the aim of maximising the client\u2019s
repayment ability and therewith avoiding a default situation or helping the client to return to a performing
situation.
For ING retail units, clear criteria has 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
on a portfolio (retail) basis.
All exposures are eligible for forbearance measures, i.e. both performing (Risk ratings 1-19) and non-
performing (risk ratings 20-22) exposures. 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 \u20ac million
2022
2021
Business line
Outstanding
s
Of which:
performin
g
Of which:
non-
performing
% of total
portfolio
Outstanding
s
Of which:
performin
g
Of which:
non-
performing
% of total
portfolio
Wholesale Banking
8,359
5,880
2,478
2.7%
9,798
7,455
2,343
3.1%
Retail Banking
8,080
4,973
3,107
1.6%
10,018
6,339
3,679
2.1%
Total
16,438
10,853
5,585
2.0%
19,816
13,793
6,022
2.5%
Wholesale Banking: Forborne portfolio by economic sector (*)
in \u20ac million
2022
2021
Industry
Outstandings
Of which:
performing
Of which: non-
Outstandings
Of which:
performing
Of which: non-
performing
performing
Natural Resources
1,239
603
636
2,047
1,177
870
Real Estate
2,000
1,917
84
1,665
1,570
95
Transportation & Logistics
1,073
868
205
1,336
1,061
274
Food, Beverages & Personal Care
1,082
543
539
1,202
749
452
Services
697
665
32
793
687
106
Automotive
172
125
46
581
535
46
Utilities
469
255
214
407
271
136
General Industries
255
176
80
366
321
45
Retail
302
227
76
361
304
57
Chemicals, Health &
Pharmaceuticals
191
168
23
347
324
22
Builders & Contractors
168
94
74
177
135
41
Other
710
240
469
516
318
197
Total
8,359
5,880
2,478
9,798
7,455
2,343
The main concentration of forborne assets in a single country was in the United Kingdom with 12% (2021:
14%) of the total WB forborne assets and 13% (2021: 18%) of the total non-performing forborne assets.
WB forborne assets decreased by \u20ac1.44 billion compared to 2021, of which the performing forborne assets
decreased by \u20ac1.58 billion. This was visible across all industries (except for Real estate) and locations (except
for Belgium and Poland).
WB's forborne assets were mainly concentrated in natural resources, real estate, transportation & logistics
and food beverages & personal care. These four economic sectors accounted for 65% of the total WB
forborne outstandings. During 2022, an increase in forborne assets was visible in the real estate industry (+\u20ac
0.3 billion), offset by a decrease in Natural Resources (-\u20ac0.8 billion), Automotive (-\u20ac 0.4 billion), Food,
Beverages & Personal Care (-\u20ac0.1 billion) and Transportation & Logistics (-\u20ac0.2 billion).
Retail Banking (*)
As of the end of December 2022, Retail Banking forborne assets totalled \u20ac8.1 billion, which represented 1.6%
of the total Retail Banking portfolio.
Retail Banking: Forborne portfolio by geographical area (*)
in \u20ac million
2022
2021
Region
Outstandings
Of which:
performing
Of which: non-
Outstandings
Of which:
performing
Of which: non-
performing
performing
Europe
Netherlands
2,832
2,043
789
4,171
3,224
947
Belgium
2,644
1,331
1,314
3,319
2,035
1,284
Germany
804
610
194
497
306
191
Poland
588
309
279
450
152
298
Turkey
64
31
32
146
97
49
Italy
131
52
79
129
47
82
Romania
124
53
71
115
49
66
Spain
35
15
20
35
11
23
Rest of Europe
73
48
25
99
68
30
America
13
12
9
7
2
Asia
3
1
1
3
1
1
Australia
768
467
302
1,045
340
705
Africa
1
1
Total
8,080
4,973
3,107
10,018
6,339
3,679
The main concentration of forborne assets in a single country was in the Netherlands with 35% (2021: 42%)
of total Retail Banking forborne assets and 25% (2021: 26%) of the non-performing forborne assets. Next to
that, Belgium had to 33% (2021: 33%) of the total Retail forborne assets.
Non-performing loans (*)
ING\u2019s loan portfolio is under constant review. Loans to obligors that are considered more than 90 days past
due and above applicable thresholds are reclassified as non-performing. For business lending portfolios,
there generally are reasons for declaring a loan non-performing prior to the obligor being 90 days past due.
These reasons include, but are not limited to, ING\u2019s assessment of the customer\u2019s perceived inability to meet
its financial obligations, or the customer filing for bankruptcy or bankruptcy protection.
The table below represents the breakdown by industry of credit risk outstandings that have been classified
as non-performing.
Non-performing Loans: outstandings by economic sector and business lines (*)1
in \u20ac million
Wholesale
Banking
Retail Benelux
Retail
Challengers &
Growth Markets
Corporate Line
Total
Industry
2022
2021
2022
2021
2022
2021
2022
2021
2022
2021
Private Individuals
2,174
2,424
1,954
2,445
4,129
4,869
Natural Resources
1,369
1,325
34
46
17
27
1,421
1,398
Food, Beverages & Personal
Care
672
681
438
428
122
130
1,233
1,239
Transportation & Logistics
367
575
165
180
51
52
583
807
Services
119
224
448
499
61
63
628
786
Real Estate
172
132
486
495
54
59
712
686
General Industries
114
66
268
272
100
123
482
461
Builders & Contractors
139
93
244
224
110
112
493
429
Retail
98
140
107
103
39
47
244
290
Utilities
387
199
7
10
7
11
401
221
Chemicals,
Health &
Pharmaceuticals
175
65
115
70
20
22
310
158
Telecom
288
28
12
1
3
3
303
31
Other
440
305
260
282
52
58
753
646
Total
4,340
3,833
4,759
5,035
2,592
3,153
11,691
12,021
1 Based on Lending and Investment outstandings.
Non-performing Loans: outstandings by economic sectors and geographical area (*)
in \u20ac million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United Kingdom
France
Luxembourg
Rest of Europe
America
Asia
Australia
Africa
2022
Private Individuals
574
1,538
739
185
194
4
11
36
470
3
4
370
1
4,129
Natural Resources
57
33
14
53
432
77
649
85
21
1,421
Food, Beverages & Personal Care
310
179
24
109
173
7
228
77
126
1,233
Transportation & Logistics
232
58
1
36
47
20
2
154
24
7
1
583
Services
136
375
2
43
5
3
2
21
40
628
Real Estate
89
376
54
84
25
19
7
47
11
712
General Industries
127
142
17
78
31
2
26
58
482
Builders & Contractors
65
187
2
86
20
101
32
493
Retail
31
85
38
26
18
1
13
22
7
2
244
Utilities
6
6
26
23
17
194
129
401
Chemicals, Health & Pharmaceuticals
51
100
2
15
14
100
28
310
Telecom
24
1
3
5
270
303
Other
40
232
48
38
50
10
79
75
130
51
753
Total
1,742
3,312
899
710
246
344
196
145
1,578
654
1,324
470
72
11,691
Non-performing Loans: outstandings by economic sectors and geographical area (*)
in \u20ac million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United Kingdom
France
Luxembourg
Rest of Europe
America
Asia
Australia
Africa
Private Individuals
776
1,578
721
206
232
8
16
35
497
3
4
791
1
4,869
Natural Resources
67
44
20
27
116
577
421
90
37
1,398
Food, Beverages & Personal Care
299
176
25
111
226
7
2
37
228
128
1
1,239
Transportation & Logistics
385
55
1
35
47
20
3
165
29
49
17
807
Services
199
385
45
5
66
4
22
52
6
1
786
Real Estate
167
303
61
88
21
21
9
16
686
General Industries
110
173
18
91
4
3
34
27
461
Builders & Contractors
43
188
4
83
2
58
50
429
Retail
40
70
34
30
56
1
21
21
14
2
290
Utilities
8
9
71
26
28
30
48
221
Chemicals, Health & Pharmaceuticals
63
48
2
16
29
158
Telecom
13
1
2
10
1
5
31
Other
42
226
129
41
2
14
15
38
37
34
1
67
646
Total
2,212
3,255
1,005
768
284
447
119
87
1,056
1,060
656
966
105
12,021
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: (1) to the economic outlook and (2) 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 \u2018credit-impaired\u2019
financial assets under IFRS 9 (Stage 3). ING has also aligned its definition of default between IFRS9 and the
regulatory technical standards (RTS) and EBA guidelines. More information can be found in section 1.7.8 of
the Consolidated financial statements.
Climate and environmental risks in IFRS 9 models (*)
ING is evolving in its credit risk management framework to further develop a better understanding of
emerging climate and environmental risks. Banks, including ING, are in the process of collecting and
analysing empirical historical data and moving towards embedding these emerging risks into their credit
risk management processes and eventually into their IFRS 9 ECL models.
In 2022, ING continued to enhance the tools used to identify and assess climate and environmental (C&E)
risks in our portfolio. We created C&E risk sector heatmaps for both WB and Retail Banking that facilitated
the identification of exposure to C&E risks by means of scores assigned to transition and physical risk
drivers. They also enabled us to understand the magnitude of the C&E risk impact on a sectoral level and
pinpointed sectors with highest C&E risk exposure. In the past two years, we have improved our
understanding of the physical risk impact of climate events on our mortgage portfolio.
The integration of quantified inputs from the heatmaps into risk modelling has not yet been implemented
for a number of reasons including a lack of data to assess C&E risks at a client level. Refer to the section
'Environmental, social and governance risk' for further details on the heatmaps and the related challenges.
At this point in time it is not possible to incorporate climate risk separately into IFRS 9 ECL models given the
lack of sufficient empirical historical data and the above-mentioned limitations in the risk assessments on
client level. Where climate and environmental factors have impacted the economy in the recent past or
present, these impacts are however currently implicitly embedded in ING's IFRS9 ECL models through the
projected macroeconomic indicators (e.g. GDP growth and unemployment rates). We note that our ECL
models are primarily sensitive to the short-term economic outlook as we use a three-year time horizon for
macroeconomic outlook, after which a mean reversion approach is applied.
With regard to our evaluation of climate-related matters, where such events have already occurred (e.g.
floods), the impact of such events are individually assessed in the calculation of Stage 3 Individual provisions
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.
As of 31 December 2022, reported ECL includes a management adjustment of \u20ac10 million to address the
increased credit risk in ING\u2019s livestock farming portfolio resulting from nitrogen reduction targets introduced
by the Dutch Government. Refer to the section 'Management overlays' for further details.
Portfolio quality (*)
The table below describes the portfolio composition over the different IFRS 9 stages and rating classes. The
Stage 1 portfolio represents 91.5% (2021: 93.5%) of the total gross carrying amounts, mainly composed of
investment grade, while Stage 2 makes up 7.3% (2021: 5.2%) and Stage 3 makes up 1.2% (2021: 1.3%) of
the total gross carrying amounts, respectively.
Gross carrying amount per IFRS 9 stage and rating class (*)1,2,3
in \u20ac million
12-month ECL (Stage 1)
Lifetime ECL not credit
impaired (Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
2022
Rating class
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Investment grade
1 (AAA)
100,885
2
284
101,169
2
2-4 (AA)
98,181
5
2,493
1
100,675
6
5-7 (A)
177,617
23
4,596
4
182,214
27
8-10 (BBB)
320,972
98
14,714
29
335,687
127
Non-Investment grade
11-13 (BB)
155,910
277
17,365
91
173,275
368
14-16 (B)
23,649
168
19,386
471
43,035
639
17 (CCC)
7,671
8
4,572
194
12,244
202
Substandard grade
18 (CC)
5,198
595
5,198
595
19 (C)
2,116
293
2,116
293
Non-performing loans
20-22 (D)
11,708
3,841
11,708
3,841
Total
884,886
581
70,725
1,679
11,708
3,841
967,319
6,101
1Compared to the credit risk portfolio, the differences are mainly undrawn committed amounts (\u20ac150.1 billion) and other positions (\u20ac4.4 billion) not included in Credit outstandings and non-IFRS 9 eligible assets (\u20ac116.1 billion, mainly guarantees, letters of credit and pre-
settlement exposures) included in Credit outstandings.
2For a reference to the Notes in the consolidated financial statements, we refer to the table \u2018Reconciliation between credit risk categories and financial position\u2019.
3IAS 37 provisions are established for non-credit replacement guarantees not in the scope of IFRS 9. Total IAS 37 provisions (\u20ac109 million) are excluded.
Gross carrying amount per IFRS 9 stage and rating class (*)1,2,3
in \u20ac million
12-month ECL (Stage 1)
Lifetime ECL not credit
impaired (Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
2021
Rating class
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Investment grade
1 (AAA)
107,788
3
107,788
3
2-4 (AA)
106,673
5
197
106,870
5
5-7 (A)
152,255
17
1,001
1
153,256
17
8-10 (BBB)
328,301
73
7,232
14
335,533
87
Non-Investment grade
11-13 (BB)
162,912
208
14,679
86
177,592
294
14-16 (B)
26,852
185
17,931
404
44,783
589
17 (CCC)
5,377
10
4,354
198
9,730
207
Substandard grade
18 (CC)
2,314
173
2,314
173
19 (C)
1,769
142
1,769
142
Non-performing loans
20-22 (D)
12,072
3,851
12,072
3,851
Total
890,158
501
49,476
1,016
12,072
3,851
951,707
5,368
1Compared to the credit risk portfolio, the differences are mainly undrawn committed amounts (\u20ac133.3 billion) not included in Credit outstandings and non-IFRS 9 eligible assets (\u20ac95.1 billion, mainly guarantees, letters of credit and pre-settlement exposures) included in Credit
outstandings.
2For a reference to the Notes in the consolidated financial statements, we refer to the table \u2018Reconciliation between credit risk categories and financial position\u2019.
3IAS 37 provisions are established for non-credit replacement guarantees not in the scope of IFRS 9. Total IAS 37 provisions (\u20ac114.4 million) are excluded.
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:
\u2022Stage 3 gross carrying amount decreased by \u20ac0.4 billion from \u20ac12.1 billion as of 31 December 2021 to\u00a0 \u00a0
\u20ac11.7 billion as of 31 December 2022, mainly as a result of write-offs and generally low inflow into NPL
(credit impaired) in 2022. Stage 3 provisions remained however flat at \u20ac3.8 billion, reflecting worsened
macroeconomic outlook.
\u2022Stage 2 gross carrying amount increased by \u20ac21.2 billion from \u20ac49.5 billion as of 31 December 2021 to\u00a0
\u20ac70.7 billion. This is mainly caused by the significant lifetime PD trigger (\u20ac14.8 billion) driven by
downgrades of the Russian portfolio and economic turmoil. Furthermore, the implementation of a
stricter PD backstop methodology has driven the increase in Stage 2 gross carrying amounts,(\u20ac11.4
billion, mainly investment grade exposures). Other Stage 2 triggers such as the 30 Days past due and
watchlist triggers (\u20ac1.2 billion and \u20ac1.1 billion respectively), were more than offset by the forbearance
trigger (-\u20ac6.4 billion). For the latter, a two-year probation period is required before a client can move back
to Stage 1 and the decrease relates to the fact that the start of the Covid-19 pandemic is now more than
two years ago.
\u2022Stage 2 provisions increased by \u20ac0.7 billion to \u20ac1.7 billion as of 31 December 2022, largely driven by the
migration of the Russian portfolio to Stage 2 and worsened macro-economic outlook. The
implementation of the threefold increase in lifetime PD backstop trigger had limited impact on provisions
as\u00a0 it mainly impacts investment grade exposures.
\u2022In 2022, the largest increases in Stage 2 by sector were in Non-bank financial institutions, Real estate,
Chemicals health & pharmaceuticals and Lower public administration of \u20ac3.5 billion, \u20ac2.8 billion, \u20ac2.5
billion and \u20ac2.1 billion respectively The increase in Stage 2 for non-bank financial institutions mainly
resulted from the implementation of the threefold increase in lifetime PD backstop trigger, that mainly
impacts investment grade exposures. Other drivers were downgrades in the Russian portfolio and
economic turmoil. The largest decreases were in Automotive and Transportation & logistics with \u20ac0.9
billion and \u20ac0.6 billion releases respectively. The largest Stage 2 outstandings per economic sector as of
31 December 2022 are Real estate, Services, Natural resources and Non-bank financial institutions
representing 10%, 7%, 7% and 7% of the total Stage 2 gross carrying amounts respectively.
Additional information on macroeconomic scenarios is included in the section \u2018Macroeconomic scenarios
and sensitivity analysis of key sources of estimation uncertainty\u2019.
Changes in gross carrying amounts and loan loss provisions (*)1, 2
in \u20ac million
12-month ECL (Stage 1)
Lifetime ECL not credit
impaired (Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
2022
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Opening balance
890,158
501
49,476
1,016
12,072
3,851
951,707
5,368
Transfer into 12-month ECL (Stage 1)
8,513
21
-8,105
-142
-408
-47
-168
Transfer into lifetime ECL not credit impaired (Stage 2)
-42,439
-76
43,222
730
-784
-90
564
Transfer into lifetime ECL credit impaired (Stage 3)
-3,524
-8
-1,216
-82
4,740
1,234
1,144
Net remeasurement of loan loss provisions
8
223
199
430
New financial assets originated or purchased
248,443
228
248,443
228
Financial assets that have been derecognised
-138,250
-70
-11,312
-94
-2,805
-215
-152,366
-379
Net drawdowns and repayments
-78,015
-1,340
21
-79,334
Changes in models/risk parameters
-8
13
25
30
Increase in loan loss provisions
95
648
1,106
1,849
Write-offs
-1
-1,129
-1,129
-1,130
-1,130
Recoveries of amounts previously written off
71
71
Foreign exchange and other movements
-15
16
-58
-57
Closing balance
884,886
581
70,725
1,679
11,708
3,841
967,319
6,101
1Stage 3 Lifetime credit impaired provision includes \u20ac4 million on Purchased or Originated Credit Impaired.
2The addition to the loan provision (in the consolidated statement of profit or loss) amounts to \u20ac1.861 million of which \u20ac1.850 million related to IFRS 9 eligible financial assets, -\u20ac3 million related to non-credit replacement guarantees and \u20ac14 million to modification gains and
losses on restructured financial assets.
Changes in gross carrying amounts and loan loss provisions (*)1,2
in \u20ac million
12-month ECL (Stage 1)
Lifetime ECL not credit
impaired (Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
2021
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Opening balance
844,020
581
59,313
1,476
13,398
3,797
916,732
5,854
Transfer into 12-month ECL (Stage 1)
15,157
20
-14,322
-279
-835
-54
-313
Transfer into lifetime ECL not credit impaired (Stage 2)
-19,737
-32
20,537
206
-800
-74
100
Transfer into lifetime ECL credit impaired (Stage 3)
-2,166
-13
-1,589
-96
3,755
820
712
Net remeasurement of loan loss provisions
-130
-228
404
46
New financial assets originated or purchased
208,501
149
208,501
149
Financial assets that have been derecognised
-125,819
-73
-11,935
-104
-1,898
-237
-139,652
-414
Net drawdowns and repayments
-29,799
-2,526
-694
-33,019
Changes in models/risk parameters
12
41
130
184
Increase in loan loss provisions
-67
-460
989
462
Write-offs
-854
-854
-854
-854
Recoveries of amounts previously written off
45
45
Foreign exchange and other movements
-13
1
-125
-138
Closing balance
890,158
501
49,476
1,016
12,072
3,851
951,707
5,368
Macroeconomic scenarios and sensitivity analysis of key sources of estimation
uncertainty (*)
Methodology (*)
Our methodology in relation to the adoption and generation of macroeconomic scenarios is described in
this section. We continue to follow this methodology in generating our probability-weighted ECL, with
consideration of alternative scenarios and management adjustments supplementing this ECL where, in
management's opinion, 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\u2019s 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). The Oxford Economics\u2019 Global Economic Model (OEGEM) is used to complement the consensus with
consistent projections for variables for which there are no consensus estimates available (most notably
house prices and \u2013 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 two panels of ING experts. The first panel
consists of economic experts from Global Markets Research and risk and modelling specialists, while the
second panel consists of relevant senior managers.
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 OEGEM.
To understand the baseline level of uncertainty around any forecast, Oxford Economics keeps track of all its
deviations (so called forecast errors) of the past 20 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, Oxford Economics 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 for the 90th percentile of that distribution because this
corresponds with the way risk management earnings-at-risk is defined within the Bank. The upside scenario
is represented by the 10th percentile of the distribution. The applicable percentiles of the distribution imply
a 20% probability for each alternative scenario. Consequently, the baseline scenario has a 60% probability
weighting. Please note that, given their technical nature, the downside and upside scenarios are not based
on an explicit specific narrative.
Macroeconomic scenarios applied (*)
The loan loss provisions are based on the December 2022 consensus forecasts.
Baseline assumptions (*)
The general picture that the consensus conveys is that global economic growth is being challenged by
persistent inflationary pressures which are being met by central banks lifting interest rates. The consensus
expects recession to occur in many European countries in 2022-2023, while the US economy is anticipated
to stagnate. Economic growth is expected to resume in the years thereafter as inflation normalises and
monetary conditions become less tight. In economies that have experienced a notable surge in house prices
during the pandemic and its aftermath, affordability pressures amid the higher interest rate environment
are expected to lead to a moderation of growth or price declines in the near to medium-term.
The December 2022 consensus expects global output (as measured by the weighted average GDP growth
rate of ING's 25 main markets) to slow further from 6.0% in 2021, to 2.5% in 2022 and 1.3% in 2023. For
2024-2025, economic growth is expected to pick up again to 2.4%.
The US economy is expected to stagnate in 2023 as high inflation, rising interest rates, supply chain
difficulties, softer labour market dynamics, and global headwinds weaken demand. Consumer spending
growth is under downward pressure as slower employment gains curb income growth and pandemic-
related savings have diminished. With the headwinds seen fading slowly, the US economy is expected to
gather strength again in 2024. The consensus expects the growth rate of the US economy to fall from 1.9%
in 2022 to 0.2% in 2023 and to recover to on average 1.7% in 2024-2025.
Eurozone economies are dealing with the consequences of the ongoing war in Ukraine, broadening
inflationary pressures and a general deterioration of sentiment across industries and consumers.
The ECB has shifted to a hawkish tilt but government fiscal support targeting higher energy prices is
softening the economic pain in many countries. Overall, the eurozone economy is forecasted to stagnate in
2023, but Germany \u2013 as well as some other countries \u2013 faces recession reflecting its large exposure to gas
supply cuts, relatively large manufacturing sector and exposure to a slower growing Chinese economy.
Elsewhere in Europe, the outlook is equally bleak. In Poland, economic fallout from the war in Ukraine and
the related energy price shock point to a significant economic slowdown from 5.0% in 2022 to 1.0% in 2023.
However, the scope for a rise in unemployment is seen to be limited as the Polish labour market remains
tight, partially due to population ageing. As in the eurozone, the central bank is tightening monetary policy,
but fiscal policy remains expansive. The consensus expectation for Turkey is also for economic growth to
ease as the economic slowdown in Europe weighs on external demand and high inflation persists. The
consensus sees economic growth in Turkey slowing from 5.2% in 2022, to on average 2.4% in 2023-2024
and increasing again to 3.0% in 2025.
After a weak growth rate of 3.1% in 2022, economic growth in China is expected to pick-up to on average
4.7% in 2023-2025. The drag exerted by the authorities\u2019 Covid-19 policies is assumed to moderate, while
state investment will support demand. However, the real estate downturn continues to weigh on the
outlook.
The global economic slowdown, together with tighter monetary policy and high inflation is weighing on
economic growth in Australia. After growing by 3.8% in 2022, the outlook sees a growth rate of 1.8% for
2023-2024 and some pick-up to 2.6% for 2025. However, despite the economic slowdown, conditions in the
labour market are expected to remain tight.
When compared to the December 2021 consensus forecast, used for the 2021 Annual Report, the December
2022 forecast assumes much weaker economic circumstances. Global GDP was expected to increase by
2.5% in 2022 (compared to 4.1% assumed before) and 1.3% in 2023 (3.1% assumed before). The downgrade
reflects the economic impacts of the war in Ukraine and tighter monetary conditions.
Alternative scenarios and risks (*)
Because of the possible consequences of the war in Ukraine, uncertainty surrounding the forecasts is higher
than usual. This relates in particular to uncertainty about European energy supplies and worries about more
persistent high inflation. To take the general increase of uncertainty surrounding the forecasts into account,
the dispersion of the alternative scenarios has been set again at the widened level used for year-end 2021
provisioning (the half-widened dispersion). As a result, the near-term dispersion of the forward-looking
distributions (from which the alternative scenarios are derived) is larger than in normal times. Meanwhile, at
the end of the scenario horizon the dispersion has remained unchanged and hence is comparable to
scenarios generated prior to the war in Ukraine.
The baseline scenario assumes a significant easing of inflation in 2023 and relatively resilient labour
markets. However, a longer period of weakness, due to stickier inflation and more aggressive monetary
policy tightening that triggers a more notable softening of the labour market and greater falls in financial
asset and property prices, could lead to a more protracted and deeper economic slowdown. As such, the
balance of risks to the baseline outlook is negative and the alternative scenarios have a downward skew in
line with the outcomes of Oxford Economics\u2019 Global Risk Survey. The downward skew is less negative
compared to what has been applied for year-end 2021 at which time \u2013 set against a higher baseline \u2013 apart
from higher inflation, worries about supply chain disruptions and further corona virus waves were being
seen as top near-term downside risks.
The downside scenario \u2013 though technical in nature \u2013 sees for most countries a fast deceleration of
economic growth followed by a recession. Unemployment increases strongly in this scenario and house
prices in most countries show outright falls. The downside scenario captures a possible escalation of the war
in Ukraine and a more pronounced and prolonged surge in inflation.
The upside scenario \u2013 while equally technical in nature \u2013 reflects the possibility of a better economic outturn
if the war in Ukraine ended quickly, fuelling a rebound in consumer spending. The recovery is further
supported by looser monetary policy as weaker inflation prompts central banks to hold back tightening.
Management adjustments applied this year (*)
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 can also be applied
where the impact of the updated macroeconomic scenarios is over- or under-estimated by the IFRS 9
models.
ING has internal governance frameworks and controls in place to assess the appropriateness of all
management adjustments.
Management adjustments to ECL models (*)
in \u20ac million
2022
2021
Economic sector based adjustments
71
341
Second order impact adjustments
334
Payment holiday adjustments
32
Mortgage portfolio adjustments
105
124
Other Post Model Adjustments1
-57
121
Total management adjustments
453
618
1 Prior period figure has been updated to conform to current year presentation.
December 2021 management adjustments included an economic sector-based management adjustment
of \u20ac341 million because of delays in defaults occurring in the Covid-19-related crisis, mainly as a result of
government support programmes. In determining the sector-based management adjustment, a heatmap
approach was used to adjust the probability of default for sectors where businesses are significantly
impacted by the pandemic. In 2022, as it became clearer the Covid-19 pandemic had less impact than
expected on the number of defaults, the economic sector-based management adjustment has been largely
released and while at the same time management adjustments for the second order impact of the war in
Ukraine were introduced (see below). Of the remaining economic sector based adjustments of \u20ac71 million as
of 31 December 2022, \u20ac61 million relates to Business Banking clients that have benefited from Covid-19
related government support programmes in the Netherlands such as deferral of tax payments that ended in
the second half of 2022, and \u20ac10 million relates to an overlay for livestock farming sector in the
Netherlands. In the Netherlands, nitrogen reduction targets affect the livestock farming sector mainly
because of endorsed closing activities nearby Natura 2000 areas and because of expected transition to
other business models in the sector. As these specific risks are not incorporated in the model ECL, an overlay
was recognised.
ING has performed an assessment for both WB and Retail Banking on the impact of the war in Ukraine, the
increase in energy prices and other second order macroeconomic developments such as an increase in
inflation and rising interest rates. This resulted in a second order impact overlay of \u20ac334 million in total as of
31 December 2022, of which \u20ac164 million relates to Retail Banking segments and \u20ac170 million to the
Wholesale Banking segment.
As the credit risk models assume that these second order effects materialise via other risk drivers such as
GDP and unemployment rates with a delay, an overlay approach was determined to timely estimate the
Expected Credit Losses related to reduced repayment capacity and affordability for private individuals and
business clients in the Retail Banking segment. The \u20ac164 million includes an overlay of \u20ac22 million for clients
participating in the payment holiday scheme in Belgium that was introduced in 2022 to support customers
impacted by the inflation and high energy prices.
In WB, it was assessed that the economic effects of Covid-19 was not the highest risk anymore and that
other risks have emerged \u2013 mainly high energy prices, high interest rates and inflation, supply chain issues
and staffing shortages. A heatmap approach was used to adjust the probability of default for clients that
are expected to be significantly impacted by these emerged risks.
Given Covid-19-related payment holiday programmes have generally expired, this management
adjustment has been fully released in 2022.
Model based ECL of mortgage portfolios has decreased over the past years and until the third quarter of
2022, driven by significant increase of house prices in various countries. Management adjustments of \u20ac105
million in total, mainly in Stage 2 and 3, have been recognised by ING in the Netherlands, Belgium, Germany
and Australia to maintain an appropriate level of ECL and reflecting a potential impact of market
uncertainty on the recovery value of residential real estate (impacted by higher inflation and interest rates).
The management adjustment for the Netherlands and part of the Belgian mortgage portfolio was
determined by developing three alternative macroeconomic forecast scenarios, in addition to the consensus
base, up- and down-scenarios, that reflect a correction in the house prices in the next three years bringing it
back in line with the historical growth rate. For other countries, management adjustments were determined
by calculating the impact of lower house prices on LTVs and LGDs.
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. These result
from both regular model maintenance and ING\u2019s multiyear programme to update ECL models for the new
definition of default. These adjustments will be removed once updates to the specific models have been
implemented.
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 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. ING also observes that,
in general, the WB business is more sensitive to the impact of forward-looking macroeconomic scenarios.
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.
Sensitivity analysis as at December 2022\u00a0 (*)
2023
2024
2025
Un-weighted
ECL (\u20ac mln)
Probability-
weighting
Reportable
ECL (\u20ac mln)1
Netherlands
Upside scenario
Real GDP
2.2
2.3
2.9
274
20%
381
Unemployment
4.0
3.9
3.8
HPI
13.0
11.8
2.5
Baseline Scenario
Real GDP
0.2
1.4
1.8
349
60%
Unemployment
4.5
4.8
4.9
HPI
3.7
3.7
2.4
Downside scenario
Real GDP
-4.2
0.7
0.9
583
20%
Unemployment
6.4
7.8
8.7
HPI
-8.0
-6.5
2.2
Germany
Upside scenario
Real GDP
1.7
2.3
1.8
606
20%
745
Unemployment
2.6
2.2
1.8
HPI
0.6
3.9
6.2
Baseline Scenario
Real GDP
-0.7
1.4
1.5
726
60%
Unemployment
3.2
3.1
3.1
HPI
-1.8
0.9
2.7
Downside scenario
Real GDP
-4.8
0.1
1.0
942
20%
Unemployment
4.8
5.3
5.6
HPI
-6.2
-3.3
-1.4
Belgium
Upside scenario
Real GDP
1.7
2.1
2.1
535
20%
596
Unemployment
5.5
5.5
5.3
HPI
2.3
2.6
3.1
Baseline Scenario
Real GDP
0.0
1.6
1.8
584
60%
Unemployment
6.1
6.3
6.1
HPI
1.4
2.2
2.5
Downside scenario
Real GDP
-3.2
1.0
1.5
692
20%
Unemployment
7.5
8.5
8.4
HPI
-1.2
0.9
1.2
United States
Upside scenario
Real GDP
3.0
1.5
3.4
100
20%
221
Unemployment
3.4
2.8
2.5
HPI
3.7
7.4
8.1
Baseline Scenario
Real GDP
0.2
1.1
2.3
188
60%
Unemployment
4.3
4.4
3.9
HPI
2.5
2.2
2.8
Downside scenario
Real GDP
-4.1
0.2
0.6
442
20%
Unemployment
6.4
7.7
8.2
HPI
-1.2
-3.8
-3.5
1 Excluding management adjustments.
Sensitivity analysis as at December 2021 (*)
2022
2023
2024
Un-weighted
ECL (\u20ac mln)
Probability-
weighting
Reportable
ECL (\u20ac mln)1
Netherlands
Upside scenario
Real GDP
5.1
2.9
2.7
259
20%
307
Unemployment
3.2
2.9
2.9
HPI
23.3
10.9
0.9
Baseline Scenario
Real GDP
3.4
2.0
1.7
289
60%
Unemployment
3.7
4.1
4.3
HPI
13.1
2.8
0.8
Downside scenario
Real GDP
-1.5
1.2
0.7
411
20%
Unemployment
5.6
6.8
7.8
HPI
0.3
-7.7
0.6
Germany
Upside scenario
Real GDP
6.2
3.1
1.6
457
20%
483
Unemployment
2.9
2.2
1.9
HPI
12.9
7.9
5.3
Baseline Scenario
Real GDP
4.0
2.3
1.4
475
60%
Unemployment
3.4
3.1
3.1
HPI
10.4
4.6
1.9
Downside scenario
Real GDP
-0.6
0.9
0.8
535
20%
Unemployment
5.0
5.4
5.7
HPI
5.3
0.4
-2.1
Belgium
Upside scenario
Real GDP
4.6
2.5
2.0
364
20%
393
Unemployment
5.6
5.6
5.9
HPI
3.9
2.7
2.9
Baseline Scenario
Real GDP
3.1
2.0
1.8
383
60%
Unemployment
6.1
6.3
6.3
HPI
3.0
2.3
2.3
Downside scenario
Real GDP
-0.4
1.4
1.4
451
20%
Unemployment
7.6
8.6
9.0
HPI
0.4
1.0
1.0
United States
Upside scenario
Real GDP
6.7
2.4
3.1
28
20%
75
Unemployment
3.5
2.5
2.4
HPI
10.4
8.1
8.7
Baseline Scenario
Real GDP
4.0
2.5
2.1
55
60%
Unemployment
4.0
3.7
3.7
HPI
9.1
3.0
3.3
Downside scenario
Real GDP
-0.7
1.1
0.3
183
20%
Unemployment
6.5
7.4
8.0
HPI
5.3
-3.2
-3.0
1 Excluding management adjustments.
When compared to the sensitivity analysis of 2021, the macroeconomic inputs for 2022 and 2023 are less
favourable, driven by a worsened macroeconomic outlook as a result of the war in Ukraine as well as its
indirect effects such as inflation and increasing interest rates. Both 2021 and 2022 contain half-widened
dispersion around upside and downside scenarios, for 2021. This reflects continuing but decreased short-
term uncertainty relating to the impact of Covid-19 and for 2022 reflecting short-term uncertainty around
the war in Ukraine and its indirect effects. The increase in reportable ECL compared to 2021 is mainly caused
by higher model ECL amounts as per December 2022 as a result of increased provisions for Russia-related
exposures in Stage 2.
While the table above does give a high-level indication of the sensitivity of the outputs to the different
scenarios, it does not provide insight into the interdependencies and correlations between different
macroeconomic variable inputs. On a total ING level, the unweighted ECL for all collective provisioned clients
in the upside scenario was \u20ac2,680 million, in the baseline scenario \u20ac3,177 million and in the downside
scenario \u20ac4,456 million compared to \u20ac3,209 million reportable collective provisions as at 31 December 2022
(excluding all management adjustments). This reconciles as follows to the reported ECL\u2019s:
Reconciliation of model (reportable) ECL to total ECL (*)
in \u20ac million
2022
2021
Total model ECL1
3,209
2,408
ECL from individually assessed impairments
2,439
2,342
ECL from management adjustments
453
618
Total ECL
6,101
5,368
1 Prior period figure has been updated to conform to current year presentation.
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 since initial origination or purchase. ING considers the credit risk of an asset
to have significantly increased when either a threshold for absolute change in lifetime probability of default
(PD) or a relative change in lifetime PD is reached.
It should be noted that the lifetime PD thresholds are not the only drivers of stage allocation. An asset can
also change stages as a result of other triggers, such as having over 30 days arrears, being on a watch list or
being forborne. Refer to section 1.7.8 of Note 1 \u2018Basis of preparation and significant accounting policies\u2019 for
an exhaustive list. Furthermore, this analysis is rudimentary in the sense that other parameters would
change when an asset changes stages.
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 thresholds for the absolute change in lifetime PD vary between 75bps for Retail
portfolios, 100bps for WB and 250bps for SMEs, based on the characteristics of the specific portfolio. ING is in
the process of refining the thresholds on a portfolio level. These have already been implemented for more
than 20 percent of the portfolio, resulting in deviating absolute lifetime PD thresholds.
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 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 that is optimised depending on the observed default rates and overall average riskiness
of the portfolio. While the scaling factor is associated with a whole portfolio/segment, the PD at origination
is facility-specific and, in this sense, the relative threshold may differ facility by facility.
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 said 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
In the table below 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 2021 and year-end 2022.
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.
Quantitative SICR thresholds\u00a0 (*)
2022
2021
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
2.7
2.3
2.7
2.2
Consumer Lending
2.8
1.8
2.8
1.7
Business Lending
2.8
2.1
4.0
2.2
Governments and Fin. Institutions
3.0
1.9
7.9
2.2
Other Wholesale Banking
2.8
1.9
4.5
2.0
As it is apparent from the disclosures above, as per ING\u2019s 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. In 3Q 2022, following up an ECB request, a
new backstop trigger was implemented. The new trigger forces Stage 2 classification in case the lifetime PD
at reporting date has increased more than three times with respect to the origination, regardless of the
actual staging thresholds in force for a given portfolio. The new requirement entails that the threshold ratio
in the table above is effectively capped at a threefold increase for December 2022. The effect of this trigger
is especially apparent in the average thresholds ratio for investment grade facilities when confronting 2021
and 2022 figures. Since for investment grade assets thresholds tend to be looser given the good quality of
underlying counterparties ratings, the backstop trigger is more impactful.
In terms of impact on ING portfolio, the application of the new backstop trigger resulted in an increase of
Stage 2 exposure. However, since the trigger impacts mainly good quality assets for which regular staging
thresholds are typically above a threefold increase in PD, the corresponding impact in provisions was
limited.
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 Bank level, the total model ECL, which is the ECL collective-assessment without taking
management adjustments into account, is \u20ac3,209 million (2021:\u00a0 \u20ac2,408 million) of which performing assets
constitute \u20ac1,884 million (2021: \u20ac1,003 million) . To demonstrate the sensitivity of the ECL to these PD
thresholds bands, an analysis was run on all collectively-assessed assets, which assumed all assets were
below the threshold (Stage 1) and apportioned a 12-month ECL. On the same asset base, analysis was run
which assumed all performing assets were above the threshold (Stage 2) and apportioned a lifetime ECL.
This gave rise to hypothetical collective-assessment ECLs of \u20ac1,348 million (2021: \u20ac634 million) and \u20ac3,391
million (2021: \u20ac2,232 million) respectively. Please note that in this analysis, all other ECL risk parameters
(except for the stage) were kept equal.
Market risk
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\u2019s 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. This means that financial instruments in
the trading books should be free of trade restrictions. 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.
ING recognises the importance of sound market risk management and bases its market risk management
framework on the need to identify, assess, control and manage market risks. The approach consists of five
recurring activities: risk identification, risk assessment, risk control, risk monitoring and risk reporting.
Governance (*)
A governance framework has been established defining specific roles and responsibilities of business
management units, market risk management units, and internal approval bodies per activity.
Supervision of market risk falls under the responsibility of the EB/MBB and is delegated to the ALCO function,
where ALCO Bank is the highest approval authority and sets the market risk appetite. ALCO Bank monitors
ING\u2019s adherence to the risk appetite for market risk and sets additional limits where appropriate. These limits
are cascaded through the organisation through lower level ALCOs. This ALCO structure facilitates top-down
risk management, limit setting, and the monitoring and control of market risk.\u00a0
FR maintains a limit framework in line with ING\u2019s Risk Appetite Framework. The businesses are responsible
for adhering to the limits which are reviewed on an annual basis and are ultimately approved by the ALCO
Bank. Limit excesses are reported to senior management in line with the ALM Limit excess reporting
procedure upon which the business needs to act accordingly. To adhere to the established limit framework,
ING implements hedging and risk mitigation strategies that range from the use of traditional market
instruments, such as interest rate swaps, to more sophisticated hedging strategies.
The organisational structure facilitates top-down risk management by recognising that risk taking and risk
management occur to a large extent at the regional/local level. Bottom-up reporting from regional/local
units to head office units allows each management level to assess the market risks relevant at the
respective levels.
Several committees govern communication between the parties involved in market risk management:
\u2022The Market Risk Model Committee (MRMC, reporting to ALCO Bank), is the dedicated authority within ING
for the approval of all funding and liquidity risk, banking and trading risk and counterparty credit risk
models, methodologies and related parameters. This is comparable with the CTRC, which reports into the
GCTP.
\u2022The Valuation Model Committee approves pricing models for trading and banking books.
Financial Risk provides risk reporting to the EB and MBB, the ALCO Bank and the senior executive
management of related business functions.
The following sections elaborate on the various elements of the risk management framework for:
\u2022Market risk economic capital (trading and banking books).
\u2022Market risks in banking books.
\u2022Market risks in trading books.
Market risk in banking books (*)
ING makes a distinction 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 it is centrally managed. The scheme below presents the transfer and
management process of market risks in the banking books:
Risk measurement (*)
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\u2019s earnings, capital, and market
value to adverse movements in interest rates originated from positions in the banking book.
Governance (*)
The management of interest rate risk follows the Interest Rate Risk in the Banking Book (IRRBB) framework
as approved by ALCO Bank. This framework describes roles, responsibilities, risk metrics, and the policies and
procedures related to interest rate risk management. Furthermore, ALCO Bank reviews and sets the risk
appetite for interest rate risk, on an annual basis. The risk appetite is translated into limits for the interest
rate risk metrics.
As a result of this framework, 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:
\u2022Investment of own funds.
\u2022Commercial business.
\u2022Group 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. The
main objective is to maximise the economic value of the capital investment book while having stable
earnings.
Commercial activities can result in linear interest rate risk, for example, tenors and duration of new
production and re-pricing of assets differ from those of liabilities. Also, interest rate risk can arise from
customer behaviour and/or convexity risk, depending on the nature of the underlying product
characteristics.
Customer behaviour risk is defined as the potential future (value) loss due to deviations in the actual
behaviour of clients versus the modelled behaviour towards the embedded options in commercial products.
General sources of customer behaviour risk, among other things, include 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 three main product
types: funds entrusted as savings and demand deposits, mortgages and loans.
Savings and demand deposits are generally invested in such a way that both the value is hedged\u00a0 and the
sensitivity of the margin to market interest rates is minimised. Interest rate risk can arise when there is a
misalignment between the change in market rates and adjustment of savings rates, which can either have
a positive or negative impact on the income as a consequence of the potential misalignment to the related
(assumption based) investment strategy of ING\u2019s savings. Interest rate risk is modelled based on the stability
of the deposit 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. Savings volumes are typically
assumed to be relatively stable and less sensitive to rate changes.
Interest rate risk for mortgages arises due to prepayment possibilities in these mortgages. In modelling this
risk, both interest rate dependent pre-payments and constant prepayments are considered. Next to a
dependence on interest rates, modelled prepayments may include other effects such as loan-to-value,
seasonality and the reset date of the loan. In addition, the interest sensitivity of embedded offered rate
options may be considered.\u00a0
Wholesale Banking loans typically do not experience interest rate dependent prepayment behaviour, 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 research. However, the substantial change in the interest rate environment makes extensive
research more challenging than before and may increase model risk. Models are backtested and updated
when deemed necessary in an annual procedure. Model parameters and the resulting risk measures are
approved by (local) ALCO.
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 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. However, 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 transferred from the
commercial books to treasury books using cap/floor contracts.
In the following sections, the interest rate risk exposures in the banking books are presented. ING uses risk
measures based on both an earnings and a value perspective. Net interest income (NII)-at-risk is used to
provide the earnings perspective and the net present value (NPV)-at-risk figures provide the value
perspective. Please note that the expected interest rate risk coming forward from the business is assumed
to be linearly hedged but no additional corrective management actions are taken into account in the NPV-
at-Risk measure. In the NII-at-Risk measure, a more dynamic hedging process is taken into account.
During 2022, the following activities related to the risk measurement for IRRBB were performed:
\u2022Annual review of the risk appetite for Market Risks in the Banking Book including further enhancement.
\u2022Further assessment and development of sub-risk types, such as tenor basis risk, vega optionality risk and
client behaviour risk.
\u2022Set up of standardised risk measurement related to climate risk.
\u2022Annual review of the interest rates scenarios used for calculating NII-at-Risk and NPV-at-Risk.
\u2022Annual savings/current account model updates.
\u2022Annual update of parameters of prepayment models for market developments.
\u2022A specific, internal firm-wide stress test relating to climate risk.
\u2022Further enhancement of the IRRBB framework in relation to upcoming regulatory requirements (e.g.
anticipation on implementation and measurement of the upcoming regulatory metric NII SOT,
development of additional requirements coming forward from latest EBA guidelines).
\u2022Improvement of the FX framework.
Net interest income (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 are included in this risk metric. NII-at-Risk is a metric
that helps provide insight to what extent ING's NII under our Dynamic Plan deviates from the interest rates
development assumed.
In its risk management, ING monitors the NII-at-Risk under a three-year timeframe. Interest rates are
stressed during the first year versus the prevailing curve, taking gradual changes over the first year. The rate
changes considered comprise both upward and downward scenarios, as well as parallel (equal movements
across the yield curve) and non-parallel scenarios.
The impact of changing interest rates on ING\u2019s NII is predominantly caused by the following factors:
\u2022Change in returns of (re-)investments of client deposits.
\u2022Change in deposits client rates (mainly savings), (partially) tracking changes in market interest rates.
\u2022Change in funding profile of mortgages, due to an expected increase or decrease in expected
prepayments.
\u2022Higher/lower returns of (re-)investments of capital investment.
\u2022Open interest rate positions, leading to changes in return because of different market rates.
\u2022Assumed 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 to
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,
amongst others, actual interest rate and savings client rate evolution, as well as changes to ING\u2019s 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 tables below reflect a parallel, linear interest rate movement during a year
('ramped') under the assumption of balance sheet developments in line with the ING's Dynamic Plan with a
time horizon of one year.
NII-at-Risk banking books per business\u00a0 - year one (*)
in \u20ac million
2022
2021
Ramped, unfloored
Ramped, unfloored
parallel \u25bc
parallel \u25b2
parallel \u25bc
parallel \u25b2
By business
Wholesale Banking
4
-47
46
-33
Retail Banking Benelux
-88
59
-122
132
Retail Challengers & Growth Markets
-41
113
-93
75
Corporate Line Banking
-18
18
-58
58
Total
-142
142
-226
232
EUR ramped (unfloored) is at +/- 100bps in 1 year
USD ramped (unfloored) is at +/- 120bps in 1 year
The NII-at-Risk is primarily driven by the difference in sensitivity of client liabilities, mainly savings, versus
the sensitivity of client assets and investments to rate changes. The investment of own funds only impacts
the earnings sensitivity marginally, as only a relatively small part has to be (re)invested within the one-year
horizon.
NII-at-Risk banking book per currency - year one (*)
in \u20ac million
2022
2021
Ramped, unfloored
Ramped, unfloored
parallel \u25bc
parallel \u25b2
parallel \u25bc
parallel \u25b2
By currency
Euro
-119
114
-181
179
US Dollar
-1
2
-23
23
Other
-23
27
-23
30
Total
-142
142
-226
232
NII. However, the main drivers in a potential change of NII sensitivity are balance sheet developments,
specifically relating to mortgages, loans and savings. In the eurozone, mortgage production was impacted
by an increase in interest rates. Next to the impact on new production, the prepayment incentive decreased
due to the increase in interest rates. The funds entrusted volume did not change significantly, The impact of
explicit and implicit floors on both rates of client assets and savings phased out in the course of the year on
the back of the interest rate increases. Pre-existing hedges, as executed by Group Treasury, were also
adjusted continuously throughout the year to hedge any interest rate risk coming from higher interest
rates. Given that Group Treasury is included in the Wholesale Banking risk numbers, these adjustments
changed the Wholesale Banking NII-at-Risk. Furthermore, ING\u2019s investment of own funds took place against
a lower duration reducing sensitivity. Excluding Model Risk, the total NII-at-Risk remains relatively limited in
comparison to ING\u2019s total interest income.\u00a0
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. This does not include positive earnings in our commercial books. The NPV-at-Risk is defined as the
outcome of an instantaneous increase or decrease in interest rates from applying currency-specific
scenarios. The NPV-at-Risk asymmetry between the downward and upward shock is mainly caused by
convexity risk in the mortgage and savings portfolio.
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.
NPV-at-Risk banking books per business (*)
in \u20ac million
2022
2021
unfloored
unfloored
parallel \u25bc
parallel \u25b2
parallel \u25bc
parallel \u25b2
By business
Wholesale Banking
-1,474
1,299
-1,477
1,444
Retail Banking Benelux
-307
-76
-953
-202
Retail Challengers & Growth Markets
1,327
-1,373
832
-1,111
Corporate Line Banking
1,049
-1,003
1,820
-1,712
Total
594
-1,153
223
-1,580
EUR (unfloored) +/- 100bp shock scenario
USD (unfloored) +/- 120bp shock scenario \u00a0
Year-on-year variance analysis (*)
The overall NPV sensitivity for the rates-up scenario decreased in 2022. This is mainly due to the shorter
duration at which ING strategically invests its own funds. These investments are done in the Corporate Line
Banking.
The changes in NPV-at-Risk in the segments Retail Benelux and Retail Challengers & Growth Markets were
partly offsetting, whereby the higher interest rates reduced the overall convexity. The resulting impact on
retail sensitivity of the increase in interest rates was hedged by Group Treasury in line with the internal ALM
practices. The Group Treasury exposure is reported under business line Wholesale Banking.
IBOR transition (*)
In line with the recommendations from the Financial Stability Board, a fundamental review of benchmarks
for important interest rates has been undertaken. Some interest benchmarks have been reformed, while
others have or will be replaced by risk-free rates (RFR) and discontinued. Following the cessation of GBP, CHF,
JPY, and EUR LIBOR rates on 31 December 2021, USD LIBOR will cease on 30 June 2023.
In 2022, the focus shifted to USD LIBOR, with new USD lending now using the recommended alternative
rates based on SOFR. This is consistent with guidance issued to limit the use of USD LIBOR from
1 January 2022 onward. Risk reduction trades to help manage the run-off of existing USD LIBOR contracts
and positions are a permitted exception.
To enable these changes, the financial sector has issued several guidance papers and other initiatives to
help phase this transition. For example, ISDA has issued an IBOR fallback supplement to help ensure clear
fallback rates apply upon the discontinuation of key IBORs. For loans, various recommendations have been
made to help ensure the inclusion of consistent robust fallback provisions. Public authorities have also
recognised that many contracts do not contain provisions for any alternatives, contain inappropriate
alternatives, or cannot be renegotiated prior to the expected cessation date (\u2018tough legacy\u2019 contracts). For
example, the Financial Conduct Authority (FCA) is expected to ask the USD LIBOR administrator to continue
publishing a 'synthetic' LIBOR rate for 15 months beyond the cessation date to provide extra time for any
remaining contracts. A similar action was taken for GBP and JPY LIBOR. The US has also implemented the
Adjustable Interest Rate (LIBOR) Act, that will revise the contractual terms of in scope contracts to reference
a rate based on SOFR upon cessation of USD LIBOR.
Due to the discontinuation of this important rate, ING, its customers, and the financial services industry face
a number of risks. These risks include legal, financial, operational, and conduct risk. Legal risks are related to
any required changes to existing transactions. Financial risks may arise due to declining liquidity and may
impact a contract directly or the ability to hedge the risks in that contract. Operational risks arise due to the
requirement to adapt IT systems, trade reporting infrastructure and operational processes. Conduct risk also
plays a role, as renegotiation of loan contracts requires active engagement from all parties to a contract,
and may lead to negotiations concentrated in a period close to actual cessation. ING continues to reach out
to impacted clients to manage the relevant timelines.
During 2022, ING sought to ensure that a large portion of the derivative portfolio is covered by ISDA
fallbacks. Regarding the loans, many facilities have already been transitioned to alternative rates.
Additionally, for the remaining portfolio the parameters for the required changes have been communicated
to counterparties, with many now in active discussions on the remaining steps.
The ING IBOR programme has governance in place with progress being tracked by business line steering
committees reporting to a central IBOR steering committee. The programme assesses and coordinates the
actions necessary to manage the required changes to internal processes and systems, including pricing, risk
management, legal documentation, hedge arrangements, as well as the impact on customers. ING
continues to monitor market developments and reform plans for other rates, to anticipate the impact on
the programme, our customers and any related risks.
One such development concerns key Polish Zloty benchmarks. The roadmap published by the Polish
National Working Group in 2022 indicates that the plan is for the market to be ready for a cessation of
WIBOR and WIBID Reference Rates in 2025. It is expected that the reform will be completed by the end of
2024, with the offering of financial products using the new benchmark (WIRON) to progress gradually in
2023 and 2024. 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.
As at 31 December 2022, ING has exposures that have yet to transition related to USD LIBOR and WIBOR.
The tables below summarise these approximate exposures. They exclude exposures that will expire before
the transition date 30 June 2023 and 1 January 2025, respectively. The GBP LIBOR, CHF LIBOR and EONIA
contracts included as at 31 December 2021 have all transitioned or matured.
Non derivative Financial instruments to transition to alternative benchmarks (*)
in \u20ac million at 31 December 2022
Financial Assets non-
derivative
Financial Liabilities\u00a0
non-derivative
Off balance sheet
commitments
Carrying value
Carrying value
Nominal value
By benchmark rate
GBP LIBOR
USD LIBOR
30,040
1,637
7,644
CHF LIBOR
EONIA
WIBOR
22,154
1,411
Total
52,194
1,637
9,055
Non derivative Financial instruments to transition to alternative benchmarks (*)
in \u20ac million at 31 December 2021
Financial Assets non-
derivative
Financial Liabilities\u00a0
non-derivative
Off balance sheet
commitments
Carrying value
Carrying value
Nominal value
By benchmark rate1
GBP LIBOR
764
350
USD LIBOR
41,805
1,542
16,435
CHF LIBOR
1
EONIA
23
184
Total
42,570
1,565
16,969
1 WIBOR transition plans became concrete in 2022 and therefore no comparatives for 2021 are included.
For derivatives linked to USD LIBOR, the conduct risk is limited as the majority are transacted with clearing
houses, which will transition through a standardised exercise in the second quarter of 2023. For USD LIBOR
derivatives that are not centrally cleared, the main transition will occur via the ISDA IBOR fallback protocol at
30 June 2023.
Derivative Financial instruments to transition to alternative benchmarks (*)
31 December 2022
31 December 2021
in \u20ac million
Nominal value
Nominal value
By benchmark rate1
GBP LIBOR
822
USD LIBOR2
495,318
488,499
WIBOR3
136,318
Total
631,636
489,321
1 For cross-currency swaps all legs of the swap are included that are linked to a main IBOR that is significant to ING.
2 The prior period has been updated to improve consistency and comparability.
3 WIBOR transition plans became concrete in 2022 and therefore no comparatives for 2021 are included.
In addition to the amounts in the table above, ING has interest rate swaptions that refer to the USD LIBOR
ICE swap rate with a notional of \u20ac10,810 million (2021: \u20ac10,343 million) that are yet to transition. The
transition of these contracts is in general governed by a specific ISDA protocol.
Given that IBOR Reform may have various accounting implications, the International Accounting Standards
Board (IASB) has undertaken a two-phase project:
\u2022Phase 1 addresses those issues that affect financial reporting before the replacement of an existing
benchmark. Phase 1 amendments to IFRS were issued by the IASB in 2019 and were early adopted by
ING in the same year. This allows ING to apply a set of temporary exceptions to continue hedge
accounting even when there is uncertainty about contractual cash flows arising from the reform. Under
these temporary exceptions, interbank offered rates are assumed to continue unaltered for the purposes
of hedge accounting until such time as the uncertainty is resolved.
\u2022Phase 2 focuses on issues that may affect financial reporting when the existing benchmark rate is
reformed or replaced. Phase 2 amendments to IFRS were issued by the IASB in 2020 and became
effective in 2021. Phase 2 amendments to IFRS relate mainly to accounting for changes in the basis for
determining the contractual cash flows of financial assets and liabilities due to the IBOR reform and
impact on hedge accounting when an existing benchmark rate is reformed or replaced with an
alternative risk-free rate.
Specifically, Phase 2 amendments require that the effective interest rate on debt financial instruments is
adjusted, and hedge accounting continues on transition to risk free rates, but only to the extent that the
modifications made to financial instruments are those necessary to implement the IBOR Reform and that
the new basis for calculating cash flows is \u2018economically equivalent\u2019 to the previous basis. By applying these
mandatory amendments, ING avoids recognising modification gains and losses on debt instruments that
would otherwise be required in the absence of Phase 2 amendments (changes to debt instruments resulting
from IBOR Reform are treated as a reset to the instrument\u2019s variable interest rate). In addition, ING avoids
hedge accounting discontinuations when modifying both hedged items and hedging instruments (and
related hedge documentation) as a consequence of IBOR reform that would otherwise be required in the
absence of Phase 2 amendments.\u00a0
As explained above, Phase 1 and Phase 2 IBOR amendments to IFRS, amongst other changes, provide
specific hedge accounting reliefs that allow hedge accounting relationships to continue when IBOR Reform is
ongoing. Phase 1 reliefs cease to apply when uncertainty arising from IBOR Reform is no longer present with
respect to the timing and amount of the IBOR-based cash flows of the relevant instruments. It is ING\u2019s policy
to cease to apply Phase 1 reliefs when the applicable contract (either hedging instrument or hedged item) is
actually modified. As a result, for these hedge accounting relationships the applicable Phase 1 reliefs ceased
to apply and Phase 2 became applicable. For USD LIBOR exposures, and although the administrator of LIBOR
confirmed on 5 March 2021 its plans for the cessation of USD LIBOR rates at the end of June 2023, there is
still uncertainty with respect to the timing of the transition as well as the transition strategy for individual
hedged items and/or hedging instruments linked to USD LIBOR. Therefore, for USD LIBOR 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, Phase 2 reliefs will become applicable.
In addition, in 2022 ING started to apply Phase 1 reliefs to the hedge accounting relationships linked to
WIBOR as there is uncertainty arising from the WIBOR reform with respect to the timing and the amount of
the underlying cash flows to which ING is exposed.
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.
Governance \u2013 Core banking business (*)
Every business unit hedges the FX risk resulting from core banking business activities into its base currency.
Consequently, assets and liabilities are matched in terms of currency.
Governance \u2013 FX translation result (*)
ING\u2019s 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. 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 \u2013 FX translation result (*)
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 Market Risk Banking Book RAS.
Foreign currency exposures banking books (*)
in \u20ac million
Foreign Investments
Hedges
Net exposures
2022
2021
2022
2021
2022
2021
US dollar1
10,470
8,218
-2,376
-99
8,093
8,119
Pound sterling
1,364
1,593
-58
1,306
1,592
Polish zloty
2,714
2,761
-321
-142
2,393
2,620
Australian dollar
3,781
3,774
-2,673
-2,511
1,108
1,263
Turkish lira
750
729
750
729
Chinese yuan
1,871
1,976
-107
1,871
1,869
Russian rouble
391
256
-174
392
82
Other currency
5,740
5,860
-3,761
-3,453
1,979
2,407
Total
27,081
25,167
-9,189
-6,486
17,892
18,681
Hyperinflation accounting and goodwill impairment had limited impact on the Turkish lira FX exposure to the CET1 Ratio.
The structural Turkish lira exposure arising from ING Bank Turkey\u2019s assets and liabilities remains within risk limits.
Equity price risk in banking books (*)
Governance (*)
ING maintains a strategic portfolio with substantial equity exposure in its banking books. Local offices are
responsible for the management of the equity investment positions. Financial Risk is responsible for
monitoring the regulatory capital for equity investments on a monthly basis and acts independently from
ING/local management when monitoring these positions.
Risk profile (*)
Equity price risk arises from the possibility that an equity security\u2019s price will fluctuate, affecting the values
of the equity security itself as well as other instruments whose value react similarly to the particular
security, a defined basket of securities, or a securities index. ING\u2019s equity exposure mainly consists of the
investments in associates and joint ventures of \u20ac1,500 million (2021: \u20ac1,587 million) and equity securities
held at fair value through other comprehensive income (FVOCI) of \u20ac1,887 million (2021: \u20ac2,457 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.
Year-on-year variance analysis (*)
In 2022, the revaluation reserve equity securities decreased by \u20ac95 million from \u20ac1,282 million to \u20ac1,187
million. In 2022, the equity securities at fair value through OCI decreased by \u20ac570 million mainly due to
divestment of HQLA eligible equity instruments.
Revaluation reserve equity securities at fair value through other comprehensive income (*)
in \u20ac million
2022
2021
Positive re-measurement
1,190
1,291
Negative re-measurement
-4
-9
Total
1,187
1,282
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 2022, 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.
Governance (*)
The Financial Markets Risk Committee (FMRC) is the market risk committee that, within the risk appetite set
by the ALCO Bank, sets the market risk limits both on an aggregated level and on a desk level. Financial Risk/
Trading Risk Management (FR/ TRM) advises both FMRC and ALCO Bank on the market risk appetite of the
trading activities.
With respect to the trading portfolios, 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. Trading activity is
systematically reviewed and positioned against the mandates are assessed jointly by the first and second
lines of defence.
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 Event Risk (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.
As of June 2022, ING has received an official permission from the ECB to perform offsetting of positions with
the exception of Ukraine, Russia and Turkey. Hence the regulatory capital numbers reported from Q2 2022
onwards, are calculated with offsetting for all base entities excluding Ukraine, Turkey\u00a0 and Russia.
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%, 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) if 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 e.g. 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\u2019s portfolio is estimated, based on
equally weighted observed market movements of the previous year (260 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 ten-day horizon the one-day risk factor shifts are scaled by the
square root of ten 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: HVaR 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
ten 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 results (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 \u2018outlier\u2019 occurs. Based on ING\u2019s one-sided confidence level of 99%, an outlier is expected once in every
100 business days.
On an overall level in 2022, there were five outliers for hypothetical P&L and three outliers for actual P&L.
The actual and hypothetical outliers occurred during the past one year concentrated in 1Q2022 mainly due
to large moves in Russian credit default swaps and Rouble volatility.
Stressed HVaR (*)
The Stressed HVaR (SVaR) is intended to replicate the HVaR calculation that would be generated on the
bank\u2019s current portfolio with inputs calibrated to the historical data from a continuous 12-month period of
significant financial stress relevant to the bank\u2019s portfolio.
To calculate SVaR, ING uses the same model that is used for 1DHVaR, with a ten-day horizon. The data for
the historical stress period used currently includes the height of the credit crisis around the fall of Lehman
Brothers, and this choice is reviewed regularly. 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% 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 are 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.
Stress testing and event risk (*)
Stress testing and event risk are valuable risk management tools. In addition to the bank-wide stress test
framework as described in the stress-testing section, FI-FM Risk performs additional assessments, specific to
the trading book, with various frequencies: sensitivity analyses (single-risk factor and multi-risk factor), ad-
hoc stress tests (e.g. Covid-19 scenarios) and structured stressed scenario tests under the event risk
framework - to monitor market risks under extreme market conditions. Event risk evaluates the bank\u2019s
financial stability under severe but plausible stress scenarios and assists in decision-making aimed at
maintaining a financially healthy going-concern institution after a severe event occurs. Event risk is based
on historical as well as hypothetical extreme scenarios. The result is an estimate of the profit and loss
caused by a potential event and its worldwide impact for ING.
ING\u2019s event risk policy is based on a large set of possible stress scenarios per risk type. 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. For equity products, for example, both a crisis scenario
(prices decrease) as well as a bull scenario (prices increase) are assumed. Scenarios are calculated based on
events happening independently, jointly by region, or in all countries simultaneously. This way, for each risk
type, a large set of scenarios is calculated. The worst scenarios per market are combined across markets by
assessing both independent events per market, and the worst events happening in all markets at the same
time.
Sensitivities (*)
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 \u20ac million
2022
2021
Foreign exchange
Foreign exchange
US Dollar
-187
US Dollar
-160
Romanian Leu
88
Taiwan Dollar
42
Japanese Yen
86
Romanian Leu
32
Chinese Yuan
32
Japanese Yen
27
South Korean Won
28
South Korean Won
-24
Most important interest rate and credit spread sensitivities at year-end (*)
in \u20ac thousand
2022
2021
Interest Rate (BPV) 1
Interest Rate (BPV) 1
Euro
-334
Euro
-501
British Pound
-95
US Dollar
185
US Dollar
-79
British Pound
-75
Taiwan Dollar
67
Taiwan Dollar
73
Japanese Yen
63
Japanese Yen
-57
Credit Spread (CSO1) 2
Credit Spread (CSO1) 2
Netherlands
162
Netherlands
535
United States
151
Germany
408
Japan
102
United States
171
France
88
France
112
Germany
87
China
110
Funding and liquidity adequacy and risk appetite (*)
ING identifies various key drivers of future liquidity and funding needs on an ongoing basis and through the
periodic risk identification process. Taking into consideration the identified drivers, ING regularly assesses its
current and future liquidity adequacy and, if deemed necessary, takes steps to further improve ING\u2019s
liquidity position and to have sufficient counterbalancing capacity. A liquidity adequacy statement is
formulated on at least a quarterly basis to substantiate and reflect the management view on the current
funding and liquidity position as well as the potential future challenges. The quarterly liquidity adequacy
statement is an important part of ING\u2019s ILAAP process.
ING assesses its F&L adequacy through three lenses \u2013 stress, economic and normative:
\u2022Through the stress lens, ING evaluates its ability to withstand a period of prolonged F&L stress for both
normative and economic requirements or limits under idiosyncratic, market-related or a combination of
idiosyncratic and market-related scenarios, which lead to customer deposit outflows, deterioration of
access to funding markets, and lower liquidity value of counterbalancing capacity.
\u2022Through the economic lens, ING assesses the extent to which its customers, professional counterparties
and investors are comfortable in providing deposits and funding in tenors, currencies and instruments
necessary to sustainably fund the business (intraday, short-term and long-term) in a going-concern
situation.
\u2022Through the normative lens, ING ascertains that the bank is in the position to meet current and
forthcoming home and host regulatory requirements.
For each lens, ING has established a related set of risk appetite statements which define ING\u2019s risk appetite
commensurate with the principles of liquidity adequacy. These risk appetite statements are summarised in
the next graph.
The F&L risk appetite statements are translated into a number of metrics with appropriate boundaries and
instruments which are used to measure and manage ING\u2019s 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 (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\u2019s risk appetite and normative
requirements.
The macroeconomic and market environment are also important considerations in ING\u2019s funding and
liquidity framework. The macroeconomic environment comprises various exogenous factors over which ING
has no control, but which may have a material impact on ING\u2019s F&L position. The main macroeconomic
factors analysed on a regular basis include:
\u2022Global and local economic performance e.g. shifts in GDP, inflation rates, unemployment rates and public
deficit/surplus.
\u2022Changing geopolitical trends.
\u2022Monetary policy with a focus on the unconventional monetary measures employed by central banks in
recent years including the measures taken since the start of the Covid-19 crisis and the more recent
period of increased inflation.
\u2022Regulatory requirements, e.g. understanding the changing regulatory landscape as well as the impact of
ING\u2019s 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.
Liquidity stress-testing (*)
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\u2019s 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 Bank, 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 and combined (idiosyncratic and market-
wide) stress scenarios. The design of the framework is based on empirical evidence supplemented by expert
judgement. 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\u2019s F&L risk framework and F&L risk
management, including:
\u2022Risk Appetite Framework (through risk appetite statements).
\u2022Risk identification and assessment.
\u2022Monitoring of the liquidity and funding position.
\u2022Business actions (if needed).
\u2022Contingency funding plan.
\u2022Early 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\u2019s liquidity position is stress tested at least monthly 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 regular 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
2022, this included stress-test scenarios dedicated to the war in Ukraine, inflation, and the impact of
monetary tightening. The internal stress scenarios also serve as input for decision making on additional
contingency measures.
Contingent F&L risks are addressed in the Contingency Capital and Funding Plan with a focus on early
warning indicators as well as organisation and planning of liquidity management in times of stress. The
contingency funding measures are developed in conjunction with the ING Recovery Plan and are tested on a
regular basis.
Governance (*)
The head of Model Risk Management (MoRM) reports to the ING chief risk officer. The Model Risk
Management Committee (MoRMC) is the dedicated authority within ING for model risk management. It is a
committee designated by the MBB. It is chaired by the ING chief risk officer and co-chaired by the head of
MoRM.
Model lines of defence (*)
ING\u2019s model risk and control structure is based on the three model lines of defence (MLoD) approach. This
approach aims to provide a sound governance framework for model risk management by defining and
implementing three different management layers with distinct roles and oversight responsibilities.
The composition and main activities within the three model lines of defence (MLoD):
\u2022The first MLoD is composed of the model owners, model users, data management and model
development, and is accountable for the implementation of model risk controls which encompass model
development, implementation and use of the models as well as monitoring of models\u2019 performance.
\u2022The second MLoD is composed of model validation and model risk oversight, which owns the model risk
management framework, proposes the model risk appetite, provides challenge to model risk
identification and assessment and provides an independent validation of models used within ING.
\u2022The third MLoD is the internal audit, reviewing the quality of model risk management execution in all
lines of defence and providing assurance over the first and second line model risk management
activities.
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. Current model RAS metrics are focused on the most important models for ING: credit
risk and other models with elevated supervisory attention. These metrics are reported to the MBB on a
quarterly basis.
Model risk management (MoRM) (*)
The MoRM policy framework comprises the total set of measures and tools put in place to manage model
risk.To enable setting model risk management standards that are proportionate to a model\u2019s importance,
ING classifies models based on their materiality and reputational risk. The classification determines the
depth and extent of the applied model risk management activities, including model validation. During 2022,
the MoRM policy framework was updated and enhanced, incorporating ING model data-ethics principles and
integrating a risk-based approach to model validation. Next to the generic MoRM policy framework,
dedicated model validation frameworks are in place. These set the validation standards for the key model
types such as credit, market, liquidity, operational risk, IRRBB, KYC, and other model categories. These
frameworks are continuously being enhanced to keep up-to-date with regulatory and technical
developments.
On an aggregated level model risk is monitored via analysis of data from the global model inventory. The
insights, from aggregated data analysis, are reported to the MoRMC and to the MBB so that senior
management can take well-informed decisions on acceptance or further mitigation of model risk.
Model lifecycle (*)
The next figure provides a schematic overview of the model lifecycle, where orange represents the activities
of the first MLoD, grey represents the second MLoD and light grey is the third MLoD. The objectives of the
different processes are outlined below.
Initiation or change: The initiation of the development of a new model or change in an existing model can
be triggered by internal or external factors, such as business needs, regulation changes and/or model
validation findings.
Data collection is the process of defining and collecting data that meets the requirements for model
development. The process includes the definition of the data needed and assessment of data availability
and data quality.
Model development is a structured process that leads to a model that is consistent with the model owner
requirements, bank policy and relevant regulation where applicable.
Pre-approval validation is an independent assessment to determine whether a newly developed or
materially changed model is valid for its intended use. The approach to model validation is proportional to
the model risk as reflected in the ING model risk classification.
The objective of the model approval stage is to ensure models are formally approved bye the designated
approval authority prior to deployment.
During the implementation stage, the model is deployed in a production environment, after completion of
required model testing and corresponding approval.
In the model use stage the model is applied by the users for the specific purpose for which it was designed.
The model may only be used after formal approval.
The objective of model monitoring is to determine if the model is performing as expected by regularly
assessing model accuracy and/or predictive ability, considering internal or external developments that may
influence model performance. Model performance monitoring begins when a model is deployed for use and
continues until the model has officially been decommissioned.
Periodic validation assesses, on a regular basis, whether a model is still valid for its intended use and if the
model is used as intended, taking into consideration any internal or external changes since the last
validation. The frequency of periodic validation depends on the model risk, model type and applicable
regulation.
A model that is/will no longer be used must be decommissioned.
As at 31\u00a0December 2022, Cash and cash equivalents includes cash and balances with central banks of EUR
87,614 million (2021: EUR 106,520 million; 2020: EUR 111,087 million). Reference is made to Note 33 'Cash
and cash equivalents'.
References relate to the accompanying notes. These are an integral part of the Consolidated financial
statements.
The table below presents the Interest and dividend received and paid.
in EUR million
2022
2021
2020
Interest received
28,110
21,515
23,365
Interest paid
-14,201
-8,723
-9,690
13,909
12,792
13,675
Dividend received 1
229
172
144
Dividend paid
-6,319
-3,165
-46
1\u00a0 Includes dividends received as recognized within Investment Income, from equity securities included in the Financial assets at fair
value through profit or loss, Financial assets at fair value through OCI, and from Investments in associates and joint ventures. Dividend
paid and received from trading positions have been included.
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.
1\u00a0 Basis of preparation and significant accounting policies
1.1\u00a0 Reporting entity and authorisation of the Consolidated financial statements
ING Bank N.V. (Naamloze vennootschap) is a company domiciled in Amsterdam, the Netherlands.
Commercial Register of Amsterdam, number 33031431. ING Bank N.V. is a wholly-owned subsidiary of ING
Groep N.V. domiciled in Amsterdam, the Netherlands. These Consolidated financial statements, as at and for
the year ended 31 December 2022, comprise ING Bank N.V. (the Parent company) and its subsidiaries,
together referred to as ING Bank. ING Bank is a global financial institution with a strong European base,
offering a wide range of retail and wholesale banking services to customers in over 40 countries.\u00a0 \u00a0\u00a0
The ING Bank Consolidated financial statements, as at and for the year ended 31 December 2022, were
authorised for issue in accordance with a resolution of the Management Board Banking on 6 March 2023.
The General Meeting of the Shareholder may decide not to adopt the financial statements, but may not
amend these.
1.2\u00a0 Basis of preparation of the Consolidated financial statements
The ING Bank Consolidated financial statements have been prepared in accordance with International
Financial Reporting Standards (IFRS) as adopted by the European Union (EU) and the relevant articles of Part
9 of Book 2 of the Dutch Civil Code.
IFRS as adopted by the EU are IFRS Standards and IFRS Interpretations as issued by the International
Accounting Standards Board (IASB) and the IFRS Interpretations Committee (IFRIC) with some limited
modifications such as the temporary \u2018carve-out\u2019 from IAS 39 \u2018Financial Instruments: Recognition and
Measurement\u2019 (herein, referred to as IFRS).
Under the EU carve-out, ING Bank applies fair value hedge accounting to portfolio hedges of interest rate risk
(macro hedging). For further information, reference is made to paragraph 1.7.4 \u2018Derivatives and hedge
accounting\u2019 of this note and to Note 36 'Derivatives and hedge accounting'.
The ING Bank Consolidated financial statements have been prepared on a going concern basis and there are
no significant doubts about the ability of ING Bank 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.
1.2.1\u00a0 Presentation of Risk management disclosures
To improve transparency, reduce duplication and present related information in one place, certain
disclosures of the nature and extent of risks related to financial instruments required by IFRS 7 \u2018Financial
instruments: Disclosures\u2019 are included in the \u2018Risk management\u2019 section of the Annual Report.
These disclosures are an integral part of ING Bank Consolidated financial statements and are indicated in the
\u2018Risk management\u2019 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.
1.3\u00a0 Impact of Russian invasion in Ukraine
The war in Ukraine had, besides an immense impact on the lives of millions of people, a negative impact on
the global economy. While businesses and households were still recovering from the economic
consequences of Covid-19, developments in Ukraine further distorted supply chains, caused higher energy
costs and aggravated an already high inflation rate environment. This, in combination with central bank
rate hikes, worsened the macroeconomic outlook.
As a result of the economic effects of Russian invasion and second order effects uncertainty and level of
management judgement remains at an elevated level in 2022, particularly in the estimation of loan loss
provisions (including the need for management adjustments), the determination of fair values and\u00a0
impairment assessment of an investment in an associate.\u00a0
Reference is made to the notes of the financial statements as well as Risk Management chapter for further
information on the impact of the Russian invasion of Ukraine and second order impacts.
.
1.4\u00a0 Changes to accounting policies and presentation
ING Bank has consistently applied its accounting policies to all periods presented in these Consolidated
financial statements.
In 2022, ING Bank updated the presentation in note 7 \u2018Loans and advances to customers\u2019 to improve
consistency and comparability. Comparative figures for 2021 have been updated accordingly.
1.4.1\u00a0 Changes in IFRS effective in 2022
The following amended standards became effective in 2022:
\u2022Amendments to IFRS 3 \u2018Business Combinations\u2019: Reference to the Conceptual Framework (issued in May
2020).
\u2022Amendments to IAS 16 \u2018Property, Plant and Equipment\u2019: Proceeds before Intended Use (issued in May
2020).
\u2022Amendments to IAS 37 \u2018Provisions, Contingent Liabilities and Contingent Assets\u2019:\u00a0 Onerous Contracts \u2014
Cost of Fulfilling a Contract (issued in May 2020).
\u2022Annual improvements to IFRS Standards 2018-2020 Cycle: Amendments to IFRS 1 \u2018First-time Adoption of
International Financial Reporting Standards\u2019, amendments to IFRS 9 \u2018Financial Instruments\u2019 and
amendments to IFRS 16 \u2018Leases\u2019 (issued in May 2020).
The above changes did not have significant impact on ING Bank\u2019s Consolidated financial statements. ING
Bank has not early adopted any standard, interpretation or amendment in 2022 which has been issued, but
is not yet effective.
1.4.2\u00a0 Upcoming changes in IFRS after 2022
The following published amendments are not mandatory for 2022 and have not been early adopted by ING
Bank
Effective in 2023 (endorsed by the EU):
\u2022IFRS 17 'Insurance Contracts' (issued in May 2017), including amendments to IFRS 17 (issued in June
2020).
IFRS 17 \u2018Insurance Contracts\u2019 is a new accounting standard for insurance contracts covering recognition and
measurement, presentation and disclosure. Once effective, IFRS 17 will replace IFRS 4 \u2018Insurance Contracts\u2019,
which allowed diversity in accounting practices for insurance contracts. In June 2020, the IASB published
amendments to IFRS 17 including a scope exclusion for credit card contracts and similar contracts that
provide insurance coverage, and an optional scope exclusion for loans with death waivers. ING does not
have an insurance business, but on a limited basis sells insurance products as a broker where it does not run
the insurance risk. ING Bank performed an impact assessment which revealed that a portfolio of loans with
death waivers in the Netherlands with a net carrying amount of approximately of EUR 750 million might be
in scope of IFRS 17. Following the above mentioned amendments to IFRS 17 in 2020 which allow an
accounting policy choice, ING Bank intends to account for assets in this portfolio in their entirety, including
death waiver features, using IFRS 9 \u2019Financial Instruments\u2019 and not IFRS 17. As a result, this portfolio will no
longer meet the \u2018solely payments of principal and interest\u2019 (SPPI) criterion, causing the portfolio to no longer
be recognised at amortised cost but rather at fair value through profit or loss. This reclassification is not
expected to have a material impact on equity or result of ING Bank, as the fair value is expected not to differ
materially from the current book value. Hence, the financial impact of IFRS 17 on ING Bank is expected to be
limited.
The following amendments will also be effective in 2023. However, the implementation of these
amendments is expected to have no significant impact on NG Bank's Consolidated financial statements.
\u2022Amendments to IAS 1 \u2018Presentation of Financial Statements\u2019: Disclosure of Accounting Policies (issued in
February 2021).
\u2022Amendments to IAS 8 \u2018Accounting Policies, Changes in Accounting Estimates and Errors\u2019: Definition of
Accounting Estimates (issued in February 2021).
\u2022Amendments to IAS 12 \u2018Income Taxes\u2019: Deferred Tax Related to Assets and Liabilities Arising From a
Single Transaction (issued in May 2021).
Effective in 2024 (not yet endorsed by the EU):
\u2022Amendments to IFRS 16 'Leases': Lease Liability in a Sale and Leaseback (issued in September 2022).
\u2022Amendments to IAS 1 \u2018Presentation of Financial Statements\u2019: Classification of Liabilities as Current or
Non-current (issued in January 2020).
1.5\u00a0 Significant judgements and critical accounting estimates and assumptions
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 Bank 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:
\u2022Loan loss provisions (financial assets);
\u2022The determination of the fair values of financial assets and liabilities;\u00a0
\u2022Impairment assessment of an investment in associate;
\u2022Provisions; and
\u2022Accounting for Targeted Longer-Term Refinancing Operations (TLTRO).
For further discussion of the significant judgements and critical accounting estimates and assumptions in
these areas, reference is made to the relevant parts in paragraph 1.7 \u2018Financial instruments\u2019 (specifically
1.7.8 \u2018Impairment of financial assets\u2019, 1.7.3 for \u2018Fair values of financial assets and liabilities\u2019, 1.11
\u2018Investments in associates and joint ventures\u2019, 1.18 \u2018Provisions, contingent liabilities and contingent assets\u2019
and 1.7.9 \u2018Accounting for Targeted Longer-Term Refinancing Operations (TLTRO)\u2019) of this note and the
applicable notes to the Consolidated financial statements.
1.6\u00a0 Other developments
Application of IAS 29 \u2018Financial Reporting in Hyperinflationary Economies\u2019
During the second quarter of 2022 Turkey became a hyperinflationary economy for accounting purposes.
As ING Bank has a subsidiary in Turkey, ING Bank applied IAS 29 \u2018Financial Reporting in Hyperinflationary
Economies\u2019 to its operations as if the economy in Turkey had always been hyperinflationary. Given that ING
Bank presents its results in EUR, comparatives were not restated and IAS 29 was applied from 1 January
2022 with the impact of the first-time application and the effect for the period both shown in these
Consolidated financial statements for the year ended 31 December 2022.
Under IAS 29, the results of the operations in Turkey 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 development of the CPI during the year ended 31 December 2022 was as follows (2003=100):
1 January 2022\u00a0 686.95
31 December 2022 1,128.45
Change for the period\u00a0 64.27%
To state all the items in the financial statements in terms of their current purchasing power at the reporting
date, ING Bank restated the non-monetary items of ING Turkey (such as properties and equipment,
intangibles, right-of use assets and shareholder\u2019s equity) for the changes in CPI up to the reporting date.
Monetary items (such as cash and balances with banks, loans and advances and deposits) are not restated
as they are already expressed in the current purchasing power. Furthermore, all items in the statement of
comprehensive income were also restated for the effects of inflation based on the developments in CPI
during the 12 month period to reflect the purchasing power as at 31 December 2022.
The effect of such restatement of the statement of comprehensive income and the balance sheet for
inflation in the current period has been recognised in the statement of profit or loss within \u2018Other net
income\u2019 as a \u2018Net monetary gain or loss\u2019. 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
Turkey.
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 Turkey are translated and presented in EUR at the exchange rate on 31
December 2022. 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 Bank selected to present both the restatement effect resulting from restating
ING Bank\u2019s interest in the equity of ING Turkey as required by IAS 29; and the translation effect from
translating at a closing rate that differs from the previous closing rate, in the Currency translation reserve.
Refer to Note 19 \u2018Equity\u2019 for the impact of applying IAS 29 during the year ended 31 December 2022.
1.7\u00a0 Financial instruments
ING Bank applies IFRS 9 \u2018Financial Instruments\u2019 to the recognition, classification and measurement, and
derecognition of financial assets and financial liabilities and the impairment of financial assets. The Group
applies the requirements of IAS 39 \u2018Financial Instruments: Recognition and Measurement\u2019 for hedge
accounting purposes.
1.7.1\u00a0 Recognition and derecognition of financial instruments
Recognition of financial assets
Financial assets are recognised in the balance sheet when ING Bank 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 Bank 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 Bank 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.
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.
1.7.2\u00a0 Classification and measurement of financial instruments
Financial assets
ING Bank classifies its financial assets in the following measurement categories:
\u2022those to be measured subsequently at fair value (either through OCI, or through profit or loss); and
\u2022those to be measured at amortised cost (AC).
At initial recognition, ING Bank 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\u2019s 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 Bank\u2019s 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 Bank 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\u2019s business model for managing the financial assets and the contractual terms of the
cash flows, there are three measurement categories into which ING Bank classifies its debt instruments:
\u2022Amortised 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.
\u2022FVOCI:
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\u2019 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.
\u2022FVPL:
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 Bank 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 repo\u2019s) 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 Interest income or 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
Interest income or Interest expense in the period in which it arises.
ING Bank 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 Bank applies the fair value through OCI option to
investments which are considered strategic, consisting of investments that add value to ING Bank\u2019s 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\u2019s 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:
\u2022the 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
\u2022the remaining amount of change in the fair value is presented in profit or loss in \u2018Valuation results and
net trading income\u2019. 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 \u2018Interest income
(expense).
A financial guarantee contract is a contract that requires ING Bank 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 \u2018Financial instruments\u2019 (see section \u201cImpairment of financial assets\u201d) and (b)
the amount initially recognised less, when appropriate, cumulative amortisation recognised in accordance
with the revenue recognition principle of IFRS 15 \u2018Revenue from contracts with customers\u2019.
1.7.3\u00a0 Fair values of financial assets and liabilities
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 \u2018Day One Profit or Loss\u2019) is deferred. ING Bank 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 Bank 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.
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 Bank 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 Bank 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 Bank\u2019s own credit risk by means of a DVA. Additionally, derivatives
valued at fair value are adjusted for credit risk by a BVA. The BVA is of a bilateral nature as both the credit
risk on the counterparty (CVA) as well as the credit risk on ING Bank (DVA) are included in the adjustment. All
input data that is used in the determination of the BVA is based on market implied data. Additionally,
wrong-way risk (when exposure to a counterparty is increasing and the credit quality of that counterparty
deteriorates) and right-way risk (when exposure to a counterparty is increasing and the credit quality of
that counterparty improves) are taken into account in the measurement of the valuation adjustment.
To include the funding risk, ING Bank applies an additional \u2018Funding Valuation Adjustment\u2019 (FVA) to the
uncollateralised derivatives based on the market price of funding liquidity. ING Bank also applies to certain
positions other valuation adjustments to arrive at the fair value: Bid-Offer adjustments, Model Risk
Adjustments and Collateral Valuation Adjustments (CollVA).
Significant judgements and critical accounting estimates and assumptions:
\u2022Even 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.\u00a0
\u2022Valuation 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.\u00a0
\u2022Price 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.
\u2022Assessing whether a market is active, and whether an input is observable and significant, requires
judgement. ING Bank 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.
\u2022Reference is made to Note 35 'Fair value of assets and liabilities ' and to the \u2018Market risk\u2019 paragraph in
the \u2018Risk management\u2019 section of the Annual Report for the basis of the determination of the fair value
of financial instruments and related sensitivities.
1.7.4\u00a0 Derivatives and hedge accounting
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 Bank decided to exercise this accounting policy choice
and did not adopt IFRS 9 hedge accounting as of 1 January 2018. Furthermore, ING Bank applies fair value
hedge accounting for portfolio hedges of interest rate risk (macro fair value hedges) in accordance with the
EU carve-out version of IAS 39.
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 and 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 Bank\u2019s risk management strategy.
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 Bank 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 Bank documents the relationship between hedging instruments and
hedged items, its risk management objective, together with the methods selected to assess hedge
effectiveness. ING Bank 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.
IBOR Transition - specific policies applicable from 1 January 2019 for hedges directly
affected by IBOR reform
As further explained in the \u2018IBOR Transition\u2019 paragraph of the \u2018Risk management\u2019 section, the financial
markets are going through a significant reform of interbank offered rates (IBOR) and financial institutions
are obligated to implement a replacement of major interest rate reference rates.
Given that IBOR reform may have various accounting implications, the International Accounting Standards
Board (IASB) has undertaken a two phase project. Phase 1 addresses those issues that affect financial
reporting before the replacement of an existing benchmark. Phase 1 amendments to IFRS were issued by
the IASB in 2019. Phase 2 focuses on issues that may affect financial reporting when the existing benchmark
rate is reformed or replaced. Phase 2 amendments to IFRS were issued by the IASB in 2020.
Phase 1 amendments to IFRS allow ING Bank to apply a set of temporary exceptions to continue hedge
accounting even when there is uncertainty about contractual cash flows arising from the reform. Under
these temporary exceptions, interbank offered rates are assumed to continue unaltered for the purposes of
hedge accounting until such time as the uncertainty is resolved.
More specifically, the following temporary reliefs are part of the Phase 1 amendments:
\u2022Highly probable requirement for cash flow hedges
When determining whether a forecast transaction is highly probable, it is assumed that the interest rate
benchmark on which the hedged cash flows are based is not altered as a result of the reform.
\u2022Prospective assessment of hedge effectiveness
When performing the prospective assessment it is assumed that the interest rate benchmark on which
the hedged cash flows are based is not altered as a result of the reform.
\u2022Retrospective assessment of hedge effectiveness
When performing the retrospective assessment hedges are allowed to pass the assessment even if
actual results are outside the 80-125% range, during the period of uncertainty arising from the IBOR
reform.
\u2022Designation of a component of an item as a hedged item
For hedges of the benchmark component of interest rate risk affected by the reform, the separately
identifiable requirement only needs to be demonstrated at the inception of such hedging relationships
(including macro hedges).
The amendments are relevant given that ING Bank hedges and applies hedge accounting to benchmark
interest rate exposure part of IBOR reform. ING Bank hedges are being progressively amended, where
necessary, to incorporate the new benchmark rates. Temporary exceptions under Phase 1 continued to be
relevant for ING Bank as at 31 December 2022 (for USD and WIBOR).
ING Bank will completely cease to apply the amendments when this uncertainty is no longer present or
when the hedging relationship is discontinued. Refer to Note 36 'Derivatives and hedge accounting' for the
disclosures relating to the application of the amendments as part of Phase 1. Refer to note \u2018Risk
management/ IBOR Transition\u2019 for more information regarding the end of Phase 1 reliefs for ING Bank\u2019s
hedging relationships.
Phase 2 amendments require that hedge accounting continues on transition to risk free rates provided that
the modifications made to financial instruments are those necessary to implement the IBOR Reform and
that the new basis for calculating cash flows is \u2018economically equivalent\u2019 to the previous basis. Particularly,\u00a0
Phase 2 amendments allow the continuation of hedging relationships, subject to amending their
documentation to reflect changes in hedged instruments, hedging instruments, hedged risk, and/or the
method for measuring effectiveness during the transition to the new benchmark rates. During 2022, Phase 2
continued to be relevant for ING Bank when ING actually transitioned its financial instruments (designated in
hedge accounting relationships) to the new benchmark rates (mainly, USD LIBOR).
More specifically, the following temporary reliefs are part of the Phase 2 amendments:
Relief from discontinuing hedging relationships
\u2022Amendments in the hedge documentation as a consequence of changes required by the IBOR reform do
not result in the discontinuation of the hedge relationship nor the designation of a new hedge
relationship. The changes can be in form of designating an alternative benchmark rate as a hedged risk,
the description of the hedging instrument, the description of the hedged item, or the method to measure
the effectiveness.
\u2022When the hedged item is amended as a consequence of the IBOR reform (or if the hedge has previously
been discontinued), amounts accumulated in the cash flow hedge reserve are deemed to be based on
the Risk-Free Rate (RFR). This results in the release of the cash flow hedge reserve to profit or loss in the
same period or periods in which the hedged cash flows that are now based on the RFR affect profit or
loss.
\u2022When the items within a designated group of hedged items are amended as a consequence of the IBOR
reform, the hedging strategy remains and is not discontinued. As items within the hedged group
transition at different times from IBORs to RFRs, they are transferred to sub-groups of instruments that
reference RFRs as the hedged risk. The existing IBORs remain designated as the hedged risk for the other
sub-group of hedged items, until they are also updated to reference the new RFR. The usual hedge
accounting requirements are applied to the hedge relationship in its entirety.
\u2022For the assessment of retrospective hedge effectiveness, the cumulative fair value changes may be reset
to zero when the exception to the retrospective assessment of the Phase 1 reliefs ends. This election is
made separately for each hedging relationship (i.e., on a hedge-by-hedge basis).
\u2022Temporary relief from having to meet the separately identifiable requirement: a RFR is considered a
separately identifiable risk component if it is reasonably expected to meet the separately identifiable
requirement within 24 months from the date it is first designated as a non-contractually specified risk
component (i.e. when the entity first designates the RFR as a non-contractually specified risk
component). This relief applies to each RFR on a rate-by-rate basis.
Non-trading derivatives that do not qualify for hedge accounting
Derivative instruments that are used by ING Bank as part of its risk management strategies, but which do
not qualify for hedge accounting under ING Bank\u2019s 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.
1.7.5\u00a0 Offsetting of financial assets and financial liabilities
Financial assets and financial liabilities are offset, and the net amount is reported in the statement of
financial position when ING Bank 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 certain interest rate swaps for which the services of a central clearing house are
used.
1.7.6\u00a0 Repurchase transactions and reverse repurchase transactions
Securities sold subject to repurchase agreements (repos), securities lending and similar agreements
continue to be recognised in the Consolidated statement of financial position. The counterparty liability is
measured at FVPL (designated) and included in Other financial liabilities at FVPL if the asset is measured at
FVPL. Otherwise, the counterparty liability is included in Deposits from banks, Customer deposits, or Trading,
as appropriate.
Securities purchased under agreements to resell (reverse repos), securities borrowings and similar
agreements are not recognised in the Consolidated statement of financial position. The consideration paid
to purchase securities is recognised as Loans and advances to customers, Loans and advances to banks,
Other financial assets at FVPL or Trading assets, as appropriate. The difference between the sale and
repurchase price is treated as interest and amortised over the life of the agreement using the effective
interest method for instruments that are not measured at FVPL.
1.7.7\u00a0 Credit risk management classification and maximum credit risk exposure
Credit risk management disclosures are provided in the \u2018Credit risk\u2019 paragraph \u2018Credit risk categories\u2019 of the
\u2018Risk management\u2019 section in the Annual Report.
The maximum credit risk exposure for items in the statement of financial position is generally the carrying
value for the relevant financial assets. For the off-balance sheet items, the maximum credit exposure is the
maximum amount that could be required to be paid. Reference is made to Note 41 \u2018Contingent liabilities
and commitments\u2019 for these off-balance sheet items. Collateral received is not taken into account when
determining the maximum credit risk exposure.
Credit risk management disclosures are provided in the \u2018Credit risk\u2019 paragraph \u2018Credit risk categories\u2019 of the
\u2018Risk management\u2019 section in the Annual Report. The manner in which ING Bank manages credit risk and
determines credit risk exposures for that purpose is explained in the Credit risk paragraph \u2018Credit Risk
Appetite and Concentration Risk Framework\u2019 of the \u2018Risk management\u2019 section in the Annual Report.
1.7.8Impairment of financial assets
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 Bank calculates the expected credit losses (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. ING Bank\u2019s approach leverages the Advanced Internal Ratings Based (AIRB)
models that are used for regulatory purposes. Adjustments are applied to make these models suitable for
determining ECL. 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:
\u2022Stage 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);
\u2022Stage 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
\u2022Stage 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 Bank 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.
The main determinate of SICR is a quantitative test, whereby the lifetime Probability of Default (PD) of an
asset at each reporting date is compared against its lifetime PD determined at the date of initial recognition.
If the delta is above pre-defined absolute or relative thresholds the item is considered to have experienced a
SICR. Furthermore, any facility which shows an increase of 200% 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. Refer to \u2018Criteria for
identifying a significant increase in credit risk\u2019 in the \u2018Risk Management\u2019 section of the Annual Report for
more details on relative and absolute PD thresholds, including quantitative disclosures on those thresholds.
Consequently, if the above quantitative SICR thresholds are exceeded, the item moves from Stage 1 to Stage
2 (unless the item is credit-impaired). In these instances, items are no longer assigned a 12 month ECL and
instead are assigned a lifetime ECL. Items can return to Stage 1 if there is sufficient evidence that there is no
longer a significant increase in credit risk.
ING Bank also relies on a number of qualitative indicators to identify and assess SICR. These include:
\u2022Forbearance status;
\u2022Watch List status;
\u2022Intensive care management;
\u2022Collective SICR assessment;
\u2022Substandard Internal rating; and
\u2022Arrears status (including 30 days past due used as a backstop).
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 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 Bank 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 Bank has established a quarterly process whereby forward-looking macroeconomics scenarios and
probability weightings are developed for the purpose of ECL. ING Bank applies data predominantly from a
leading service provider (Oxford Economics (OE))\u00a0 enriched with the internal ING Bank view. A baseline, up-
scenario and a down-scenario are determined to reflect an unbiased and probability-weighted ECL amount.
As a baseline scenario, ING Bank 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.
Measurement of ECL
ING Bank 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 Bank 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 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\u2019 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 purpose of ECL, ING Bank\u2019s 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 Bank 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 Bank\u2019s 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 others, 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 is no longer recognised based on the accrual income
based on the gross carrying amount of the asset. Rather, interest income is calculated by applying the
original EIR to the AC 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 even if the lifetime ECL at the reporting date is lower than the estimated lifetime ECL at
origination.
Modifications
In certain circumstances ING Bank 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 is executed based on credit concerns it is also referred to as forbearance (refer to the \u2018Risk
Management\u2019 section of the Annual Report for more details). In such cases, the net present value of the
postponement, reduction of loan principal and/or interest payments is taken into account in the
determination of the appropriate level of ECL. If the forbearance 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. ING Bank determines whether there has been a substantial modification using both
quantitative and qualitative factors.
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:
\u2022After a restructuring has been completed and there is a high improbability of recovery of part of the
remaining loan exposure (including partial debt forgiveness);
\u2022In a bankruptcy liquidation scenario;
\u2022After divestment or sale of a credit facility at a discount;
\u2022Specific 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 \u2018Addition to loan loss provisions\u2019 in the Consolidated
statement of profit or loss..
Debt forgiveness (or debt settlement) involves write-off but additionally involves the forgiveness of a legal
obligation, in whole or in part. This means that ING Bank forfeits the legal right to recover the debt. As a
result, the financial asset needs to be derecognised. Distinction is made in situations where ING Bank ends
the relationship with the client and situations where ING Bank (partially) continues the financing of the
client.
Presentation of ECL
ECL for financial assets measured at AC are deducted from the gross carrying amount of the assets. For
debt instruments at FVOCI, the ECL is recognised in OCI, instead of deducted 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, are 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:
Considerable management judgement is exercised in determining the amount of ECL for financial assets
assessed on both a collective and an individual basis. In particular, this judgement requires ING Bank to
make various assumptions about the risk of default, the credit loss rates in case of a default and expected
future cash flows. These assumptions are based on a combination of ING Bank\u2019s past history, existing
market conditions and forward-looking estimates at the end of each reporting period. Changes in these
assumptions may lead to changes in the ECL over time. Given they are subjective and complex in nature,
and because the ECL and the underlying exposures subject to ECL are material, these assumptions are
considered critical accounting assumptions. The sensitivity of these assumptions is assessed in the credit
risk section of the \u2018Risk Management\u2019 section in the Annual Report.
\u2022The use of forward-looking macroeconomic scenarios in both collective and individual impairment
assessments
Forward-looking macroeconomic scenarios are uncertain in nature. The process ING Bank follows involves
two internal groups, the Macroeconomics Scenarios Team and the Macroeconomics Scenarios Expert
Panel. The latter team consists of senior management representatives from the Business, Risk and
Finance. These groups review inputs obtained from a third party provider and subject these to internal
expert challenge to ensure the inputs used in the models reflect ING Bank\u2019s view on the macro economy.
The use of alternate forward-looking macroeconomic scenarios can produce significantly different
estimates of ECL. This is demonstrated in the sensitivity analysis in the \u2018Risk Management\u2019 section of the
Annual Report, where the un-weighted ECL under each of the three scenarios for some significant
portfolios is disclosed.
\u2022The probability weights applied to each of the three scenarios
ING Bank uses three macroeconomic scenarios when determining IFRS 9 ECL (baseline, upside and
downside). Management judgement is applied in the design of the approach used to determine the
weights of each scenario and in selecting the parts of the distribution of forecast errors from which the
weights are derived. Reference is made to the \u2018Alternative scenarios and probability weights\u2019 and the
sensitivity analysis in the \u2018Risk Management\u2019 section of the Annual Report for further details.
\u2022The criteria for identifying a significant increase in credit risk
When determining whether the credit risk on a financial asset has increased significantly, ING Bank\u00a0
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\u2019s 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 constitute a significant judgement. Analysis
of the sensitivity associated with the assessment of significant increase in credit risk is presented in the
\u2018Risk Management\u2019 section of the Annual Report.
\u2022The definition of default
Judgement is exercised in management\u2019s evaluation of whether there is objective evidence that larger
exposures are credit-impaired. Management judgement is required in assessing evidence of credit-
impairment.
\u2022Management adjustments applied as at 31 December 2022
To reflect the risks that are not properly captured by the ECL models, a number of management
adjustments to the model-based ECL were necessary as at 31 December 2022. Reference is made to the
\u2018Management adjustments applied this year\u2019 paragraph in the \u2018Risk management\u2019 section of the Annual
Report.
1.7.9\u00a0 Accounting for Targeted Longer-Term Refinancing Operations (TLTRO)
ING Bank participates in Targeted Longer-Term Refinancing Operations (TLTRO III), reference is made to Note
12 \u2018Deposits from banks\u2019.
ING Bank considers 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 is considered to be a market conforming rate and TLTRO funding is
recognized fully as a financial liability.
ING Bank interprets 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 results in discrete rates for discrete interest
periods over the life of TLTRO. The change in the applicable rate between interest periods is seen as a
change in the floating rate and is accounted for prospectively. Similarly, if the ECB announces changes in
the rate for the amounts already drawn under the existing TLTRO, then such changes also represent a
change in a floating rate. Following this, such changes lead 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 relates to the
periods already passed, the impact for those past periods is recognised in profit or loss immediately.
Furthermore, the change in the TLTRO rate driven by changes in expectations of meeting the targets
impacts interest income. As a result, interest income which relates to the period that already passed until
the moment when the change in expectations occurs, is recognised as a catch up adjustment in
Consolidated statement of profit or loss. This change occurs only when ING Bank has a reasonable
expectation that the lending targets will be met.
ING Bank views \u2018reasonable expectation\u2019 in case of TLTRO funding as a high hurdle. This is the moment when
it becomes highly probable, i.e. the probability of meeting the lending targets is substantially greater than
the probability that it will not. As a result, if interest income is recognised during the period based on the
expectation of meeting the targets, there should only be a limited possibility that the interest may need to
be reversed in future reporting periods. Reference is made to note 12 \u2018Deposits from banks\u2019 and to note 20
\u2018Net interest income\u2019 for the presentation of ING Bank\u2019s participation in TLTRO programmes.
Significant judgements:
Significant management judgement is exercised in determining the accounting treatment of TLTRO
transactions. In particular, ING Bank\u00a0 applied judgement in:
\u2022assessing and concluding that in ING Bank'\u2019s view the rate under TLTRO is considered to be a market
conforming rate and, hence, accounting for TLTRO in accordance with IFRS 9; and
\u2022selecting accounting policies regarding the calculation of the effective interest rate under TLTRO.
Treatment of changes in expectations of meeting the lending targets was an area of significant
judgment in the comparative periods but no longer relevant in 2022.
1.8\u00a0 Consolidation
ING Bank comprises ING Bank N.V. (the Parent Company) and all other subsidiaries. Subsidiaries are entities
controlled by ING Bank N.V. Control exists if ING Bank N.V. is exposed or has rights to variable returns and
has the ability to affect those returns through the power over the subsidiary. Control is usually achieved
through situations including, but not limited to:
\u2022Ownership, directly or indirectly, of more than half of the voting power;\u00a0
\u2022Ability to appoint or remove the majority of the board of directors;\u00a0
\u2022Power to govern operating and financial policies under statute or agreement; and\u00a0
\u2022Power over more than half of the voting rights through an agreement with other investors.\u00a0
The existence and effect of potential voting rights that are currently exercisable or convertible are
considered in assessing whether ING Bank controls another entity.
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.
A list of principal subsidiaries is included in Note 44 \u2018Principal subsidiaries\u2019 and a description of ING's activities
involving structured entities is included in Note 45 '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.
The results of the operations and the net assets of subsidiaries are included in the statement of profit or loss
and the statement of financial position from the date control is obtained until the date control is lost. On
disposal, the difference between the sales proceeds, net of directly attributable transaction costs, and the
net assets is included in net result.
A subsidiary which ING Bank has agreed to sell but is still legally owned by ING Bank may still be controlled
by ING Bank at the balance sheet date and therefore, still be included in the consolidation. Such a subsidiary
may be presented as a held for sale disposal group if certain conditions are met.
All intercompany transactions, balances and unrealised surpluses and deficits on transactions between
group companies are eliminated. Where necessary, the accounting policies used by subsidiaries are
changed to ensure consistency with group policies. In general, the reporting dates of subsidiaries are the
same as the reporting date of ING Bank N.V.
ING Bank 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\u2019s 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 in respect of minimum capital requirements that are imposed by
industry regulators in the countries in which the subsidiaries operate, other limitations exist in certain
countries.
1.9\u00a0 Segment reporting
An operating segment is a distinguishable component of ING Bank, engaged in providing products or
services, whose operating results are regularly reviewed by the Management Board Banking of ING Bank
(the Chief Operating Decision Maker (CODM)) to make decisions about resources to be allocated to the
segments and assess its performance. A geographical area is a distinguishable component of ING Bank
engaged in providing products or services within a particular economic environment that is subject to risks
and returns that differ from those of segments operating in other economic environments.
The CODM examines ING Bank\u2019s performance both by line of business and geographic perspective and has
identified five reportable segments by line of business. The geographical analyses are based on the location
of the office from which the transactions are originated.
1.10\u00a0 Foreign currency translation
Functional and presentation currency
Items included in the financial statements of each of ING Bank\u2019s 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 Bank\u2019s 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 \u2018Valuation results and
net trading income\u2019. Reference is made to Note 22 \u2018Valuation results and net trading income\u2019, 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 \u2018Result on disposal of group companies\u2019. Reference is also made to Note 19 \u2018Equity\u2019, 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:
\u2022Assets and liabilities are translated at the closing rate at the date of the statement of financial position;\u00a0
\u2022Income 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 and expenses are translated at the dates of the transactions). However, under hyperinflation
accounting, income and expenses of ING Turkey are translated at the closing rate; and\u00a0
\u2022All resulting exchange rate differences are recognised in a separate component of equity.\u00a0
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\u2019 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 liabilities of the foreign operation and translated at the exchange rate prevailing at the balance sheet
date.
1.11\u00a0 Investments in associates and joint ventures
Associates are all entities over which ING Bank 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:
\u2022Representation on the board of directors;\u00a0
\u2022Participation in the policymaking process; and\u00a0
\u2022Interchange of managerial personnel.\u00a0
Joint ventures are entities over which ING Bank has joint control. Joint control is the contractually agreed
sharing of control over an arrangement or entity, which exists only when decisions about the relevant
activities require the unanimous consent of the parties sharing control. Joint control means that no party to
the agreement is able to act unilaterally to control the activity of the entity. The parties to the agreement
must act together to control the entity and therefore exercise the joint control.
Investments in associates and joint ventures are initially recognised at cost and subsequently accounted for
using the equity method of accounting.
ING Bank\u2019s investment in associates and joint ventures (net of any accumulated impairment loss) includes
goodwill identified on acquisition. ING Bank\u2019s 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 Bank\u2019s 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 Bank
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 Bank and its associates and joint ventures are eliminated to
the extent of ING Bank\u2019s 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 Bank.
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. 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. 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.
Significant judgements and critical accounting estimates and assumptions:
The most significant estimates and assumptions relate to the assessment of (reversal of) impairment of
the investment in TMBThanachart Bank Public Company Limited (hereafter: TTB) which involves estimation
of value in use.
Management's best estimate of the expected future earnings of TTB is based on forecasts derived from
broker consensus over the short to medium term and reasonable and supportable assumptions capturing
a combination of TTB specific and market data points for longer term and steady state expectations into
perpetuity. A capital maintenance charge is applied, which is management\u2019s forecast of the earnings that
need to be withheld in order for TTB to meet target regulatory requirements over the forecast period. Both
of these factors are subject to a high degree of uncertainty.
Key assumptions used in estimating TTB\u2019s value in use and the sensitivity of the value in use calculations
to different assumptions are described in note 8 \u2018Investments in associates and joint ventures\u2019.
1.12\u00a0 Property and equipment
Property in own use
Land and buildings held for own use are stated at fair value at the balance sheet date. Increases in the
carrying amount arising on revaluation of land and buildings held for own use are credited to the
revaluation reserve in shareholders\u2019 equity. Decreases in the carrying amount that offset previous increases
of the same asset are charged against the revaluation reserve directly in equity; all other decreases are
charged to the statement of profit or loss. Increases that reverse a revaluation decrease on the same asset
previously recognised in net result are recognised in the statement of profit or loss. Depreciation is
recognised based on the fair value and the estimated useful life (in general 20\u201350 years). Depreciation is
calculated on a straight-line basis. On disposal, the related revaluation reserve is transferred to retained
earnings.
In principle, the fair values of land and buildings are appraised annually by independent qualified valuers.
Subsequent expenditure is included in the asset\u2019s carrying amount when it is probable that future economic
benefits associated with the item will flow to ING Bank and the cost of the item can be measured reliably.
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:
for data processing equipment two to five years, and four to ten years for fixtures and fittings. Expenditure
incurred on maintenance and repairs is recognised in the statement of profit or loss as incurred. Expenditure
incurred on major improvements is capitalised and depreciated.
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 Bank 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 Bank. 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\u2019s 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:
\u2022Fixed payments (including in-substance fixed payments), less any lease incentives receivable;
\u2022Variable lease payments that are based on an index or a rate;
\u2022Amounts expected to be payable by the lessee under residual value guarantees;
\u2022The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and
\u2022Payments 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\u2019s 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. This rate is approximated by using the risk free rate applicable to the
lease term, the currency of the lease payment and jurisdiction, with the Fund Transfer Pricing (FTP) rate as
an add-on. The FTP rate is used to transfer interest rate risk and funding and liquidity risk positions between
the ING Bank business and treasury departments. It is determined by either ING Bank or Local Asset and
Liability Committee (ALCO). Reference is made to the \u2018Risk management\u2019 section of the Annual Report.
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.
Payments associated with short-term leases and leases of low-value assets are recognised on a straight-
line basis as an expense in profit or loss. Short-term leases are leases with a lease term of 12 months or less.
Low-value assets comprise mainly IT-equipment (for example mobile phones or laptops) and small items of
office furniture.
The right-of-use asset is included in the statement of financial position line-item \u2018Property and equipment\u2019,
the lease liability is included in the statement of financial position line-item \u2018Other liabilities\u2019. Refer to note 9
\u2018Property and equipment\u2019 and to note 16 \u2018Other liabilities\u2019.
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
decrease 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.
1.13\u00a0 ING Bank as lessor
When ING Bank acts as a lessor, a distinction should be made between finance leases and operating leases.
For ING Bank 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.
1.14\u00a0 Acquisitions, goodwill and other intangible assets
Goodwill resulting from a business combination
ING Bank\u2019s business combinations are accounted for using the acquisition method of accounting. The
consideration for each business combination is measured at the aggregate of the fair values (at the date of
exchange) of assets given, liabilities incurred or assumed, and equity instruments issued in exchange for
control of the acquiree. Goodwill, being the difference between the cost of the acquisition (including
assumed debt) and the Group\u2019s interest in the fair value of the investee's identifiable assets, liabilities and
contingent liabilities as at the date of acquisition, is capitalised as an intangible asset. Goodwill is only
recognised separately on acquisitions. The results of the operations of the acquired companies are included
in the statement of profit or loss from the date control is obtained.
Where applicable, the consideration for the business combination includes any asset or liability resulting
from a contingent consideration arrangement, the contingent consideration is measured at its acquisition-
date fair value. Contingent consideration arrangements classified as an asset or a liability, are subsequently
measured at fair value and the changes in fair value are recognised in the statement of profit or loss.
Changes in the fair value of the contingent consideration classified as equity, are not recognised.
Where a business combination is achieved in stages, ING Bank\u2019s previously held interests in the assets and
liabilities of the acquired entity are remeasured to fair value at the acquisition date (i.e. the date ING Bank
obtains control) and the resulting gain or loss, if any, is recognised in the statement of profit or loss.
Amounts arising from interests in the acquiree prior to the acquisition date that have previously been
recognised in other comprehensive income are reclassified to the statement of profit or loss, where such
treatment would be appropriate if that interest were disposed of. Acquisition related costs are recognised in
the statement of profit or loss as incurred and presented in the statement of profit or loss as Other
operating expenses.
The initial accounting for the fair value of the net assets of the companies acquired during the year may be
determined only provisionally as the determination of the fair value can be complex and the time between
the acquisition and the preparation of the Financial statements can be limited. The initial accounting shall
be completed within a year after acquisition. Adjustments to the fair value as at the date of acquisition of
acquired assets and liabilities, that are identified within one year after acquisition are recognised as an
adjustment to goodwill; any subsequent adjustment is recognised as income or expense. On disposal of
group companies where control is lost, the difference between the sale proceeds and carrying value
(including goodwill) and the unrealised results (including the currency translation reserve in equity) is
included in the statement of profit or loss.
Impairment of goodwill and other non-financial assets
ING Bank 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. The carrying value is
determined on a basis that is consistent with the way in which the recoverable amount of the CGU is
determined. The recoverable amount is estimated as the higher of fair value less costs of disposal and value
in use. 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. This period will generally not exceed five years. Amortisation is included in Other operating expenses.
Other intangible assets
Other intangible assets are capitalised and amortised over their expected economic life, which is generally
between three and ten years.
1.15\u00a0 Taxation
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.
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 Bank 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 equity and is subsequently recognised in the statement of profit or loss together with the
deferred gain or loss.
Uncertain tax positions are assessed continually by ING Bank and in case it is probable that there will be a
cash outflow, a current tax liability is recognised.
1.16\u00a0 Other assets
Investment property
Investment properties are recognised at fair value at the balance sheet date. The fair values of investment
properties are appraised annually by independent qualified valuers. Changes in the carrying amount
resulting from revaluations are recognised in the statement of profit or loss. On disposal, the difference
between the sale proceeds and carrying value is recognised in the statement of profit or loss.
Property obtained from foreclosures
Property obtained from foreclosures is stated at the lower of cost and net realisable value. Net realisable
value is the estimated selling price, less applicable variable selling expenses. Property obtained from
foreclosures is included in Other assets - Property development and obtained from foreclosures.
Property development
Property developed and under development is included in Other assets \u2013 Property development and
obtained from foreclosures. Depending on the intention of ING Bank after completion of the development,
the property is measured as follows:
\u2022Intention to sell: at the lower of cost and net realisable value;
\u2022Intention to use as a real estate investment: at fair value.
1.17\u00a0 Disposal groups held for sale and discontinued operations
Disposal groups (and non-current assets) are classified as held for sale if their carrying amount will be
recovered principally through a sale transaction rather than through continuing use. This is only the case
when the sale is highly probable and the disposal group (or non-current assets) is available for immediate
sale in its present condition; including management must be committed to the sale, which is expected to
occur within one year from the date of classification as held for sale.
Upon classification as held for sale, the disposal group is measured at the lower of its carrying amount and
fair value less costs to sell, except where specifically exempt from IFRS 5 \u2018Non-current Assets Held for Sale
and Discontinued Operations. An impairment loss is recognised for any initial or subsequent write-down of
the disposal group to fair value less costs to sell. A gain is recognised for any subsequent increases in fair
value less costs to sell of the disposal group, but not in excess of any cumulative impairment loss previously
recognised. A gain or loss not previously recognised by the date of the sale of the disposal group is
recognised at the date of derecognition. Assets within the disposal group are not depreciated or amortised
while they are classified as held for sale. Interest and other net income/expenses attributable to the
liabilities of a disposal group classified as held for sale continue to be recognised. The assets of the disposal
group classified as held for sale are presented separately from the other assets in the balance sheet. The
liabilities of a disposal group classified as held for sale are presented separately from other liabilities in the
balance sheet.
When a group of assets that is classified as held for sale represents a major line of business or geographical
area the disposal group is classified as discontinued operations. Upon classification of a business as held for
sale and discontinued operations the individual income and expenses are presented within the Total net
result from discontinued operations instead of being presented in the usual line items in the Consolidated
statement of profit or loss. All comparative years in the Consolidated statement of profit or loss are restated
and presented as discontinued operations for all periods presented. Furthermore, the individual assets and
liabilities are presented in the Consolidated statement of financial position as Assets and liabilities held for
sale and are no longer included in the usual line items in the Consolidated statement of financial position.
Changes in assets and liabilities as a result of classification as held for sale are included in the notes in the
line \u2018Changes in composition of the group and other changes\u2019.
1.18\u00a0 Provisions, contingent liabilities and contingent assets
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 Bank 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 Bank; 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 Bank. 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.
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 Bank\u00a0 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 Bank
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 Bank consults with internal and external legal experts. Even taking into
consideration legal experts\u2019 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'.
1.19\u00a0 Other liabilities
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.
Plan assets are measured at fair value at the balance sheet date. For determining the pension expense, the
return on plan assets is determined using a high quality corporate bond rate identical to the discount rate
used in determining the defined benefit obligation.
Changes in plan assets that effect Shareholders\u2019 equity and/or Net result, include mainly:
\u2022Return on plan assets using a high quality corporate bond rate at the start of the reporting period which
are recognised as staff costs in the statement of profit or loss; and\u00a0
\u2022Remeasurements which are recognised in Other comprehensive income.\u00a0
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. The actuarial assumptions may differ
significantly from the 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 the defined
benefit plan obligation and future pension costs.
Changes in the defined benefit obligation that effect Shareholders\u2019 equity and/or Net result, include mainly:
\u2022Service cost which is recognised as staff costs in the statement of profit or loss;\u00a0
\u2022Interest expenses using a high quality corporate bond rate at the start of the period which are
recognised as staff costs in the Statement of profit or loss; and\u00a0
\u2022Remeasurements which are recognised in Other comprehensive income (equity).\u00a0
Remeasurements recognised in other comprehensive income are not recycled to 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. 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.
Defined contribution plans
For defined contribution plans, ING Bank pays contributions to publicly or privately administered pension
insurance plans on a mandatory, contractual or voluntary basis. ING Bank 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 accounting methodology similar to that for defined benefit pension plans.
1.20\u00a0 Income recognition
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 Bank
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 is presented in \u2018Interest income (expense) using effective interest rate
method\u2019. 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 \u2018Other interest income
(expense)\u2019. Interest result on all other financial assets and liabilities at FVTPL is recognised in \u2018Valuation
results and net trading income\u2019.
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 Bank 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 \u2013 such as the arrangement of the acquisition of shares or other securities or the
purchase or sale of businesses \u2013 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 Bank is the
lessor are divided into an interest component (recognised as interest income) and a repayment component
based on a pattern reflecting a constant periodic rate of return on the lessor\u2019s net investment in the lease.
1.21\u00a0 Expense recognition
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 are generally a result from a contract with ING service
providers in order to perform the service for ING Bank\u2019s customers. Costs are generally presented as
\u2018Commission expenses\u2019 if they are specific, incremental, directly attributable and identifiable to generate
commission income.\u00a0
Share-based payments
ING Bank 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 of service.
1.22\u00a0 Statement of cash flows
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 comprise balances with less
than three months\u2019 maturity from the date of acquisition, including cash and balances with central banks,
treasury bills and other eligible bills, amounts due from other banks, and deposits from banks. 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.
1.23\u00a0 Parent company accounts
The parent company accounts of ING Bank N.V. are prepared in accordance with the financial reporting
requirements included in Part 9 of Book 2 of the Dutch Civil Code. In accordance with subsection 8 of section
362, Book 2 of the Dutch Civil Code, the recognition and measurement principles applied in the Parent
company accounts are the same as those applied in the Consolidated financial statements.
2\u00a0 Cash and balances with central banks
Cash and balances with central banks
in EUR million
2022
2021
Amounts held at central banks 1
85,934\u00a0
104,870\u00a0
Cash and bank balances
1,681\u00a0
1,650\u00a0
87,614
106,520
1 Amounts held at central banks include an amount of EUR -12 million (2021: EUR -6 million) of Loan loss provisions.
The movement in Cash and balances with central banks reflects ING\u2019s active liquidity management.
Amounts held at central banks reflect on demand balances.
Reference is made to Note 39 'Transfer of financial assets, assets pledged and received as collateral' for
restrictions on amounts held at central banks.
3\u00a0 Loans and advances to banks
Loans and advances to banks
Netherlands
Rest of the world
Total
in EUR million
2022
2021
2022
2021
2022
2021
Loans and advances to banks
23,462
7,018
11,679
16,595
35,140
23,613
Loan loss provisions
-12
-10
-26
-13
-37
-22
23,450
7,009
11,653
16,582
35,103
23,591
Loans include balances (mainly reverse repos) with central banks amounting to EUR 19,395 million (2021:
EUR 3,403 million). 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\u00a0December 2022 and at 31 December 2021, all loans and advances to banks are non-subordinated.
4\u00a0 Financial assets at fair value through profit or loss
Financial assets at fair value through profit or loss
in EUR million
2022
2021
Trading assets
56,875
51,389
Non-trading derivatives
3,893
1,536
Designated at fair value through profit or loss
6,159
6,355
Mandatorily measured at fair value through profit or loss
46,844
42,684
113,770
101,964
Securities purchased under agreements to resell (reverse repos), securities borrowings and similar
agreements are not recognised in the consolidated statement of financial position. 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, Other financial assets 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. The counterparty liability is
measured at FVPL (designated) and included in Other financial liabilities at FVPL if the asset is measured at
FVPL. Otherwise, the counterparty liability is included in Deposits from banks, or Trading, as appropriate.
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.
Trading assets
Trading assets by type
in EUR million
2022
2021
Equity securities
11,741
17,574
Debt securities
4,189
5,319
Derivatives
30,841
19,764
Loans and receivables
10,103
8,733
56,875
51,389
for information on
trading liabilities.
Non-trading derivatives
Non-trading derivatives by type
in EUR million
2022
2021
Derivatives used in
-\u00a0 fair value hedges
836
365
-\u00a0 cash flow hedges
814
300
-\u00a0 hedges of net investments in foreign operations
119
18
Other non-trading derivatives
2,124
852
3,893
1,536
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 and foreign exchange 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
2022
2021
Debt securities
5,437
5,870
Loans and receivables
722
485
6,159
6,355
\u2018Financial assets designated at fair value through profit or loss\u2019 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 \u2018Financial assets designated at fair value through profit or loss\u2019
approximates its carrying value and amounts to EUR 6,159 million (2021: EUR 6,355 million). The cumulative
change in fair value of the loans and debt securities attributable to changes in credit risk is EUR 345 million
(2021: EUR 99 million)
The notional value of the related credit derivatives is EUR 3,370\u00a0million (2021: EUR 2,640 million). The
cumulative change in fair value of the credit derivatives attributable to changes in credit risk since the
financial assets were first designated, amounts to EUR 3\u00a0million (2021: EUR -69 million) and the change for
the current year is EUR 72\u00a0million (2021: EUR -53 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
2022
2021
Equity securities
203
161
Debt securities
821
787
Loans and receivables
45,820
41,735
46,844
42,684
Equity securities are individually insignificant for ING Bank. For debt securities ING Bank total exposure
reference is made to Note 6 'Securities at amortised cost'. Loans and receivables include mainly reverse
repurchase agreements.
5\u00a0 Financial assets at fair value through other comprehensive income
Financial assets at fair value through other comprehensive income by type
in EUR million
2022
2021
Equity securities
1,887
2,457
Debt securities 1
29,095
27,340
Loans and advances 1
643
838
31,625
30,635
1 Debt securities include an amount of EUR -21\u00a0million (2021: EUR -12 million) and the Loans and advances includes EUR
-1\u00a0million(2021: EUR -1 million) of Loan loss provisions.
Exposure to equity securities
Equity securities designated as at fair value through other comprehensive income
Carrying
value
Carrying
value
Dividend
income
Dividend
income
in EUR million
2022
2021
2022
2021
Investment in Bank of Beijing
1,614
1,700
111
97
Other Investments
273
757
38
25
1,887
2,457
149
122
1Fair value through other comprehensive income debt instruments includes both debt securities and loans and advances.
2Changes in unrealized revaluations of FVOCI debt instruments include changes on hedged items which are recognized in the
statement of profit or loss. Reference is made to .Note 19 'Equity' for details on the changes in revaluation reserve.
FVOCI equity securities
In 2022, disposals of EUR 492 million mainly relate to the sale in the second quarter of HQLA eligible equity
instruments triggered by the changing interest rate environment and deteriorating market sentiment. This
portfolio was built up in early 2021 (additions in 2021: EUR 499 million) and was a relatively small part of the
HQLA portfolio. This was a diversified buy-and-hold portfolio aimed at generating stable dividend income
stream.
In 2022, exchange rate differences of EUR -39 million are mainly related to the stake in Bank of Beijing
following the depreciation of CNY vs EUR. Furthermore, changes in unrealised revaluations of equity
securities are mainly related to negative revaluation of the stake in Bank of Beijing following a decline in
share price (EUR -49 million).
FVOCI debt instruments
In 2022, changes in unrealised revaluations of EUR -3,230 million relate to increased yield curves.
Reference is made to Note 6 'Securities at amortised cost' for details on ING Bank\u2019s total exposure to debt
securities.
6\u00a0 Securities at amortised cost
Securities at amortised cost fully consist of Debt securities. ING Bank\u2019s exposure to debt securities is
included in the following lines in the statement of financial position:
Exposure to debt securities
in EUR million
2022
2021
Debt securities at fair value through other comprehensive income
29,095
27,340
Debt securities at amortised cost
48,160
48,319
Debt securities at fair value through other comprehensive income and amortised cost
77,255
75,659
Trading assets
4,189
5,319
Debt securities at fair value through profit or loss
6,258
6,658
Total debt securities at fair value through profit or loss
10,447
11,976
87,703
87,635
ING Bank\u2019s total exposure to debt securities (excluding debt securities held in the trading portfolio) of EUR
83,513 million (31\u00a0December 2021: EUR 82,316 million) is specified as follows:
Debt securities by type of exposure
Debt Securities at
FVPL
Debt Securities at
FVOCI
Debt Securities at
AC
Total
in EUR million
2022
2021
2022
2021
2022
2021
2022
2021
Government bonds
63
48
16,016
16,271
24,629
26,588
40,708
42,908
Sub-sovereign, Supranationals
and Agencies
2,343
3,115
8,529
7,587
14,210
13,752
25,082
24,454
Covered bonds
2,663
1,729
5,543
5,063
8,206
6,792
Corporate bonds
857
778
108
156
26
90
991
1,024
Financial institutions' bonds
2,237
1,993
772
798
2,551
1,932
5,561
4,724
ABS portfolio
758
723
1,028
810
1,217
913
3,003
2,445
6,258
6,658
29,116
27,352
48,177
48,338
83,551
82,347
Loan loss provisions
-21
-12
-17
-19
-39
-31
Debt securities portfolio
6,258
6,658
29,095
27,340
48,160
48,319
83,513
82,316
7\u00a0 Loans and advances to customers
Loans and advances to customers by type 1
Netherlands
Rest of the world
Total
in EUR million
2022
2021
2022
2021
2022
2021
Loans to public authorities
837
1,153
11,840
9,672
12,677
10,824
Residential mortgages
107,952
110,283
205,511
203,529
313,463
313,813
Other personal lending
5,835
6,551
30,345
31,511
36,180
38,063
Corporate Lending
68,128
68,104
211,092
202,020
279,220
270,124
182,752
186,091
458,789
446,733
641,541
632,824
Loan loss provisions
-993
-1,119
-4,990
-4,156
-5,984
-5,274
181,759
184,972
453,798
442,577
635,557
627,550
As at 31\u00a0December 2022 EUR 635,361 million (2021: EUR 627,390 million) of loans and advances to
customers are non-subordinated.
No individual loan or advance has terms and conditions that significantly affect the amount, timing or
certainty of the consolidated cash flows of ING Bank.
Loans and advances to customers and to banks include finance lease receivables and are detailed as
follows:
Finance lease receivables 1
in EUR million
2022
2021
Maturities of gross investment in finance lease receivables
-\u00a0 within 1 year
3,452
3,204
-\u00a0 between 1-2 years
2,463
2,311
-\u00a0 between 2-3 years
1,870
1,716
-\u00a0 between 3-4 years
1,294
1,178
-\u00a0 between 4-5 years
747
734
-\u00a0 more than 5 years
1,423
1,495
11,251
10,637
Unearned future finance income on finance leases
-792
-525
Net investment in finance leases
10,459
10,112
Included in Loans and advances to banks
6
5
Included in Loans and advances to customers
10,453
10,106
10,459
10,112
1The total loan loss provision of EUR 160 million (2021: EUR\u00a0167 million) for finance lease receivables is classified into the following loan
loss provision stages: Stage 1: EUR 9 million (2021: EUR 8 million), Stage 2: EUR 28 million (2021: EUR 30 million) and Stage 3: EUR 123
million (2021: EUR 129 million).
The finance lease receivables mainly relate to the financing of equipment and are mainly part of corporate
lending. To a lesser extent, the finance lease receivables relate to real estate for third parties, where ING is
the lessor. Interest income in 2022 on finance lease receivables amounts to EUR 292 million (2021: EUR 217
million).
8\u00a0 Investment in associates and joint ventures
Investments in associates and joint ventures
in EUR million
2022
Interest
held (%)
Fair value of
listed invest-
ments
Balance
sheet
value
Total
assets
Total
liabilities
Total
income
Total
expenses
TMBThanachart Bank Public
Company Limited
23%
849
1,109
49,506
43,677
1,303
957
Other investments in associates and
joint ventures
391
1,500
Investments in associates and joint ventures
in EUR million
2021
Interest
held (%)
Fair value of
listed invest-
ments
Balance
sheet value
Total
assets
Total
liabilities
Total
income
Total
expenses
TMBThanachart Bank Public
Company Limited
23%
866
1,208
46,478
40,957
1,286
1,038
Other investments in associates
and joint ventures
379
1,587
TMBThanachart Bank Public Company Limited
ING Bank has a 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 shareholding and representation on the Board.
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 represents a number of
associates and joint ventures that are individually not significant to ING Bank.
Significant influence for associates in which the interest held is below 20%, is based on the combination of
ING Bank\u2019s 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, rating agency and regulatory
views, which can change over time.
Changes in Investments in associates and joint ventures
in EUR million
2022
2021
Opening balance
1,587
1,475
Additions
48
91
Revaluations
-8
-24
Share of results
92
141
Dividends received
-48
-34
Disposals
-10
-23
Impairments
-192
-3
Exchange rate differences
27
-31
Other
4
-5
Closing balance
1,500
1,587
Share of results from associates and joint ventures of EUR 92 million (2021: EUR 141 million) as included in
the table above is mainly attributable to results of TTB of EUR 81\u00a0million (2021: EUR 61 million). In 2021,
share of results from associates includes additional EUR 28 million gain on our stake in Ebusco.
Impairments
In 2022, Impairments of EUR 192 million is predominantly attributable to TTB of EUR 165 million. TTB is part
of the Retail Other segment.
Impairment testing TTB
The fair value of TTB has been below the purchase cost of the investment for a prolonged period of time
(since 1Q 2020). This is considered to be objective evidence of impairment. As a result ING performed
quarterly impairment tests that led to impairment loss of EUR 165 million (2021: EUR nil).
The impairment test performed in 2022 led to an impairment at 31 March 2022 of EUR 150 million and EUR
15 million at 30 September 2022, as the recoverable amount as determined by a Value in Use calculation,
was below the carrying amount\u00a0 at that point in time. The impairment test at year end resulted in no further
impairments.
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and Value in Use
(\u2018VIU\u2019). Fair value less costs of disposal is based on observable share price. The VIU calculation uses
discounted cash flow projections based on management\u2019s 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:
\u2022the estimation of future earnings over a 5 year forecast period; and
\u2022the 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 2022 (and as at 30 September 2022
resulting in impairment)
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:
\u2022Expected 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\u00a0 assumptions capturing a combination of TTB specific and market data
points. A capital maintenance charge is applied, which is management\u2019s forecast of the earnings that
need to be withheld in order for TTB to meet target regulatory requirements over the forecast period;
\u2022Discount rate (cost of equity): 9.71% (30 September 2022: 10.54%), based on the capital asset pricing
model (CAPM) calculated for TTB using current market data.
\u2022Terminal growth rate: 3.05% (30 September 2022: 3.82%) consistent with current long term government
bond yield in Thailand as a proxy for a risk-free rate;
To assess the risk of further impairment at 31 December 2022, 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. Holding the other key assumptions constant, a reduction in all of the forecasted
annual cash flows, including terminal value, of 836bps would reduce the recoverable amount to the carrying
amount. An increase of 55bps in terminal growth rate and discount rate would cause the VIU to equal the
carrying amount.
Reversal of the impairment loss recognised was not considered appropriate as at 31 December 2022 mainly
due to the lack of sufficiently positive changes observed in the underlying performance of TTB since the
impairment loss as reflected in the broker consensus. Furthermore, the share price remains below the
original cost of the investment for a prolonged period of time.
9\u00a0 Property and equipment
Property and equipment by type
in EUR million
2022
2021
Property in own use
681
702
Equipment:
- Data processing equipment
213
207
- Other equipment
476
493
Right- of- use assets:
- ROU property
1,000
1,009
- ROU cars
64
83
- ROU other leases
12
21
2,446
2,515
1 Impairments of property and equipment are presented within 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.
Property in own use purchase costs amounted to EUR 847 million (2021: EUR\u00a0910 million). Cost or the
purchase price less accumulated depreciation and impairments would have been EUR 368 million (2021:
EUR 403 million) had property in own use been valued at cost instead of at fair value.
The reported impairment losses of EUR -35 million (2021: EUR -33 million) mainly result from a change in the
post-pandemic way of working through downscaling of physical office spaces.
10\u00a0 Intangible assets
Changes in intangible assets
Goodwill
Software
Other
Total
in EUR million
2022
2021
2022
2021
2022
2021
2022
2021
Opening balance
472
533
682
846
2
15
1,156
1,394
Opening balance adjustment
25
25
Additions
54
44
54
44
Capitalised expenses
144
135
144
135
Amortisation
-226
-260
-1
-226
-261
Impairments 1
-32
-22
-82
-12
-54
-94
Reversal of impairment
Exchange rate differences
-1
-61
4
2
-62
Disposals
-3
-3
Changes in the composition of the group and
other changes
3
-1
3
Closing balance
464
472
636
682
2
2
1,102
1,156
Gross carrying amount
464
472
2,491
2,521
8
59
2,962
3,052
Accumulated amortisation
-1,787
-1,710
-4
-9
-1,790
-1,719
Accumulated impairments
-69
-129
-2
-48
-70
-177
Net carrying value
464
472
636
682
2
2
1,102
1,156
1 Impairments of intangible assets are presented within Other operating expenses in the statement of Profit or Loss.
Goodwill
Following a change in monitoring from a centralised towards a de-centralised approach for Retail as from
the beginning of 2022, goodwill related to the group of cash generating units (CGUs) 'Retail Growth Markets'
was re-allocated to the underlying CGUs Retail Romania, Retail Poland and Retail Turkey using a relative
value approach.
Goodwill is allocated to groups of cash generating units (CGUs) as follows:
Goodwill allocation to group of CGUs
in EUR million
Method used for
recoverable amount
Discount rate
Terminal
growth rate
Goodwill
Goodwill
Group of CGU\u2019s
2022
2021
Retail Netherlands
Value in use
8.46%
2.04%
30
30
Retail Germany
Value in use
8.35%
1.82%
349
349
Retail Poland
Value in use
10.31%
2.50%
69
70
Retail Romania
Value in use
12.32%
2.60%
15
15
Retail Turkey
7
464
472
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 transaction 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, amongst others, short term
receivables relating to mortgage issuance and other amounts receivable from customers.
12\u00a0 Deposits from banks
Deposits from banks includes non-subordinated deposits and repurchase agreements from banks.
Deposits from banks by type
Netherlands
Rest of the world
Total
in EUR million
2022
2021
2022
2021
2022
2021
Non-interest bearing
86
570
315
321
400
891
Interest bearing
32,858
51,893
23,374
32,307
56,232
84,201
32,943
52,463
23,689
32,629
56,632
85,092
For the details of the applicable rates and impact on net interest
income reference is made to Note 20 'Net interest income'.
13\u00a0 Customer deposits
Customer deposits
in EUR million
2022
2021
Savings accounts
321,005
314,893
Credit balances on customer accounts
283,886
280,028
Corporate deposits
43,308
28,183
Other
38,143
34,727
686,341
657,831
Trading liabilities
Trading liabilities by type
in EUR million
2022
2021
Equity securities
935
322
Debt securities
1,291
753
Funds on deposit
5,993
7,513
Derivatives
30,869
18,525
39,088
27,113
Reference is made to Note 36 'Derivatives and hedge accounting' for information on derivatives used for
hedge accounting.
Other non-trading derivatives mainly includes interest rate swaps and foreign currency swaps for hedging
purposes, but 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
2022
2021
Debt securities
6,069
5,585
Funds entrusted
44,731
35,993
Subordinated liabilities
82
230
50,883
41,808
As at 31\u00a0December 2022, 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 -75 million (2021: EUR\u00a095 million) on a cumulative
basis. 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 Bank 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 8,408 million (2021: EUR\u00a06,853 million).
Funds entrusted include mainly repurchase agreements. In 2022, the balance increased to EUR 44,731
million as a result of rising customer demand.
15\u00a0 Provisions
Provisions by type
in EUR million
2022
2021
Reorganisation provisions
418
421
Litigation provisions
150
132
Other provisions
462
420
1,030
973
Changes in provisions
Reorganisation
Litigation
Other
Total
in EUR million
2022
2021
2022
2021
2022
2021
2022
2021
Opening balance
421
381
132
105
420
180
973
666
Additions
217
310
59
50
227
354
503
715
Interest
-2
-2
-2
-2
Releases
-46
-96
-8
-11
-166
-79
-221
-186
Utilised
-170
-172
-33
-18
-15
-25
-218
-215
Exchange rate differences
-3
-2
-1
-4
Other changes
-4
-3
9
-1
-7
-4
-1
Closing balance
418
421
150
132
462
420
1,030
973
for developments in litigation provisions.
The additions to the Other provisions in 2022 include EUR 75 million which relates to the provision for the
compensation of Dutch retail customers for past interest charges that did not sufficiently track market rates
and largely reflects the impact of interest-on-interest compensation. This is in addition to the provision of
EUR 180 million recognised in 2021.
In 2022, Other provisions include provisions of EUR 29 million (2021: EUR 34 million) that relate to credit
replacement facilities and EUR 109 million (2021: EUR 114 million) that relate to non-credit replacement off
balance facilities. The additions and releases in 2022 include EUR 138 million (2021: EUR 109 million) and
EUR 141 million (2021: EUR 66 million) respectively related to these off balance facilities.\u00a0
As at 31\u00a0December 2022, amounts expected to be settled within twelve months in provisions amount to EUR
815\u00a0million (2021: EUR 740 million). The amounts included are based on best estimates with regard to
amounts and timing of cash flows required to settle the obligation.
Additions to provisions and unused amounts released are presented in Note 27 'Other operating expenses'.
16\u00a0 Other liabilities
Other liabilities by type
In EUR million
2022
2021
Net defined benefit liability
139
227
Other post-employment benefits
29
72
Other staff-related liabilities
633
612
Other taxation and social security contributions
365
409
Rents received in advance
30
19
Costs payable
2,014
2,015
Amounts to be settled
6,714
5,082
Lease liabilities
1,174
1,220
Other
2,247
3,038
13,344
12,695
Disclosures in respect of Net defined benefit liabilities are provided in Note 33 'Pensions and other post-
employment benefits'.
Other staff-related liabilities includes vacation leave provisions, variable compensation provisions, jubilee
provisions, and disability/illness provisions.
Amounts to be settled includes primarily transactions not settled at the balance sheet date. The nature of
these transactions is short term and have settled\u00a0 after the closing date of the balance sheet.
Lease liabilities relate to right-of-use assets. Disclosures in respect to right-of-use assets are provided in
Note 9 'Property and equipment'. The total cash outflow for leases in 2022 was EUR 296\u00a0million (2021: EUR
301 million).
The line Other relates mainly to balances on margin accounts or amounts payable to customers.
17\u00a0 Debt securities in issue
Debt securities in issue relates 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 Bank, except for subordinated items. Debt securities in issue does not include debt securities
presented as Financial liabilities at fair value through profit or loss. ING Bank does not have debt securities
that are issued on terms other than those available in the normal course of business.
Debt securities in issue \u2013 maturities
In EUR million
2022
2021
Fixed rate debt securities
Within 1 year
18,044
31,785
More than 1 year but less than 2 years
1,217
3,135
More than 2 years but less than 3 years
4,702
1,235
More than 3 years but less than 4 years
2,903
1,729
More than 4 years but less than 5 years
2,880
2,914
More than 5 years
13,221
13,133
Total fixed rate debt securities
42,969
53,930
Floating rate debt securities
Within 1 year
13,856
2,266
More than 1 year but less than 2 years
307
130
More than 2 years but less than 3 years
256
137
More than 3 years but less than 4 years
494
194
More than 4 years but less than 5 years
97
192
More than 5 years
96
593
Total floating rate debt securities
15,106
3,513
Total debt securities
58,075
57,443
Reference is made to Note 29 'Changes in liabilities arising from financing activities' for further information
on issuances, redemptions and non-cash movements.
18\u00a0 Subordinated loans
Subordinated loans
In EUR million
2022
2021
Subordinated loans
15,789
16,719
15,789
16,719
Subordinated loans relate to subordinated capital debentures and private loans which may be included in
the calculation of the capital ratio.\u00a0
Subordinated loans include loans that qualify as Tier 1 and Tier 2 (CRD IV eligible) capital. Subordinated loans
of EUR 16,364 million (2021: EUR 15,879 million) have been placed with ING Bank N.V. by ING Groep N.V.
Reference is made to Note 39 'Derivatives and hedge accounting' for details on fair value hedge accounting.
In 2022 ING Groep N.V. issued in August EUR 1 billion 4.13% Fixed Rate Subordinated Tier 2 Green Notes. This
issuance was subsequently placed by ING Groep N.V. with ING Bank N.V. against the same conditions.
ING Bank N.V. redeemed with ING Group N.V. in April 2022 USD 1 billion 6.875% Perpetual Additional Tier 1
Contingent Convertible Capital Securities and in May 2022 JPY 10 billion 1.10% Subordinated Tier 2 Notes on
the first call dates.
Reference is made to Note 32 'Changes in liabilities arising from financing activities' for further information
on issuances and redemptions.
The average interest rate on subordinated loans is 4.00% (2021: 3.74%). The interest expense during the
year 2022 was EUR 646 million (2021: EUR 573 million).
19\u00a0 Equity
Total equity
In EUR million
2022
2021
2020
Share capital and share premium
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Share capital
525
525
525
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Share premium
16,542
16,542
16,542
17,067
17,067
17,067
Other reserves
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Revaluation reserve: Equity securities at FVOCI
1,187
1,282
1,181
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Revaluation reserve: Debt instruments at FVOCI
-339
92
296
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Revaluation reserve: Cash flow hedge
-3,055
-153
1,450
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Revaluation reserve: Credit liability
70
-80
-117
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Revaluation reserve: Property in own use
176
208
221
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Net defined benefit asset/liability remeasurement reserve
-232
-212
-307
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Currency translation reserve
-2,395
-3,483
-3,636
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Share of associates and joint ventures and other reserves
3,604
3,416
3,246
-984
1,069
2,334
Retained earnings
26,462
29,778
28,273
Shareholders\u2019 equity (parent)
42,546
47,914
47,675
Non-controlling interests
504
736
1,022
Total equity
43,050
48,650
48,697
No change occurred in the issued share capital and share premium in 2022, 2021 and 2020.
All ordinary shares are in registered form. No share certificates have been issued. Ordinary shares may be
transferred by means of a deed of transfer, subject to the approval of the general meeting of ING Bank. The
par value of ordinary shares is EUR 1.13.
The authorised ordinary share capital of ING Bank N.V. consists of 1,600 million shares of which as at
31\u00a0December 2022, 465 million ordinary shares were issued and fully paid.
ING Bank has 50 authorised preference shares with par value of EUR 1.13 per preference share. As at
31\u00a0December 2022, 7 preference shares were issued and fully paid (2021: 7 preference shares; 2020: 7
preference shares) amounting to EUR 8 (2021: EUR 8 and 2020: EUR 8).
Dividend restrictions
ING Bank 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\u2019s own funds over the sum of the
paid-up capital and reserves required by law. Additionally, certain Bank companies are subject to restrictions
on the amount of funds they may transfer in the form of dividends or otherwise to the parent company.
Furthermore, in addition to the restrictions in respect of minimum capital requirements that are imposed by
industry regulators in the countries in which subsidiaries operate, other limitations exist in certain countries.
Other reserves
Revaluation reserves
Changes in revaluation reserve: Equity securities and Debt instruments at FVOCI
Equity securities at FVOCI
Debt instruments at FVOCI
In EUR million
2022
2021
2020
2022
2021
2020
Opening balance
1,282
1,181
1,580
92
296
299
Unrealised revaluations
-118
94
-337
-406
-164
31
Realised gains/losses transferred to the
statement of profit or loss
-25
-40
-33
Realised revaluations transferred to
retained earnings
23
6
-1
Other changes
-62
Closing balance
1,187
1,282
1,181
-339
92
296
Equity securities at FVOCI
In 2022, the unrealised revaluation of EUR -118\u00a0million (2021: 94 million and 2020: -337 million) includes
revaluation of shares in Bank of Beijing for EUR -86 million(2021: 38 million and 2020: -339 million).
In 2020, Other changes of EUR -62 million is related to prior years revaluations of Visa shares, which are
reclassified to Financial assets at fair value through profit or loss and for which the unrealised revaluation up
until 2020 is transferred to retained earnings.
Cash flow hedge
ING mainly hedges floating rate lending with interest rate swaps. Due to an increase in yield curves in 2022
the interest rate swaps had a negative revaluation of EUR -2,901\u00a0million which is recognised in the cash flow
hedge reserve.
Changes in cash flow hedge and credit liability reserve
Cash flow hedge
Credit liability
In EUR million
2022
2021
2020
2022
2021
2020
Opening balance
-153
1,450
1,208
-80
-117
-114
Changes in credit liability reserve
165
37
-19
Unrealised revaluations
-2,901
-1,603
242
Realised revaluations transferred to retained
earnings
-15
16
Other changes
Closing balance
-3,055
-153
1,450
70
-80
-117
Changes in Property in own use reserve
Property in own use
In EUR million
2022
2021
2020
Opening balance
208
221
253
Impact IAS 29 on opening balance 1
-20
Unrealised revaluations
15
-2
-7
Realised revaluations transferred to retained earnings
-26
-11
-26
Other changes
Closing balance
176
208
221
1 Impact of application of hyperinflation accounting under IAS 29 from 1 January 2022.
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
2022
2021
2020
Opening balance
-3,483
-3,636
-2,079
Impact IAS 29 on opening balance 1
647
Unrealised revaluations
-7
-61
106
Realised gains/losses transferred to the statement of profit or loss
4
-1
Exchange rate differences
444
214
-1,662
Closing balance
-2,395
-3,483
-3,636
1 Impact of application of hyperinflation accounting under IAS 29 from 1 January 2022.
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 increase of unrealized revaluations and Exchange rate differences of EUR 437
million is related to several currencies including USD (EUR 380 million), TRY (EUR 192 million including EUR
364 million IAS 29 indexation effect), GBP (EUR -73 million), PLN (EUR -49 million), CHF (EUR 41 million), AUD
(EUR -20 million), UAH (EUR -27 million) and other currencies (EUR -7 million).
Share of associates and joint ventures and other reserves
Changes in share of associates, joint ventures and other reserves
In EUR million
2022
2021
2020
Opening balance
3,416
3,246
3,189
Result for the year
161
191
94
Transfer to/from retained earnings
26
-21
-37
Closing balance
3,604
3,416
3,246
The Share of associates, joint ventures and other reserves includes non-distributable profits from associates
and joint ventures of EUR 797 million (2021: EUR 738 million). Other reserves includes a statutory reserve of
EUR 2,264 million (2021: EUR 2,103 million) related to the former Stichting Regio Bank and the former
Stichting Vakbondsspaarbank SPN and a legal reserve of EUR 540 million (2021: EUR 573 million) related to
own developed software.
Retained earnings
Changes in retained earnings
In EUR million
2022
2021
2020
Opening balance
29,778
28,273
25,857
Impact IAS 29 on opening balance 1
-563
Transfer to/from other reserves
-8
26
108
Result for the year
3,506
4,579
2,321
Dividend and other distributions
-6,277
-3,125
-43
Employee stock options and share plans
27
28
23
Changes in composition of the group and other changes
-1
-3
7
Closing balance
26,462
29,778
28,273
for more details).
21\u00a0 Net fee and commission income
Net fee and commission income
in EUR million
2022
2021
2020
Fee and commission income
Payment Services
1,888
1,661
1,566
Securities business
632
853
700
Insurance and other broking
682
734
705
Portfolio management
600
617
525
Lending business
556
477
368
Financial guarantees and other commitments
496
458
364
Other
232
204
286
Total fee and commission income
5,085
5,004
4,514
Fee and commission expenses
Payment Services
600
563
611
Securities business
160
164
133
Distribution of products (Externally)
555
591
548
Other
184
169
211
Total fee and commission expenses
1,499
1,487
1,503
Net fee and commission income
3,586
3,517
3,011
1 ING changed the presentation of net fee and commission income as of 2021. The comparative figure for 2020 has been updated\u00a0
accordingly. The reclassification does not affect the total amount of 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 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\u2019s products and services through external providers.
All of ING\u2019s net fee and commission income are in scope of IFRS 15 \u2018Revenue from Contracts with
Customers\u2019. Reference is made to Note 31 'Segments' which includes net fee and commission income, as
reported to the Management Board Banking, disaggregated by line of business and by geographical
segment.
22\u00a0 Valuation results and net trading income
Valuation results and net trading income
in EUR million
2022
2021
2020
Securities trading results
-356
787
-500
Derivatives trading results
11
-554
701
Other trading results
71
84
72
Change in fair value of derivatives relating to
\u2013\u00a0 fair value hedges
5,265
-85
246
\u2013\u00a0 cash flow hedges (ineffective portion)
20
1
-5
\u2013\u00a0 other non-trading derivatives
1,164
-53
222
Change in fair value of assets and liabilities (hedged items)
-5,150
113
-183
Valuation results on assets and liabilities designated at FVPL (excluding trading)
444
-12
-121
Foreign exchange transactions results
33
566
422
1,503
847
852
and Note 14
'Financial liabilities at fair value through profit or loss' for information on trading assets and trading liabilities
respectively.
\u2018Valuation results and net trading income\u2019 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. During 2022, the interest rate movements
significantly affected the fair value changes of other non-trading derivatives as well as 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 is 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 CollVA). Spreads widened in 2022 compared to 2021 and the fair value changes increased.
In 2022, Derivatives trading results include EUR\u00a043 million CVA/DVA adjustments on trading derivatives
(2021: EUR 98 million; 2020: EUR 17 million).
Valuation results on assets and liabilities designated at fair value through profit or loss (excluding trading)\u2019
include fair value changes on financial assets and financial liabilities driven by changed market conditions.
Refer to Note 4 'Financial assets at fair value through profit or loss' and to Note 14 'Financial liabilities at fair
value through profit or loss'.
In addition, \u2018Valuation results on assets and liabilities designated at fair value through profit or loss
(excluding trading)\u2019 include fair value adjustments on own issued notes amounting to EUR 709 million (2021:
EUR 56 million; 2020: EUR 8 million).
Interest income from trading assets in 2022 amounted to EUR 18,593 million (2021: EUR 13,737 million;
2020: EUR 13,412 million). Interest expense from trading liabilities in 2022 amounted to EUR 18,765 million
(2021: EUR 14,079 million; 2020: EUR 13,052 million).
23\u00a0 Investment income
Investment income
in EUR million
2022
2021
2020
Dividend income
149
122
107
Realised gains/losses on disposal of debt instruments measured at FVOCI
32
45
44
Income from and fair value gains/losses on investment properties
-1
1
181
167
152
In 2022, 2021 and 2020 dividend income mainly consists of dividend received from ING\u2019s equity stake in
Bank of Beijing.
24\u00a0 Net result on derecognition of financial assets measured at amortised
cost
Net result on derecognition of financial assets measured at amortised cost
in EUR million
2022
2021
2020
Loans at amortised cost
1
4
Securities at amortised cost
-5
-1
185
-5
0
189
Remuneration of senior management, Management Board Banking and Supervisory
Board
Reference is made to Note 46 'Related parties'.
Share plans and Stock Options
ING grants various types of share awards, namely deferred shares, performance shares 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 Management Board members of ING Bank as well as identified
staff, have a retention obligation that must be adhered to upon vesting, typically a minimum retention of 12
months applies. ING has the authority to apply a holdback to awarded but unvested shares and a clawback
to vested shares
The share awards granted in 2022 relate to the performance year 2021. In 2022, 55,651 share awards
(2021: 0; 2020: 63,837) were granted to the members of the Executive Board, and 137,506 share awards
(2021: 123,750; 2020: 186,176) were granted to the Management Board Banking. To senior\u00a0 management
and other employees\u00a0 2,913,926 share awards (2021: 3,267,372; 2020: 3,678,775) were granted.
Changes in share awards
Share awards (in numbers)
Weighted average grant date
fair values (in euros)
2022
2021
2020
2022
2021
2020
Opening balance
3,672,659
3,876,206
3,855,035
7.60
7.25
11.14
Granted
3,107,083
3,391,122
3,864,951
8.99
9.69
5.12
Vested
-2,962,698
-3,459,163
-3,690,340
8.60
9.25
9.01
Forfeited
-119,502
-135,506
-153,440
7.63
7.61
8.55
Closing balance
3,697,542
3,672,659
3,876,206
7.97
7.60
7.25
for (reversals of) impairments of property and
equipment and Note 10 'Intangible assets' for (reversals of) impairments of intangible assets.
For further information on addition to (unused amounts reversed of) provision for reorganisations refer to
Note 15 'Provisions' and for further 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 2022, are
contributions to DGS of EUR 425 million (2021: EUR 435 million; 2020: EUR 413 million) mainly related to the
Netherlands, Germany, Belgium, and Poland and contributions to the SRF and local resolution funds of EUR
354 million (2021: EUR 308 million; 2020: EUR 277 million). In 2022 local bank taxes decreased by EUR 51
million from EUR 522 million in 2021 to EUR 470 million (2020: EUR 414 million).
In 2022, ING Bank Slaski, together with seven other Polish banks, has established an Institutional Protection
Scheme (IPS). The fund can be used to ensure the liquidity and solvency of each of its participants, and to
assist in the resolution of participating and non-participating banks. The contribution by ING amounts to EUR
99 million and is recognized as regulatory costs (DGS).
Audit and non-audit services
Audit and non-audit services include fees for services provided by the Bank\u2019s auditors and remained stable
for 2022. The increase of audit fees in 2021 follow from the re-appointment of the current auditor that also
triggered a revision of the audit fees.
28\u00a0 Net cash flow from operating activities
The table below shows a detailed overview of the net cash flow from operating activities.
Cash flows from operating activities
in EUR million
2022
2021
2020
Cash flows from operating activities
Result before tax
5,493
6,774
3,810
Adjusted for:
- Depreciation and amortisation
711
834
829
-\u00a0 Addition to loan loss provisions
1,861
516
2,675
-\u00a0 Other non-cash items included in result before tax
5,519
413
1,259
Taxation paid
-1,489
-1,871
-1,735
Changes in:
\u2013\u00a0\u00a0Loans and advances to banks, not available on demand
-5,836
262
10,031
\u2013\u00a0\u00a0Deposits from banks, not payable on demand
-26,976
8,438
43,044
Net change in loans and advances to/ from banks, not available/
payable on demand
-32,813
8,700
53,076
\u2013\u00a0\u00a0Trading assets
-5,485
-29
-2,095
\u2013\u00a0 Trading liabilities
11,975
-5,596
4,667
Net change in Trading assets and Trading liabilities
6,490
-5,624
2,571
Loans and advances to customers
-19,306
-27,772
2,888
Customer deposits
34,005
18,339
40,576
\u2013\u00a0\u00a0Non\u2013trading derivatives
-5,469
290
-1,420
\u2013\u00a0\u00a0Assets designated at fair value through profit or loss
56
-1,905
-1,371
\u2013\u00a0\u00a0Assets mandatorily at fair value through profit or loss
-4,143
1,650
-1,963
\u2013\u00a0\u00a0Other assets
-2,861
-121
1,092
\u2013\u00a0\u00a0Other financial liabilities at fair value through profit or loss
9,843
-6,795
1,190
\u2013\u00a0\u00a0Provisions and other liabilities
-667
-1,298
-298
Other
-3,241
-8,179
-2,770
Net cash flow from/(used in) operating activities
-2,769
-7,869
103,179
in unrealised revaluations' represent fair value adjustments to the hedged item attributable to the hedged
interest rate risk. Reference is made to paragraph 'fair value hedge accounting' in Note 36 'Derivatives and
hedge accounting'.
30\u00a0 Cash and cash equivalents
Cash and cash equivalents
in EUR million
2022
2021
2020
Treasury bills and other eligible bills
1
23
Deposits from banks/Loans and advances to banks
7,775
1,121
477
Cash and balances with central banks
87,614
106,520
111,087
Cash and cash equivalents at end of year
95,390
107,664
111,565
Treasury bills and other eligible bills included in cash and cash equivalents
in EUR million
2022
2021
2020
Treasury bills and other eligible bills included in trading assets
0
0
0
Treasury bills and other eligible bills included in FVOCI
0
0
0
Treasury bills and other eligible bills included in securities at AC
0
23
0
1
23
0
Deposits from banks/Loans and advances to banks
in EUR million
2022
2021
2020
Included in cash and cash equivalents:
\u2013\u00a0 Deposits from banks
-6,172
-7,059
-8,788
\u2013\u00a0 Loans and advances to banks
13,947
8,180
9,265
7,775
1,121
477
Not included in cash and cash equivalents:
\u2013\u00a0 Deposits from banks
-50,460
-78,033
-69,310
\u2013\u00a0 Loans and advances to banks
21,156
15,411
16,098
-29,304
-62,621
-53,212
Total as included in the statement of financial position:
\u2013\u00a0 Deposits from banks
-56,632
-85,092
-78,098
\u2013\u00a0 Loans and advances to banks
35,103
23,591
25,363
-21,529
-61,501
-52,734
collateral' for restrictions on Cash and balances with central banks.
31\u00a0 Segments
ING Bank\u2019s segments are based on the internal reporting structure by lines of business.
The Management Board Banking of ING Bank (Chief Operating Decision Maker (CODM)) set the performance
targets, 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.
Recognition and measurement of segment results are in line with the accounting policies as described in
Note 1 \u2018Basis of preparation and significant accounting policies\u2019. 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.
The following table specifies the segments by line of business and main sources of income of each of the
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 (Market Leaders)
Income from retail and private banking activities in the Netherlands, including the
SME and mid-corporate segments, and the Real Estate Finance portfolio related
to Dutch domestic mid-corporates. The main products offered are current and
savings accounts, business lending, mortgages and other consumer lending in
the Netherlands.
Retail Belgium (Market Leaders)
Income from retail and private banking activities in Belgium (including
Luxembourg), including the SME and mid-corporate segments. The main products
offered are similar to those in the Netherlands.
Retail Germany (Challengers and
Growth Markets)
Income from retail and private banking activities in Germany (including Austria
up to and including 2021, after which ING left the retail market). The main
products offered are current and savings accounts, mortgages and other
customer lending.
Retail Other (Challengers and
Growth Markets)
Income from retail banking activities in the rest of the world, including the SME
and mid-corporate segments in specific countries. The main products offered are
similar to those in the Netherlands.
Wholesale Banking
Income from wholesale banking activities. The main products are: lending, debt
capital markets, working capital solutions, export finance, daily banking solutions,
treasury and risk solutions, and corporate finance.
1 Retail Banking Austria and Retail Banking Czech Republic up to and including 2021, after which ING left the retail market
2 In 2022, ING discontinued its retail activities in France and the Philippines.
3 As from 2022, Wholesale Banking Austria as well as Wholesale Banking Czech Republic are recorded in Wholesale Banking Rest of
\u00a0 \u00a0 \u00a0 \u00a0 \u00a0 World. Previously these financials were reported in Germany and Other Challengers respectively.
ING Bank monitors and evaluates the performance of ING Bank at a consolidated level and by segment. The
Management Board Banking consider this to be relevant to an understanding of the Bank\u2019s financial
performance, because it allows investors to understand the primary method used by management to
evaluate the Bank\u2019s operating performance and make decisions about allocating resources.
ING Bank reconciles the total segment results to the total result using Corporate Line. The Corporate Line is a
reflection of capital management activities and certain income and expenses that are not allocated to the
banking businesses. Furthermore, the Corporate Line includes the isolated legacy costs (mainly negative
interest results) caused by the replacement of short-term funding with long-term funding during 2013 and
2014. 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\u2019 book equity
and the currency they operate in. In 2022, results in the Corporate Line were impacted by the application of
hyperinflation accounting in the consolidation of our subsidiary in Turkey.
Income in 2022 included a hyperinflation accounting impact of EUR -279 million and a net TLTRO impact of
EUR 16 million, while previous year was supported by a EUR 143 million net TLTRO impact and the
recognition of a EUR 72 million receivable related to the insolvency of a financial institution. The decline was
partly compensated by higher income from foreign currency ratio hedging, mainly on US dollar and the
Polish zloty. Expenses in 2022 included a hyperinflation impact of EUR 30 million and a EUR 32 million
impairment loss related to the goodwill allocated to Turkey, while previous year had included EUR 87 million
of regulatory costs due to an incidental 50% increase in the Dutch bank tax.
The information presented in this note is in line with the information presented to the Management Board
Banking of ING Bank.
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 and is therefore not readily available.
Segments by line of business
12 month period
2022
2021
2020
in EUR million
Retail
Nether-
lands
Retail
Belgium
Retail
Germany
Retail
Other 1
Wholesale
Banking
Corporate
Line
Total
Retail
Nether-
lands
Retail
Belgium
Retail
Germany
2
Retail
Other 2
Wholesale
Banking
Corporate
Line
Total
Retail
Nether-
lands
Retail
Belgium
Retail
Germany
Retail
Other
Wholesale
Banking
Corporate
Line
Total
Income
\u2013 Net interest income
2,888
1,668
1,666
2,726
4,260
539
13,745
3,290
1,747
1,447
2,712
4,151
268
13,615
3,511
1,816
1,587
2,760
3,718
208
13,600
\u2013 Net fee and commission
income
892
511
437
535
1,217
-6
3,586
771
519
497
530
1,197
3
3,517
681
413
437
412
1,069
-1
3,011
\u2013 Total investment and
other income
417
-32
69
402
849
-490
1,215
201
209
65
361
568
-51
1,354
279
145
93
89
609
-180
1,034
Total income
4,196
2,147
2,172
3,663
6,325
43
18,546
4,262
2,475
2,009
3,602
5,916
221
18,485
4,471
2,373
2,117
3,261
5,396
27
17,645
Expenditure
\u2013 Operating expenses
2,115
1,786
1,140
2,516
3,114
523
11,193
2,403
1,667
1,174
2,452
2,926
574
11,195
2,236
1,737
1,110
2,469
3,218
390
11,160
\u2013 Addition to loan loss
provisions
67
139
131
302
1,220
2
1,861
-76
225
49
202
117
516
157
514
57
593
1,351
3
2,675
Total expenses
2,182
1,924
1,271
2,818
4,334
525
13,053
2,326
1,892
1,223
2,654
3,042
574
11,711
2,393
2,251
1,167
3,063
4,568
393
13,835
Result before taxation
2,014
223
901
845
1,991
-482
5,493
1,936
583
786
949
2,874
-353
6,774
2,078
122
950
199
827
-366
3,810
Taxation
540
72
202
257
581
71
1,723
499
146
252
212
703
64
1,876
523
51
331
105
295
13
1,317
Non-controlling interests
3
47
52
1
102
4
98
26
128
-1
4
55
20
78
Net result IFRS
1,474
151
696
541
1,358
-553
3,667
1,437
437
529
639
2,144
-417
4,770
1,556
71
615
39
512
-378
2,415
1 In\u00a0 2022, ING discontinued its retail activities in France and the Philippines.
2 In the fourth quarter of 2021, ING exited from the retail banking markets in Austria and the Czech Republic.
Geographical split of the segments
12 month period
2022
2021
2020
in EUR million
Nether
-lands
Belgium
Ger-
many
Other
Challen
gers 1
Growth
markets
1
Whole-
sale
Banking
Rest of
World
Other
Total
Nether
-lands
Belgium
Ger-
many
2,3
Other
Challen
gers 2,3
Growth
markets
Whole-
sale
Banking
Rest of
World 3
Other
Total
Nether-
lands
Belgium
Ger-
many 3
Other
Challen
gers 3
Growth
markets
Whole-
sale
Banking
Rest of
World 3
Other
Total
Income
\u2013 Net interest income
3,782
2,065
2,126
1,988
1,464
1,786
534
13,745
4,068
2,109
1,938
1,833
1,532
1,866
269
13,615
4,178
2,116
2,083
1,744
1,578
1,697
204
13,600
\u2013 Net fee and
commission income
1,171
714
494
312
376
526
-6
3,586
1,070
717
523
327
351
525
3
3,517
981
583
466
271
286
425
-1
3,011
\u2013 Total investment and
other income
577
-14
94
192
416
435
-485
1,215
314
265
118
80
446
182
-51
1,354
398
196
125
28
215
244
-172
1,034
Total income
5,531
2,765
2,714
2,491
2,256
2,746
43
18,546
5,452
3,092
2,578
2,240
2,330
2,574
221
18,485
5,557
2,896
2,674
2,043
2,078
2,366
31
17,645
Expenditure
\u2013 Operating expenses
3,001
2,120
1,318
1,456
1,444
1,331
523
11,193
3,279
1,960
1,339
1,516
1,276
1,251
574
11,195
3,347
2,037
1,263
1,536
1,272
1,310
395
11,160
\u2013 Addition to loan loss
provisions
181
230
460
241
230
517
2
1,861
28
184
118
100
110
-23
516
421
589
267
297
412
685
3
2,675
Total expenses
3,182
2,350
1,778
1,696
1,674
1,847
525
13,053
3,307
2,143
1,457
1,616
1,386
1,228
574
11,711
3,769
2,627
1,530
1,833
1,684
1,995
397
13,835
Result before taxation
2,349
415
936
795
581
899
-482
5,493
2,145
948
1,121
623
944
1,346
-353
6,774
1,788
269
1,144
209
395
371
-366
3,810
Retail Banking
2,014
223
901
547
298
3,983
1,936
583
786
206
742
4,253
2,078
122
950
-27
225
3,348
Wholesale Banking
335
192
34
248
284
899
1,991
209
365
336
417
202
1,346
2,874
-290
147
194
236
169
371
827
Corporate Line
-482
-482
-353
-353
-366
-366
Result before taxation
2,349
415
936
795
581
899
-482
5,493
2,145
948
1,121
623
944
1,346
-353
6,774
1,788
269
1,144
209
395
371
-366
3,810
Taxation
658
114
297
255
156
189
55
1,723
556
240
358
185
178
296
63
1,876
518
89
380
90
141
87
12
1,317
Non-controlling
interests
3
98
1
102
4
124
128
-1
4
75
78
Net result IFRS
1,691
301
636
540
327
710
-538
3,667
1,589
708
759
438
641
1,050
-415
4,770
1,271
180
760
119
178
284
-378
2,415
1 In 2022, ING discontinued its retail activities France and the Philippines.
2 In the fourth quarter of 2021, ING exited from the retail banking markets in Austria and the Czech Republic.
3 As from 2022, Wholesale Banking Austria as well as Wholesale Banking Czech Republic are recorded in Wholesale Banking Rest of World. Previously these financials were reported in Germany and Other Challengers respectively. Historical figures have been adjusted.
32\u00a0 Information on geographical areas
ING Bank\u2019s business lines operate in Seven main geographical areas: the Netherlands, Belgium, Rest of
Europe, North America, Latin America, Asia and Australia. A geographical area is a distinguishable
component of the Group engaged in providing products or services within a particular economic
environment that is subject to risks and returns that are different from those of geographical areas
operating in other economic environments. The geographical analyses are based on the location of the
office from which the transactions are originated and do not include countries where ING only has
representation offices. The Netherlands is ING Bank\u2019s country of domicile.
In order to increase ING Bank\u2019s tax transparency, additional financial information on a per country basis has
been included in this disclosure: Tax paid represents all income tax paid to and/or received from tax
authorities in the current year, irrespective of the fiscal year to which these payments or refunds relate.
Total assets by country does not include intercompany balances and reconciles to the total assets in the
consolidated statement of financial position of ING Bank. In December 2021 the OECD released a draft
legislative framework that is designed to ensure, from 2024 onwards, that large multinational groups pay
income tax at a minimum rate of 15% in all the countries they are present in. At the date when these
financial statements were authorized for issue, of all the countries ING is present in, only South Korea has
enacted legislation to this effect. At 31 December 2022 ING Bank does not have sufficient information to
determine the future potential quantitative impact.
The table below provide additional information, for the years 2022, 2021 and 2020 respectively, on names
of principal subsidiaries and branches, nature of main activities and average number of employees on a full
time equivalent basis by country/tax jurisdiction.
Additional information by country
Geographical
area
Country/Tax
jurisdiction
Name of principal
subsidiary
Main (banking)
activity
Average number of employees
at full time equivalent basis
Total income
Total assets
Result before tax
Taxation
Tax paid
2022
2021
2020
2022
2021
2020
2022
2021
2020
2022
2021
2020
2022
2021
2020
2022
2021
2020
Netherlands
Netherlands
ING Bank N.V.
Wholesale / Retail
14,488
15,138
15,201
5,017
5,671
5,422
308,931
301,446
286,119
1,069
1,442
934
418
506
493
392
428
591
Belgium
Belgium
ING Belgi\u00eb N.V.
Wholesale / Retail
6,582
6,965
7,397
2,353
2,719
2,581
127,085
130,687
133,843
286
808
156
81
204
61
152
174
66
Luxembourg
ING Luxembourg S.A.
Wholesale / Retail
927
856
855
422
338
300
18,351
20,452
15,335
180
161
120
45
41
30
37
20
24
Rest of Europe
Poland 1
ING Bank Slaski S.A
Wholesale / Retail
11,130
10,674
9,425
1,652
1,509
1,399
45,598
43,888
40,928
544
660
438
143
154
131
-23
235
232
Germany
ING DiBa A.G.
Wholesale / Retail
5,573
5,521
5,059
2,815
2,387
2,545
161,997
159,805
162,935
1,039
1,012
1,065
328
338
364
189
493
409
Romania 1
Branch of ING Bank N.V.
Wholesale / Retail
3,580
3,319
3,049
584
495
456
10,555
9,635
8,526
324
273
141
51
41
20
67
21
24
Turkey
ING Bank A.S.
Wholesale / Retail
3,076
3,338
3,724
64
335
420
5,400
5,818
7,316
-143
144
125
65
35
27
79
33
25
Spain
Branch of ING Bank N.V.
Wholesale / Retail
1,439
1,380
1,228
877
743
679
32,262
32,559
29,899
299
212
104
98
57
37
101
59
52
Italy
Branch of ING Bank N.V.
Wholesale / Retail
1,118
1,099
1,025
345
335
337
14,152
13,983
13,747
63
73
44
22
25
24
2
2
2
UK
Branch of ING Bank N.V.
Wholesale
692
698
709
693
636
546
46,066
50,734
64,676
286
277
97
81
73
15
58
50
32
France 2,3
Branch of ING Bank N.V.
Wholesale
600
764
737
372
271
266
8,934
12,381
11,570
44
-107
-43
12
-27
-10
22
-7
9
Russia
ING Bank (Eurasia) Z.A.O.
Wholesale
272
281
297
246
38
51
2,783
898
1,035
128
3
3
9
0
0
21
-7
-3
Czech Republic 4
Branch of ING Bank N.V.
Wholesale
137
285
355
78
121
83
3,192
2,894
3,851
38
54
-3
6
12
0
13
-2
4
Hungary
Branch of ING Bank N.V.
Wholesale
120
119
131
82
44
43
1,993
1,148
1,092
38
12
6
5
3
2
2
2
1
Slovakia 1
Branch of ING Bank N.V.
Wholesale
1,129
983
878
15
15
18
391
352
385
-1
3
7
1
0
3
0
2
1
Ukraine
PJSC ING Bank Ukraine
Wholesale
91
96
108
45
22
26
385
409
335
9
11
16
2
2
3
2
2
3
Austria 4
Branch of ING Bank N.V.
Wholesale
17
292
332
19
175
75
261
419
1,840
9
101
0
2
16
-5
3
6
-14
Bulgaria
Branch of ING Bank N.V.
Wholesale
60
61
65
15
14
13
436
420
406
1
2
2
0
0
0
0
0
0
Ireland
Branch of ING Bank N.V.
Wholesale
72
64
50
66
70
72
2,771
1,831
2,050
26
65
58
3
8
7
6
8
7
Portugal
Branch of ING Bank N.V.
Wholesale
11
11
13
15
15
16
689
675
790
9
9
11
3
3
7
2
3
4
Switzerland
Branch of ING Bank N.V.
Wholesale
277
259
256
290
241
187
9,513
11,081
7,939
182
148
88
25
21
13
45
67
14
1Includes significant number of FTEs in relation to global services provided.
2Public subsidies received, as defined in article 89 of the CRD IV, amounts to EUR 0.1 million (2021: EUR 0.0 million; 2020: EUR 0.3 million).
3In 2022, ING discontinued its retail activities in France and the Philippines.
4In the fourth quarter of 2021, ING exited from the retail banking markets in Austria and the Czech Republic.
Additional information by country (continued)
Geographical
area
Country/Tax
jurisdiction
Name of principal
subsidiary
Main (banking)
activity
Average number of
employees at full time
equivalent basis
Total Income
Total assets
Result before tax
Taxation
Tax paid
2022
2021
2020
2022
2021
2020
2022
2021
2020
2022
2021
2020
2022
2021
2020
2022
2021
2020
North America
Canada
Payvision Canada Services
Ltd.
In liquidation
0
0
1
0
0
3
0
0
0
0
0
0
0
0
0
0
0
0
USA
ING Financial Holdings Corp.
Wholesale
586
563
600
892
936
720
65,024
55,582
48,205
413
779
39
115
182
16
135
148
38
Latin America
Brazil
Branch of ING Bank N.V.
Closed in 2022
30
63
89
17
13
30
57
288
1,813
9
1
3
1
5
19
5
8
4
Colombia
ING Capital Colombia S.A.S.
Dissolved in 2021
0
3
0
1
0
2
0
0
0
0
0
0
Mexico
ING Consulting, S.A. de C.V.
Wholesale
6
6
7
0
1
1
1
3
2
-2
-1
-1
0
0
0
0
0
0
Asia
China
Branch of ING Bank N.V.
Wholesale
76
79
90
30
26
26
1,181
1,654
1,598
4
0
-2
5
6
1
13
-1
-5
Japan
Branch of ING Bank N.V.
Wholesale
31
30
32
30
25
29
5,128
2,256
3,104
20
4
-1
7
2
-1
-1
3
2
Singapore
Branch of ING Bank N.V.
Wholesale
565
573
608
354
331
353
25,701
24,163
24,498
105
133
42
14
19
8
21
9
7
Macau
Payvision Macau Ltd.
Liquidated in
2022
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Hong Kong
Branch of ING Bank N.V.
Wholesale
103
105
122
82
79
92
4,343
6,691
7,030
-33
5
-9
-5
1
-1
0
-7
15
Philippines 1,3
Branch of ING Bank N.V.
Wholesale
3,098
2,414
1,857
10
6
13
381
567
497
-39
-33
-26
8
-5
6
2
1
2
South Korea
Branch of ING Bank N.V.
Wholesale
78
75
77
86
65
66
7,989
5,800
6,692
47
26
18
12
6
4
7
-2
10
Taiwan
Branch of ING Bank N.V.
Wholesale
35
33
34
33
26
36
3,578
2,963
3,160
-16
-3
19
-5
-1
4
4
0
1
Indonesia
PT ING Securities Indonesia
Liquidated in
2022
0
0
0
0
0
0
5
5
0
0
0
0
0
0
0
0
0
Malaysia
Branch of ING Bank N.V.
Closed in 2022
4
6
0
0
1
1
1
141
0
-1
-1
0
0
0
0
0
0
Sri Lanka
Branch of ING Hubs B.V.
Global services
4
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
United Arab
Emirates
Branch of ING Bank N.V.
Wholesale
10
10
10
-1
0
0
1
1
1
-1
-1
-2
0
0
0
0
0
0
Australia
Australia
ING Bank (Australia) Ltd.
Wholesale / Retail
1,556
1,503
1,472
948
782
740
52,728
49,826
46,014
557
500
362
172
149
40
135
121
181
Other
Mauritius
ING Mauritius Investment I
Liquidated in
2022
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Total
57,569
57,660
55,901
18,546
18,485
17,645
967,861
967,861
937,379
5,493
6,774
3,810
1,723
1,876
1,317
1,489
1,871
1,735
credit exposures declined significantly, as we have recognized EUR 0.5 billion risk costs related to these
exposures. The local results on a stand-alone basis were higher compared to 2021.
This was driven by the high local interest rate environment and increased rouble inflow from existing,
predominantly non-Russian, clients. Under local law and banking regulations, ING Russia must accept these
rouble inflows. Furthermore, the local result before tax expressed in euro (EUR 128 million) was positively
impacted by the appreciation of the rouble against the euro for an amount of EUR 80 million throughout
2022. Going forward, we will continue to actively reduce our Russia-related credit exposure.
The higher tax charge in Poland is mainly caused by non-deductible regulatory and other costs.
2021
The higher tax charge of 35% in the Netherlands (compared to the statutory rate of 25%) is mainly caused
by the non-deductible Dutch bank tax (EUR 260 million) and the impairments on deferred tax assets
regarding Payvision and Yolt (EUR 26 million tax).
The lower tax charge in Austria is caused by previously not recognised tax losses (EUR -10 million tax).
The higher tax charge in Poland is mainly caused by non-deductible regulatory- and other costs.
2020
The higher tax charge of 53% in the Netherlands (compared to the statutory rate of 25%) is mainly caused
by the non-deductible Dutch bank tax (EUR 169 million) and the non-deductible impairments regarding
goodwill (EUR 266 million) and TMB (EUR 230 million).
The lower tax charge in Australia is caused by a release of a tax provision after concluding a settlement with
the Australian Tax Authorities on an issue related to former Insurance activities, which issue was fully
indemnified by NN Group.
The higher tax charges in Brazil and the Philippines are mainly caused by the de-recognition of tax benefits
for incurred tax losses due to expected insufficient future taxable profits.
The higher tax charges in Poland and Belgium are mainly caused by non-deductible regulatory- and other
costs.
33\u00a0 Pensions and other post-employment benefits
Most group companies sponsor defined contribution pension plans. The assets of all ING Bank\u2019s defined
contribution plans are held in independently administered funds. Contributions, including the defined
contribution plan in the Netherlands, are principally determined as a percentage of remuneration. These
plans do not give rise to provisions in the statement of financial position, other than relating to short-term
timing differences included in other assets and in other liabilities.
ING Bank maintains defined benefit retirement plans in some countries. These plans provide benefits that
are related to the remuneration and service of employees upon retirement. The benefits in some of these
plans are subject to various forms of indexation. The indexation is, in some cases, at the discretion of
management; in other cases it is dependent upon the sufficiency of plan assets.
Annual contributions are paid to the funds at a rate necessary to adequately finance the accrued liabilities
of the plans calculated in accordance with local legal requirements. Plans in all countries are designed to
comply with applicable local regulations governing investments and funding levels.
ING Bank provides other post-employment benefits to certain former employees. These are primarily
discounts on ING products.
Defined contribution plans
ING, as part of the labour agreements with its employee\u2019s , sponsors a number of defined contribution plans.
ING\u2019s obligation is limited to contributions which are agreed in advance and also includes employee
contributions. The most significant plans are in The Netherlands and Belgium. The Employer contribution are
recognized as an expense which amounted for 2022 EUR 364 million (2021: EUR 369 million).
Defined benefit retirement plans
Statement of financial position - Net defined benefit asset/liability
Plan assets and defined benefit obligation per country
Plan assets
Defined benefit
obligation
Funded Status
in EUR million
2022
2021
2022
2021
2022
2021
The Netherlands
310
427
400
578
-90
-151
United States
248
332
230
312
18
20
United Kingdom
1,277
1,968
750
1,236
527
732
Belgium
507
606
475
617
32
-11
Other countries
295
338
305
372
-10
-34
Funded status (Net defined benefit asset/liability)
2,637
3,671
2,159
3,115
478
556
Presented as:
- Other assets
617
783
- Other liabilities
-139
-227
478
556
The most recent (actuarial) valuations of the plan assets and the present value of the defined benefit
obligation were carried out as at 31\u00a0December 2022. The present value of the defined benefit obligation, and
the related current service cost and past service cost, were determined using the projected unit credit
method.
The current worldwide uncertainty due to the Russian invasion in the Ukraine and the resulting increasing
interest rates and inflation has a strong negative impact on most investment markets in 2022, the effect on
the fair value of ING Bank\u2019s plan assets and defined benefit obligation is significant however the funding
status declined only by EUR -78 million mainly following the Liability Driven Investment (LDI) strategy in the
United Kingdom.
Changes in the fair value of plan assets for the period were as follows:
Changes in fair value of plan assets
in EUR million
2022
2021
Opening balance
3,671
3,583
Interest income
54
37
Remeasurements: Return on plan assets excluding amounts included in interest income
-947
2
Employer's contribution
34
26
Participants contributions
3
2
Benefits paid
-126
-136
Exchange rate differences
-53
158
Closing balance
2,637
3,671
Actual return on the plan assets
-894
39
Amounts recognised directly in Other comprehensive income were as follows:
Changes in the net defined benefit assets/liability remeasurement reserve
in EUR million
2022
2021
Opening balance
-212
-307
Remeasurement of plan assets
-947
2
Actuarial gains and losses arising from changes in demographic assumptions
5
Actuarial gains and losses arising from changes in financial assumptions
882
122
Taxation and Exchange rate differences
46
-34
Total Other comprehensive income movement for the year
-19
95
Closing balance
-232
-212
In 2022 EUR -947 million (2021: EUR 2\u00a0 million) remeasurement of plan assets, that is recognised as a loss in
other comprehensive income, is driven by higher yields on investments. Also the war in Ukraine and high
inflation had impact on the investment return. Material changes in interest rates and equity returns
impacted plan assets negatively during 2022 substantially.
The EUR 882\u00a0million (2021: EUR 122 million) actuarial gains arising from changes in financial assumptions in
the calculation of the defined benefit obligation are mainly due to an increase in discount rates.
The accumulated amount of remeasurements recognised directly in Other comprehensive income is EUR
-289\u00a0million(EUR -232 million after tax) as at 31\u00a0December 2022 (2021: EUR -296\u00a0million; EUR -212\u00a0million
after tax).
Amounts recognised in the statement of profit or loss related to pension and other staff related benefits are
as follows:
Pension and other staff-related benefit costs
Net defined benefit
asset/liability
Other post-employment
benefits
Total
in EUR million
2022
2021
2020
2022
2021
2020
2022
2021
2020
Current service cost
33
33
31
1
1
-2
34
34
29
Past service cost
2
-1
2
Net Interest cost
-8
-6
-6
1
2
2
-6
-4
-4
Effect of curtailment or settlement
-2
-2
Defined benefit plans
26
27
27
2
1
0
27
28
28
Defined contribution plans
364
369
356
Pension and other post employment
benefits
392
397
383
Other staff related benefits
-2
11
12
Pension and other staff-related benefits
390
408
395
Determination of the net defined benefit asset/liability
The net defined benefit asset/liability is reviewed and adjusted annually. The assumptions used in the
determination of the net defined benefit asset/liability and the Other post-employment benefits include
discount rates, mortality rates, expected rates of salary increases (excluding promotion increases), and
indexation. The rates used for salary developments, interest discount factors, and other adjustments reflect
country-specific conditions.
The key assumption in the determination of the net defined benefit asset/liability is the discount rate. The
discount rate is the weighted average of the discount rates that are applied in different regions where ING
Bank has defined benefit pension plans (weighted by the defined benefit obligation). The discount rate is
based on a methodology that uses market yields on high quality corporate bonds of the specific regions
with durations matching the pension liabilities as key input. Market yields of high quality corporate bonds
reflect the yield on corporate bonds with an AA rating for durations where such yields are available. An
extrapolation is applied in order to determine the yield to the longer durations for which no AA-rated
corporate bonds are available. As a result of the limited availability of long-duration AA-rated corporate
bonds, extrapolation is an important element of the determination of the discount rate. The weighted
average discount rate applied for net defined benefit asset/liability for 2022 was 4.3% (2021: 1.5%) based on
the pension plan in the Netherlands, Germany, Belgium, The United States of America, and the United
Kingdom. The average discount rate applied for Other post-employment benefits in 2022 was 5.5% (2021:
2.9%)
Sensitivity analysis of key assumptions
ING performs sensitivity analyses on the most significant assumptions: discount rates, mortality, expected
rate of salary increase, and indexation. The sensitivity analysis has been carried out under the assumption
that the changes occurred at the end of the reporting period.
The sensitivity analysis calculates the financial impact on the defined benefit obligation of an increase or
decrease of the weighted averages of each significant actuarial assumption, all other assumptions held
constant. In practice, this is unlikely to occur, and some changes of the assumptions may be correlated.
Changes to mortality, expected rate of salary increase, and indexation would have no material impact on
the defined benefit obligation. The most significant impact would be from a change in the discount rate. An
increase or decrease in the discount rate of 1.0% creates an impact on the defined benefit obligation of\u00a0 EUR
247 million (decrease) and EUR 287 million (increase), respectively.
Expected cash flows
Annual contributions are paid to the funds at a rate necessary to adequately finance the accrued liabilities
of the plans calculated in accordance with local supervisory requirements. Plans in all countries are designed
to comply with applicable local regulations governing investments and funding levels. ING Bank\u2019s
subsidiaries should fund the cost of the entitlements expected to be earned on a yearly basis.
For 2023 the expected contributions to defined benefit pension plans are EUR 33 million.
The benefit payments for defined benefit and other post-employment benefits expected to be made by the
plan between 2023-2027 are estimated to be between EUR 128 million and EUR 150 million per year. From
2028 to 2032 the total payments made by the plan are expected to be EUR 739 million.
34\u00a0 Taxation
Statement of financial position \u2013 Deferred tax
Deferred taxes are recognised on all temporary differences under the liability method using tax rates
applicable in the jurisdictions in which ING Bank is subject to taxation.
Changes in deferred tax
in EUR million
2022
Net
liability\u00a0(-)
Net asset\u00a0(+)
opening
balance
Change
through
equity
Change
through
net\u00a0result
Exchange
rate
differences
Changes in the
composition of
the group and
other changes
Net
liability\u00a0(-)
Net asset\u00a0(+)
ending
balance
Financial assets at FVOCI
-70
148
5
-3
80
Financial assets and liabilities at FVPL
107
-88
9
28
Depreciation
-7
-5
-2
-13
Cash flow hedges
-126
875
2
752
Pension and post-employment
benefits
-49
6
-13
8
-7
-54
Other provisions
19
44
-4
59
Loans and advances
430
177
-3
7
612
Unused tax losses carried forward
199
137
-8
327
Other
-148
-123
26
-6
-251
354
907
283
-5
0
1,539
Presented in the statement of
financial position as:
\u2013\u00a0 Deferred tax liabilities
-603
-257
\u2013\u00a0 Deferred tax assets
957
1,796
354
1,539
The above mentioned deferred tax asset of EUR 365 million (2021: EUR 300 million) and the related unused
tax losses carried forward exclude the deferred tax liability recognised in the Netherlands with respect to the
recapture of tax losses originated in the United Kingdom but previously deducted in the Netherlands for the
amount of EUR 37\u00a0million (2021: EUR 102 million).
Deferred tax assets are recognised for temporary deductible differences, for tax losses carried forward and
unused tax credits only to the extent that realisation of the related tax benefit is probable.
Breakdown of certain net deferred tax asset positions by jurisdiction
in EUR million
2022
2021
Poland
391
265
France
70
66
Philippines
0
7
China
0
12
Czech
0
2
Hong Kong
6
1
United States of America
1
1
Turkey
7
Taiwan
8
483
354
The table above includes a breakdown of certain net deferred tax asset positions by jurisdiction for which
the utilisation of the deferred tax asset is dependent on future taxable profits in excess of the profits arising
from the reversal of existing taxable temporary differences whilst the related entities have incurred losses in
either the current or the preceding year.
In 2022 and 2021 ING Bank Slaski (Poland) incurred a tax loss following the large value changes of the cash
flow hedge derivatives which are settled net via a central clearing party. This tax loss can be carried forward
for 5 years. Based on a taxable profit forecast, ING considers it probable that the future taxable profits will
compensate for this tax loss carry forward position within 2 years. Based on this a deferred tax asset on
unused tax losses carried forward (EUR 224 million) is fully recognised. The remaining deferred tax asset in
Poland of EUR 167 million relates to temporary tax differences on loans and advances and financial assets
at fair value through profit and loss.
Recognition is based on the fact that it is probable that the entity will have taxable profits and/or can utilise
tax planning opportunities before expiration of the deferred tax assets. Changes in circumstances in future
periods may adversely impact the assessment of the recoverability. The uncertainty of the recoverability is
taken into account in establishing the deferred tax assets.
At 31 December 2021 and 2022, ING Bank had no significant temporary differences associated with the
parent company\u2019s investments in subsidiaries as any economic benefit from those investments will not be
taxable at parent company level.
Statement of profit or loss \u2013 Taxation
Taxation by type
Netherlands
Rest of the world
Total
in EUR million
2022
2021
2020
2022
2021
2020
2022
2021
2020
Current taxation
496
459
428
1,510
1,447
1,015
2,006
1,906
1,442
Deferred taxation
-79
47
64
-204
-78
-189
-283
-30
-125
417
507
492
1,306
1,369
826
1,723
1,876
1,317
Reconciliation of the weighted average statutory income tax rate to ING Bank\u2019s effective income tax rate
in EUR million
2022
2021
2020
Result before tax from continuing operations
5,493
6,774
3,810
Weighted average statutory tax rate
24.8%
24.3%
25.6%
Weighted average statutory tax amount
1,363
1,645
975
Permanent differences affecting current tax
Participation exemption
-64
-68
-46
Other income not subject to tax
-40
-32
-5
Expenses not deductible for tax purposes
403
201
320
Current tax from previously unrecognised amounts
10
51
17
State and local taxes
68
64
44
Adjustments to prior periods
-29
-12
-16
Differences affecting deferred tax
Impact on deferred tax from change in tax rates
5
9
10
Deferred tax benefit from previously unrecognised amounts
-3
-18
-6
Write-off/reversal of deferred tax assets
10
37
24
Effective tax amount
1,723
1,876
1,317
Effective tax rate
31.4%
27.7%
34.6%
The weighted average statutory tax rate in 2022 ( 24.8%) increased compared to that of 2021 (24.3%).
The effective tax rate of 31.4% in 2022 is higher than the weighted average statutory tax rate. This is mainly
caused by the impact in 2022 of the following non-deductible items for income tax purposes: hyperinflation
accounting loss in Turkey, impairments on TTB and interest expenses in various countries.
The weighted average statutory tax rate in 2021 (24.3%) was lower than the rate of 25.6% in 2020.
The effective tax rate of 27.7% in 2021 was significantly higher than the weighted average statutory tax
rate. This is mainly caused by a high amount of expenses non-deductible for tax purposes like the non-
deductible bank tax and a tax charge caused by the recapture of tax losses originated in the United
Kingdom but previously deducted in the Netherlands.
The effective tax rate of 34.6% in 2020 was higher than the weighted average statutory tax rate. This is
mainly caused by a high amount of expenses non-deductible for tax purposes like the non-deductible bank
tax and non-deductible losses with respect to goodwill impairments and impairments on associates in the
Netherlands and in some other European countries.
Adjustments to prior periods in 2020 relates to a release of a tax provision of EUR 68 million after concluding
on a settlement with the Australian tax authorities with respect to\u00a0 an issue related to former insurance
activities, which issue was fully indemnified by NN Group.
Equity \u2013 Other comprehensive income
Income tax related to components of other comprehensive income
in EUR million
2022
2021
2020
Unrealised revaluations financial assets at fair value through other comprehensive
income and other revaluations
140
14
-3
Realised gains/losses transferred to the statement of profit or loss (reclassifications
from equity to profit or loss)
8
12
10
Changes in cash flow hedge reserve
875
233
-23
Remeasurement of the net defined benefit asset/liability
6
-54
-8
Changes in fair value of own credit risk of financial liabilities at fair value through
profit or loss
19
-8
-1
Exchange rate differences and other
-141
-77
63
Total income tax related to components of other comprehensive income
907
120
38
35\u00a0 Fair value of assets and liabilities
a) Valuation Methods
The estimated fair values represent 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 is a market-
based measurement, which is based on assumptions that market participants would use and takes into
account the characteristics of the asset or liability that market participants would take into account when
pricing the asset or liability.
Fair values of financial assets and liabilities are based on quoted prices in active market where available.
When such quoted prices are not available, the fair value is determined by using valuation techniques.
In 2022 the financial market witnessed globally a higher-volatility due to a confluence of factors, such as
changing expectations about the paths of future interest rates in major advanced economies, energy crisis
and geopolitical tensions after Russia's invasion of Ukraine.\u00a0 Globally, interest rates hike across EU and US.
The USD appreciates against EURO and various currencies during the year. These main factors drive the
market-to-market movements across different asset classes and spread movement through the year.
Overall in 2022, financial assets and liabilities, including Level 3, continued to be valued using agreed
methodologies and ING continued to limit the unobservable input to arrive at the most appropriate Fair
Market value.
b) Valuation Control framework
The valuation control framework covers the product approval process (PARP), pricing, market data
assessment and independent price verification (IPV), valuation adjustments, model use, fair value hierarchy
and day one profit or loss. Valuation processes are governed by various governance bodies, including Local
Parameter Committees, Global Valuation and Impairment Committee, Market Data Committee and
Valuation Model Committee. All relevant committees meet on a regular basis (monthly/quarterly), where
agenda covers the aforementioned valuation controls.
The Global Valuation and Impairment Committee is responsible for the oversight and the approval of the
outcome of impairments (other than loan loss provisions) and valuation processes. It oversees the quality
and coherence of valuation methodologies and performance. The Valuation Model Committee is responsible
for the approval of all valuation models used for the Fair valuation (IFRS) and Prudent Valuation (CRR) of
positions measured at fair value. The Local Parameter Committee discusses the valuation results and
monitors the performance of the valuation activities carried out on local or regional level. The Market Data
Committee is responsible for the approval of the market data used in valuation.\u00a0
c) Valuation Adjustments
Valuation adjustments are an integral part of the fair value. They are the adjustments to the output from a
valuation technique in order to appropriately determine a fair value in accordance with IFRS13. ING
considers various fair value adjustments including Bid-Offer adjustments, Model Risk adjustments, Bilateral
Valuation Adjustments (BVA, consisting of Credit Valuation Adjustments or CVA, and Debit valuation
Adjustments or DVA), Collateral Valuation Adjustment (CollVA) and Funding Valuation Adjustment (FVA).
For financial instruments where the fair value at initial recognition is based on one or more significant
unobservable inputs, a difference between the transaction price and the fair value resulting from the
internal valuation process can occur. Such difference is referred to as Day One Profit or Day One Loss (DOP).
ING defers material Day One Profit or Loss of instruments with significant unobservable valuation inputs,
which are the financial instruments classified as Level 3 and financial instruments with material
unobservable inputs into CVA which are not necessarily classified as Level 3. The Day One Profit or Loss is
amortised over the life of the instrument, or until the significant unobservable inputs become observable, or
until the significant unobservable inputs become non-significant. Both the impact on the profit and loss in
2022 and the Day One Profit or Loss reserve is disclosed in the below table.
The following table presents the models reserves for financial assets and liabilities.
Valuation adjustment reserves on financial assets and liabilities
in EUR million
2022
2021
Deferred Day One Profit or Loss 1
-108
-7
Own credit adjustments 2
75
-95
Bid/Offer
-216
-143
Model Risk
-13
-11
CVA
-192
-159
DVA 2
99
30
CollVA
-8
-8
FVA
-78
-95
Total Valuation Adjustments
-441
-489
1.In 2022, the presentation of Day One Profit or Loss reserve has been included in the table above
2. The change in the DVA as of 2022 entails the split into DVA on derivatives and Own credit adjustments on own issued liabilities.
Comparatives figures for 2021 have been updated accordingly.\u00a0
Overall, the fair value adjustments balance move down compared to last year end explained by own credit
adjustments on own issued liabilities, mainly driven by the widening of ING CDS curve spread across all
tenors, and for DVA on derivatives.
Deferred Day One Profit or Loss Reserve
The table below summarizes the movement in the aggregate profit not recognised when financial
instruments were initially recognised (Day One Profit or Loss), because of the use of valuation techniques for
which not all the inputs were market observable data.
As at 31 December 2022 ING further refined the thresholds to identify trades with significant unobservable
CVA which triggered more Day One Profit or Loss deferral. Reference is made to the table below.
Deferred day one profit or loss reserve
in EUR million
2022
2021
Opening balance at 1 January
-7
-5
DOP deferred on new transactions during the period
-107
-8
DOP recognised in the statement of profit or loss during the period
6
6
Closing balance at 31 December
-108
-7
The following methods and assumptions were used by ING Bank to estimate the fair value of the financial
instruments:
Equity securities
Instrument description: Equity securities include stocks and shares, corporate investments and private
equity investments.
Valuation: If available, the fair values of publicly traded equity securities and private equity securities are
based on quoted market prices. In absence of active markets, fair values are estimated by analysing the
investee\u2019s financial position, result, risk profile, prospect, price, earnings comparisons and revenue multiples.
Additionally, reference is made to valuations of peer entities where quoted prices in active markets are
available. For equity securities best market practice will be applied using the most relevant valuation
method. All non-listed equity investments, including investments in private equity funds, are subject to a
standard review framework which ensures that valuations reflect the fair values.
Fair value hierarchy: The majority of equity securities are publicly traded and quoted prices are readily and
regularly available. Hence, these securities are classified as Level 1.\u00a0 Equity securities which are not traded in
active markets mainly include corporate investments, fund investments and other equity securities and are
classified as Level 3.
Debt securities
Instrument description: Debt securities include government bonds, financial institutions bonds and Asset-
backed securities (ABS).
Valuation: Where available, fair values for debt securities are generally based on quoted market prices.
Quoted market prices are obtained from an exchange market, dealer, broker, industry group, pricing service,
or regulatory service. The quoted prices from non-exchange sources are reviewed on their tradability of
market prices. If quoted prices in an active market are not available, fair value is based on an analysis of
available market inputs, which includes consensus prices obtained from one or more pricing services.
Furthermore, fair values are determined by valuation techniques discounting expected future cash flows
using market interest rate curves, referenced credit spreads, maturity of the investment, and estimated
prepayment rates where applicable.
Fair value hierarchy: Government bonds and financial institutions bonds are generally traded in active
markets, where quoted prices are readily and regularly available and are hence, classified as Level 1. The
remaining positions are classified as Level 2 or Level 3.\u00a0 Asset backed securities for which no active market is
available and a wide discrepancy in quoted prices exists, are classified as Level 3.
Derivatives
Instrument description: Derivatives contracts can either be exchange-traded or over the counter (OTC).
Derivatives include interest rate derivatives, FX derivatives, Credit derivatives, Equity derivatives and
commodity derivatives.
Valuation: The fair value of exchange-traded derivatives is determined using quoted market prices in an
active market and are classified as Level 1 of the fair value hierarchy. For instruments that are not actively
traded, fair values are estimated based on valuation techniques. OTC derivatives and derivatives trading in
an inactive market are valued using valuation techniques. The valuation techniques and inputs depend on
the type of derivatives and the nature of the underlying instruments. The principal techniques used to value
these instruments are based on (amongst others) discounted cash flows, option pricing models and Monte
Carlo simulations. These valuation models calculate the present value of expected future cash flows, based
on \u2018no-arbitrage\u2019 principles. The models are commonly used in the financial industry and inputs to the
validation models are determined from observable market data where possible. Certain inputs may not be
observable in the market, but can be determined from observable prices via valuation model calibration
procedures. These inputs include prices available from exchanges, dealers, brokers or providers of pricing,
yield curves, credit spreads, default rates, recovery rates, dividend rates, volatility of underlying interest
rates, equity prices, and foreign currency exchange rates and reference is made to quoted prices, recently
executed trades, independent market quotes and consensus data, where available.
For uncollateralised OTC derivatives, ING applies Credit Valuation Adjustment to correctly reflect the
counterparty credit risk in the valuation and Debit Valuation Adjustments to reflect the credit risk of ING for
its counterparty. In addition, for these derivatives ING applies Funding Valuation Adjustment. See sections
CVA/DVA and FVA in section c) Valuation Adjustments for more details regarding the calculation.
Fair value hierarchy: The majority of the derivatives are priced using observable inputs and are classified as
Level 2. Derivatives for which the input cannot be implied from observable market data are classified as
Level 3.
Loans and receivables
Instrument description: Loans and receivables are non-derivative financial assets with fixed or determinable
payments that are not quoted in an active market. Loans and receivables carried at fair value includes
trading loans, being securities lending and similar agreement comparable to collateralised lending,
syndicated loans, loans expected to be sold and receivables with regards to reverse repurchase
transactions.
Valuation: The fair value of loans and receivables is generally estimated by discounting expected future cash
flows using a discount rate that reflects credit risk, liquidity, and other current market conditions. The fair
value of mortgage loans is estimated by taking into account prepayment behaviour. Fair value hierarchy:
Loans and receivables are predominantly classified as Level 2. Loans and receivables for which current
market information about similar assets to use as observable, corroborated data for all significant inputs
into a valuation model is not available, are classified as Level 3.
Financial liabilities at fair value through profit and loss
Instrument description: Financial liabilities at fair value through profit and loss include debt securities, debt
instruments, primarily comprised of structured notes, which are held at fair value under the fair value
option. Besides that, it includes derivative contracts and repurchase agreements.
Valuation: The fair values of securities in the trading portfolio and other liabilities at fair value through profit
or loss are based on quoted market prices, where available. For those securities not actively traded, fair
values are estimated based on internal discounted cash flow valuation techniques using interest rates and
credit spreads that apply to similar instruments.
Fair value hierarchy: The majority of the derivatives and debt instruments are classified as Level 2.
Derivatives and debt instruments for which the input cannot be derived from observable market data are
classified as Level 3.
e) Transfers between Level 1 and 2
As a consequence of change in observable inputs, ING recorded an EUR 1.8 billion transfer from Level 2 to
Level 1 in debt securities measured at fair value through other comprehensive income. No significant
transfers from Level 1 to Level 2 were recorded in the reporting period 2022.
f) Level 3: Valuation techniques and inputs used
Financial assets and liabilities in Level 3 include both assets and liabilities for which the fair value was
determined using (i) valuation techniques that incorporate unobservable inputs as well as (ii) quoted prices
which have been adjusted to reflect that the market was not actively trading at or around the balance sheet
date. Unobservable inputs are inputs which are based on ING\u2019s own assumptions about the factors that
market participants would use in pricing an asset or liability, developed based on the best information
available in the circumstances. Unobservable inputs may include volatility, correlation, spreads to discount
rates, default rates and recovery rates, prepayment rates, and certain credit spreads. Valuation techniques
that incorporate unobservable inputs are sensitive to the inputs used.
Of the total amount of financial assets classified as Level 3 as at 31\u00a0December 2022 of EUR 7.5 billion
(31\u00a0December 2021: EUR 6.2 billion), an amount of EUR 2.2 billion (29.2%) (31\u00a0December 2021: EUR 2.0
billion, being 32.5%) is based on unadjusted quoted prices in inactive markets. As ING does not generally
adjust quoted prices using its own inputs, there is no significant sensitivity to ING\u2019s own unobservable inputs.
Furthermore, Level 3 financial assets includes approximately EUR 4.2 billion (31\u00a0December 2021: EUR 2.9
billion) which relates to financial assets that are part of structures that are designed to be fully neutral in
terms of market risk. Such structures include various financial assets and liabilities for which the overall
sensitivity to market risk is insignificant. Whereas the fair value of individual components of these structures
may be determined using different techniques and the fair value of each of the components of these
structures may be sensitive to unobservable inputs, the overall sensitivity is by design not significant.
The remaining EUR 1.1 billion (31\u00a0December 2021: EUR 1.3 billion of the fair value classified in Level 3
financial assets is established using valuation techniques that incorporates certain inputs that are
unobservable.
Of the total amount of financial liabilities classified as Level 3 as at 31\u00a0December 2022 of EUR 0.7 billion
(31\u00a0December 2021: EUR 0.3 billion), an amount of EUR 0.02 billion (2.5%) (31\u00a0December 2021: EUR 0.1
billion, being 42.0%) is based on unadjusted quoted prices in inactive markets. As ING does not generally
adjust quoted prices using its own inputs, there is no significant sensitivity to ING\u2019s own unobservable inputs.
Furthermore, Level 3 financial liabilities includes approximately EUR 0.6 billion (31\u00a0December 2021: EUR 0.1
billion) which relates to financial liabilities that are part of structures that are designed to be fully neutral in
terms of market risk. As explained above, the fair value of each of the components of these structures may
be sensitive to unobservable inputs, but the overall sensitivity is by design not significant.
The remaining EUR 0.1 billion (31\u00a0December 2021: EUR 0.1 billion of the fair value classified in Level 3
financial liabilities is established using valuation techniques that incorporates certain inputs that are
unobservable.
The table below provides a summary of the valuation techniques, key unobservable inputs and the lower
and upper range of such unobservable inputs, by type of Level 3 asset/liability. The lower and upper range
mentioned in the overview represent the lowest and highest variance of the respective valuation input as
actually used in the valuation of the different financial instruments. Amounts and percentages stated are
unweighted. The range can vary from period to period subject to market movements and change in Level\u00a03
position. Lower and upper bounds reflect the variability of Level 3 positions and their underlying valuation
inputs in the portfolio, but do not adequately reflect their level of valuation uncertainty. For valuation
uncertainty assessment, reference is made to section Sensitivity analysis of unobservable inputs (Level 3).
Valuation techniques and range of unobservable inputs (Level 3)
Assets
Liabilities
Valuation techniques
Significant unobservable inputs
Lower range
Upper range
In EUR million
2022
2021
2022
2021
2022
2021
2022
2021
At fair value through profit or loss
Debt securities
3,447
2,643
1
1
Price based
Price (%)
0%
0%
125%
121%
Price (price per share)
208
208
Present value techniques
Credit spread (bps)
60
100
Price (%)
97%
100%
Equity securities
156
134
Price based
Price (price per share)
0
0
5,457
5,475
Loans and advances
1,485
1,598
Price based
Price (%)
0%
0%
100%
100%
Present value techniques
Credit spread (bps)
2
0
12
250
(Reverse) repo's
1,062
650
Present value techniques
Interest rate (%)
3%
0%
5%
1%
Structured notes
3
0
53
135
Price based
Price (%)
84%
84%
107%
125%
Option pricing model
Equity volatility (%)
13%
13%
42%
30%
Equity/Equity correlation
0.5
n.a.
1.0
n.a.
Equity/FX correlation
-0.4
0.0
0.6
0.0
Dividend yield (%)
0%
3%
8%
4%
Present value techniques
Credit spreads (bps)
96
96
Derivatives
\u2013\u00a0\u00a0Rates
431
5
476
35
Option pricing model
Interest rate volatility (bps)
49
43
148
82
Present value techniques
Reset spread (%)
0%
2%
1%
2%
Interest rate (%)
2%
2%
Prepayment rate (%)
5%
13%
\u2013\u00a0\u00a0FX
5
27
4
30
Present value techniques
FX volatility (%)
1%
16%
Option pricing model
Implied volatility (%)
6%
1%
20%
22%
\u2013\u00a0\u00a0Credit
13
75
175
94
Present value techniques
Credit spread (bps)
5
1
623
359
Price based
Price (%)
0%
0%
100%
100%
\u2013\u00a0\u00a0Equity
33
30
22
27
Option pricing model
Equity volatility (%)
0%
11%
77%
119%
Equity/Equity correlation
0.5
0.5
0.9
0.8
Equity/FX correlation
-0.5
-0.7
0.1
0.1
Dividend yield (%)
1%
0%
14%
18%
Price based
Price (%)
n.a
0%
n.a
0%
\u2013\u00a0\u00a0Other
1
3
9
Option pricing model
Commodity volatility (%)
0%
20%
63%
89%
At fair value through other comprehensive income
\u2013\u00a0\u00a0Loans and advances
643
838
Present value techniques
Prepayment rate (%)
6%
9%
6%
9%
Price based
Price (%)
67%
99%
99%
100%
\u2013\u00a0\u00a0Equity
247
225
Present value techniques
Credit spread (bps)
6.7
1.9
6.7
1.9
Interest rate (%)
4%
3%
4%
3%
Price based
Price (%)
n.a
1%
n.a
1%
Price based
Other (EUR)
70
63
90
80
Total
7,526
6,228
732
330
Price
For securities where market prices are not available, fair value is measured by comparison with observable
pricing data from similar instruments. Prices of 0% are distressed to the point that no recovery is expected,
while prices significantly in excess of 100% or par are expected to pay a yield above current market rates.
Credit spreads
Credit spread is the premium above a benchmark interest rate required by the market participant to accept
a lower credit quality. Higher credit spreads indicate lower credit quality and a lower value of an asset.
Volatility
Volatility is a measure for variation of the price of a financial instrument or other valuation input over time.
Volatility is one of the key inputs in option pricing models. Typically, the higher the volatility, the higher
value of the option. Volatility varies by the underlying reference (equity, commodity, foreign currency and
interest rates), by strike, and maturity of the option. The minimum level of volatility is 0% and there is no
theoretical maximum.
Correlation
Correlation is a measure of dependence between two underlying references which is relevant for valuing
derivatives and other instruments having more than one underlying reference. High positive correlation
(close to 1) indicates strong positive (statistical) relationship, where underliers move, everything else equal,
into the same direction. The same holds for a high negative correlation.
Reset spread
Reset spreads are key inputs to mortgage linked prepayment swaps valuation. Reset spread is the future
spread at which mortgages will re-price at interest rate reset dates.
Inflation rate Inflation rate is a key input to inflation linked instruments. Inflation linked instruments protect
against price inflation and are denominated and indexed to investment units. Interest payments would be
based on the inflation index and nominal rate in order to receive/pay the real rate of return. A rise in
nominal coupon payments is a result of an increase in inflation expectations, real rates, or both.
Dividend yield
Dividend yield is an important input for equity option pricing models showing how much dividends a
company is expected to pay out each year relative to its share price. Dividend yields are generally expressed
as an annualised percentage of share price.
Jump rate
Jump rates simulate abrupt changes in valuation models. The rate is an added component to the discount
rate in the model to include default risks.
Prepayment rate
Prepayment rate is a key input to mortgage and loan valuation. Prepayment rate is the estimated rate at
which mortgage borrowers will repay their mortgages early, e.g. 5% per year. Prepayment rate and reset
spread are key inputs to mortgage linked prepayment swaps valuation.
Level 3: Changes during the period
Changes in Level 3 Financial assets
Trading assets
Non-trading
derivatives
Financial assets
mandatorily at FVPL
Financial assets
designated at FVPL
Financial assets at
FVOCI
Total
in EUR million
2022
2021
2022
2021
2022
2021
2022
2021
2022
2021
2022
2021
Opening balance
822
882
1
1
1,862
1,191
2,480
796
1,063
1,231
6,228
4,101
Realised gain/loss\u00a0 recognised in the statement of profit or loss during the period 1
53
22
52
-57
32
122
-80
8
-12
178
-37
Revaluation recognised in other comprehensive income during the period 2
0
-84
22
-84
22
Purchase of assets
694
453
15
3
1,586
1,496
772
1,919
221
165
3,288
4,036
Sale of assets
-49
-48
-4
-3
-669
-612
-191
-141
-275
-234
-1,187
-1,037
Maturity/settlement
-511
-14
-2
-617
-163
-13
-59
-109
-1,188
-299
Reclassifications
0
-18
-5
10
-6
-8
-11
Transfers into Level 3
288
43
474
605
-1
322
-43
-1
1,646
42
Transfers out of Level 3
-442
-517
-115
-1
-856
-98
-1,414
-615
Exchange rate differences
18
0
14
20
-12
49
9
68
29
Changes in the composition of the group and other changes
0
-2
-2
Closing balance
873
822
421
1
1,849
1,862
3,492
2,480
891
1,063
7,526
6,228
i) Financial instruments not measured at fair value
The following table presents the estimated fair values of the financial instruments not measured at fair
value in the statement of financial position. The aggregation of the fair values presented below does not
represent, and should not be construed as representing, the underlying value of ING Bank.
Methods applied in determining fair values of financial assets and liabilities (carried at amortised cost)
Carrying Amount
Carrying amount
approximates fair value
Level 1
Level 2
Level 3
Total fair value
in EUR million
2022
2021
2022
2021
2022
2021
2022
2021
2022
2021
2022
2021
Financial Assets
Loans and advances to banks 1
35,103
23,591
2,858
1,674
1
29,459
17,033
2,786
4,926
35,103
23,634
Loans and advances to customers
635,557
627,550
19,101
16,943
15,264
18,465
575,805
600,253
610,170
635,661
Securities at amortised cost
48,160
48,319
39,787
40,314
3,160
7,327
1,406
681
44,353
48,323
718,820
699,459
21,959
18,617
39,788
40,316
47,883
42,825
579,996
605,860
689,626
707,618
Financial liabilities
Deposits from banks
56,632
85,092
3,696
4,298
48,524
75,847
3,954
5,890
56,174
86,035
Customer deposits
686,341
657,831
590,321
586,151
80,305
61,158
15,511
11,861
686,136
659,171
Debt securities in issue
58,075
57,443
20,308
15,320
20,501
27,718
17,577
14,756
58,385
57,794
Subordinated loans
15,789
16,719
15,548
17,203
15,548
17,203
816,838
817,085
594,016
590,449
20,308
15,321
164,878
181,926
37,041
32,507
816,243
820,203
1 The prior period has been updated to improve consistency and comparability of level 3 and 2.
The following methods and assumptions were used by ING Bank to estimate the fair value of the financial
instruments which are nor recorded and measured at fair value. These fair values were calculated for
disclosure purposes only. The carrying amount of financial instruments presented in the above table
includes the fair value hedge adjustment, this explains why the carrying amount approximates fair value.
Loans and advances to banks
For short term receivables from banks carrying amounts represent a reasonable estimate of the fair value.
The fair value of long term receivables from banks is estimated by discounting expected future cash flows
using a discount rate based on specific available market data, such as interest rates and appropriate
spreads that reflects current credit risk or quoted bonds.
Loans and advances to customers
For short term loans carrying amounts represent a reasonable estimate of the fair value. The fair value of
long term loans is estimated by discounting expected future cash flows using a discount rate that reflects
current credit risk, current interest rates, and other current market conditions where applicable. The fair
value of mortgage loans is estimated by taking into account prepayment behaviour. Loans with similar
characteristics are aggregated for calculation purposes.
Deposits from banks
For short term payables to banks carrying amounts represent a reasonable estimate of the fair value. The
fair value of long term payables to banks is estimated by discounting expected future cash flows using a
discount rate based on available market interest rates and appropriate spreads that reflects ING\u2019s own
credit risk.
Customer deposits
The carrying values of customer deposits with an immediate on demand features approximate their fair
values. The fair values of deposits with fixed contractual terms have been estimated based on discounting
future cash flows using the interest rates currently applicable to deposits of similar maturities.
Debt securities in issue
The fair value of debt securities in issue is generally based on quoted market prices, or if not available, on
estimated prices by discounting expected future cash flows using a current market interest rate and credit
spreads applicable to the yield, credit quality and maturity.
Subordinated loans
The fair value of publicly traded subordinated loans are based on quoted market prices when available.
Where no quoted market prices are available, fair value of the subordinated loans is estimated using
discounted cash flows based on interest rates and credit spreads that apply to similar instruments.
36\u00a0 Derivatives and hedge accounting
Use of derivatives
ING uses derivatives for economic hedging purposes to manage its asset and liability portfolios and
structural risk positions. The primary objective of ING\u2019s hedging activities is to manage the risks which arises
from structural imbalances in the duration and other profiles of its assets and liabilities. The objective of
economic hedging is to enter into positions with an opposite risk profile to an identified risk exposure to
reduce that exposure. The main risks which are being hedged are interest rate risk and foreign currency
exchange rate risk. These risks are primarily hedged with interest rate swaps, cross currency swaps and
foreign exchange forwards/swaps.
ING uses credit derivatives to manage its economic exposure to credit risk, including total return swaps and
credit default swaps, to sell or buy protection for credit risk exposures in the loan, investment, and trading
portfolios. Hedge accounting is not applied in relation to these credit derivatives.
Hedge accounting
Derivatives that qualify for hedge accounting under IFRS are classified and accounted for in accordance with
the nature of the instrument hedged and the type of IFRS hedge accounting model that is applicable. The
three models applicable under IFRS are: fair value hedge accounting, cash flow hedge accounting, and
hedge accounting of a net investment in a foreign operation. How and to what extent these models are
applied are described under the relevant headings below. The company\u2019s detailed accounting policies for
these three hedge models are set out in paragraph 1.7 \u2018Financial instruments\u2019 of Note 1 \u2018Basis of preparation
and significant accounting policies\u2019.
IBOR transition
Reference is made to the note Risk management/ IBOR Transition for information on how ING is managing
the transition to alternative benchmark rates and INGs progress in completing the transition.
At the reporting date, ING assessed the extent to which hedge relationships are subject to uncertainties
driven by IBOR reform.
The IBOR's in scope of ING\u2019s IBOR Transition program are a component of either the hedging instrument and/
or the hedged item where the interest rate and/or foreign currency risk are the designated hedged risk. The
hedged exposures are mainly loan portfolios, issued debt securities and purchased debt instruments.
ING early adopted the amendments to IAS 39 issued in September 2019 to these hedging relationships
directly affected by IBOR reform (Phase 1). This excludes EURIBOR hedges as EURIBOR is Benchmarks
Regulation compliant and continues to be available. Refer to section 1.7.4 of Note 1 \u2018Basis of preparation
and significant accounting policies\u2019 for more information on the Phase 1 amendments.
Phase 1 amendments to IFRS allow ING to apply a set of temporary exceptions to continue hedge
accounting even when there is uncertainty about contractual cash flows arising from IBOR reform. Phase 1
reliefs cease to apply when uncertainty arising from IBOR Reform is no longer present with respect to the
timing and amount of the IBOR-based cash flows of the relevant instruments.
In Poland the local working group (the 'National Working Group') for benchmark reform issued a roadmap to
replace the current Polish benchmark rate Warsaw Interbank Offered Rate (WIBOR) with a new rate named
Warsaw Interest Rate Overnight (WIRON). The National Working Group indicated that the plan is for the
market to be ready for a cessation of WIBOR by the start of 2025, consequently ING extended the
application of the phase 1 reliefs to those hedge accounting relationships that will be subject to WIBOR
reform.
Hedging relationships are being amended to incorporate the new benchmark rates. During 2022, ING
focussed on USD LIBOR contracts. In the coming year, ING will continue the focus on the remaining USD
LIBOR contracts as the used USD LIBOR tenors will cease to be published on 30 June 2023.
As of 31 December 2022, USD LIBOR and WIBOR indexed fair value and cash flow hedges are directly
affected by the uncertainties arising from the IBOR reform. In particular, uncertainties over the timing and
amount of the replacement rate may impact the effectiveness and highly probable assessment.
For these affected fair value and cash flow hedge relationships ING assumes that the USD LIBOR and WIBOR
based cash flows from the hedging instrument and hedged item will remain unaffected.
The same assumption is used to assess the likelihood of occurrence of the forecast transactions that are
subject to cash flow hedges. The hedged cash flows in cash flow hedges directly impacted by the IBOR
reform still meet the highly probable requirement, assuming the USD LIBOR and WIBOR benchmark on
which the hedged cash flows are based is not altered as a result of the reform.
The total gross notional amounts of hedging instruments as at 31 December that are used in the ING's
hedge accounting relationships for which the Phase 1 amendments to IAS39 were applied are:
Notional amounts of Hedging instruments in EUR mln as at 31 December
Benchmark
2022
2021
USD LIBOR
28,316
41,473
WIBOR1
57,774
1 WIBOR transition plans became concrete in 2022 and therefore no comparatives for 2021 are included.
Approximately 89% (31\u00a0December 2021: 72%) of the notional amounts for USD LIBOR have a maturity date
beyond 30 June 2023. Approximately 71% of the notional amounts for WIBOR have a maturity date beyond
1 January 2025.
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.
TLTRO
ING hedged the interest rate risk of the TLTRO-III funding with derivatives and designated this in a fair value
hedge relationship. In Q4 2022 the ECB changed the terms of the TLTRO-III, resulting in the discontinuation
of the hedging relationship. The fair value hedge adjustment was amortized to profit or loss over the revised
interest period (i.e. until the date the change in TLTRO-III terms became effective). The impact of this is
recorded in net interest income. Refer to Note 20 'Net interest income' for more details.
Fair value hedge accounting
ING\u2019s fair value hedges principally consist of interest rate swaps that are used to protect against changes in
the fair value of fixed-rate instruments due to movements in market interest rates. ING\u2019s approach to
manage market risk, including interest rate risk, is discussed in \u2018Risk management \u2013Market risk\u2019. ING\u2019s
exposure to interest rate risk is disclosed in paragraph \u2018Interest rate risk in banking book\u2019.
ING Bank designates specific non-contractual risk components of hedged items. This is usually determined
by designating benchmark interest rates such as EURIBOR, SOFR, SONIA or TONAR, between others.
By using derivative financial instruments to hedge exposures to changes in interest rates, ING also exposes
itself to credit risk of the derivative counterparty, which is not offset by the hedged item. ING minimises
counterparty credit risk in derivative instruments by clearing most of the derivatives through Central
Clearing Counterparties. In addition, ING only enters into transactions with high-quality counterparties and
requires posting collateral.
ING applies fair value hedge accounting on micro level in which one hedged item is hedged with one or
multiple hedging instruments as well as on macro level whereby a portfolio of items is hedged with multiple
hedging instruments. For these macro hedges of interest rate risk ING applies the EU carve-out. The EU
\u2018carve-out\u2019 for macro hedging enables a group of derivatives (or proportions) to be viewed in combination
and jointly designated as the hedging instrument and removes some of the limitations in fair value hedge
accounting relating to hedging core deposits and under-hedging strategies. In retail operations, exposure on
retail funding (savings and current accounts) and retail lending (mortgages) is initially offset. The remaining
exposure is hedged in a portfolio hedge, using the EU carve-out, in which a portion of the retail lending
portfolio and core deposits are designated as a hedged item for hedge accounting purposes.
For portfolio hedges the fair value is projected based on contractual terms and other variables including
prepayment expectations. These projected fair value of the portfolios form the basis for identifying the
notional amount subject to interest rate risk that is designated under fair value hedge accounting.
Micro fair value hedge accounting is mainly applied on issued debt securities and purchased debt
instruments for hedging interest rate risk.
Before fair value hedge accounting is applied, ING determines whether an economic relationship between
the hedged item and the hedging instrument exists based on an evaluation of the quantitative
characteristics of these items and the hedged risk that is supported by quantitative analysis. ING considers
whether the critical terms of the hedged item and hedging instrument closely align when assessing the
presence of an economic relationship. ING evaluates whether the fair value of the hedged item and the
hedging instrument respond similarly to similar risks. In addition, ING is mainly using regression analysis to
assess whether the hedging instrument is expected to be and has been highly effective in offsetting
changes in the fair value of the hedged item.
For the macro hedge on the loan portfolio ING follows a dynamic hedging strategy. This means that on
monthly basis, based on the new portfolio projection, the hedging relationship is renewed. From an
operational point of view, the existing hedging relationship is adjusted based on the new portfolio projection
and additional hedging instruments are added to the hedging relationship.
ING uses the following derivative financial instruments in a fair value hedge accounting relationship:
Gross carrying value of derivatives designated under fair value hedge accounting
in EUR million
Assets
2022
Liabilities
2022
Assets
2021
Liabilities
2021
As at 31 December
Hedging instrument on interest rate risk
\u2013 Interest rate swaps
40,346
32,482
6,629
5,940
\u2013 Other interest derivatives
395
39
87
83
Gains and losses on derivatives designated under fair value hedge accounting are recognised in the
statement of profit or loss. The effective portion of the fair value change on the hedged item is also
recognised in the statement of profit or loss in 'Valuation results and net trading income'. As a result, only
the net accounting ineffectiveness has an impact on the net result.
Hedged items included in a fair value hedging relationship
Carrying amount of the hedged items
Accumulated amount of fair value hedge
adjustment on the hedged item included in
the carrying amount of the hedged item
Change in fair value
used for measuring
ineffectiveness for the
period
Change in fair value
hedging instruments
Hedge ineffectiveness
recognised in the
statement of profit or
loss gain (+) / loss (-)
in EUR million
Assets
Liabilities
Assets
Liabilities
As at 31 December 2022
Interest rate risk
\u2013 Debt securities at fair value through other comprehensive income
19,816
n/a
-2,798
\u2013 Loans at FVOCI
35
n/a
-4
\u2013 Loans and advances to customers
58,673
-12,112
-11,466
\u2013 Debt instruments at amortised cost
4,098
-448
-678
\u2013 Debt securities in issue
26,040
-2,815
3,746
\u2013 Subordinated loans
15,767
-1,344
1,470
\u2013 Amounts due to banks
483
\u2013 Customer deposits and other funds on deposit
36,843
-3,373
4,099
\u2013 Discontinued hedges
2,966
34
Total
82,623
78,650
-9,594
-7,497
-5,150
5,265
115
As at 31 December 2021
Interest rate risk
\u2013 Debt securities at fair value through other comprehensive income
17,307
n/a
-798
\u2013 Loans at FVOCI
105
n/a
-2
\u2013 Loans and advances to customers
68,704
-923
-1,451
\u2013 Debt instruments at amortised cost
3,458
301
-165
\u2013 Debt securities in issue
22,553
945
962
\u2013 Subordinated loans
16,559
115
414
\u2013 Amounts due to banks
\u2013 Customer deposits and other funds on deposit
40,924
385
1,152
\u2013 Discontinued hedges
3,774
73
Total
89,574
80,037
3,153
1,518
112
-86
26
During 2022, the interest rate movements significantly affected the fair value changes of both the
derivatives and the hedged items designated in fair value hedges. Refer to note 22 \u2018Valuation results and
net trading income'.
In addition, the decrease in customer deposits is due to the discontinuation of the customer deposits
portfolio fair value hedge in Belgium. This hedge was discontinued and the related fair value adjustment
released due to changes in expected repricing of client rates as a result of the steep increase in interest
rates occurred in 2022. Discontinued hedges further mainly relate to the transfer of derivatives from UK
based clearing houses to EU based clearing houses related to Brexit in 2020.
The main sources of ineffectiveness are:
\u2022differences in maturities of the hedged item(s) and hedging instrument(s);
\u2022different interest rate curves applied to discount the hedged item(s) and hedging instrument(s);
\u2022differences in timing of cash flows of the hedged item(s) and hedging instrument(s).
Additionally, for portfolio (macro) fair value hedges of ING\u2019s fixed rate mortgage portfolio, ineffectiveness
also arises from the disparity between expected and actual prepayments (prepayment risk).
There were no other sources of significant ineffectiveness in these hedging relationships.
Cash flow hedge accounting
ING applies cash flow hedge accounting on micro and macro level. ING\u2019s cash flow hedges mainly consist of
interest rate swaps and cross-currency swaps that are used to protect against the exposure to variability in
future cash flows on non-trading assets and liabilities that bear interest at variable rates or are expected to
be refunded or reinvested in the future. The amounts and timing of future cash flows, representing both
principal and interest flows, are projected for each portfolio of financial assets and liabilities, based on
contractual terms and other variables including estimates of prepayments. These projected cash flows form
the basis for identifying the notional amount subject to interest rate risk or foreign currency exchange rate
risk that is designated under cash flow hedge accounting.
ING\u2019s approach to manage market risk, including interest rate risk and foreign currency exchange rate risk, is
discussed in \u2018Risk management \u2013 Credit risk and Market risk\u2019. ING determines the amount of the exposures
to which it applies hedge accounting by assessing the potential impact of changes in interest rates and
foreign currency exchange rates on the future cash flows from its floating-rate assets and liabilities. This
assessment is performed using analytical techniques.
As noted above for fair value hedges, by using derivative financial instruments to hedge exposures to
changes in interest rates and foreign currency exchange rates, ING exposes itself to credit risk of the
derivative counterparty, which is not offset by the hedged items. This exposure is managed similarly to that
for fair value hedges.
Gains and losses on the effective portions of derivatives designated under cash flow hedge accounting are
recognised in Other Comprehensive Income. Interest cash flows on these derivatives are recognised in the
statement of profit or loss in \u2018Net interest income\u2019 consistent with the manner in which the forecasted cash
flows affect net result. The gains and losses on ineffective portions of such derivatives are recognised
immediately in the statement of profit or loss in \u2018Valuation results and net trading income\u2019.
ING determines an economic relationship between the cash flows of the hedged item and the hedging
instrument based on an evaluation of the quantitative characteristics of these items and the hedged risk
that is supported by quantitative analysis. ING considers whether the critical terms of the hedged item and
hedging instrument closely align when assessing the presence of an economic relationship. ING evaluates
whether the cash flows of the hedged item and the hedging instrument respond similarly to the hedged
risk, such as the benchmark interest rate of foreign currency. In addition, a regression analysis is performed
to assess whether the hedging instrument is expected to be and has been highly effective in offsetting
changes in the fair value of the hedged item.
ING uses the following derivative financial instruments in a cash flow hedge accounting relationship:
Gross carrying value of derivatives used for cash flow hedge accounting
Assets
Liabilities
Assets
Liabilities
in EUR million
2022
2022
2021
2021
As at 31\u00a0December
Hedging instrument on interest rate risk
\u2013 Interest rate swaps
10,038
14,836
-437
781
Hedging instrument on combined interest and FX rate risk
\u2013 Cross currency interest rate derivatives
428
168
73
285
The derivatives used for cash flow hedge accounting are included in the statement of financial position line-
item \u2018Financial assets at fair value through profit or loss \u2013 Non-trading derivatives\u2019 EUR 814 million (2021:
EUR 300 million) respectively \u2018Financial liabilities at fair value through profit or loss \u2013 Non-trading derivatives\u2019
EUR 1,275 million (2021: EUR 485 million). The difference between the gross carrying value as presented in
the table and the net carrying value as presented in the statement of financial position is due to offsetting
with other derivatives and collaterals paid or received.
For the main currencies the average fixed rate for interest rate swaps used in cash flow hedge accounting
are 0.51% (2021: -0.16%) for EUR, 3.27% (2021: 1.73%) for PLN, 1.96% (2021: 2.09%) for USD and 1.28%
(2021: 0.55%) for AUD. The average currency exchange rates for cross currency swaps used in cash flow
hedge accounting is for EUR/USD 0.99 (2021: 1.01) and for EUR/AUD 1.58 (2021: 1.61).
The following table shows the net notional amount of derivatives designated in cash flow hedging split into
the maturity of the instruments. The net notional amounts presented in the table are a combination of
payer (+) and receiver (-) swaps.
Maturity derivatives designated in cash flow hedging
in EUR million
As at 31
December 2022
Less
than 1
month
1 to 3
months
3 to 12
months
1 to 2
year
2 to 3
years
3 to\u00a0 4
years
4 to 5
years
>5 years
Total
Hedging
instrument on
interest rate risk
\u2013 Interest rate
swaps
-562
-935
-6,730
-12,464
-8,926
-8,115
-3,620
-8,947
-50,300
Hedging
instrument on
combined interest
and FX rate risk
\u2013 Cross currency
interest rate
derivatives
-834
-1,535
-721
-2,140
-52
7
-48
-5,323
As at 31
December 2021
Hedging
instrument on
interest rate risk
\u2013 Interest rate
swaps
418
-1,075
-6,939
-5,470
-6,711
-5,825
-5,272
-18,107
-48,982
Hedging
instrument on
combined interest
and FX rate risk
\u2013 Cross currency
interest rate
derivatives
-256
-1,048
-1,760
-3,831
-2,528
-2,580
181
-56
-11,878
1 The carrying amount is the gross amount, excluding tax adjustments.
The decrease in the carrying amount of the cash flow hedge reserve is driven by increased interest rates.
The main sources of ineffectiveness for cash flow hedges are:
\u2022differences in timing of cash flows of the hedged item(s) and hedging instrument(s);
\u2022mismatches in reset frequency between hedged item and hedging instrument.
Hedges of net investments in foreign operations
A foreign currency exposure arises from a net investment in subsidiaries that have a different functional
currency from the presentation currency of ING. The risk arises from the fluctuation in spot exchange rates
between the functional currency of the subsidiaries and ING\u2019s presentation currency, which causes the
amount of the net investment to vary in the consolidated financial statements of ING. This risk may have a
significant impact on ING\u2019s financial statements. ING\u2019s policy is to hedge these exposures only when not
doing so it is expected to have a significant impact on the regulatory capital ratios of ING and its
subsidiaries.
ING\u2019s net investment hedges principally consist of derivatives (including currency forwards and swaps) and
non-derivative financial instruments such as foreign currency denominated funding. When the hedging
instrument is foreign currency denominated debt, ING assesses effectiveness by comparing past changes in
the carrying amount of the debt that are attributable to a change in the spot rate with past changes in the
investment in the foreign operation due to movement in the spot rate (the offset method).
Gains and losses on the effective portions of derivatives designated under net investment hedge accounting
are recognised in Other Comprehensive Income. The balance in equity is recognised in the statement of
profit or loss when the related foreign subsidiary is disposed. The gains and losses on ineffective portions are
recognised immediately in the statement of profit or loss in 'Valuation results and net trading income'.
ING has the following derivative financial instruments used for net investment hedging:
Gross carrying value of derivatives used for net investment hedging
Assets
Liabilities
Assets
Liabilities
in EUR million
2022
2022
2021
2021
As at 31 December
\u2013 FX forwards and Cross currency swaps
119
83
18
88
The derivatives used for net investment hedge accounting are included in the statement of financial position
line-item \u2018Financial assets at fair value through profit or loss \u2013 Non-trading derivatives\u2019 EUR 119 million
(2021: EUR 18 million) respectively \u2018Financial liabilities at fair value through profit or loss \u2013 Non trading
derivatives\u2019 EUR 83 million (2021: EUR 88 million).
For ING\u2019s main currencies the average exchange rates used in net investment hedge accounting for 2022
are EUR/USD 1.06 (2021: 1.18), EUR/PLN 4.68 (2021: 4.58), EUR/AUD 1.52 (2021: 1.58) and EUR/THB 36.87
(2021: 37.84).
The following table shows the notional amount of derivatives designated in net investment hedging split
into the maturity of the instruments:
Maturity derivatives designated in net investment hedging
in EUR million
As at 31
December 2022
Less than
1 month
1 to 3
months
3 to 12
months
1 to 2
year
2 to 3
years
3 to\u00a0 4
years
4 to 5
years
>5 years
Total
\u2013 FX forwards and
cross currency
swaps
-6,164
-2,638
-97
-8,899
As at 31
December 2021
\u2013 FX forwards and
Cross currency
swaps
-4,462
-461
-590
-5,514
The effect of the net investment hedge accounting in the statement of profit or loss and other
comprehensive income is as follows:
Net investment hedge accounting \u2013 Impact on statement of profit or loss and other comprehensive income
in EUR million
As at 31 December 2022
Change in
value used for
calculating
hedge
ineffectiveness
for the period
Carrying
amount net
investment
hedge reserve
at the end of
the reporting
period1
Hedged item
affected
statement of
profit or loss
Change in
value of
hedging
instrument
recognised in
OCI
Hedge
ineffectiveness
recognised in
the statement
of profit or loss,
gain(+) /
Loss(-)
Investment in foreign operations
0
-33
0
0
Discontinued hedges
304
-1
As at 31 December 2021
Investment in foreign operations
72
330
-72
-1
Discontinued hedges
-59
1 The carrying amount is the gross amount, excluding tax adjustments.
37\u00a0 Assets by contractual maturity
Amounts presented in these tables by contractual maturity are the amounts as presented in the statement
of financial position and are discounted cash flows. Reference is made to \u2018Risk Management \u2013 Funding and
liquidity risk\u2019.
Assets by contractual maturity
2022
Less than 1 month 1
1-3 months
3-12 months
1-5 years
Over 5 years
Maturity not applicable
Total
Cash and balances with central banks
87,614
87,614
Loans and advances to banks
28,733
1,633
2,331
2,190
216
35,103
Financial assets at fair value through profit or loss
\u2013\u00a0 Trading assets
15,520
5,399
9,991
13,062
12,904
56,875
\u2013\u00a0 Non-trading derivatives
623
95
592
1,555
1,027
3,893
\u2013\u00a0 Mandatorily at fair value through profit or loss
29,153
10,504
3,753
2,329
901
203
46,844
\u2013\u00a0 Designated as at fair value through profit or loss
287
158
185
2,497
3,031
6,159
Financial assets at fair value through other comprehensive income
\u2013\u00a0 Equity securities
1,887
1,887
\u2013\u00a0 Debt securities
167
420
2,458
12,587
13,463
29,095
\u2013\u00a0 Loans and advances
3
1
7
226
407
643
Securities at amortised cost
1,810
1,719
4,566
24,689
15,376
48,160
Loans and advances to customers
54,482
23,554
54,056
197,275
306,190
635,557
Other assets 2
7,151
272
1,154
1,436
1,418
4,600
16,031
Total assets
225,545
43,754
79,093
257,846
354,933
6,690
967,861
2021
Cash and balances with central banks
106,520
106,520
Loans and advances to banks
15,162
2,204
3,921
1,937
367
23,591
Financial assets at fair value through profit or loss
\u2013\u00a0 Trading assets
21,055
3,859
8,735
7,922
9,818
51,389
\u2013\u00a0 Non-trading derivatives
240
171
217
421
488
1,536
\u2013\u00a0 Mandatorily at fair value through profit or loss
20,462
12,063
7,487
1,741
770
161
42,684
\u2013\u00a0 Designated as at fair value through profit or loss
96
120
520
2,510
3,109
6,355
Financial assets at fair value through other comprehensive income
\u2013\u00a0 Equity securities
2,457
2,457
\u2013\u00a0 Debt securities
593
518
1,926
11,182
13,121
27,340
\u2013\u00a0 Loans and advances
14
11
173
214
427
838
Securities at amortised cost
1,108
1,217
4,509
24,413
17,072
48,319
Loans and advances to customers
52,311
26,414
53,616
188,222
306,988
627,550
Other assets2
3,823
362
1,505
841
1,482
4,725
12,738
Total assets
221,382
46,940
82,608
239,401
353,642
7,343
951,317
1 Includes assets on demand.
2 Includes other financial assets such as current and deferred tax assets as presented in the consolidated statement of the financial position. Additionally, non-financial assets are included in that position where maturities are not applicable as property and equipment and
investments in associates and joint ventures. Due to their nature non-financial assets consist mainly of assets expected to be recovered after more than 12 months.
38\u00a0 Liabilities and off-balance sheet commitments by maturity
The tables below include all liabilities and off-balance sheet commitments by maturity based on
contractual, undiscounted cash flows. These balances are included in the maturity analysis as follows:
\u2022Perpetual liabilities are included in the column \u2018Maturity not applicable\u2019.
\u2022Derivative liabilities are included on a net basis if cash flows are settled net. For other derivative liabilities
the contractual gross cash flow payable is included.
\u2022Undiscounted future coupon interest on financial liabilities payable is included in a separate line and in
the relevant maturity bucket.
\u2022Non-financial liabilities are included based on a breakdown of the amounts per statement of financial
position, per expected maturity.
\u2022Loans and other credit-related commitments are classified on the basis of the earliest date they can be
drawn down.
ING Bank\u2019s expected cash flows on some financial liabilities vary significantly from contractual cash flows.
Principal differences are in demand deposits from customers that are expected to remain stable or increase
and in unrecognised loan commitments that are not all expected to be drawn down immediately. Reference
is made to the liquidity risk paragraph in \u2018Risk Management \u2013 Funding and liquidity risk\u2019 for a description on
how liquidity risk is managed.
Liabilities and off-balance sheet commitments by maturity
in EUR million
2022
Less than 1 month 1
1\u20133 months
3\u201312 months
1\u20135 years
Over 5 years
Maturity not applicable
Adjustment\u00a0 2
Total
Deposits from banks
10,053\u00a0
2,238\u00a0
33,268\u00a0
9,878\u00a0
1,794\u00a0
\u00a0
-598\u00a0
56,632\u00a0
Customer deposits
605,706\u00a0
16,294\u00a0
22,637\u00a0
24,641\u00a0
20,304\u00a0
\u00a0
-3,240\u00a0
686,341\u00a0
Financial liabilities at fair value through profit or loss
\u2013\u00a0 Other trading liabilities
5,778\u00a0
875\u00a0
304\u00a0
771\u00a0
575\u00a0
\u00a0
-83\u00a0
8,219\u00a0
\u2013\u00a0 Trading derivatives
2,100\u00a0
2,319\u00a0
4,942\u00a0
9,330\u00a0
3,609\u00a0
\u00a0
8,570\u00a0
30,869\u00a0
\u2013\u00a0 Non-trading derivatives
345\u00a0
288\u00a0
216\u00a0
1,204\u00a0
470\u00a0
\u00a0
525\u00a0
3,048\u00a0
\u2013\u00a0 Designated at fair value through profit or loss
31,505\u00a0
11,472\u00a0
1,626\u00a0
3,177\u00a0
3,699\u00a0
21\u00a0
-618\u00a0
50,883\u00a0
Debt securities in issue
2,049\u00a0
11,227\u00a0
18,626\u00a0
12,857\u00a0
15,905\u00a0
\u00a0
-2,587\u00a0
58,075\u00a0
Subordinated loans
\u00a0
\u00a0
760\u00a0
\u00a0
9,936\u00a0
6,307\u00a0
-1,214\u00a0
15,789\u00a0
Lease liabilities
19\u00a0
43\u00a0
170\u00a0
593\u00a0
377\u00a0
\u00a0
-28\u00a0
1,174\u00a0
Financial liabilities
657,554\u00a0
44,755\u00a0
82,548\u00a0
62,450\u00a0
56,668\u00a0
6,328\u00a0
727\u00a0
911,030\u00a0
Other liabilities 3
9,659\u00a0
683\u00a0
2,395\u00a0
638\u00a0
406\u00a0
\u00a0
\u00a0
13,781\u00a0
Total liabilities
667,213\u00a0
45,438\u00a0
84,943\u00a0
63,089\u00a0
57,074\u00a0
6,328\u00a0
727\u00a0
924,811\u00a0
Coupon interest due on financial liabilities
426\u00a0
719\u00a0
3,171\u00a0
6,408\u00a0
3,166\u00a0
348\u00a0
\u00a0
14,237\u00a0
Contingent liabilities in respect of
\u2013\u00a0 Discounted bills
\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
\u2013\u00a0 Guarantees
28,304\u00a0
\u00a0
\u00a0
4\u00a0
550\u00a0
\u00a0
\u00a0
28,859\u00a0
\u2013\u00a0 Irrevocable letters of credit
15,660\u00a0
19\u00a0
3\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
15,682\u00a0
\u2013\u00a0 other
\u00a0
\u00a0
\u00a0
\u00a0
3\u00a0
\u00a0
\u00a0
3\u00a0
Irrevocable facilities
161,147\u00a0
\u00a0
194\u00a0
434\u00a0
166\u00a0
\u00a0
\u00a0
161,940\u00a0
205111.478
18.786
197.475
438.013
718.593
0\u00a0
0\u00a0
206,484\u00a0
1 Includes liabilities on demand.
2 This column reconciles the contractual undiscounted cash flows on financial liabilities to the statement of financial position values. The adjustments mainly relate to the impact of discounting and fair value hedge adjustments, and for derivatives, to the fact that the contractual
cash flows are presented on a gross basis (unless the cash flows are actually settled net).
3 Includes Other liabilities, Current and deferred tax liabilities, and Provisions as presented in the Consolidated statement of financial position.
Liabilities and off-balance sheet commitments by maturity
in EUR million
2021
Less than 1 month 1
1\u20133 month
3\u201312 months
1\u20135 years
Over 5 years
Maturity not applicable
Adjustment 2
Total
Deposits from banks
10,477
1,062
1,387
71,413
1,719
-967
85,092
Customer deposits
597,906
14,989
6,849
17,814
19,718
557
657,831
Financial liabilities at fair value through profit or loss
\u2013\u00a0 Other trading liabilities
6,965
397
322
462
438
4
8,588
\u2013\u00a0 Trading derivatives
1,689
1,608
3,674
8,295
5,731
-2,472
18,525
\u2013\u00a0 Non-trading derivatives
546
245
422
900
571
-564
2,120
\u2013\u00a0 Designated at fair value through profit or loss
24,862
10,224
771
1,850
3,719
20
362
41,808
Debt securities in issue
2,766
15,826
15,459
9,667
12,581
1,145
57,443
Subordinated loans
716
8,948
6,822
233
16,719
Lease liabilities
18
40
159
571
454
-23
1,220
Financial liabilities
645,229
44,391
29,042
111,688
53,880
6,843
-1,725
889,346
Other liabilities 3
8,810
487
2,500
591
934
13,321
Total liabilities
654,039
44,877
31,541
112,279
54,813
6,843
-1,725
902,668
Coupon interest due on financial liabilities
195
407
1,010
2,602
2,727
387
7,328
Contingent liabilities in respect of
\u2013\u00a0 Discounted bills
\u2013\u00a0 Guarantees
25,911
550
26,461
\u2013\u00a0 Irrevocable letters of credit
16,851
16,851
\u2013\u00a0 other
1
2
5
8
Irrevocable facilities4
143,891
1
13
184
78
144,167
186,653
1
15
189
628
0
0
187,486
1 Includes liabilities on demand.
2 This column reconciles the contractual undiscounted cash flows on financial liabilities to the statement of financial position values. The adjustments mainly relate to the impact of discounting and fair value hedge adjustments, and for derivatives, to the fact that the contractual
cash flows are presented on a gross basis (unless the cash flows are actually settled net).
3 Includes Other liabilities, Current and deferred tax liabilities, and Provisions as presented in the Consolidated statement of financial position.
39\u00a0 Transfer of financial assets, assets pledged and received as collateral
Financial assets pledged as collateral
The financial assets pledged as collateral consist primarily of Loans and advances to customers pledged to
secure Debt securities in issue, deposits from the Dutch Central Bank and other banks, as well as debt
securities used in securities lending or sale and repurchase transactions. They serve to secure margin
accounts and are used for other purposes required by law. Pledges are generally conducted under terms
that are usual and customary for collateralised transactions including standard sale and repurchase
agreements, securities lending and borrowing and derivatives margining. The financial assets pledged are as
follows:
Financial assets pledged as collateral
in EUR million
2022
2021
Banks
\u2013\u00a0 Cash and balances with central banks
364
465
\u2013\u00a0 Loans and advances to banks
4,007
3,310
Financial assets at fair value through profit or loss
17,079
15,334
Financial assets at fair value through OCI
2,142
2,320
Securities at amortised cost
3,578
4,468
Loans and advances to customers
98,917
118,868
Other assets
596
796
126,682
145,560
Transfer of financial assets
The majority of ING's financial assets that have been transferred, but do not qualify for derecognition are
debt instruments used in securities lending or sale and repurchase transactions.
Transfer of financial assets not qualifying for derecognition
Securities lending
Sale and repurchase
Equity
Debt
Equity
Debt
in EUR million
2022
2021
2022
2021
2022
2021
2022
2021
Transferred assets at carrying amount
Financial assets at fair value through profit or
loss
2,087
3,109
6,357
4,384
7,178
5,863
Financial assets at fair value through other
comprehensive income
499
453
527
Loans and advances to customers
4,637
4,386
Securities at amortised cost
435
261
992
Associated liabilities at carrying amount1
Financial liabilities at fair value through profit
or loss
n/a
n/a
n/a
n/a
6,245
4,130
8,932
7,538
1The table includes the associated liabilities which are reported after offsetting, compared to the gross positions of the encumbered
assets.
2The prior period on Financial assets at fair value through other comprehensive income and Securities at amortised cost has been
updated to improve consistency and comparability
The table above does not include assets transferred to consolidated securitisation entities as the related
assets remain recognised in the consolidated statement of financial position. Transferred financial assets
that are derecognised in their entirety are mentioned in Note 45 'Structured entities'
40\u00a0 Offsetting financial assets and liabilities
The following tables include information about rights to offset and the related arrangements. The amounts
included consist of all recognised financial instruments that are presented net in the statement of financial
position under the IFRS netting criteria (legal right to offset and intention to settle net or to realise the asset
and settle the liability simultaneously) and amounts presented gross in the statement of financial position
but subject to enforceable master netting arrangements or similar arrangements.
At ING Bank amounts that are offset mainly relate to derivatives transactions, sale and repurchase
agreements, securities lending agreements and cash pooling arrangements. A significant portion of
offsetting is applied to OTC derivatives which are cleared through central clearing parties.
Related amounts not set off in the statement of financial position include transactions where:
\u2022The counterparty has an offsetting exposure and a master netting or similar arrangement is in place with
a right to set off only in the event of default, insolvency or bankruptcy, or the offsetting criteria are
otherwise not satisfied, and
\u2022In the case of derivatives and securities lending or sale and repurchase agreements, cash and non-cash
collateral has been received or pledged to cover net exposure in the event of a default or other
predetermined events. The effect of over-collateralisation is excluded.
The net amounts resulting after set off are not intended to represent ING\u2019s actual exposure to counterparty
risk, as risk management employs a number of credit risk mitigation strategies in addition to netting and
collateral arrangements. Reference is made in the Risk Management Credit risk\u2019 section \u2018Credit risk
mitigation'.
Financial assets subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million
2022
Gross amounts of
recognised financial
assets
Gross amounts of
recognised financial
liabilities offset in
the statement of
financial position
Net amounts of
financial assets
presented in the
statement of
financial position
Related amounts not offset\u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0
in the statement of financial position
Net amount
Amounts not
subject to
enforceable
netting
arrangements
Statement of
financial position
total \u00b9
Financial
instruments
Cash and financial
instruments
received as
collateral
Statement of financial position line item
Financial instrument
Loans and advances to banks 2
Reverse repurchase, securities\u00a0
borrowing and similar agreements
2,576
2,576
2,549
27
16,820
19,395
Other
1
1
1
-1
2,576
2,576
1
2,549
27
16,819
19,395
Financial assets at fair value through profit or
loss
Trading and Non-trading
Reverse repurchase, securities
borrowing and similar agreements
51,870
-21,245
30,625
102
29,813
710
22,260
52,886
Derivatives
134,253
-106,523
27,730
18,190
4,525
5,015
7,004
34,734
186,123
-127,768
58,355
18,292
34,337
5,726
29,264
87,619
Loans and advances to customers 3
Reverse repurchase, securities
borrowing and similar agreements
155
155
155
1,151
1,306
Cash pools
224,261
-222,857
1,404
74
889
441
1,404
224,416
-222,857
1,559
74
1,044
441
1,151
2,710
Other items where offsetting is applied in the
statement of financial position 4
6,750
-5,899
851
74
777
851
Total financial assets
419,865
-356,524
63,341
18,440
37,930
6,971
47,234
110,576
1\u2018The statement of financial position total\u2019 is the sum of \u2018Net amounts of financial assets presented in the statement of financial position\u2019 and \u2019Amounts not subject to enforceable master netting arrangements\u2019.
2At 31 December 2021, the total amount of \u2018Loans and advances to banks\u2019 excluding repurchase agreements is EUR 20,188 million which is not subject to offsetting.
3At 31 December 2021, the total amount of \u2018Loans and advances to customers\u2019 excluding repurchase agreements is EUR 627,063 million of which the net cash pool position of EUR 1,806 million is subject to offsetting.
4Other items mainly include amounts to be settled with Central Clearing Counterparties regarding securities and derivatives transactions and is included in \u2018Other Assets \u2013 Amounts to be settled\u2019 for EUR 2,424 million in the statement of financial position of which EUR 222 million
is subject to offsetting as at 31 December 2021.
Financial liabilities subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million
2022
Related amounts not offset in the
statement of financial position
Amounts not
subject to
enforceable
netting
arrangements
Statement of
financial
position total \u00b9
Gross amounts of
recognised financial
liabilities
Gross amounts of
recognised financial
assets offset in the
statement of
financial position
Net amounts of
financial liabilities
presented in the
statement of
financial position
Financial
instruments
Cash and financial
instruments
pledged as
collateral
Net amount
Statement of financial position line item
Financial instrument
Deposits from banks 2
Repurchase, securities lending
and similar agreements
3,809
3,809
Other
3,809
3,809
Customer deposits 3
Repurchase, securities lending
and similar agreements
Cash pools
236,219
-222,857
13,362
52
13,310
13,362
236,219
-222,857
13,362
52
13,310
13,362
Financial liabilities at fair value through profit or
loss
Trading and Non-trading
Repurchase, securities lending
and similar agreements
57,871
-21,245
36,626
102
31,868
4,655
12,220
48,846
Derivatives
127,937
-103,988
23,949
18,215
4,964
770
9,967
33,917
185,808
-125,233
60,575
18,317
36,833
5,425
22,187
82,762
Other items where offsetting is applied in the
statement of financial position 4
8,535
-8,435
100
70
30
100
Total financial liabilities
430,561
-356,524
74,037
18,440
36,833
18,765
25,996
100,033
1\u2018The statement of financial position total\u2019 is the sum of \u2018Net amounts of financial liabilities presented in the statement of financial position\u2019 and \u2019Amounts not subject to enforceable master netting arrangements\u2019.
2At 31 December 2021, the total amount of \u2018Deposits from banks\u2019 excluding repurchase agreements is EUR 80,954 million of which EUR 2 million is subject to offsetting.
3At 31 December 2021, the total amount of \u2018Customers deposits\u2019 excluding repurchase agreements is EUR 657,831 million of which the net cash pool position of EUR 13,408 million is subject to offsetting.
4Other items mainly include amounts to be settled with Central Clearing Counterparties regarding securities and derivatives transactions and is included in \u2018Other Liabilities \u2013 Amounts to be settled\u2019 for EUR 5,082 million in the statement of financial position of which EUR 250
million is subject to offsetting as at 31 December 2021.
41\u00a0 Contingent liabilities and commitments
In the normal course of business, ING Bank is party to activities where risks are not reflected in whole or in
part in the consolidated financial statements. In response to the needs of its customers, the Group offers
financial products related to loans. These products include traditional off-balance sheet credit-related
financial instruments.
Contingent liabilities and commitments
in EUR million
2022
2021
Contingent liabilities in respect of
\u2013\u00a0 Guarantees
28,859
26,461
\u2013\u00a0 Irrevocable letters of credit
15,682
16,851
\u2013\u00a0 Other
3
8
44,544
43,319
Irrevocable facilities
161,940
144,167
206,484
187,486
Guarantees relate both to credit and non-credit substitute guarantees. Credit substitute guarantees are
guarantees given by ING Bank in respect of credit granted to customers by a third party. Many of them are
expected to expire without being drawn on and therefore do not necessarily represent future cash outflows.
Irrevocable letters of credit mainly secure payments to third parties for a customer\u2019s foreign and domestic
trade transactions in order to finance a shipment of goods. ING Bank\u2019s credit risk in these transactions is
limited since these transactions are collateralized by the commodity shipped and are of a short duration.
Other contingent liabilities include acceptances of bills and are of a short-term nature. Other contingent
liabilities also include contingent liabilities resulting from the operations of the Real Estate business including
obligations under development and construction contracts.
Irrevocable facilities mainly constitute unused portions of irrevocable credit facilities granted to corporate
clients. Many of these facilities are for a fixed duration and bear interest at a floating rate. ING Bank\u2019s credit
risk and interest rate risk in these transactions is limited. The unused portion of irrevocable credit facilities is
partly secured by customers\u2019 assets or counter-guarantees by the central governments and other public
sector entities under the regulatory requirements. Irrevocable facilities also include commitments made to
purchase securities to be issued by governments and private issuers.
In addition to the items included in contingent liabilities, ING Bank has issued certain guarantees as
participant in collective arrangements of national banking funds and as a participant in required collective
guarantee schemes which apply in different countries.
ING Bank N.V. provided a guarantee to the German Deposit Guarantee Fund (\u2018Einlagensicherungsfonds\u2019 or
ESF) under section 5 (10) of the by-laws of this fund, where ING Bank N.V. indemnifies the Association of
German Banks Berlin against any losses it might incur as result of actions taken with respect to ING
Germany. The ESF is a voluntary collective guarantee scheme for retail savings and deposits in excess of EUR
100,000.
Furthermore we refer to Note 42 'Legal proceedings' for any contingent liabilities in respect of legal
proceedings.
42\u00a0 Legal proceedings
ING Bank and its consolidated subsidiaries are involved in governmental, regulatory, arbitration and legal
proceedings and investigations in the Netherlands and in a number of foreign jurisdictions, including the
U.S., involving claims by and against them which arise in the ordinary course of their businesses, including in
connection with their activities as lenders, broker-dealers, underwriters, issuers of securities and investors
and their position as employers and taxpayers. In certain of such proceedings, very large or indeterminate
amounts are sought, including punitive and other damages. While it is not feasible to predict or determine
the ultimate outcome of all pending or threatened governmental, regulatory, arbitration and legal
proceedings and investigations, ING is of the opinion that some of the proceedings and investigations set
out below may have or have in the recent past had a significant effect on the financial position, profitability
or reputation of the ING and/or the ING and its consolidated subsidiaries.
Settlement agreement: On 4 September 2018, ING announced that it had entered into a settlement
agreement with the Dutch Public Prosecution Service relating to previously disclosed investigations
regarding various requirements for client on-boarding and the prevention of money laundering and corrupt
practices. Following the entry into the settlement agreement, ING has experienced heightened scrutiny
from authorities in various countries. ING is also aware, including as a result of media reports, that other
parties may, among other things, seek to commence legal proceedings against ING in connection with the
subject matter of the settlement. Certain parties filed requests with the Court of Appeal in The Netherlands
to reconsider the prosecutor\u2019s decision to enter into the settlement agreement with ING and not to
prosecute ING or (former) ING employees. In December 2020, the Court of Appeal issued its final ruling. In
this ruling the prosecutors' decision to enter into the settlement agreement with ING was upheld, making
the settlement final. However, in a separate ruling, the Court ordered the prosecution of ING\u2019s former CEO.
Findings regarding AML processes: As previously disclosed, after its September 2018 settlement with Dutch
authorities concerning anti-money laundering matters, and in the context of significantly increased
attention on the prevention of financial economic crime, ING has experienced heightened scrutiny by
authorities in various countries. The interactions with such regulatory and judicial authorities have included,
and can be expected to continue to include, onsite visits, information requests, investigations and other
enquiries. Such interactions, as well as ING\u2019s internal assessments in connection with its global
enhancement programme, have in some cases resulted in satisfactory outcomes, and also have resulted in,
and may continue to result in, findings, or other conclusions which may require appropriate remedial
actions by ING, or may have other consequences. ING intends to continue to work in close cooperation with
authorities as it seeks to improve its management of non-financial risks in terms of policies, tooling,
monitoring, governance, knowledge and behaviour.
In January 2022, a Luxembourg investigating judge informed ING Luxembourg that he intends to instruct
the relevant prosecutor to prepare a criminal indictment regarding alleged shortcomings in AML process at
ING Luxembourg. Although this matter remains at an early procedural stage and it is currently not possible
to determine how this matter will be resolved or the timing of any such resolution, ING does not expect a
financial outcome of this matter to have a material effect.
Payvision is the subject of a criminal investigation by Dutch authorities regarding money laundering and
various requirements of the Dutch act on Anti-Money Laundering and Counter Terrorist Financing, focusing
on the period from 1 January 2015 up to and including April 2020. Payvision is cooperating with such
ongoing investigation. It is currently not feasible to determine how the ongoing investigation may be
resolved or the timing of any such resolution, nor to estimate reliably the possible timing, scope or amounts
of any resulting fines, penalties and/or other outcome.
ING continues to take steps to enhance its management of compliance risks and embed stronger awareness
across the whole organisation. These steps are part of the global KYC programme and set of initiatives,
which includes enhancing KYC files and working on various structural improvements in compliance policies,
tooling, monitoring, governance, knowledge and behaviour.
Tax cases: 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 the Issuer believes that it has
adequately provided for all its tax positions, the ultimate resolution of these audits, investigations and
procedures is uncertain and may result in liabilities which are materially different from the amounts
recognised.
SIBOR \u2013 SOR litigation: In July 2016, investors in derivatives tied to the Singapore Interbank Offer Rate
(\u201cSIBOR\u201d) filed a U.S. class action complaint in the New York District Court alleging that several banks,
including ING, conspired to rig the prices of derivatives tied to SIBOR and the Singapore Swap Offer Rate
(\u201cSOR\u201d). The lawsuit refers to investigations by the Monetary Authority of Singapore (\u201cMAS\u201d) and other
regulators, including the U.S. Commodity Futures Trading Commission (\u201cCFTC\u201d), in relation to rigging prices
of SIBOR- and SOR based derivatives. In October 2018, the New York District Court issued a decision
dismissing all claims against ING Group and ING Capital Markets LLC, but leaving ING Bank, together with
several other banks, in the case, and directing plaintiffs to file an amended complaint consistent with the
Court's rulings. In October 2018, plaintiffs filed such amended complaint, which asserts claims against a
number of defendants but none against ING Bank (or any other ING entity), effectively dismissing ING Bank
from the case. In December 2018, plaintiffs sought permission from the Court to file a further amended
complaint that names ING Bank as a defendant. In July 2019, the New York District Court granted the
defendants\u2019 motion to dismiss and denied leave to further amend the complaint, effectively dismissing all
remaining claims against ING Bank. In March 2021, the Second Circuit court vacated the District Court\u2019s
ruling. The case was remanded to the District Court to reconsider the amended complaint that would add
ING Bank N.V. back to the case. In April 2021, the defendants filed a petition for rehearing with the Second
Circuit court. In May 2021, the Second Circuit court denied the defendants\u2019 petition. In March 2022, plaintiffs
and ING executed a formal class settlement agreement. On 29 November 2022, the Court entered its final
judgement, approving ING\u2019s settlement (and those of all other defendants) with plaintiffs. The case is now
closed.
Claims regarding accounts with predecessors of ING Bank Turkey: ING Bank Turkey has received numerous
claims from (former) customers of legal predecessors of ING Bank Turkey. The claims are based on offshore
accounts held with these banks, which banks were seized by the Savings Deposit Insurance Fund (\u201cSDIF\u201d)
prior to the acquisition of ING Bank Turkey in 2007 from OYAK. Pursuant to the acquisition contract, ING can
claim compensation from SDIF if a court orders ING to pay amounts to the offshore account holders. SDIF
has made payments to ING pursuant to such compensation requests, but filed various lawsuits to receive
those amounts back. These lawsuits are ongoing. In April 2022 the Turkish Supreme Court decided that the
prescription period for the offshore account holders\u2019 compensation claims starts on the transfer date of the
account holders to the offshore accounts. The exact impact of this decision on the ongoing cases is not clear
yet. At this moment it is not possible to assess the outcome of these procedures nor to provide an estimate
of the (potential) financial effect of these claims.
Interest rate derivatives claims: ING is involved in several legal proceedings in the Netherlands with respect
to interest rate derivatives that were sold to clients in connection with floating interest rate loans in order to
hedge the interest rate risk of the loans. These proceedings are based on several legal grounds, depending
on the facts and circumstances of each specific case, inter alia alleged breach of duty of care, insufficient
information provided to the clients on the product and its risks and other elements related to the interest
rate derivatives that were sold to clients. In some cases, the court has ruled in favour of the claimants and
awarded damages, annulled the interest rate derivative or ordered repayment of certain amounts to the
claimants.
Interest surcharges claims: ING received complaints and was involved in litigation with certain individuals in
the Netherlands regarding increases in interest surcharges with respect to several credit products, including
but not limited to commercial property. ING has reviewed the relevant product portfolio. The provision
previously taken has been reversed for certain of these complaints. All claims are dealt with individually.
Thus far, the courts have ruled in favour of ING in each case, ruling that ING was allowed to increase the
interest surcharge based upon the essential obligations in the contract. In a relevant case the Dutch
Supreme Court ruled in favor of another Dutch bank, addressing the question whether or not a bank is
allowed to increase interest surcharges unilaterally. The Supreme Court ruled affirmative and referred the
case to the Court of Appeal in The Hague. The Court of Appeal also ruled in favour of the Dutch bank in
October 2022. ING will continue to deal with all claims individually.
Mortgage expenses claims: ING Spain has received claims and is involved in procedures with customers
regarding reimbursement of expenses associated with the formalisation of mortgages. In most court
proceedings in first instance the expense clause of the relevant mortgage contract has been declared null
and ING Spain has been ordered to reimburse all or part of the applicable expenses. Since 2018, the Spanish
Supreme Court and the European Court of Justice have issued rulings setting out which party should bear
notary, registration, agency, and stamp duty costs. In January 2021, the Spanish Supreme Court ruled that
valuation costs of mortgages, signed prior to 16 June 2019, the date the new mortgage law entered into
force, should be borne by the bank. Media attention for the statute of limitations applicable to the right to
claim reimbursement of costs resulted in an increased number of claims at the beginning of 2021. In June
2021, the Supreme Court published a press release informing of its decision to ask the European Court of
Justice for a preliminary ruling regarding the criteria that should be applied to determine the date from
which the action for claiming the reimbursement of mortgage expenses is considered to be expired.\u00a0 ING
Spain has also been included, together with other Spanish banks, in three class actions filed by customer
associations. In one of the class actions an agreement was reached with the association. In another class
action ING filed an appeal asking the Spanish Court of Appeal to determine that the ruling of the court of
first instance is only applicable to the consumers that were part of the case. The National Court has revoked
the ruling and declared that the consumers will not be able to initiate an action for compensation based on
the first instance ruling, as the claimant association intended. This last decision is not yet final, as it could be
appealed in the Supreme Court. A provision has been established in the past and has been adjusted where
appropriate.
Imtech claim: In January 2018, ING Bank received a claim from Stichting ImtechClaim.nl and Imtech
Shareholders Action Group B.V. on behalf of certain (former) shareholders of Imtech N.V. (\u201cImtech\u201d).
Furthermore, in March 2018, ING Bank received another claim on the same subject matter from the Dutch
Association of Stockholders (Vereniging van Effectenbezitters, \u201cVEB\u201d). In June 2022, VEB reiterated and
further substantiated its claim in a letter to ING. Each of the claimants allege inter alia that shareholders
were misled by the prospectus of the rights issues of Imtech in July 2013 and October 2014. ING Bank, being
one of the underwriters of the rights issues, is held liable by the claimants for the damages that investors in
Imtech would have suffered. ING Bank responded to the claimants denying any and all responsibility in
relation to the allegations made in the relevant letters. In September 2018, the trustees in the bankruptcy of
Imtech claimed from various financing parties, including ING, payment of what the security agent has
collected following bankruptcy or intends to collect, repayment of all that was repaid to the financing
parties, as well as compensation for the repayment of the bridge financing. At this moment it is not possible
to assess the outcome of these claims nor to provide an estimate of the (potential) effect of these claims.
Claims regarding mortgage loans in Swiss franc in Poland: ING Poland is a defendant in several lawsuits
with retail customers who took out mortgage loans indexed to the Swiss franc. Such customers have alleged
that the mortgage loan contract contains abusive clauses. One element that the court is expected to
consider in determining whether such contracts contain abusive clauses is whether the rules to determine
the exchange rate used for the conversion of the loan from Polish zloty to Swiss franc are unambiguous and
verifiable. In December 2020, the Polish Financial Supervision Authority (PFSA) proposed that lenders offer
borrowers voluntary out-of-court settlements on foreign-currency mortgage disputes, with mortgages
indexed to Swiss franc serving as a reference point. In February 2021, ING Poland announced its support for
this initiative and in October 2021 began offering the settlements to the borrowers following the PFSA\u2019s
proposal. ING has recorded a portfolio provision with respect to the claims and the PFSA proposal. The Polish
Supreme Court was expected to provide further clarity on this topic in a ruling scheduled for November
2021, however the court\u2019s session on this matter was postponed and the date of the next session has not
yet been announced. In October 2022, a hearing of the European Court of Justice (CJEU) was held inter alia
on the question whether, after cancellation of a contract regarding a Swiss franc loan by a court, banks may
still charge interests for the amount borrowed under such loan prior to cancellation.
On 16 February 2023, the Advocate General (AG) of the CJEU provided his opinion on the matter. The AG
opined that banks cannot claim any remuneration (i.e. interest) for the duration the principal amount was
available to the customer. The customer, however, may assert claims against banks in addition to
reimbursement of interest and instalments previously paid to the bank. The AG\u2019s opinion is not binding on
the CJEU. His role is to propose to the CJEU a legal solution to this case. Should the CJEU follow the opinion
of the AG, this will have negative effect for banks in Poland. The CJEU\u2019s ruling is expected within a few
months.
Certain Consumer Credit Products: In October 2021, ING announced that it would offer compensation to
certain of its Dutch retail customers in connection with certain revolving consumer loans with variable
interest rates that allegedly did not sufficiently follow market rates. This announcement was made in
response to a number of rulings by the Dutch Institute for Financial Disputes (Kifid) regarding similar
products at other banks. ING currently expects that any such compensation will be paid before the end of
2022. ING has recognized a provision of EUR 180 million in 2021 for compensation and costs in connection
with this matter. On 22 December 2021, ING announced that it has reached an agreement with the Dutch
Consumers\u2019 Association (Consumentenbond) on the compensation methodology for revolving credits. Based
on a recent Kifid ruling regarding similar products, ING will amend its previously announced compensation
scheme by also compensating interest on interest. In the third quarter of 2022, ING increased its provision
for this matter by EUR 75 million. In the fourth quarter of 2022, ING and the Dutch Consumers\u2019 Association
reached an agreement on the compensation of customers who have had an overdraft or a revolving credit
card with a variable interest rate. ING will compensate such customers according to Kifid jurisprudence
about revolving credits including \u2018interest-on-interest\u2019-effect. Compensation will start in the first half of
2023.
43\u00a0 Consolidated companies and businesses acquired and divested
Acquisitions
There were no significant acquisitions in 2022, 2021 or 2020.
Divestments 2022
ING announced at 13 December 2022 that it has sold their interest (80%) in Intersoftware Holding BV to the
Sky Group/ DIAS and realised a transaction result of EUR 11.0 million which consists of a profit of EUR 7.0 on
sale of InterSoftware Holding BV and the release of the redemption liability of EUR 3.0 million.
Divestments 2021
On 18 February 2021 ING announced the intention to withdraw from the retail banking market in the Czech
Republic. \u00a0The decision to discontinue Czech Retail Banking entails the closure of retail customer accounts /
mutual funds and the sale of assets comprising the related government bond portfolio. ING\u2019s retail
customers in the Czech Republic have received a welcome offer from Raiffeisenbank Czech Republic. ING\u2019s
departure from the Czech Retail banking market resulted in EUR 2.5 billion saving accounts being transferred
to Raiffeisenbank and the government bond portfolio with a carrying amount of EUR 0.5 billion being sold in
the second quarter of 2021.
At 12 July 2021, ING announced that it has reached an agreement to transfer ING\u2019s Retail Banking
operations in Austria to Bank99. Under the terms of the agreement, approximately EUR 1.7 billion of savings
deposits and approximately EUR 1.0 billion of mortgages, approximately EUR 0.4 billion other personal
lending and approximately EUR 0.4 billion loans to banks of ING Austria have been transferred to Bank99. In
December 2021 the transaction was completed and a loss on disposal of EUR 26 million was realised. In
2022 some final closing activities resulted in an additional loss of EUR 1 million. ING Austria was included in
the segment Retail Challengers & Growth Markets.
In 2021, ING and the board of Makelaarsland agreed to continue Makelaarsland independently. The new
board will take over all clients and employees, and services to clients will continue unchanged. The negative
result on disposal of group companies from this management buyout amounted to approximately EUR 3
million.
On 28 October 2021 ING announced that its subsidiary Payvision will start phasing out its services as a
payment service provider and acquirer. In 2021, Payvision recognised\u00a0an impairment loss of\u00a0intangible
assets of\u00a0EUR 44 million, mainly with respect to Brand, IT and Customer relationships\u00a0and an impairment
loss of\u00a0the deferred tax asset of EUR 14 million.
ING has been active in the French retail banking market since 2000 as an online bank. In December 2021 ING
announced that it will leave the retail banking market in France in order to sharpen the focus of its business
portfolio. ING and Boursorama (a subsidiary of Soci\u00e9t\u00e9 G\u00e9n\u00e9rale) have signed an agreement to offer the
attractive services to retail customers of ING in France.
The contract allows ING customers to join Boursorama and benefit from a simplified account opening
process and exclusive offers. The agreement also includes the transfer to Boursorama of
\u2018assurance'vie\u2019 (investment products) contracts, for which ING acts as a broker with Generali Vie. Home loans
and consumer loans are not included in the agreement and the portfolio will continue to be managed by
ING.
The agreement follows ING\u2019s announcement in December 2021 to exit the French retail banking market. The
exit is finalised end of 2022. ING\u2019s departure from the France retail banking market is proceeding well with
EUR 9.7 billion saving accounts already transferred to Boursorama. ING will continue its Wholesale Banking
activities in France, with a focus on strengthening its position and the ambition to be the go-to bank for
sustainable finance.
Most significant companies disposed in 2021
in EUR million
Makelaarsland
BV & Above BV
ING Austria
Retail Banking
Total divested
Sales Proceeds
Sales proceeds
29
29
Non-cash proceeds
Cash proceeds
29
29
Cash outflow / inflow on disposal
29
29
Assets
Cash assets
3
3
Loans and advances to customers
1,404
1,404
Amounts due from banks
378
378
Miscalleneous other assets
8
8
Liabilities
Customer deposits and other funds on deposit
1,725
1,725
Miscallaneous other liabilities
1
8
9
Net assets
3
56
58
% disposed
100%
100%
Net assets disposed
3
56
58
Result on disposal
-3
-26
-29
In 2020 there were no significant divestments.
44\u00a0 Principal subsidiaries, investments in associates and joint ventures
For the majority of ING\u2019s principal subsidiaries, ING Bank 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\u2019s financial interest and its rights from other contractual
arrangements which result in control over the operating and financial policies of the entity.
For each of the subsidiaries listed, the voting rights held equal the proportion of ownership interest and
consolidation by ING is based on the majority of ownership.
For the principal investments in associates and joint ventures ING Bank has significant influence but not
control. Significant influence generally results from a shareholding of between 20% and 50% of the voting
rights, but also the ability to participate in the financial and operating policies through situations including,
but not limited to one or more of the following:
\u2022Representation on the board of directors;
\u2022Participation in the policymaking process; and
\u2022Interchange of managerial personnel.
The principal subsidiaries, investments in associates and joint ventures of ING Bank N.V. and their statutory
place of incorporation or primary place of business are as follows:
Principal subsidiaries, investments in associates and joint ventures
Proportion of
ownership and
interest held
by the group
2022
2021
Subsidiary
Statutory place of
Incorporation
Country of operation
Bank Mendes Gans N.V.
Amsterdam
the Netherlands
100%
100%
ING Belgium S.A./N.V.
Brussels
Belgium
100%
100%
ING Luxembourg S.A.
Luxembourg City
Luxembourg
100%
100%
ING-DiBa AG
Frankfurt am Main
Germany
100%
100%
ING Bank Slaski S.A.1
Katowice
Poland
75%
75%
ING Financial Holdings Corporation
Delaware
United States of America
100%
100%
ING Bank A.S.
Istanbul
Turkey
100%
100%
ING Bank (Australia) Ltd
Sydney
Australia
100%
100%
ING Commercial Finance B.V.
Amsterdam
the Netherlands
100%
100%
ING Groenbank N.V.
Amsterdam
the Netherlands
100%
100%
Investments in associates and joint
ventures
TMBThanachart Bank Public Company
Ltd2
Bangkok
Thailand
23%
23%
1 The shares of the non-controlling interest stake of 25% are listed on the Warsaw Stock Exchange, for summarised financial
\u00a0 \u00a0 \u00a0 \u00a0 \u00a0 information we refer to \u2018Note 33 \u2018Information on geographical areas.
2 Reference is made to Note 8 Investments in Associates and Joint Ventures.
45\u00a0 Structured entities
ING Bank\u2019s activities involve transactions with various structured entities (SE) in the normal course of its
business. A structured entity is an entity that has been designed so that voting or similar rights are not the
dominant factor in deciding who controls the entity, such as when any voting rights relate to administrative
tasks only and the relevant activities are directed by means of contractual arrangements. ING Bank\u2019s
involvement in these entities varies and includes both debt financing and equity financing of these entities
as well as other relationships. Based on its accounting policies, as disclosed in the section Principles of
valuation and determination of results of these financial statements, ING establishes whether these
involvements result in no significant influence, significant influence, joint control or control over the
structured entity.
The structured entities over which ING can exercise control are consolidated. ING may provide support to
these consolidated structured entities as and when appropriate. However, this is fully reflected in the
consolidated financial statements of ING Bank as all assets and liabilities of these entities are included and
off-balance sheet commitments are disclosed.
ING\u2019s activities involving structured entities are explained below in the following categories:
1.Consolidated ING originated securitisation programmes;
2.Consolidated ING originated Covered bond programme (CBC);
3.Consolidated ING sponsored Securitisation programme (Mont Blanc);
4.Unconsolidated Securitisation programme; and
5.Other structured entities.
1. Consolidated ING originated securitisation programmes
ING Bank enters into liquidity management securitisation programmes in order to obtain funding and
improve liquidity. Within the programme ING Bank sells ING originated assets to a structured entity. The
underlying exposures include residential mortgages and SME loans in the Netherlands, Belgium, Spain, Italy,
Australia and Germany.
The structured entity issues securitised notes (traditional securitisations) which are eligible collateral for
central bank liquidity purposes. In most programmes ING Bank acts as investor of the securitised notes. ING
Bank continues to consolidate these structured entities if it is deemed to control the entities.
The structured entity issues securitisation notes in two or more tranches, of which the senior tranche
obtains a high rating (AAA or AA) by a rating agency. The tranche can subsequently be used by ING Bank as
collateral in the money market for secured borrowings.
ING Bank originated various securitisations, as at 31\u00a0December 2022, these consisted of approximately EUR
65 billion (2021: EUR 74 billion) of senior and subordinated notes, of which approximately EUR 1 billion
(2021: EUR 1 billion) were issued externally. The underlying exposures are residential mortgages and SME
loans. Apart from the third party funding, these securitisations did not impact ING Bank\u2019s Consolidated
statement of financial position and profit or loss.
In 2022, there are no non-controlling interests as part of the securitisation structured entities that are
significant to ING Bank. ING Bank for the majority of the securitisation vehicles provides the funding for the
entity except for EUR 1 billion (2021: EUR 1 billion).
In addition ING Bank originated various securitisations for liquidity management optimisation purposes. As
at 31\u00a0December 2022, these consisted of EUR 444 million (2021: EUR 662 million) of senior secured portfolio
loans, which have been issued to ING subsidiaries in Germany. The underlying exposures are senior loans to
large corporations and financial institutions, and real estate finance loans, mainly in the Netherlands. These
securitisations did not impact ING Bank\u2019s consolidated statement of financial position and profit or loss.
2. Consolidated ING originated Covered bond programme (CBC)
ING Bank has entered into a covered bond programme. Under the covered bond programme ING issues
bonds. The payment of interest and principal is guaranteed by the ING administered structured entities, ING
Covered Bond Company B.V., and ING SB Covered Bond Company B.V. In order for these entities to fulfil their
guarantee, ING legally transfers mainly Dutch mortgage loans originated by ING. Furthermore ING offers
protection against deterioration of the mortgage loans. The entities are consolidated by ING Bank.
Covered bond programme
Fair value pledged
mortgage loans
in EUR million
2022
2021
Dutch Covered Bond Companies
21,379
16,586
21,379
16,586
In addition, subsidiaries of ING in Germany, Belgium and Australia also issued covered bonds with pledged
mortgages loans of approximately EUR 24,880 million (2021: EUR 22,597 million) in total.
For the covered bond programme, third-party investors in securities issued by the structured entity have
recourse to the assets of the entity and to the assets of ING Bank.
3. Consolidated ING sponsored Securitisation programme (Mont Blanc)
In the normal course of business, ING Bank structures financing transactions for its clients by assisting them
in obtaining sources of liquidity by selling the clients\u2019 receivables or other financial assets to a Special
Purpose Vehicle (SPV). The senior positions in these transactions may be funded by the ING administered
multi seller Asset Backed Commercial Paper (ABCP) conduit Mont Blanc Capital Corp. (rated A-1/P-1). Mont
Blanc Capital Corp. funds itself externally\u00a0 in the ABCP markets.
In its role as administrative agent, ING Bank facilitates these transactions by acting as administrative agent,
swap counterparty and liquidity provider to Mont Blanc Capital Corp. ING Bank also provides support facilities
(i.e. liquidity) backing the transactions funded by the conduit. The types of asset currently in the Mont Blanc
conduit include trade receivables, consumer finance receivables, car leases and residential mortgages.
ING Bank supports the commercial paper programmes by providing Mont Blanc Capital Corp. with short-
term liquidity facilities. Once drawn these facilities bear normal credit risk.
The liquidity facilities, provided to Mont Blanc are EUR 2,446 million (2021: EUR 2,581 million). The drawn
liquidity amount is nil as at 31\u00a0December 2022 (2021: nil).
The standby liquidity facilities are reported under irrevocable facilities. All facilities, which vary in risk profile,
are granted to the Mont Blanc Capital Corp. subject to normal ING Bank credit and liquidity risk analysis
procedures. The fees received for services provided and for facilities are charged subject to market
conditions.
4. Unconsolidated Securitisation programme
In 2013 ING transferred financial assets (mortgage loans) for an amount of approximately EUR 2 billion to a
special purpose vehicle (SPV). The transaction resulted in full derecognition of the financial assets from ING\u2019s
statement of financial position. Following this transfer ING continues to have two types of on-going
involvement in the transferred assets: as counterparty to the SPE of a non-standard interest rate swap and
as servicer of the transferred assets. ING has an option to unwind the transaction by redeeming all notes at
their principal outstanding amount, in the unlikely event of changes in accounting and/or regulatory
requirements that significantly impact the transaction. The fair value of the swap held by ING at
31\u00a0December 2022 amounted to EUR -40\u00a0million (2021: EUR -34\u00a0million); fair value changes on this swap
recognised in the statement of profit or loss in 2022 were EUR -6 million (2021: EUR 0 million). Service fee
income recognised, for the role as administrative agent, in the statement of profit or loss in 2022 amounted
to EUR 1 million (2021: EUR 1 million). The cumulative income recognised in profit or loss since derecognition
amounts to EUR 18 million (2021: EUR 17 million).
5. Other structured entities
In the normal course of business, ING Bank enters into transactions with structured entities as counterparty.
Predominantly in its structured finance operations, ING can be instrumental in facilitating the creation of
these structured entity counterparties. These entities are generally not included in the consolidated
financial statements of ING Bank, as ING facilitates these transactions as administrative agent by providing
structuring, accounting, funding, lending, and operation services.
ING Bank offers various investment fund products to its clients. ING Bank does not invest in these investment
funds for its own account nor acts as the fund manager.
46\u00a0 Related parties
In the normal course of business, ING Bank 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 Bank include, among others, its
subsidiaries, associates, joint ventures, key management personnel, and various defined benefit and
contribution plans. For post-employment benefit plans, reference is made to Note 33 'Pensions and other
post-employment benefits'. Transactions between related parties include rendering or receiving of services,
leases, transfers under finance arrangements and provisions of guarantees or collateral. All transactions
with related parties took place at conditions customary in the market. There are no significant provisions for
doubtful debts or individually significant bad debt expenses recognised on outstanding balances with
related parties.
ING Bank forms part of ING Group and also enters into transactions with ING Group. These transactions vary
from financing activities to regular purchase and sales transactions. Disclosed in the table below, are the
transactions with ING Groep N.V.
Parent Company
Transactions with ING Groep N.V.
in EUR million
2022
2021
Assets
56
55
Liabilities
65,704
56,349
Income received
4
15
Expenses paid
1,426
1,158
Assets, liabilities, commitments, and income related to Associates and joint ventures result from
transactions which are executed as part of the normal Banking business.
Key management personnel compensation
The Executive Board of ING Groep N.V., the Management Board Banking and the Supervisory Board are
considered Key Management personnel of ING Group. In 2022 and 2021, the three members of the
Executive Board of ING Groep N.V. were also members of the Management Board Banking.
Transactions with key management personnel, including their compensation are included in the tables
below.
Key management personnel compensation (Executive Board and Management Board Banking)
2022
in EUR thousands
Executive
Board of ING
Groep N.V.
Management
Board Banking 1
Total
Fixed Compensation
\u2013\u00a0 Base salary
4,220
4,969
9,189
\u2013\u00a0 Collective fixed allowances 2
1,011
1,073
2,084
\u2013\u00a0 Pension costs
70
116
186
\u2013\u00a0 Severance benefits
932
932
Variable compensation
\u2013\u00a0 Upfront cash
803
803
\u2013\u00a0 Upfront shares
268
803
1,071
\u2013\u00a0 Deferred cash
1,204
1,204
\u2013\u00a0 Deferred shares
401
1,204
1,605
\u2013\u00a0 Other emoluments 3
296
638
934
Total compensation
6,266
11,742
18,008
1Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.
2The collective fixed allowances consist of two savings allowances applicable to employees in the Netherlands; an individual savings
allowance of 3.5% and a collective savings allowance to compensate for loss of pension benefits with respect to salary in excess of
EUR 114,866.
3This includes amongst others: housing, school/tuition fees, international health insurance, relocation costs and tax and financial
planning.
Key management personnel compensation (Executive Board and Management Board Banking)
Executive
Board of ING
Groep N.V. 3
Managemen
t Board
Banking 1,4
Total
2021
in EUR thousands
Fixed Compensation
\u2013\u00a0 Base salary
3,836
5,024
8,860
\u2013\u00a0 Collective fixed allowances 2
954
1,214
2,168
\u2013\u00a0 Pension costs
64
116
180
\u2013\u00a0 Severance benefits
1,075
1,075
Variable compensation
\u2013\u00a0 Upfront cash
664
664
\u2013\u00a0 Upfront shares
265
691
956
\u2013\u00a0 Deferred cash
997
997
\u2013\u00a0 Deferred shares
398
1,036
1,434
\u2013\u00a0 Other emoluments 5
274
959
1,233
Total compensation
5,791
11,776
17,567
Loans and advance to key management personnel
As at 31 December 2022 Loans and advances outstanding to key management personnel amounted to EUR
2.7 million (2021: EUR 2.4 million) and loan commitments to key management personnel amounted to EUR
203 thousand (2021: EUR 197\u00a0thousand). Total interest received in 2022 on these loans and advances
amounted to EUR 62 thousand (EUR 37 thousand).
These loans and advances and loan commitments (1) were made in the ordinary course of business, (2)
were granted on conditions that are comparable to those of loans and advances granted to all employees
and (3) did not involve more than the normal risk of collectability or present other unfavourable features.
Loans and advances to members of the Executive Board and Management Board Banking are compliant
with the standards set out in the DNB guidelines for loans to officers and directors of a regulated entity,
such as ING.
Deposits outstanding to key management personnel
As at 31 December 2022 Deposits outstanding from key management personnel amounted to EUR 11.5
million (2021: EUR 6.1 million). Total interest paid in 2022 on these deposits amounted to EUR 36\u00a0thousand
(2021: EUR 14 thousand).
Number of ING Groep N.V. shares and stock options to key management personnel
ING Groep N.V. shares
in numbers
2022
2021
Executive Board members
108,217
91,853
Management Board Banking
294,574
237,525
Supervisory Board members
5,295
5,295
Total number of shares and stock options
408,086
334,673
47\u00a0 Capital management
Objectives
Group Treasury (\u201cGT\u201d) Balance Sheet & Capital Management, is responsible for maintaining the adequate
capitalisation of ING Group and ING Bank entities, to manage the risk associated with ING\u2019s business
activities. This involves not only managing, planning and allocating capital within ING Group, ING Bank and
its various entities, but also helping to execute necessary capital market transactions, term (capital) funding
and risk management transactions. ING takes an integrated approach to assess the adequacy of its capital
position in relation to its risk profile and operating environment. This means GT Balance Sheet & Capital
Management takes into account both regulatory and internal, economic based metrics and requirements as
well as the interests of key stakeholders such as shareholders and rating agencies.
ING Bank applies the following main capital definitions:
\u2022Common Equity Tier 1 capital (CET1) - is defined as shareholders\u2019 equity less regulatory adjustments.
CET1 capital divided by risk-weighted assets equals the CET1 ratio.
\u2022Tier 1 capital \u2013 is defined as CET1 capital plus Additional Tier 1 (hybrid) securities and other regulatory
adjustments. Tier 1 capital divided by risk-weighted assets equals the Tier 1 capital ratio.
\u2022Total capital \u2013 is Tier 1 capital plus subordinated Tier 2 liabilities and regulatory adjustments. Total capital
divided by risk-weighted assets equals the Total capital ratio.
\u2022Leverage ratio \u2013 is defined as Tier 1 capital divided by the leverage exposure.
Capital developments
ING Bank\u2019s capital ratios at the end of the year decreased compared to 2021 primarily due to higher risk-
weighted assets and as most of the net profit of the year with EUR 2.75 billion additional distributions were
up streamed to ING Group. Risk-weighted assets were mainly impacted by rating downgrades on Russia-
related exposure, currency movements, the implementation of EBA guidelines on the treatment of
structural FX positions, and model impacts. Model impacts reflect the introduction of a risk-weight floor on
Dutch residential mortgages by the Dutch Central Bank as well as ongoing redevelopment of internal
models and EBA guidelines.
ING Bank paid EUR 3.5 billion of dividend to ING Group in relation to the 2022 profit and an additional EUR
2.75 billion for distribution to shareholders by the Group.
ING Bank N.V. has a CET1 ratio of 12.6% versus an overall CET1 requirement (including buffer requirements)
of 7.10%. The Bank\u2019s Tier 1 ratio decreased from 16.5% to 14.5% compared to last year. The Banks\u2019s Total
capital ratio decreased to 17.5%.
ING Bank capital position according to CRR II / CRD V
in EUR million
2022
2021
Shareholders\u2019 equity 1
42,546
47,914
-Interim profits not included in CET 1 capital
-913
-934
- Other adjustments
332
-2,130
Regulatory adjustments
-580
-3,064
Available common equity Tier 1 capital
41,966
44,850
Additional Tier 1 securities
6,280
6,792
Regulatory adjustments additional Tier 1
78
78
Available Tier 1 capital
48,324
51,720
Supplementary capital Tier 2 bonds\u00a0 2
10,046
9,341
Regulatory adjustments Tier 2
41
21
Available Total capital
58,411
61,081
Risk weighted assets
332,853
312,616
Common equity Tier 1 ratio
12.61%
14.35%
Tier 1 ratio
14.52%
16.54%
Total capital ratio
17.55%
19.54%
2All T2 securities are CRR/CRD V-compliant for 2022 (2021: EUR 153 million was subject to CRR/CRD IV grandfathering rules).
In accordance with the applicable regulation, credit and operational risk models used in the capital ratios
calculations are not audited.
Processes for managing capital
GT Balance Sheet & Capital Management ensures adherence to ING\u2019s solvency risk appetite statements by
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 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 assesses continuously 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\u2019s risk management framework. Contingency capital
measures and early warning indicators are in place in conjunction with ING\u2019s 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\u2019s risk and capital management framework. It allows to (i) identify and assess potential
vulnerabilities in ING\u2019s businesses, business model, portfolios or operating environment; (ii) understand the
sensitivities of the core assumptions used in ING\u2019s 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.
Regulatory requirements
Capital adequacy and the use of required regulatory capital are based on the guidelines developed by the
Basel Committee on Banking Supervision (The Basel Committee) and the European Union Directives, as
implemented by the Dutch Central Bank and the ECB for supervisory purposes. In 2010, the Basel Committee
issued new solvency and liquidity requirements that superseded Basel II, implemented in the EU via CRR /
CRD. In accordance with the CRR the minimum Pillar 1 capital requirements applicable to ING Bank are: a
CET1 ratio of 4.5%, a Tier 1 ratio of 6.0% and a Total capital ratio of 8.0% of risk-weighted assets.
The overall CET1 requirement (including buffer requirements) for ING Bank N.V. at a consolidated level was
7.10% in 2022. This requirement is the sum of a 4.5% Pillar I requirement, a 2.5% Capital Conservation Buffer
(CCB) and a 0.10% Countercyclical Buffer (CCyB) (based on December 2022 positions).
Ratings
ING\u2019s credit ratings and outlook are shown in the table below. Each of these ratings reflects only the view of
the applicable rating agency at the time the rating was issued, and any explanation of the significance of a
rating may be obtained only from the rating agency.
Main credit ratings of ING Bank N.V. at 31 December 2022
S&P
Moody\u2019s
Fitch
GBB-Rating
ING Bank N.V.
Issuer rating
Long-term
A+
A1
AA-
A+
Short-term
A-1
P-1
F1+
n/a
Outlook
Stable
Stable
Stable
Indeterminate
Senior unsecured rating
A+
A1
AA-
A security rating is not a recommendation to buy, sell or hold securities and 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 a rating will not be lowered, suspended or withdrawn entirely by the
rating agency if, in the rating agency\u2019s judgment, circumstances so warrant. ING accepts no responsibility
for the accuracy or reliability of the ratings.
48\u00a0 Subsequent events
On 6 February 2023, a devastating earthquake with multiple aftershocks struck southern and central Turkey
and northern and western Syria causing a significant tragedy for the people and is causing disruption to
business and economic activity in the region. This qualifies as a non-adjusting subsequent event.", "dimensions": { "concept": "ifrs-full:DisclosureOfNotesAndOtherExplanatoryInformationExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV80MC9mcmFnOmRhNTQ5OWI2ZGQ5MjRjMzY4ZDAwNDg0M2RkOTM5MWQ2L3RleHRyZWdpb246ZGE1NDk5YjZkZDkyNGMzNjhkMDA0ODQzZGQ5MzkxZDZfMjE5OTAyMzI3MzM2OTI_4f48685d-d645-4f89-afc7-d1943d98ef70": { "value": "
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.
Governance (*)
ING\u2019s credit risk strategy is to maintain an internationally diversified loan and bond portfolio, while avoiding
large risk concentrations. The emphasis is on managing business developments within the business lines by
means of a top-down risk appetite framework (RAF), which sets concentration limits for countries, individual
clients, sectors, products, secondary risk (collateral/guarantees) and investment activities. The aim is to
support relationship banking activities, while maintaining internal risk/reward guidelines and controls.
A new Credit Risk department was established in 2022. This department is responsible for setting the credit
risk strategy for ING and aims to ensure credit risk and credit restructuring are managed from an
overarching point of view rather than per business line. The head of Credit Risk is supported by the following
teams within this new department:
\u2022Portfolio, Strategy & Governance team: responsible for setting up credit risk strategies and risk appetite
statements, performing analysis and monitoring of the credit risk position of ING, as well as setting and
maintaining the credit risk framework and policies.
\u2022Credit Risk Control Unit: responsible for the design or selection, implementation, oversight and
performance of the rating systems.
\u2022Global Credit Risk Restructuring: responsible for a safe, compliant and data driven credit loss process by
managing loan loss provisioning and finding solutions for business customers in financial difficulty. The
team focuses on management of the global loan loss provisioning, not only of individual WB provisions,
but also collective WB and Retail Banking provisions.
While the Credit Risk department has oversight of the Bank credit risk strategy and risk appetite across
Retail Banking risk and Wholesale Banking risk, the head of Retail/Rest of World (RoW) Risk and head of
Wholesale Banking Risk aim to ensure the management of the risk within these business lines. Also refer to
the Risk governance and organisational structure in the introductory section of the Risk management
chapter.
The credit risk function encompasses the following activities:
\u2022Measuring, monitoring and managing credit risks in the bank\u2019s portfolio, including the measures taken in
response to the war in Ukraine.
\u2022Challenging and approving new and modified transactions and borrower reviews.
\u2022Managing the levels of provisioning and risk costs, and advising on impairments.
\u2022Providing consistent credit risk policies, systems and tools to manage the credit lifecycle of all activities.
Credit risk categories (*)
In the following table the different types of credit risk categories are described and a reconciliation with the
notes in the financial statements is also included:
Reconciliation between credit risk categories and financial position (*)
Credit risk categories
Notes in the financial statements
Lending risk: is 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.
Note
2
Cash and balances with central banks
Note
3
Loans and advances to banks
Note
4
Financial assets at fair value through profit
or loss
Note
5
Financial assets at fair value through other
comprehensive income
Note
7
Loans and advances to customers
Note
41
Contingent liabilities and commitments
Investment risk: is the credit default and risk rating migration risk
that is associated with ING\u2019s 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.
Note
4
Financial assets at fair value through profit
or loss
Note
5
Financial assets at fair value through other
comprehensive income
Note
6
Securities at amortised cost
Money market risk: arises when ING places short-term deposits
with a counterparty in to manage excess liquidity. In the event of
a counterparty default, ING may lose the deposit placed.
Note
2
Cash and balances with central banks
Note
3
Loans and advances to banks
Note
7
Loans and advances to customers
Pre-settlement risk: 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).
Note
4
Financial assets at fair value through profit
or loss
Note
14
Financial liabilities at fair value through
profit or loss
Note
40
Offsetting financial assets and liabilities
Settlement risk: 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.
Note
4
Financial assets at fair value through profit
or loss
Note
11
Other assets
Note
14
Financial liabilities at fair value through
profit or loss
Note
16
Other liabilities
1 Based on credit risk measurement contained in lending, pre-settlement, money market and investment activities.
2 Based on the total amount of credit risk in the respective column using ING\u2019s internal credit risk measurement methodologies. Economic sectors (industry) below 2% are not shown separately but grouped in Other.
3 Geographical areas are based on country of residence, except for private individuals for which the geographical areas are based on the primary country of risk.
Overall portfolio (*)
During 2022, ING\u2019s portfolio size increased by \u20ac24.0 billion (+2.62%) to \u20ac937.7 billion outstandings. The net
volume growth was spread across all the business lines. Foreign exchange rate changes had a positive
impact on portfolio growth, mainly in WB, and increased total outstanding by \u20ac6.3 billion, driven by the
appreciation of the US dollar (+6.2%) against the euro, partially compensated by the British pound sterling
(-5.3%), the Polish new zloty (-1.8%), and new Turkish lira (-23.7%).
Rating distribution (*)
Overall, the rating class distribution remained stable in 2022. The share of investment grade rating classes
increased from 75.1% to 76.2%, while the share of non-investment grade decreased, from 23.2% to 21.7%.
Sub-standard grade outstandings increased from 0.4% to 0.8% of the total portfolio, whereas non-
performing loans decreased from 1.3% to 1.2%.
With respect to the rating distribution within the business lines, in WB, investment grade increased to 81.2%
(from 79.7%), where non-investment grade exposures decreased to 16.8% (from 19.1%) compared to 2021.
Substandard grade assets increased from 0.2% to 1.0% of total Wholesale Banking assets, primarily as a
result of increases in Russia, in the natural resources industry. The share of non-performing loans for WB
remained stable at 1.0% (from 0.9%).
The rating distribution for Retail Benelux improved mostly because of Dutch residential mortgages, shifting
from rating class BB/BBB to A. The share of A-rated mortgages increased from 9.3% to 24.0% of the
portfolio. In Belgium, residential mortgages showed a modest increase of BBB assets, from single A.
Substandard grade Belgium mortgage outstandings increased to 1.0% (from 0.8%).
In Retail Challengers & Growth Markets, the distribution across rating classes remained rather stable in 2022.
Overall share of investment grade decreased from 76.1% to 75.2%, NPL decreased to 1.0% (from 1.3%).
Industry (*)
In line with our objective to give stakeholders insight into the portfolio, we present the business lending
portfolio per industry breakdown in accordance with the NAICS definition. The industry composition within
Retail is concentrated in private individuals with 65.0% for Retail Benelux and 76.0% for Retail Challengers &
Growth Markets.
In Market Leaders, the overall volumes increase is mainly explained by Belgium (+4.7%), whereas the
Netherlands remained stable in 2022 (+1.1%). In C&G, the increase in volume is in private individuals,
primarily in Germany, and to a lesser extent in Australia and Spain. A decrease in France is explained by the
discontinuation of retail activities. Within WB, an increase in exposures is noted mainly in non-bank financial
institutions (NBFI) of \u20ac7.7 billion (notably in Germany, France and the US). Apart from NBFI, an increase is
observed in other industries (+\u20ac6.1 billion), compensated by a decrease in natural resources (\u20ac7.2 billion).
Outstandings by economic sectors and geographical area (*) 1
in \u20ac million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United
Kingdom
Luxembourg
France
Rest of
Europe
America
Asia
Australia
Africa
2022
Private Individuals
114,625
44,193
101,529
13,767
24,865
138
3,486
2,731
13,654
161
131
35,528
24
354,831
Central Banks
35,202
14,338
21,041
1,060
347
427
6,820
35
18,092
0
4,962
2,695
24
105,043
Natural Resources
3,084
1,356
809
746
169
4,442
2,764
470
12,154
8,771
10,398
1,028
361
46,549
Real Estate
17,586
10,112
1,388
2,374
1,391
413
3,797
3,155
3,378
3,474
1,180
4,263
2
52,513
Commercial Banks
1,359
265
3,974
551
402
4,933
4,480
4,371
6,368
9,945
12,041
1,765
409
50,863
Non-Bank Financial Institutions
2,710
1,041
5,054
2,299
99
8,229
4,489
3,220
4,495
19,636
4,091
896
0
56,258
Central Governments
3,342
7,716
1,179
6,578
4,578
46
175
1,797
8,444
13,979
333
636
551
49,356
Transportation & Logistics
3,967
2,183
608
1,300
690
1,787
583
733
7,808
3,378
6,806
531
608
30,982
Utilities
1,551
1,630
2,814
679
1,227
2,953
572
980
4,302
4,347
1,545
1,897
200
24,698
Food, Beverages & Personal Care
7,249
3,002
573
2,334
475
739
1,667
469
2,668
3,245
942
248
13
23,623
Services
4,819
8,816
1,254
1,101
67
685
808
1,066
1,120
1,821
357
632
0
22,546
General Industries
5,430
2,689
1,007
2,849
311
330
604
245
3,152
2,926
1,311
9
0
20,865
Lower Public Administration
272
5,638
5,197
644
200
0
313
3,126
402
1,310
0
4,564
0
21,666
Other
17,353
13,602
6,302
6,946
1,416
3,058
1,164
1,179
10,952
9,457
4,891
1,424
188
77,932
Total
218,548
116,580
152,730
43,229
36,237
28,179
31,720
23,576
96,989
82,450
48,989
56,116
2,381
937,725
Rating class
Investment grade
174,972
76,244
130,285
27,501
28,556
23,160
26,053
17,545
64,884
63,870
39,903
41,476
213
714,662
Non-Investment grade
40,325
36,036
20,967
14,596
7,330
4,634
5,442
5,814
27,617
17,615
7,638
13,914
1,858
203,786
Sub-standard grade
1,508
984
579
422
105
41
80
16
2,903
311
124
257
239
7,569
Non-performing loans
1,743
3,316
899
710
246
344
145
201
1,584
654
1,325
470
72
11,708
Total
218,548
116,580
152,730
43,229
36,237
28,179
31,720
23,576
96,989
82,450
48,989
56,116
2,381
937,725
1\u00a0 Geographical areas are based on country of residence, except for private individuals for which the geographical areas are based on the primary country of risk.
Outstandings by economic sectors and geographical area (*) 1
in \u20ac million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United
Kingdom
Luxembourg
France
Rest of
Europe
America
Asia
Australia
Africa
2021
Private Individuals
113,846
42,961
95,583
14,397
23,895
157
3,388
3,115
13,215
167
155
35,058
27
345,965
Central Banks
46,902
18,253
17,811
112
3,027
2,853
8,569
1,039
4,485
0
2,856
1,168
18
107,094
Natural Resources
3,734
1,180
1,208
722
291
4,487
2,497
405
15,471
9,473
12,593
1,013
780
53,855
Real Estate
17,426
10,011
1,520
2,357
1,528
436
4,201
3,254
3,461
3,521
935
4,045
4
52,699
Commercial Banks
1,378
318
3,887
707
392
4,156
3,205
5,520
6,353
7,089
13,526
2,265
413
49,208
Non-Bank Financial Institutions
3,043
921
3,146
1,718
72
7,764
4,798
1,790
3,947
17,772
3,209
411
0
48,590
Central Governments
4,911
7,396
1,179
7,473
4,417
67
203
2,065
7,695
10,927
299
533
477
47,642
Transportation & Logistics
4,572
2,209
506
1,177
723
1,760
582
982
6,837
3,410
5,682
645
514
29,597
Utilities
1,545
1,213
3,024
822
1,270
2,980
397
1,433
4,202
4,106
1,355
1,368
220
23,935
Food, Beverages & Personal Care
6,581
2,869
616
2,146
489
711
1,600
1,232
2,580
3,131
1,140
235
12
23,340
Services
4,615
9,115
1,105
866
119
523
450
1,470
861
1,539
479
565
36
21,743
General Industries
5,389
2,891
1,011
2,612
381
395
532
271
3,363
2,116
1,151
15
0
20,127
Lower Public Administration
343
5,158
5,787
636
0
0
296
2,732
467
1,197
46
2,608
0
19,271
Other
15,485
13,424
5,573
6,319
940
2,277
1,168
1,210
9,297
8,803
4,732
1,454
0
70,682
Total
229,771
117,919
141,956
42,063
37,542
28,567
31,887
26,517
82,233
73,251
48,159
51,382
2,501
913,749
Rating class
Investment grade
180,787
78,195
119,311
26,856
29,522
22,820
26,150
20,622
52,875
53,725
36,777
38,200
79
685,920
Non-Investment grade
45,530
35,600
21,250
14,148
7,647
5,234
5,568
5,774
27,993
18,184
10,534
11,998
2,259
211,721
Sub-standard grade
1,230
868
390
290
89
56
81
2
308
203
191
217
58
3,985
Non-performing loans
2,224
3,256
1,006
768
284
458
87
119
1,056
1,139
656
966
105
12,124
Total
229,771
117,919
141,956
42,063
37,542
28,567
31,887
26,517
82,233
73,251
48,159
51,382
2,501
913,749
Risk management at ING Bank'. Apart from Russia, noticeable
moves occurred in France, where NPL increased from 0.4% to 0.9% impacted by the decommissioning of
the Retail business in France. And in the UK, where NPL decreased from 1.6% to 1.2%.
The increase in exposure in the Americas region was mainly driven by FX impact. In terms of rating
distribution for America region, an increase in investment grade is observed to 77.6% (from 73.0%), non-
investment grade decreased to 21.3% from 25.1%. Sub-standard grade increased to 0.4%, while NPL
improved to 0.8% (from 1.5%). Australia\u2019s rating distribution improved with a decrease of NPL\u2019s from 1.9% to
0.8% of the portfolio.
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 \u2018cover\u2019. While a cover may be an important mitigant of credit risk and an
alternative source of repayment, generally it is ING\u2019s practice to lend on the basis of the customer\u2019s
creditworthiness rather than exclusively 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
on 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 to ensure 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\u2019s 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 increased the haircuts applied to collateral values used in stage 3 individual provisions as at
31 December 2021 and 31 December 2022 to reflect the increased risk of inflated asset prices in certain
sectors of the economy. The haircut is applied on real estate, shipping and aviation collateral values 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, financial collateral (cash
and securities) and guarantees. ING obtains cover that is eligible for credit risk mitigation under CRR/CRDIV,
as well as cover that is not eligible. Collateral covering financial market transactions is valued on a daily
basis, and 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 performing and non-performing
portfolio. Our definition of non-performing is explained in detail in \u2018Credit restructuring\u2019 (below). For
additional insight, a breakdown of ING\u2019s portfolio by industry and geography is provided.
The next table gives an overview of the collateralisation of the ING\u2019s total portfolio.
Cover values including guarantees received (*)
in \u20ac million
Cover type
Collateralisation
2022
Outstandings
Mortgages
Financial
Collateral
Guarantees
Other covers
No Cover
Partially
covered
Fully covered
Consumer lending
353,323
700,961
5,626
24,231
42,817
6.2%
7.6%
86.2%
Business lending
379,070
167,122
29,501
118,294
438,864
37.5%
22.3%
40.2%
Investment and money market
141,432
0
5
1,213
2
99.1%
0.6%
0.3%
Total lending, investment and money market
873,824
868,083
35,132
143,738
481,683
34.8%
12.9%
52.3%
Pre-settlement
63,901
Total Bank
937,725
Cover values including guarantees received (*)
in \u20ac million
Cover type
Collateralisation
2021
Outstandings
Mortgages
Financial
Collateral
Guarantees
Other covers
No Cover
Partially
covered
Fully covered
Consumer lending
344,188
690,752
6,533
25,688
40,618
6.3%
7.6%
86.1%
Business lending
413,670
160,694
23,454
112,095
332,989
44.2%
20.2%
35.5%
Investment and money market
112,360
43
63
1,100
167
98.9%
0.8%
0.3%
Total lending, investment and money market
870,218
851,490
30,050
138,882
373,774
36.0%
12.8%
51.2%
Pre-settlement
43,531
Total Bank
913,749
Excluding the pre-settlement portfolio, 52.3% (2021: 51.2%) of ING\u2019s outstandings were fully collateralised in
2022. Since investments traditionally do not require covers, the percentage for \u2018no covers\u2019 in this portfolio is
above 95%. However, 99% of the investment outstanding is investment grade. Improved economic
conditions in ING\u2019s main markets contributed to improved collateral valuations, observed in consumer
lending. Relative to the overall developments in the housing markets and the impact on provisioning, note
the paragraphs on \u2018management adjustments\u2019 in the Loan Loss provisioning section, that were made to
reflect potential impact of higher inflation, higher rates and market uncertainty.
Consumer lending portfolio (*)
The consumer lending portfolio accounts for 37.7% (2021: 37.7%) of ING\u2019s total outstanding, primarily
consisting of residential mortgage loans and other consumer lending loans. As a result, 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\u2019s residential mortgage portfolio is in
the Netherlands (34.4%), Germany (28.0%), Belgium and Luxembourg (13.2%) and Australia (10.7%).
Relative to the overall developments in the housing markets and loan loss provisions for the mortgage
portfolio\u2019s, note that management adjustments are recognised to maintain an appropriate level of
provisions. See paragraph on \u2018management adjustments\u2019 in the loan loss provisioning section.
Business lending portfolio (*)
Business lending accounts for 40.4% (2021: 45.3%) of ING\u2019s total outstanding. Business lending presented in
this section does not include pre-settlement, investment and money market exposures.
Credit quality (*)
Credit risk categories (*)
Regular
Watch List
Restructuring1
Non-performing1
Possible ratings
1\u201319
1\u201319
11\u201320
20-22
Typical ratings
1\u201314
15\u201317
18\u201320
20-22
Deterioration in risk
Not significant
Significant
Significant
Significant
Significant intervention
Not required
Not required
Required
Required
Account Ownership
Front Office
Front Office
Front Office
Front Office
Credit Risk Management
Regular
Regular
Credit Restructuring
Credit Restructuring
Primary Manager
Front Office
Front Office
Credit Restructuring
Credit Restructuring
Accounting provisioning
Stage 1/2
Stage 1/2
Stage 2/3
Stage 3
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 is applicable to private
individuals, as well as business lending. An obligation is considered \u2018past due\u2019 if a payment of interest or
principal is more than one day late. ING aims to help its customers as soon as they are past due by
reminding them of their payment obligations. In its contact with the 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 cured, for example because the customer is unable or unwilling to pay, the contract
is sent to the recovery unit. The facility is downgraded to risk rating 20 (non-performing) when the facility or
obligor \u2013 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.
ING has aligned the regulatory concept of non-performing with that of the definition of default. Hence, in
WB, obligors are classified as non-performing when a default trigger occurs:
\u2022ING 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:
\u2022The borrower (or third party) has started insolvency proceedings.
\u2022A group company/co-borrower has NPL status.
\u2022Indication of fraud (affecting the company\u2019s ability to service its debt).
\u2022There is doubt as to the borrower\u2019s ability to generate stable and sufficient cash flows to service its
debt.
\u2022Restructuring of debt.
\u2022ING has granted concessions relating to the borrower\u2019s financial difficulty, the effect of which is a
reduction in expected future cash flows of the financial asset below current carrying amount.
\u2022The 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.
Further, WB has an individual name approach, using early warnings indicators to signal possible future
issues in debt service.\u00a0
Ageing analysis (past due but performing): Consumer lending portfolio by geographic area, outstandings (*)1,2
in \u20ac million
2022
2021
Region
Past due for
1\u201330 days
Past due for
31\u201360 days
Past due for
61\u201390 days
Past due for
>90 days
Total
Past due for
1\u201330 days
Past due for
31\u201360 days
Past due for
61\u201390 days
Past due for
>90 days
Total
Europe
Belgium
294
27
18
339
599
53
61
714
Germany
68
34
13
116
105
27
11
143
Luxembourg
43
4
2
48
73
3
1
1
78
Netherlands
36
10
5
50
31
9
3
43
Poland
59
8
4
71
35
5
3
43
Spain
13
9
5
27
13
7
5
26
France
2
2
2
2
United Kingdom
1
Rest of Europe
60
15
8
83
52
9
5
66
America
1
1
Australia
29
11
2
42
17
7
1
25
Total
604
119
57
780
927
123
91
1
1,142
1 Based on consumer lending. The amount of past due but performing financial assets in respect of non-lending activities was not significant.
2 The absolute and relative materiality thresholds used for determining a defaulted status do not apply for the purposes of classification as past due. Below these thresholds, arrears of more than 90 days are reported as past due.
The past due but performing outstanding of consumer lending decreased by \u20ac362 million. The largest
decrease was observed in Belgium (-\u20ac375 million), in term loans (-\u20ac188 million) and in Residential Mortgage
(-\u20ac113 million). Moderate increase was seen in Poland (+\u20ac28 million), Rest of Europe (+\u20ac17 million) and
Australia (+\u20ac16 million), with each mainly visible in the 1\u201330 days past due bucket.
Ageing analysis (past due but performing): Business lending portfolio by geographic area, outstandings (*)1
in \u20ac million
2022
2021
Region
Past due for
1\u201330 days
Past due for
31\u201360 days
Past due for
61\u201390 days
Past due for
>90 days
Total
Past due for
1\u201330 days
Past due for
31\u201360 days
Past due for
61\u201390 days
Past due for
>90 days
Total
Europe
Belgium
579
49
10
639
1,676
178
8
1,863
United
Kingdom
1,147
77
512
1,736
1,036
108
16
1,159
Luxembourg
302
1
303
586
270
1
856
Netherlands
730
30
15
775
553
16
4
574
Poland
279
35
14
329
94
5
2
1
102
Spain
95
1
96
France
83
6
90
36
5
41
Germany
44
16
60
5
2
7
Rest of Europe
474
239
1
1
715
571
57
1
1
629
America
1,901
67
19
1,986
2,076
71
2,146
Asia
553
48
601
276
25
302
Australia
359
61
4
2
426
327
17
1
345
Total
6,452
629
575
4
7,659
7,331
727
60
3
8,121
1 The absolute and relative materiality thresholds used for determining a defaulted status do not apply for the purposes of classification as past due. Below these thresholds, arrears of more than 90 days are reported as past due.
Total past due but performing outstanding of business lending decreased by \u20ac462 million. These were
mainly contributed by decreased outstanding in the 1-30 days (\u20ac879 million) past due bucket, partly offset
by increased outstanding in 61\u201390 days past due bucket (\u20ac515 million). The top three areas of decrease in
the 1-30 days bucket were Belgium (\u20ac1,097 million), Luxembourg (\u20ac284 million) and America (\u20ac175 million).
The top three areas of increase in the 1-30 days bucket were Asia (\u20ac277 million), Poland (\u20ac185 million) and
the Netherlands (\u20ac177 million).
Credit restructuring (*)
Global Credit Restructuring (GCR) is the dedicated and independent department that deals with non-
performing loans and loans that hold a reasonable probability that ING will end up with a loss, if no specific
action is taken. GCR handles accounts or portfolios requiring an active approach, which may include
renegotiation of terms and conditions and business or financial restructuring. The loans are managed by
GCR or by units in the various regions and business units. ING uses three distinct statuses to categorise the
management of clients with (perceived) deteriorating credit risk profiles, i.e. there is increasing doubt as to
the performance and the collectability of the client\u2019s contractual obligations:
\u2022Watch list: Usually, a client is first classified as watch list when there are concerns of any potential or
material deterioration in credit risk profile that may affect the ability of the client to adhere to its debt
service obligations or to refinance its existing loans. Watch List status requires more than usual
attention, increased monitoring and quarterly reviews. Some clients with a Watch List status may
develop into a Restructuring status or even a Recovery status.
\u2022Restructuring: A client is classified in restructuring when there are concerns about the client\u2019s financial
stability, credit worthiness, and/or ability to repay, but where the situation does not require the
termination or acceleration of facilities or the liquidation of collateral. ING\u2019s actions aim to maintain the
going concern status of the client by:
\u2022restoring the client\u2019s financial stability;
\u2022supporting the client\u2019s turnaround;
\u2022restoring the balance between debt and equity; and
\u2022restructuring the debt to a sustainable situation.
\u2022Recovery: A client is classified as in recovery when ING and/or the client concludes that the client\u2019s
financial situation cannot be restored and a decision is made to terminate the (credit) relationship or
even to enter into bankruptcy. ING prefers an amicable exit, but will enforce and liquidate the collateral
or claim under the guarantees if deemed necessary.
Watch list, restructuring and recovery accounts are reviewed at least quarterly by the front office, GCR and
the relevant credit risk management executives.
Forbearance (*)
Forbearance occurs when a client is unable to meet their financial commitments due to financial difficulties
they face or are about to face and ING grants concessions towards them. Forborne assets are assets in
respect of 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 with the aim of maximising the client\u2019s
repayment ability and therewith avoiding a default situation or helping the client to return to a performing
situation.
For ING retail units, clear criteria has 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
on a portfolio (retail) basis.
All exposures are eligible for forbearance measures, i.e. both performing (Risk ratings 1-19) and non-
performing (risk ratings 20-22) exposures. 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 \u20ac million
2022
2021
Business line
Outstanding
s
Of which:
performin
g
Of which:
non-
performing
% of total
portfolio
Outstanding
s
Of which:
performin
g
Of which:
non-
performing
% of total
portfolio
Wholesale Banking
8,359
5,880
2,478
2.7%
9,798
7,455
2,343
3.1%
Retail Banking
8,080
4,973
3,107
1.6%
10,018
6,339
3,679
2.1%
Total
16,438
10,853
5,585
2.0%
19,816
13,793
6,022
2.5%
Wholesale Banking: Forborne portfolio by economic sector (*)
in \u20ac million
2022
2021
Industry
Outstandings
Of which:
performing
Of which: non-
Outstandings
Of which:
performing
Of which: non-
performing
performing
Natural Resources
1,239
603
636
2,047
1,177
870
Real Estate
2,000
1,917
84
1,665
1,570
95
Transportation & Logistics
1,073
868
205
1,336
1,061
274
Food, Beverages & Personal Care
1,082
543
539
1,202
749
452
Services
697
665
32
793
687
106
Automotive
172
125
46
581
535
46
Utilities
469
255
214
407
271
136
General Industries
255
176
80
366
321
45
Retail
302
227
76
361
304
57
Chemicals, Health &
Pharmaceuticals
191
168
23
347
324
22
Builders & Contractors
168
94
74
177
135
41
Other
710
240
469
516
318
197
Total
8,359
5,880
2,478
9,798
7,455
2,343
The main concentration of forborne assets in a single country was in the United Kingdom with 12% (2021:
14%) of the total WB forborne assets and 13% (2021: 18%) of the total non-performing forborne assets.
WB forborne assets decreased by \u20ac1.44 billion compared to 2021, of which the performing forborne assets
decreased by \u20ac1.58 billion. This was visible across all industries (except for Real estate) and locations (except
for Belgium and Poland).
WB's forborne assets were mainly concentrated in natural resources, real estate, transportation & logistics
and food beverages & personal care. These four economic sectors accounted for 65% of the total WB
forborne outstandings. During 2022, an increase in forborne assets was visible in the real estate industry (+\u20ac
0.3 billion), offset by a decrease in Natural Resources (-\u20ac0.8 billion), Automotive (-\u20ac 0.4 billion), Food,
Beverages & Personal Care (-\u20ac0.1 billion) and Transportation & Logistics (-\u20ac0.2 billion).
Retail Banking (*)
As of the end of December 2022, Retail Banking forborne assets totalled \u20ac8.1 billion, which represented 1.6%
of the total Retail Banking portfolio.
Retail Banking: Forborne portfolio by geographical area (*)
in \u20ac million
2022
2021
Region
Outstandings
Of which:
performing
Of which: non-
Outstandings
Of which:
performing
Of which: non-
performing
performing
Europe
Netherlands
2,832
2,043
789
4,171
3,224
947
Belgium
2,644
1,331
1,314
3,319
2,035
1,284
Germany
804
610
194
497
306
191
Poland
588
309
279
450
152
298
Turkey
64
31
32
146
97
49
Italy
131
52
79
129
47
82
Romania
124
53
71
115
49
66
Spain
35
15
20
35
11
23
Rest of Europe
73
48
25
99
68
30
America
13
12
9
7
2
Asia
3
1
1
3
1
1
Australia
768
467
302
1,045
340
705
Africa
1
1
Total
8,080
4,973
3,107
10,018
6,339
3,679
The main concentration of forborne assets in a single country was in the Netherlands with 35% (2021: 42%)
of total Retail Banking forborne assets and 25% (2021: 26%) of the non-performing forborne assets. Next to
that, Belgium had to 33% (2021: 33%) of the total Retail forborne assets.
Non-performing loans (*)
ING\u2019s loan portfolio is under constant review. Loans to obligors that are considered more than 90 days past
due and above applicable thresholds are reclassified as non-performing. For business lending portfolios,
there generally are reasons for declaring a loan non-performing prior to the obligor being 90 days past due.
These reasons include, but are not limited to, ING\u2019s assessment of the customer\u2019s perceived inability to meet
its financial obligations, or the customer filing for bankruptcy or bankruptcy protection.
The table below represents the breakdown by industry of credit risk outstandings that have been classified
as non-performing.
Non-performing Loans: outstandings by economic sector and business lines (*)1
in \u20ac million
Wholesale
Banking
Retail Benelux
Retail
Challengers &
Growth Markets
Corporate Line
Total
Industry
2022
2021
2022
2021
2022
2021
2022
2021
2022
2021
Private Individuals
2,174
2,424
1,954
2,445
4,129
4,869
Natural Resources
1,369
1,325
34
46
17
27
1,421
1,398
Food, Beverages & Personal
Care
672
681
438
428
122
130
1,233
1,239
Transportation & Logistics
367
575
165
180
51
52
583
807
Services
119
224
448
499
61
63
628
786
Real Estate
172
132
486
495
54
59
712
686
General Industries
114
66
268
272
100
123
482
461
Builders & Contractors
139
93
244
224
110
112
493
429
Retail
98
140
107
103
39
47
244
290
Utilities
387
199
7
10
7
11
401
221
Chemicals,
Health &
Pharmaceuticals
175
65
115
70
20
22
310
158
Telecom
288
28
12
1
3
3
303
31
Other
440
305
260
282
52
58
753
646
Total
4,340
3,833
4,759
5,035
2,592
3,153
11,691
12,021
1 Based on Lending and Investment outstandings.
Non-performing Loans: outstandings by economic sectors and geographical area (*)
in \u20ac million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United Kingdom
France
Luxembourg
Rest of Europe
America
Asia
Australia
Africa
2022
Private Individuals
574
1,538
739
185
194
4
11
36
470
3
4
370
1
4,129
Natural Resources
57
33
14
53
432
77
649
85
21
1,421
Food, Beverages & Personal Care
310
179
24
109
173
7
228
77
126
1,233
Transportation & Logistics
232
58
1
36
47
20
2
154
24
7
1
583
Services
136
375
2
43
5
3
2
21
40
628
Real Estate
89
376
54
84
25
19
7
47
11
712
General Industries
127
142
17
78
31
2
26
58
482
Builders & Contractors
65
187
2
86
20
101
32
493
Retail
31
85
38
26
18
1
13
22
7
2
244
Utilities
6
6
26
23
17
194
129
401
Chemicals, Health & Pharmaceuticals
51
100
2
15
14
100
28
310
Telecom
24
1
3
5
270
303
Other
40
232
48
38
50
10
79
75
130
51
753
Total
1,742
3,312
899
710
246
344
196
145
1,578
654
1,324
470
72
11,691
Non-performing Loans: outstandings by economic sectors and geographical area (*)
in \u20ac million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United Kingdom
France
Luxembourg
Rest of Europe
America
Asia
Australia
Africa
Private Individuals
776
1,578
721
206
232
8
16
35
497
3
4
791
1
4,869
Natural Resources
67
44
20
27
116
577
421
90
37
1,398
Food, Beverages & Personal Care
299
176
25
111
226
7
2
37
228
128
1
1,239
Transportation & Logistics
385
55
1
35
47
20
3
165
29
49
17
807
Services
199
385
45
5
66
4
22
52
6
1
786
Real Estate
167
303
61
88
21
21
9
16
686
General Industries
110
173
18
91
4
3
34
27
461
Builders & Contractors
43
188
4
83
2
58
50
429
Retail
40
70
34
30
56
1
21
21
14
2
290
Utilities
8
9
71
26
28
30
48
221
Chemicals, Health & Pharmaceuticals
63
48
2
16
29
158
Telecom
13
1
2
10
1
5
31
Other
42
226
129
41
2
14
15
38
37
34
1
67
646
Total
2,212
3,255
1,005
768
284
447
119
87
1,056
1,060
656
966
105
12,021
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: (1) to the economic outlook and (2) 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 \u2018credit-impaired\u2019
financial assets under IFRS 9 (Stage 3). ING has also aligned its definition of default between IFRS9 and the
regulatory technical standards (RTS) and EBA guidelines. More information can be found in section 1.7.8 of
the Consolidated financial statements.
Climate and environmental risks in IFRS 9 models (*)
ING is evolving in its credit risk management framework to further develop a better understanding of
emerging climate and environmental risks. Banks, including ING, are in the process of collecting and
analysing empirical historical data and moving towards embedding these emerging risks into their credit
risk management processes and eventually into their IFRS 9 ECL models.
In 2022, ING continued to enhance the tools used to identify and assess climate and environmental (C&E)
risks in our portfolio. We created C&E risk sector heatmaps for both WB and Retail Banking that facilitated
the identification of exposure to C&E risks by means of scores assigned to transition and physical risk
drivers. They also enabled us to understand the magnitude of the C&E risk impact on a sectoral level and
pinpointed sectors with highest C&E risk exposure. In the past two years, we have improved our
understanding of the physical risk impact of climate events on our mortgage portfolio.
The integration of quantified inputs from the heatmaps into risk modelling has not yet been implemented
for a number of reasons including a lack of data to assess C&E risks at a client level. Refer to the section
'Environmental, social and governance risk' for further details on the heatmaps and the related challenges.
At this point in time it is not possible to incorporate climate risk separately into IFRS 9 ECL models given the
lack of sufficient empirical historical data and the above-mentioned limitations in the risk assessments on
client level. Where climate and environmental factors have impacted the economy in the recent past or
present, these impacts are however currently implicitly embedded in ING's IFRS9 ECL models through the
projected macroeconomic indicators (e.g. GDP growth and unemployment rates). We note that our ECL
models are primarily sensitive to the short-term economic outlook as we use a three-year time horizon for
macroeconomic outlook, after which a mean reversion approach is applied.
With regard to our evaluation of climate-related matters, where such events have already occurred (e.g.
floods), the impact of such events are individually assessed in the calculation of Stage 3 Individual provisions
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.
As of 31 December 2022, reported ECL includes a management adjustment of \u20ac10 million to address the
increased credit risk in ING\u2019s livestock farming portfolio resulting from nitrogen reduction targets introduced
by the Dutch Government. Refer to the section 'Management overlays' for further details.
Portfolio quality (*)
The table below describes the portfolio composition over the different IFRS 9 stages and rating classes. The
Stage 1 portfolio represents 91.5% (2021: 93.5%) of the total gross carrying amounts, mainly composed of
investment grade, while Stage 2 makes up 7.3% (2021: 5.2%) and Stage 3 makes up 1.2% (2021: 1.3%) of
the total gross carrying amounts, respectively.
Gross carrying amount per IFRS 9 stage and rating class (*)1,2,3
in \u20ac million
12-month ECL (Stage 1)
Lifetime ECL not credit
impaired (Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
2022
Rating class
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Investment grade
1 (AAA)
100,885
2
284
101,169
2
2-4 (AA)
98,181
5
2,493
1
100,675
6
5-7 (A)
177,617
23
4,596
4
182,214
27
8-10 (BBB)
320,972
98
14,714
29
335,687
127
Non-Investment grade
11-13 (BB)
155,910
277
17,365
91
173,275
368
14-16 (B)
23,649
168
19,386
471
43,035
639
17 (CCC)
7,671
8
4,572
194
12,244
202
Substandard grade
18 (CC)
5,198
595
5,198
595
19 (C)
2,116
293
2,116
293
Non-performing loans
20-22 (D)
11,708
3,841
11,708
3,841
Total
884,886
581
70,725
1,679
11,708
3,841
967,319
6,101
1Compared to the credit risk portfolio, the differences are mainly undrawn committed amounts (\u20ac150.1 billion) and other positions (\u20ac4.4 billion) not included in Credit outstandings and non-IFRS 9 eligible assets (\u20ac116.1 billion, mainly guarantees, letters of credit and pre-
settlement exposures) included in Credit outstandings.
2For a reference to the Notes in the consolidated financial statements, we refer to the table \u2018Reconciliation between credit risk categories and financial position\u2019.
3IAS 37 provisions are established for non-credit replacement guarantees not in the scope of IFRS 9. Total IAS 37 provisions (\u20ac109 million) are excluded.
Gross carrying amount per IFRS 9 stage and rating class (*)1,2,3
in \u20ac million
12-month ECL (Stage 1)
Lifetime ECL not credit
impaired (Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
2021
Rating class
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Investment grade
1 (AAA)
107,788
3
107,788
3
2-4 (AA)
106,673
5
197
106,870
5
5-7 (A)
152,255
17
1,001
1
153,256
17
8-10 (BBB)
328,301
73
7,232
14
335,533
87
Non-Investment grade
11-13 (BB)
162,912
208
14,679
86
177,592
294
14-16 (B)
26,852
185
17,931
404
44,783
589
17 (CCC)
5,377
10
4,354
198
9,730
207
Substandard grade
18 (CC)
2,314
173
2,314
173
19 (C)
1,769
142
1,769
142
Non-performing loans
20-22 (D)
12,072
3,851
12,072
3,851
Total
890,158
501
49,476
1,016
12,072
3,851
951,707
5,368
1Compared to the credit risk portfolio, the differences are mainly undrawn committed amounts (\u20ac133.3 billion) not included in Credit outstandings and non-IFRS 9 eligible assets (\u20ac95.1 billion, mainly guarantees, letters of credit and pre-settlement exposures) included in Credit
outstandings.
2For a reference to the Notes in the consolidated financial statements, we refer to the table \u2018Reconciliation between credit risk categories and financial position\u2019.
3IAS 37 provisions are established for non-credit replacement guarantees not in the scope of IFRS 9. Total IAS 37 provisions (\u20ac114.4 million) are excluded.
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:
\u2022Stage 3 gross carrying amount decreased by \u20ac0.4 billion from \u20ac12.1 billion as of 31 December 2021 to\u00a0 \u00a0
\u20ac11.7 billion as of 31 December 2022, mainly as a result of write-offs and generally low inflow into NPL
(credit impaired) in 2022. Stage 3 provisions remained however flat at \u20ac3.8 billion, reflecting worsened
macroeconomic outlook.
\u2022Stage 2 gross carrying amount increased by \u20ac21.2 billion from \u20ac49.5 billion as of 31 December 2021 to\u00a0
\u20ac70.7 billion. This is mainly caused by the significant lifetime PD trigger (\u20ac14.8 billion) driven by
downgrades of the Russian portfolio and economic turmoil. Furthermore, the implementation of a
stricter PD backstop methodology has driven the increase in Stage 2 gross carrying amounts,(\u20ac11.4
billion, mainly investment grade exposures). Other Stage 2 triggers such as the 30 Days past due and
watchlist triggers (\u20ac1.2 billion and \u20ac1.1 billion respectively), were more than offset by the forbearance
trigger (-\u20ac6.4 billion). For the latter, a two-year probation period is required before a client can move back
to Stage 1 and the decrease relates to the fact that the start of the Covid-19 pandemic is now more than
two years ago.
\u2022Stage 2 provisions increased by \u20ac0.7 billion to \u20ac1.7 billion as of 31 December 2022, largely driven by the
migration of the Russian portfolio to Stage 2 and worsened macro-economic outlook. The
implementation of the threefold increase in lifetime PD backstop trigger had limited impact on provisions
as\u00a0 it mainly impacts investment grade exposures.
\u2022In 2022, the largest increases in Stage 2 by sector were in Non-bank financial institutions, Real estate,
Chemicals health & pharmaceuticals and Lower public administration of \u20ac3.5 billion, \u20ac2.8 billion, \u20ac2.5
billion and \u20ac2.1 billion respectively The increase in Stage 2 for non-bank financial institutions mainly
resulted from the implementation of the threefold increase in lifetime PD backstop trigger, that mainly
impacts investment grade exposures. Other drivers were downgrades in the Russian portfolio and
economic turmoil. The largest decreases were in Automotive and Transportation & logistics with \u20ac0.9
billion and \u20ac0.6 billion releases respectively. The largest Stage 2 outstandings per economic sector as of
31 December 2022 are Real estate, Services, Natural resources and Non-bank financial institutions
representing 10%, 7%, 7% and 7% of the total Stage 2 gross carrying amounts respectively.
Additional information on macroeconomic scenarios is included in the section \u2018Macroeconomic scenarios
and sensitivity analysis of key sources of estimation uncertainty\u2019.
Changes in gross carrying amounts and loan loss provisions (*)1, 2
in \u20ac million
12-month ECL (Stage 1)
Lifetime ECL not credit
impaired (Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
2022
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Opening balance
890,158
501
49,476
1,016
12,072
3,851
951,707
5,368
Transfer into 12-month ECL (Stage 1)
8,513
21
-8,105
-142
-408
-47
-168
Transfer into lifetime ECL not credit impaired (Stage 2)
-42,439
-76
43,222
730
-784
-90
564
Transfer into lifetime ECL credit impaired (Stage 3)
-3,524
-8
-1,216
-82
4,740
1,234
1,144
Net remeasurement of loan loss provisions
8
223
199
430
New financial assets originated or purchased
248,443
228
248,443
228
Financial assets that have been derecognised
-138,250
-70
-11,312
-94
-2,805
-215
-152,366
-379
Net drawdowns and repayments
-78,015
-1,340
21
-79,334
Changes in models/risk parameters
-8
13
25
30
Increase in loan loss provisions
95
648
1,106
1,849
Write-offs
-1
-1,129
-1,129
-1,130
-1,130
Recoveries of amounts previously written off
71
71
Foreign exchange and other movements
-15
16
-58
-57
Closing balance
884,886
581
70,725
1,679
11,708
3,841
967,319
6,101
1Stage 3 Lifetime credit impaired provision includes \u20ac4 million on Purchased or Originated Credit Impaired.
2The addition to the loan provision (in the consolidated statement of profit or loss) amounts to \u20ac1.861 million of which \u20ac1.850 million related to IFRS 9 eligible financial assets, -\u20ac3 million related to non-credit replacement guarantees and \u20ac14 million to modification gains and
losses on restructured financial assets.
Changes in gross carrying amounts and loan loss provisions (*)1,2
in \u20ac million
12-month ECL (Stage 1)
Lifetime ECL not credit
impaired (Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
2021
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Opening balance
844,020
581
59,313
1,476
13,398
3,797
916,732
5,854
Transfer into 12-month ECL (Stage 1)
15,157
20
-14,322
-279
-835
-54
-313
Transfer into lifetime ECL not credit impaired (Stage 2)
-19,737
-32
20,537
206
-800
-74
100
Transfer into lifetime ECL credit impaired (Stage 3)
-2,166
-13
-1,589
-96
3,755
820
712
Net remeasurement of loan loss provisions
-130
-228
404
46
New financial assets originated or purchased
208,501
149
208,501
149
Financial assets that have been derecognised
-125,819
-73
-11,935
-104
-1,898
-237
-139,652
-414
Net drawdowns and repayments
-29,799
-2,526
-694
-33,019
Changes in models/risk parameters
12
41
130
184
Increase in loan loss provisions
-67
-460
989
462
Write-offs
-854
-854
-854
-854
Recoveries of amounts previously written off
45
45
Foreign exchange and other movements
-13
1
-125
-138
Closing balance
890,158
501
49,476
1,016
12,072
3,851
951,707
5,368
Macroeconomic scenarios and sensitivity analysis of key sources of estimation
uncertainty (*)
Methodology (*)
Our methodology in relation to the adoption and generation of macroeconomic scenarios is described in
this section. We continue to follow this methodology in generating our probability-weighted ECL, with
consideration of alternative scenarios and management adjustments supplementing this ECL where, in
management's opinion, 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\u2019s 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). The Oxford Economics\u2019 Global Economic Model (OEGEM) is used to complement the consensus with
consistent projections for variables for which there are no consensus estimates available (most notably
house prices and \u2013 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 two panels of ING experts. The first panel
consists of economic experts from Global Markets Research and risk and modelling specialists, while the
second panel consists of relevant senior managers.
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 OEGEM.
To understand the baseline level of uncertainty around any forecast, Oxford Economics keeps track of all its
deviations (so called forecast errors) of the past 20 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, Oxford Economics 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 for the 90th percentile of that distribution because this
corresponds with the way risk management earnings-at-risk is defined within the Bank. The upside scenario
is represented by the 10th percentile of the distribution. The applicable percentiles of the distribution imply
a 20% probability for each alternative scenario. Consequently, the baseline scenario has a 60% probability
weighting. Please note that, given their technical nature, the downside and upside scenarios are not based
on an explicit specific narrative.
Macroeconomic scenarios applied (*)
The loan loss provisions are based on the December 2022 consensus forecasts.
Baseline assumptions (*)
The general picture that the consensus conveys is that global economic growth is being challenged by
persistent inflationary pressures which are being met by central banks lifting interest rates. The consensus
expects recession to occur in many European countries in 2022-2023, while the US economy is anticipated
to stagnate. Economic growth is expected to resume in the years thereafter as inflation normalises and
monetary conditions become less tight. In economies that have experienced a notable surge in house prices
during the pandemic and its aftermath, affordability pressures amid the higher interest rate environment
are expected to lead to a moderation of growth or price declines in the near to medium-term.
The December 2022 consensus expects global output (as measured by the weighted average GDP growth
rate of ING's 25 main markets) to slow further from 6.0% in 2021, to 2.5% in 2022 and 1.3% in 2023. For
2024-2025, economic growth is expected to pick up again to 2.4%.
The US economy is expected to stagnate in 2023 as high inflation, rising interest rates, supply chain
difficulties, softer labour market dynamics, and global headwinds weaken demand. Consumer spending
growth is under downward pressure as slower employment gains curb income growth and pandemic-
related savings have diminished. With the headwinds seen fading slowly, the US economy is expected to
gather strength again in 2024. The consensus expects the growth rate of the US economy to fall from 1.9%
in 2022 to 0.2% in 2023 and to recover to on average 1.7% in 2024-2025.
Eurozone economies are dealing with the consequences of the ongoing war in Ukraine, broadening
inflationary pressures and a general deterioration of sentiment across industries and consumers.
The ECB has shifted to a hawkish tilt but government fiscal support targeting higher energy prices is
softening the economic pain in many countries. Overall, the eurozone economy is forecasted to stagnate in
2023, but Germany \u2013 as well as some other countries \u2013 faces recession reflecting its large exposure to gas
supply cuts, relatively large manufacturing sector and exposure to a slower growing Chinese economy.
Elsewhere in Europe, the outlook is equally bleak. In Poland, economic fallout from the war in Ukraine and
the related energy price shock point to a significant economic slowdown from 5.0% in 2022 to 1.0% in 2023.
However, the scope for a rise in unemployment is seen to be limited as the Polish labour market remains
tight, partially due to population ageing. As in the eurozone, the central bank is tightening monetary policy,
but fiscal policy remains expansive. The consensus expectation for Turkey is also for economic growth to
ease as the economic slowdown in Europe weighs on external demand and high inflation persists. The
consensus sees economic growth in Turkey slowing from 5.2% in 2022, to on average 2.4% in 2023-2024
and increasing again to 3.0% in 2025.
After a weak growth rate of 3.1% in 2022, economic growth in China is expected to pick-up to on average
4.7% in 2023-2025. The drag exerted by the authorities\u2019 Covid-19 policies is assumed to moderate, while
state investment will support demand. However, the real estate downturn continues to weigh on the
outlook.
The global economic slowdown, together with tighter monetary policy and high inflation is weighing on
economic growth in Australia. After growing by 3.8% in 2022, the outlook sees a growth rate of 1.8% for
2023-2024 and some pick-up to 2.6% for 2025. However, despite the economic slowdown, conditions in the
labour market are expected to remain tight.
When compared to the December 2021 consensus forecast, used for the 2021 Annual Report, the December
2022 forecast assumes much weaker economic circumstances. Global GDP was expected to increase by
2.5% in 2022 (compared to 4.1% assumed before) and 1.3% in 2023 (3.1% assumed before). The downgrade
reflects the economic impacts of the war in Ukraine and tighter monetary conditions.
Alternative scenarios and risks (*)
Because of the possible consequences of the war in Ukraine, uncertainty surrounding the forecasts is higher
than usual. This relates in particular to uncertainty about European energy supplies and worries about more
persistent high inflation. To take the general increase of uncertainty surrounding the forecasts into account,
the dispersion of the alternative scenarios has been set again at the widened level used for year-end 2021
provisioning (the half-widened dispersion). As a result, the near-term dispersion of the forward-looking
distributions (from which the alternative scenarios are derived) is larger than in normal times. Meanwhile, at
the end of the scenario horizon the dispersion has remained unchanged and hence is comparable to
scenarios generated prior to the war in Ukraine.
The baseline scenario assumes a significant easing of inflation in 2023 and relatively resilient labour
markets. However, a longer period of weakness, due to stickier inflation and more aggressive monetary
policy tightening that triggers a more notable softening of the labour market and greater falls in financial
asset and property prices, could lead to a more protracted and deeper economic slowdown. As such, the
balance of risks to the baseline outlook is negative and the alternative scenarios have a downward skew in
line with the outcomes of Oxford Economics\u2019 Global Risk Survey. The downward skew is less negative
compared to what has been applied for year-end 2021 at which time \u2013 set against a higher baseline \u2013 apart
from higher inflation, worries about supply chain disruptions and further corona virus waves were being
seen as top near-term downside risks.
The downside scenario \u2013 though technical in nature \u2013 sees for most countries a fast deceleration of
economic growth followed by a recession. Unemployment increases strongly in this scenario and house
prices in most countries show outright falls. The downside scenario captures a possible escalation of the war
in Ukraine and a more pronounced and prolonged surge in inflation.
The upside scenario \u2013 while equally technical in nature \u2013 reflects the possibility of a better economic outturn
if the war in Ukraine ended quickly, fuelling a rebound in consumer spending. The recovery is further
supported by looser monetary policy as weaker inflation prompts central banks to hold back tightening.
Management adjustments applied this year (*)
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 can also be applied
where the impact of the updated macroeconomic scenarios is over- or under-estimated by the IFRS 9
models.
ING has internal governance frameworks and controls in place to assess the appropriateness of all
management adjustments.
Management adjustments to ECL models (*)
in \u20ac million
2022
2021
Economic sector based adjustments
71
341
Second order impact adjustments
334
Payment holiday adjustments
32
Mortgage portfolio adjustments
105
124
Other Post Model Adjustments1
-57
121
Total management adjustments
453
618
1 Prior period figure has been updated to conform to current year presentation.
December 2021 management adjustments included an economic sector-based management adjustment
of \u20ac341 million because of delays in defaults occurring in the Covid-19-related crisis, mainly as a result of
government support programmes. In determining the sector-based management adjustment, a heatmap
approach was used to adjust the probability of default for sectors where businesses are significantly
impacted by the pandemic. In 2022, as it became clearer the Covid-19 pandemic had less impact than
expected on the number of defaults, the economic sector-based management adjustment has been largely
released and while at the same time management adjustments for the second order impact of the war in
Ukraine were introduced (see below). Of the remaining economic sector based adjustments of \u20ac71 million as
of 31 December 2022, \u20ac61 million relates to Business Banking clients that have benefited from Covid-19
related government support programmes in the Netherlands such as deferral of tax payments that ended in
the second half of 2022, and \u20ac10 million relates to an overlay for livestock farming sector in the
Netherlands. In the Netherlands, nitrogen reduction targets affect the livestock farming sector mainly
because of endorsed closing activities nearby Natura 2000 areas and because of expected transition to
other business models in the sector. As these specific risks are not incorporated in the model ECL, an overlay
was recognised.
ING has performed an assessment for both WB and Retail Banking on the impact of the war in Ukraine, the
increase in energy prices and other second order macroeconomic developments such as an increase in
inflation and rising interest rates. This resulted in a second order impact overlay of \u20ac334 million in total as of
31 December 2022, of which \u20ac164 million relates to Retail Banking segments and \u20ac170 million to the
Wholesale Banking segment.
As the credit risk models assume that these second order effects materialise via other risk drivers such as
GDP and unemployment rates with a delay, an overlay approach was determined to timely estimate the
Expected Credit Losses related to reduced repayment capacity and affordability for private individuals and
business clients in the Retail Banking segment. The \u20ac164 million includes an overlay of \u20ac22 million for clients
participating in the payment holiday scheme in Belgium that was introduced in 2022 to support customers
impacted by the inflation and high energy prices.
In WB, it was assessed that the economic effects of Covid-19 was not the highest risk anymore and that
other risks have emerged \u2013 mainly high energy prices, high interest rates and inflation, supply chain issues
and staffing shortages. A heatmap approach was used to adjust the probability of default for clients that
are expected to be significantly impacted by these emerged risks.
Given Covid-19-related payment holiday programmes have generally expired, this management
adjustment has been fully released in 2022.
Model based ECL of mortgage portfolios has decreased over the past years and until the third quarter of
2022, driven by significant increase of house prices in various countries. Management adjustments of \u20ac105
million in total, mainly in Stage 2 and 3, have been recognised by ING in the Netherlands, Belgium, Germany
and Australia to maintain an appropriate level of ECL and reflecting a potential impact of market
uncertainty on the recovery value of residential real estate (impacted by higher inflation and interest rates).
The management adjustment for the Netherlands and part of the Belgian mortgage portfolio was
determined by developing three alternative macroeconomic forecast scenarios, in addition to the consensus
base, up- and down-scenarios, that reflect a correction in the house prices in the next three years bringing it
back in line with the historical growth rate. For other countries, management adjustments were determined
by calculating the impact of lower house prices on LTVs and LGDs.
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. These result
from both regular model maintenance and ING\u2019s multiyear programme to update ECL models for the new
definition of default. These adjustments will be removed once updates to the specific models have been
implemented.
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 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. ING also observes that,
in general, the WB business is more sensitive to the impact of forward-looking macroeconomic scenarios.
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.
Sensitivity analysis as at December 2022\u00a0 (*)
2023
2024
2025
Un-weighted
ECL (\u20ac mln)
Probability-
weighting
Reportable
ECL (\u20ac mln)1
Netherlands
Upside scenario
Real GDP
2.2
2.3
2.9
274
20%
381
Unemployment
4.0
3.9
3.8
HPI
13.0
11.8
2.5
Baseline Scenario
Real GDP
0.2
1.4
1.8
349
60%
Unemployment
4.5
4.8
4.9
HPI
3.7
3.7
2.4
Downside scenario
Real GDP
-4.2
0.7
0.9
583
20%
Unemployment
6.4
7.8
8.7
HPI
-8.0
-6.5
2.2
Germany
Upside scenario
Real GDP
1.7
2.3
1.8
606
20%
745
Unemployment
2.6
2.2
1.8
HPI
0.6
3.9
6.2
Baseline Scenario
Real GDP
-0.7
1.4
1.5
726
60%
Unemployment
3.2
3.1
3.1
HPI
-1.8
0.9
2.7
Downside scenario
Real GDP
-4.8
0.1
1.0
942
20%
Unemployment
4.8
5.3
5.6
HPI
-6.2
-3.3
-1.4
Belgium
Upside scenario
Real GDP
1.7
2.1
2.1
535
20%
596
Unemployment
5.5
5.5
5.3
HPI
2.3
2.6
3.1
Baseline Scenario
Real GDP
0.0
1.6
1.8
584
60%
Unemployment
6.1
6.3
6.1
HPI
1.4
2.2
2.5
Downside scenario
Real GDP
-3.2
1.0
1.5
692
20%
Unemployment
7.5
8.5
8.4
HPI
-1.2
0.9
1.2
United States
Upside scenario
Real GDP
3.0
1.5
3.4
100
20%
221
Unemployment
3.4
2.8
2.5
HPI
3.7
7.4
8.1
Baseline Scenario
Real GDP
0.2
1.1
2.3
188
60%
Unemployment
4.3
4.4
3.9
HPI
2.5
2.2
2.8
Downside scenario
Real GDP
-4.1
0.2
0.6
442
20%
Unemployment
6.4
7.7
8.2
HPI
-1.2
-3.8
-3.5
1 Excluding management adjustments.
Sensitivity analysis as at December 2021 (*)
2022
2023
2024
Un-weighted
ECL (\u20ac mln)
Probability-
weighting
Reportable
ECL (\u20ac mln)1
Netherlands
Upside scenario
Real GDP
5.1
2.9
2.7
259
20%
307
Unemployment
3.2
2.9
2.9
HPI
23.3
10.9
0.9
Baseline Scenario
Real GDP
3.4
2.0
1.7
289
60%
Unemployment
3.7
4.1
4.3
HPI
13.1
2.8
0.8
Downside scenario
Real GDP
-1.5
1.2
0.7
411
20%
Unemployment
5.6
6.8
7.8
HPI
0.3
-7.7
0.6
Germany
Upside scenario
Real GDP
6.2
3.1
1.6
457
20%
483
Unemployment
2.9
2.2
1.9
HPI
12.9
7.9
5.3
Baseline Scenario
Real GDP
4.0
2.3
1.4
475
60%
Unemployment
3.4
3.1
3.1
HPI
10.4
4.6
1.9
Downside scenario
Real GDP
-0.6
0.9
0.8
535
20%
Unemployment
5.0
5.4
5.7
HPI
5.3
0.4
-2.1
Belgium
Upside scenario
Real GDP
4.6
2.5
2.0
364
20%
393
Unemployment
5.6
5.6
5.9
HPI
3.9
2.7
2.9
Baseline Scenario
Real GDP
3.1
2.0
1.8
383
60%
Unemployment
6.1
6.3
6.3
HPI
3.0
2.3
2.3
Downside scenario
Real GDP
-0.4
1.4
1.4
451
20%
Unemployment
7.6
8.6
9.0
HPI
0.4
1.0
1.0
United States
Upside scenario
Real GDP
6.7
2.4
3.1
28
20%
75
Unemployment
3.5
2.5
2.4
HPI
10.4
8.1
8.7
Baseline Scenario
Real GDP
4.0
2.5
2.1
55
60%
Unemployment
4.0
3.7
3.7
HPI
9.1
3.0
3.3
Downside scenario
Real GDP
-0.7
1.1
0.3
183
20%
Unemployment
6.5
7.4
8.0
HPI
5.3
-3.2
-3.0
1 Excluding management adjustments.
When compared to the sensitivity analysis of 2021, the macroeconomic inputs for 2022 and 2023 are less
favourable, driven by a worsened macroeconomic outlook as a result of the war in Ukraine as well as its
indirect effects such as inflation and increasing interest rates. Both 2021 and 2022 contain half-widened
dispersion around upside and downside scenarios, for 2021. This reflects continuing but decreased short-
term uncertainty relating to the impact of Covid-19 and for 2022 reflecting short-term uncertainty around
the war in Ukraine and its indirect effects. The increase in reportable ECL compared to 2021 is mainly caused
by higher model ECL amounts as per December 2022 as a result of increased provisions for Russia-related
exposures in Stage 2.
While the table above does give a high-level indication of the sensitivity of the outputs to the different
scenarios, it does not provide insight into the interdependencies and correlations between different
macroeconomic variable inputs. On a total ING level, the unweighted ECL for all collective provisioned clients
in the upside scenario was \u20ac2,680 million, in the baseline scenario \u20ac3,177 million and in the downside
scenario \u20ac4,456 million compared to \u20ac3,209 million reportable collective provisions as at 31 December 2022
(excluding all management adjustments). This reconciles as follows to the reported ECL\u2019s:
Reconciliation of model (reportable) ECL to total ECL (*)
in \u20ac million
2022
2021
Total model ECL1
3,209
2,408
ECL from individually assessed impairments
2,439
2,342
ECL from management adjustments
453
618
Total ECL
6,101
5,368
1 Prior period figure has been updated to conform to current year presentation.
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 since initial origination or purchase. ING considers the credit risk of an asset
to have significantly increased when either a threshold for absolute change in lifetime probability of default
(PD) or a relative change in lifetime PD is reached.
It should be noted that the lifetime PD thresholds are not the only drivers of stage allocation. An asset can
also change stages as a result of other triggers, such as having over 30 days arrears, being on a watch list or
being forborne. Refer to section 1.7.8 of Note 1 \u2018Basis of preparation and significant accounting policies\u2019 for
an exhaustive list. Furthermore, this analysis is rudimentary in the sense that other parameters would
change when an asset changes stages.
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 thresholds for the absolute change in lifetime PD vary between 75bps for Retail
portfolios, 100bps for WB and 250bps for SMEs, based on the characteristics of the specific portfolio. ING is in
the process of refining the thresholds on a portfolio level. These have already been implemented for more
than 20 percent of the portfolio, resulting in deviating absolute lifetime PD thresholds.
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 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 that is optimised depending on the observed default rates and overall average riskiness
of the portfolio. While the scaling factor is associated with a whole portfolio/segment, the PD at origination
is facility-specific and, in this sense, the relative threshold may differ facility by facility.
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 said 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
In the table below 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 2021 and year-end 2022.
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.
Quantitative SICR thresholds\u00a0 (*)
2022
2021
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
2.7
2.3
2.7
2.2
Consumer Lending
2.8
1.8
2.8
1.7
Business Lending
2.8
2.1
4.0
2.2
Governments and Fin. Institutions
3.0
1.9
7.9
2.2
Other Wholesale Banking
2.8
1.9
4.5
2.0
As it is apparent from the disclosures above, as per ING\u2019s 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. In 3Q 2022, following up an ECB request, a
new backstop trigger was implemented. The new trigger forces Stage 2 classification in case the lifetime PD
at reporting date has increased more than three times with respect to the origination, regardless of the
actual staging thresholds in force for a given portfolio. The new requirement entails that the threshold ratio
in the table above is effectively capped at a threefold increase for December 2022. The effect of this trigger
is especially apparent in the average thresholds ratio for investment grade facilities when confronting 2021
and 2022 figures. Since for investment grade assets thresholds tend to be looser given the good quality of
underlying counterparties ratings, the backstop trigger is more impactful.
In terms of impact on ING portfolio, the application of the new backstop trigger resulted in an increase of
Stage 2 exposure. However, since the trigger impacts mainly good quality assets for which regular staging
thresholds are typically above a threefold increase in PD, the corresponding impact in provisions was
limited.
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 Bank level, the total model ECL, which is the ECL collective-assessment without taking
management adjustments into account, is \u20ac3,209 million (2021:\u00a0 \u20ac2,408 million) of which performing assets
constitute \u20ac1,884 million (2021: \u20ac1,003 million) . To demonstrate the sensitivity of the ECL to these PD
thresholds bands, an analysis was run on all collectively-assessed assets, which assumed all assets were
below the threshold (Stage 1) and apportioned a 12-month ECL. On the same asset base, analysis was run
which assumed all performing assets were above the threshold (Stage 2) and apportioned a lifetime ECL.
This gave rise to hypothetical collective-assessment ECLs of \u20ac1,348 million (2021: \u20ac634 million) and \u20ac3,391
million (2021: \u20ac2,232 million) respectively. Please note that in this analysis, all other ECL risk parameters
(except for the stage) were kept equal.
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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 certain financial guarantees issued.
ING distinguishes between two types of calculation methods for credit loss allowances:
\u2022Collective 12-month ECL (Stage 1) and collective Lifetime ECL (Stage 2) for portfolios of financial
instruments, as well as Lifetime ECL for credit impaired exposures (Stage 3) below \u20ac1 million.
\u2022Individual Lifetime ECL for credit-impaired (Stage 3) financial instruments with exposures above \u20ac1
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: (1) to the economic outlook and (2) 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 \u2018credit-impaired\u2019
financial assets under IFRS 9 (Stage 3). ING has also aligned its definition of default between IFRS9 and the
regulatory technical standards (RTS) and EBA guidelines. More information can be found in section 1.7.8 of
the Consolidated financial statements.
Climate and environmental risks in IFRS 9 models (*)
ING is evolving in its credit risk management framework to further develop a better understanding of
emerging climate and environmental risks. Banks, including ING, are in the process of collecting and
analysing empirical historical data and moving towards embedding these emerging risks into their credit
risk management processes and eventually into their IFRS 9 ECL models.
In 2022, ING continued to enhance the tools used to identify and assess climate and environmental (C&E)
risks in our portfolio. We created C&E risk sector heatmaps for both WB and Retail Banking that facilitated
the identification of exposure to C&E risks by means of scores assigned to transition and physical risk
drivers. They also enabled us to understand the magnitude of the C&E risk impact on a sectoral level and
pinpointed sectors with highest C&E risk exposure. In the past two years, we have improved our
understanding of the physical risk impact of climate events on our mortgage portfolio.
The integration of quantified inputs from the heatmaps into risk modelling has not yet been implemented
for a number of reasons including a lack of data to assess C&E risks at a client level. Refer to the section
'Environmental, social and governance risk' for further details on the heatmaps and the related challenges.
At this point in time it is not possible to incorporate climate risk separately into IFRS 9 ECL models given the
lack of sufficient empirical historical data and the above-mentioned limitations in the risk assessments on
client level. Where climate and environmental factors have impacted the economy in the recent past or
present, these impacts are however currently implicitly embedded in ING's IFRS9 ECL models through the
projected macroeconomic indicators (e.g. GDP growth and unemployment rates). We note that our ECL
models are primarily sensitive to the short-term economic outlook as we use a three-year time horizon for
macroeconomic outlook, after which a mean reversion approach is applied.
With regard to our evaluation of climate-related matters, where such events have already occurred (e.g.
floods), the impact of such events are individually assessed in the calculation of Stage 3 Individual provisions
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.
As of 31 December 2022, reported ECL includes a management adjustment of \u20ac10 million to address the
increased credit risk in ING\u2019s livestock farming portfolio resulting from nitrogen reduction targets introduced
by the Dutch Government. Refer to the section 'Management overlays' for further details.
Portfolio quality (*)
The table below describes the portfolio composition over the different IFRS 9 stages and rating classes. The
Stage 1 portfolio represents 91.5% (2021: 93.5%) of the total gross carrying amounts, mainly composed of
investment grade, while Stage 2 makes up 7.3% (2021: 5.2%) and Stage 3 makes up 1.2% (2021: 1.3%) of
the total gross carrying amounts, respectively.
Gross carrying amount per IFRS 9 stage and rating class (*)1,2,3
in \u20ac million
12-month ECL (Stage 1)
Lifetime ECL not credit
impaired (Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
2022
Rating class
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Investment grade
1 (AAA)
100,885
2
284
101,169
2
2-4 (AA)
98,181
5
2,493
1
100,675
6
5-7 (A)
177,617
23
4,596
4
182,214
27
8-10 (BBB)
320,972
98
14,714
29
335,687
127
Non-Investment grade
11-13 (BB)
155,910
277
17,365
91
173,275
368
14-16 (B)
23,649
168
19,386
471
43,035
639
17 (CCC)
7,671
8
4,572
194
12,244
202
Substandard grade
18 (CC)
5,198
595
5,198
595
19 (C)
2,116
293
2,116
293
Non-performing loans
20-22 (D)
11,708
3,841
11,708
3,841
Total
884,886
581
70,725
1,679
11,708
3,841
967,319
6,101
1Compared to the credit risk portfolio, the differences are mainly undrawn committed amounts (\u20ac150.1 billion) and other positions (\u20ac4.4 billion) not included in Credit outstandings and non-IFRS 9 eligible assets (\u20ac116.1 billion, mainly guarantees, letters of credit and pre-
settlement exposures) included in Credit outstandings.
2For a reference to the Notes in the consolidated financial statements, we refer to the table \u2018Reconciliation between credit risk categories and financial position\u2019.
3IAS 37 provisions are established for non-credit replacement guarantees not in the scope of IFRS 9. Total IAS 37 provisions (\u20ac109 million) are excluded.
Gross carrying amount per IFRS 9 stage and rating class (*)1,2,3
in \u20ac million
12-month ECL (Stage 1)
Lifetime ECL not credit
impaired (Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
2021
Rating class
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Gross
Carrying
Amount
Provisions
Investment grade
1 (AAA)
107,788
3
107,788
3
2-4 (AA)
106,673
5
197
106,870
5
5-7 (A)
152,255
17
1,001
1
153,256
17
8-10 (BBB)
328,301
73
7,232
14
335,533
87
Non-Investment grade
11-13 (BB)
162,912
208
14,679
86
177,592
294
14-16 (B)
26,852
185
17,931
404
44,783
589
17 (CCC)
5,377
10
4,354
198
9,730
207
Substandard grade
18 (CC)
2,314
173
2,314
173
19 (C)
1,769
142
1,769
142
Non-performing loans
20-22 (D)
12,072
3,851
12,072
3,851
Total
890,158
501
49,476
1,016
12,072
3,851
951,707
5,368
1Compared to the credit risk portfolio, the differences are mainly undrawn committed amounts (\u20ac133.3 billion) not included in Credit outstandings and non-IFRS 9 eligible assets (\u20ac95.1 billion, mainly guarantees, letters of credit and pre-settlement exposures) included in Credit
outstandings.
2For a reference to the Notes in the consolidated financial statements, we refer to the table \u2018Reconciliation between credit risk categories and financial position\u2019.
3IAS 37 provisions are established for non-credit replacement guarantees not in the scope of IFRS 9. Total IAS 37 provisions (\u20ac114.4 million) are excluded.
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:
\u2022Stage 3 gross carrying amount decreased by \u20ac0.4 billion from \u20ac12.1 billion as of 31 December 2021 to\u00a0 \u00a0
\u20ac11.7 billion as of 31 December 2022, mainly as a result of write-offs and generally low inflow into NPL
(credit impaired) in 2022. Stage 3 provisions remained however flat at \u20ac3.8 billion, reflecting worsened
macroeconomic outlook.
\u2022Stage 2 gross carrying amount increased by \u20ac21.2 billion from \u20ac49.5 billion as of 31 December 2021 to\u00a0
\u20ac70.7 billion. This is mainly caused by the significant lifetime PD trigger (\u20ac14.8 billion) driven by
downgrades of the Russian portfolio and economic turmoil. Furthermore, the implementation of a
stricter PD backstop methodology has driven the increase in Stage 2 gross carrying amounts,(\u20ac11.4
billion, mainly investment grade exposures). Other Stage 2 triggers such as the 30 Days past due and
watchlist triggers (\u20ac1.2 billion and \u20ac1.1 billion respectively), were more than offset by the forbearance
trigger (-\u20ac6.4 billion). For the latter, a two-year probation period is required before a client can move back
to Stage 1 and the decrease relates to the fact that the start of the Covid-19 pandemic is now more than
two years ago.
\u2022Stage 2 provisions increased by \u20ac0.7 billion to \u20ac1.7 billion as of 31 December 2022, largely driven by the
migration of the Russian portfolio to Stage 2 and worsened macro-economic outlook. The
implementation of the threefold increase in lifetime PD backstop trigger had limited impact on provisions
as\u00a0 it mainly impacts investment grade exposures.
\u2022In 2022, the largest increases in Stage 2 by sector were in Non-bank financial institutions, Real estate,
Chemicals health & pharmaceuticals and Lower public administration of \u20ac3.5 billion, \u20ac2.8 billion, \u20ac2.5
billion and \u20ac2.1 billion respectively The increase in Stage 2 for non-bank financial institutions mainly
resulted from the implementation of the threefold increase in lifetime PD backstop trigger, that mainly
impacts investment grade exposures. Other drivers were downgrades in the Russian portfolio and
economic turmoil. The largest decreases were in Automotive and Transportation & logistics with \u20ac0.9
billion and \u20ac0.6 billion releases respectively. The largest Stage 2 outstandings per economic sector as of
31 December 2022 are Real estate, Services, Natural resources and Non-bank financial institutions
representing 10%, 7%, 7% and 7% of the total Stage 2 gross carrying amounts respectively.
Additional information on macroeconomic scenarios is included in the section \u2018Macroeconomic scenarios
and sensitivity analysis of key sources of estimation uncertainty\u2019.
Changes in gross carrying amounts and loan loss provisions (*)1, 2
in \u20ac million
12-month ECL (Stage 1)
Lifetime ECL not credit
impaired (Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
2022
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Opening balance
890,158
501
49,476
1,016
12,072
3,851
951,707
5,368
Transfer into 12-month ECL (Stage 1)
8,513
21
-8,105
-142
-408
-47
-168
Transfer into lifetime ECL not credit impaired (Stage 2)
-42,439
-76
43,222
730
-784
-90
564
Transfer into lifetime ECL credit impaired (Stage 3)
-3,524
-8
-1,216
-82
4,740
1,234
1,144
Net remeasurement of loan loss provisions
8
223
199
430
New financial assets originated or purchased
248,443
228
248,443
228
Financial assets that have been derecognised
-138,250
-70
-11,312
-94
-2,805
-215
-152,366
-379
Net drawdowns and repayments
-78,015
-1,340
21
-79,334
Changes in models/risk parameters
-8
13
25
30
Increase in loan loss provisions
95
648
1,106
1,849
Write-offs
-1
-1,129
-1,129
-1,130
-1,130
Recoveries of amounts previously written off
71
71
Foreign exchange and other movements
-15
16
-58
-57
Closing balance
884,886
581
70,725
1,679
11,708
3,841
967,319
6,101
1Stage 3 Lifetime credit impaired provision includes \u20ac4 million on Purchased or Originated Credit Impaired.
2The addition to the loan provision (in the consolidated statement of profit or loss) amounts to \u20ac1.861 million of which \u20ac1.850 million related to IFRS 9 eligible financial assets, -\u20ac3 million related to non-credit replacement guarantees and \u20ac14 million to modification gains and
losses on restructured financial assets.
Changes in gross carrying amounts and loan loss provisions (*)1,2
in \u20ac million
12-month ECL (Stage 1)
Lifetime ECL not credit
impaired (Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
2021
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Opening balance
844,020
581
59,313
1,476
13,398
3,797
916,732
5,854
Transfer into 12-month ECL (Stage 1)
15,157
20
-14,322
-279
-835
-54
-313
Transfer into lifetime ECL not credit impaired (Stage 2)
-19,737
-32
20,537
206
-800
-74
100
Transfer into lifetime ECL credit impaired (Stage 3)
-2,166
-13
-1,589
-96
3,755
820
712
Net remeasurement of loan loss provisions
-130
-228
404
46
New financial assets originated or purchased
208,501
149
208,501
149
Financial assets that have been derecognised
-125,819
-73
-11,935
-104
-1,898
-237
-139,652
-414
Net drawdowns and repayments
-29,799
-2,526
-694
-33,019
Changes in models/risk parameters
12
41
130
184
Increase in loan loss provisions
-67
-460
989
462
Write-offs
-854
-854
-854
-854
Recoveries of amounts previously written off
45
45
Foreign exchange and other movements
-13
1
-125
-138
Closing balance
890,158
501
49,476
1,016
12,072
3,851
951,707
5,368
Macroeconomic scenarios and sensitivity analysis of key sources of estimation
uncertainty (*)
Methodology (*)
Our methodology in relation to the adoption and generation of macroeconomic scenarios is described in
this section. We continue to follow this methodology in generating our probability-weighted ECL, with
consideration of alternative scenarios and management adjustments supplementing this ECL where, in
management's opinion, 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\u2019s 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). The Oxford Economics\u2019 Global Economic Model (OEGEM) is used to complement the consensus with
consistent projections for variables for which there are no consensus estimates available (most notably
house prices and \u2013 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 two panels of ING experts. The first panel
consists of economic experts from Global Markets Research and risk and modelling specialists, while the
second panel consists of relevant senior managers.
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 OEGEM.
To understand the baseline level of uncertainty around any forecast, Oxford Economics keeps track of all its
deviations (so called forecast errors) of the past 20 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, Oxford Economics 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 for the 90th percentile of that distribution because this
corresponds with the way risk management earnings-at-risk is defined within the Bank. The upside scenario
is represented by the 10th percentile of the distribution. The applicable percentiles of the distribution imply
a 20% probability for each alternative scenario. Consequently, the baseline scenario has a 60% probability
weighting. Please note that, given their technical nature, the downside and upside scenarios are not based
on an explicit specific narrative.
Macroeconomic scenarios applied (*)
The loan loss provisions are based on the December 2022 consensus forecasts.
Baseline assumptions (*)
The general picture that the consensus conveys is that global economic growth is being challenged by
persistent inflationary pressures which are being met by central banks lifting interest rates. The consensus
expects recession to occur in many European countries in 2022-2023, while the US economy is anticipated
to stagnate. Economic growth is expected to resume in the years thereafter as inflation normalises and
monetary conditions become less tight. In economies that have experienced a notable surge in house prices
during the pandemic and its aftermath, affordability pressures amid the higher interest rate environment
are expected to lead to a moderation of growth or price declines in the near to medium-term.
The December 2022 consensus expects global output (as measured by the weighted average GDP growth
rate of ING's 25 main markets) to slow further from 6.0% in 2021, to 2.5% in 2022 and 1.3% in 2023. For
2024-2025, economic growth is expected to pick up again to 2.4%.
The US economy is expected to stagnate in 2023 as high inflation, rising interest rates, supply chain
difficulties, softer labour market dynamics, and global headwinds weaken demand. Consumer spending
growth is under downward pressure as slower employment gains curb income growth and pandemic-
related savings have diminished. With the headwinds seen fading slowly, the US economy is expected to
gather strength again in 2024. The consensus expects the growth rate of the US economy to fall from 1.9%
in 2022 to 0.2% in 2023 and to recover to on average 1.7% in 2024-2025.
Eurozone economies are dealing with the consequences of the ongoing war in Ukraine, broadening
inflationary pressures and a general deterioration of sentiment across industries and consumers.
The ECB has shifted to a hawkish tilt but government fiscal support targeting higher energy prices is
softening the economic pain in many countries. Overall, the eurozone economy is forecasted to stagnate in
2023, but Germany \u2013 as well as some other countries \u2013 faces recession reflecting its large exposure to gas
supply cuts, relatively large manufacturing sector and exposure to a slower growing Chinese economy.
Elsewhere in Europe, the outlook is equally bleak. In Poland, economic fallout from the war in Ukraine and
the related energy price shock point to a significant economic slowdown from 5.0% in 2022 to 1.0% in 2023.
However, the scope for a rise in unemployment is seen to be limited as the Polish labour market remains
tight, partially due to population ageing. As in the eurozone, the central bank is tightening monetary policy,
but fiscal policy remains expansive. The consensus expectation for Turkey is also for economic growth to
ease as the economic slowdown in Europe weighs on external demand and high inflation persists. The
consensus sees economic growth in Turkey slowing from 5.2% in 2022, to on average 2.4% in 2023-2024
and increasing again to 3.0% in 2025.
After a weak growth rate of 3.1% in 2022, economic growth in China is expected to pick-up to on average
4.7% in 2023-2025. The drag exerted by the authorities\u2019 Covid-19 policies is assumed to moderate, while
state investment will support demand. However, the real estate downturn continues to weigh on the
outlook.
The global economic slowdown, together with tighter monetary policy and high inflation is weighing on
economic growth in Australia. After growing by 3.8% in 2022, the outlook sees a growth rate of 1.8% for
2023-2024 and some pick-up to 2.6% for 2025. However, despite the economic slowdown, conditions in the
labour market are expected to remain tight.
When compared to the December 2021 consensus forecast, used for the 2021 Annual Report, the December
2022 forecast assumes much weaker economic circumstances. Global GDP was expected to increase by
2.5% in 2022 (compared to 4.1% assumed before) and 1.3% in 2023 (3.1% assumed before). The downgrade
reflects the economic impacts of the war in Ukraine and tighter monetary conditions.
Alternative scenarios and risks (*)
Because of the possible consequences of the war in Ukraine, uncertainty surrounding the forecasts is higher
than usual. This relates in particular to uncertainty about European energy supplies and worries about more
persistent high inflation. To take the general increase of uncertainty surrounding the forecasts into account,
the dispersion of the alternative scenarios has been set again at the widened level used for year-end 2021
provisioning (the half-widened dispersion). As a result, the near-term dispersion of the forward-looking
distributions (from which the alternative scenarios are derived) is larger than in normal times. Meanwhile, at
the end of the scenario horizon the dispersion has remained unchanged and hence is comparable to
scenarios generated prior to the war in Ukraine.
The baseline scenario assumes a significant easing of inflation in 2023 and relatively resilient labour
markets. However, a longer period of weakness, due to stickier inflation and more aggressive monetary
policy tightening that triggers a more notable softening of the labour market and greater falls in financial
asset and property prices, could lead to a more protracted and deeper economic slowdown. As such, the
balance of risks to the baseline outlook is negative and the alternative scenarios have a downward skew in
line with the outcomes of Oxford Economics\u2019 Global Risk Survey. The downward skew is less negative
compared to what has been applied for year-end 2021 at which time \u2013 set against a higher baseline \u2013 apart
from higher inflation, worries about supply chain disruptions and further corona virus waves were being
seen as top near-term downside risks.
The downside scenario \u2013 though technical in nature \u2013 sees for most countries a fast deceleration of
economic growth followed by a recession. Unemployment increases strongly in this scenario and house
prices in most countries show outright falls. The downside scenario captures a possible escalation of the war
in Ukraine and a more pronounced and prolonged surge in inflation.
The upside scenario \u2013 while equally technical in nature \u2013 reflects the possibility of a better economic outturn
if the war in Ukraine ended quickly, fuelling a rebound in consumer spending. The recovery is further
supported by looser monetary policy as weaker inflation prompts central banks to hold back tightening.
Management adjustments applied this year (*)
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 can also be applied
where the impact of the updated macroeconomic scenarios is over- or under-estimated by the IFRS 9
models.
ING has internal governance frameworks and controls in place to assess the appropriateness of all
management adjustments.
Management adjustments to ECL models (*)
in \u20ac million
2022
2021
Economic sector based adjustments
71
341
Second order impact adjustments
334
Payment holiday adjustments
32
Mortgage portfolio adjustments
105
124
Other Post Model Adjustments1
-57
121
Total management adjustments
453
618
1 Prior period figure has been updated to conform to current year presentation.
December 2021 management adjustments included an economic sector-based management adjustment
of \u20ac341 million because of delays in defaults occurring in the Covid-19-related crisis, mainly as a result of
government support programmes. In determining the sector-based management adjustment, a heatmap
approach was used to adjust the probability of default for sectors where businesses are significantly
impacted by the pandemic. In 2022, as it became clearer the Covid-19 pandemic had less impact than
expected on the number of defaults, the economic sector-based management adjustment has been largely
released and while at the same time management adjustments for the second order impact of the war in
Ukraine were introduced (see below). Of the remaining economic sector based adjustments of \u20ac71 million as
of 31 December 2022, \u20ac61 million relates to Business Banking clients that have benefited from Covid-19
related government support programmes in the Netherlands such as deferral of tax payments that ended in
the second half of 2022, and \u20ac10 million relates to an overlay for livestock farming sector in the
Netherlands. In the Netherlands, nitrogen reduction targets affect the livestock farming sector mainly
because of endorsed closing activities nearby Natura 2000 areas and because of expected transition to
other business models in the sector. As these specific risks are not incorporated in the model ECL, an overlay
was recognised.
ING has performed an assessment for both WB and Retail Banking on the impact of the war in Ukraine, the
increase in energy prices and other second order macroeconomic developments such as an increase in
inflation and rising interest rates. This resulted in a second order impact overlay of \u20ac334 million in total as of
31 December 2022, of which \u20ac164 million relates to Retail Banking segments and \u20ac170 million to the
Wholesale Banking segment.
As the credit risk models assume that these second order effects materialise via other risk drivers such as
GDP and unemployment rates with a delay, an overlay approach was determined to timely estimate the
Expected Credit Losses related to reduced repayment capacity and affordability for private individuals and
business clients in the Retail Banking segment. The \u20ac164 million includes an overlay of \u20ac22 million for clients
participating in the payment holiday scheme in Belgium that was introduced in 2022 to support customers
impacted by the inflation and high energy prices.
In WB, it was assessed that the economic effects of Covid-19 was not the highest risk anymore and that
other risks have emerged \u2013 mainly high energy prices, high interest rates and inflation, supply chain issues
and staffing shortages. A heatmap approach was used to adjust the probability of default for clients that
are expected to be significantly impacted by these emerged risks.
Given Covid-19-related payment holiday programmes have generally expired, this management
adjustment has been fully released in 2022.
Model based ECL of mortgage portfolios has decreased over the past years and until the third quarter of
2022, driven by significant increase of house prices in various countries. Management adjustments of \u20ac105
million in total, mainly in Stage 2 and 3, have been recognised by ING in the Netherlands, Belgium, Germany
and Australia to maintain an appropriate level of ECL and reflecting a potential impact of market
uncertainty on the recovery value of residential real estate (impacted by higher inflation and interest rates).
The management adjustment for the Netherlands and part of the Belgian mortgage portfolio was
determined by developing three alternative macroeconomic forecast scenarios, in addition to the consensus
base, up- and down-scenarios, that reflect a correction in the house prices in the next three years bringing it
back in line with the historical growth rate. For other countries, management adjustments were determined
by calculating the impact of lower house prices on LTVs and LGDs.
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. These result
from both regular model maintenance and ING\u2019s multiyear programme to update ECL models for the new
definition of default. These adjustments will be removed once updates to the specific models have been
implemented.
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 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. ING also observes that,
in general, the WB business is more sensitive to the impact of forward-looking macroeconomic scenarios.
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.
Sensitivity analysis as at December 2022\u00a0 (*)
2023
2024
2025
Un-weighted
ECL (\u20ac mln)
Probability-
weighting
Reportable
ECL (\u20ac mln)1
Netherlands
Upside scenario
Real GDP
2.2
2.3
2.9
274
20%
381
Unemployment
4.0
3.9
3.8
HPI
13.0
11.8
2.5
Baseline Scenario
Real GDP
0.2
1.4
1.8
349
60%
Unemployment
4.5
4.8
4.9
HPI
3.7
3.7
2.4
Downside scenario
Real GDP
-4.2
0.7
0.9
583
20%
Unemployment
6.4
7.8
8.7
HPI
-8.0
-6.5
2.2
Germany
Upside scenario
Real GDP
1.7
2.3
1.8
606
20%
745
Unemployment
2.6
2.2
1.8
HPI
0.6
3.9
6.2
Baseline Scenario
Real GDP
-0.7
1.4
1.5
726
60%
Unemployment
3.2
3.1
3.1
HPI
-1.8
0.9
2.7
Downside scenario
Real GDP
-4.8
0.1
1.0
942
20%
Unemployment
4.8
5.3
5.6
HPI
-6.2
-3.3
-1.4
Belgium
Upside scenario
Real GDP
1.7
2.1
2.1
535
20%
596
Unemployment
5.5
5.5
5.3
HPI
2.3
2.6
3.1
Baseline Scenario
Real GDP
0.0
1.6
1.8
584
60%
Unemployment
6.1
6.3
6.1
HPI
1.4
2.2
2.5
Downside scenario
Real GDP
-3.2
1.0
1.5
692
20%
Unemployment
7.5
8.5
8.4
HPI
-1.2
0.9
1.2
United States
Upside scenario
Real GDP
3.0
1.5
3.4
100
20%
221
Unemployment
3.4
2.8
2.5
HPI
3.7
7.4
8.1
Baseline Scenario
Real GDP
0.2
1.1
2.3
188
60%
Unemployment
4.3
4.4
3.9
HPI
2.5
2.2
2.8
Downside scenario
Real GDP
-4.1
0.2
0.6
442
20%
Unemployment
6.4
7.7
8.2
HPI
-1.2
-3.8
-3.5
1 Excluding management adjustments.
Sensitivity analysis as at December 2021 (*)
2022
2023
2024
Un-weighted
ECL (\u20ac mln)
Probability-
weighting
Reportable
ECL (\u20ac mln)1
Netherlands
Upside scenario
Real GDP
5.1
2.9
2.7
259
20%
307
Unemployment
3.2
2.9
2.9
HPI
23.3
10.9
0.9
Baseline Scenario
Real GDP
3.4
2.0
1.7
289
60%
Unemployment
3.7
4.1
4.3
HPI
13.1
2.8
0.8
Downside scenario
Real GDP
-1.5
1.2
0.7
411
20%
Unemployment
5.6
6.8
7.8
HPI
0.3
-7.7
0.6
Germany
Upside scenario
Real GDP
6.2
3.1
1.6
457
20%
483
Unemployment
2.9
2.2
1.9
HPI
12.9
7.9
5.3
Baseline Scenario
Real GDP
4.0
2.3
1.4
475
60%
Unemployment
3.4
3.1
3.1
HPI
10.4
4.6
1.9
Downside scenario
Real GDP
-0.6
0.9
0.8
535
20%
Unemployment
5.0
5.4
5.7
HPI
5.3
0.4
-2.1
Belgium
Upside scenario
Real GDP
4.6
2.5
2.0
364
20%
393
Unemployment
5.6
5.6
5.9
HPI
3.9
2.7
2.9
Baseline Scenario
Real GDP
3.1
2.0
1.8
383
60%
Unemployment
6.1
6.3
6.3
HPI
3.0
2.3
2.3
Downside scenario
Real GDP
-0.4
1.4
1.4
451
20%
Unemployment
7.6
8.6
9.0
HPI
0.4
1.0
1.0
United States
Upside scenario
Real GDP
6.7
2.4
3.1
28
20%
75
Unemployment
3.5
2.5
2.4
HPI
10.4
8.1
8.7
Baseline Scenario
Real GDP
4.0
2.5
2.1
55
60%
Unemployment
4.0
3.7
3.7
HPI
9.1
3.0
3.3
Downside scenario
Real GDP
-0.7
1.1
0.3
183
20%
Unemployment
6.5
7.4
8.0
HPI
5.3
-3.2
-3.0
1 Excluding management adjustments.
When compared to the sensitivity analysis of 2021, the macroeconomic inputs for 2022 and 2023 are less
favourable, driven by a worsened macroeconomic outlook as a result of the war in Ukraine as well as its
indirect effects such as inflation and increasing interest rates. Both 2021 and 2022 contain half-widened
dispersion around upside and downside scenarios, for 2021. This reflects continuing but decreased short-
term uncertainty relating to the impact of Covid-19 and for 2022 reflecting short-term uncertainty around
the war in Ukraine and its indirect effects. The increase in reportable ECL compared to 2021 is mainly caused
by higher model ECL amounts as per December 2022 as a result of increased provisions for Russia-related
exposures in Stage 2.
While the table above does give a high-level indication of the sensitivity of the outputs to the different
scenarios, it does not provide insight into the interdependencies and correlations between different
macroeconomic variable inputs. On a total ING level, the unweighted ECL for all collective provisioned clients
in the upside scenario was \u20ac2,680 million, in the baseline scenario \u20ac3,177 million and in the downside
scenario \u20ac4,456 million compared to \u20ac3,209 million reportable collective provisions as at 31 December 2022
(excluding all management adjustments). This reconciles as follows to the reported ECL\u2019s:
Reconciliation of model (reportable) ECL to total ECL (*)
in \u20ac million
2022
2021
Total model ECL1
3,209
2,408
ECL from individually assessed impairments
2,439
2,342
ECL from management adjustments
453
618
Total ECL
6,101
5,368
1 Prior period figure has been updated to conform to current year presentation.
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 since initial origination or purchase. ING considers the credit risk of an asset
to have significantly increased when either a threshold for absolute change in lifetime probability of default
(PD) or a relative change in lifetime PD is reached.
It should be noted that the lifetime PD thresholds are not the only drivers of stage allocation. An asset can
also change stages as a result of other triggers, such as having over 30 days arrears, being on a watch list or
being forborne. Refer to section 1.7.8 of Note 1 \u2018Basis of preparation and significant accounting policies\u2019 for
an exhaustive list. Furthermore, this analysis is rudimentary in the sense that other parameters would
change when an asset changes stages.
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 thresholds for the absolute change in lifetime PD vary between 75bps for Retail
portfolios, 100bps for WB and 250bps for SMEs, based on the characteristics of the specific portfolio. ING is in
the process of refining the thresholds on a portfolio level. These have already been implemented for more
than 20 percent of the portfolio, resulting in deviating absolute lifetime PD thresholds.
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 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 that is optimised depending on the observed default rates and overall average riskiness
of the portfolio. While the scaling factor is associated with a whole portfolio/segment, the PD at origination
is facility-specific and, in this sense, the relative threshold may differ facility by facility.
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 said 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
In the table below 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 2021 and year-end 2022.
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.
Quantitative SICR thresholds\u00a0 (*)
2022
2021
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
2.7
2.3
2.7
2.2
Consumer Lending
2.8
1.8
2.8
1.7
Business Lending
2.8
2.1
4.0
2.2
Governments and Fin. Institutions
3.0
1.9
7.9
2.2
Other Wholesale Banking
2.8
1.9
4.5
2.0
As it is apparent from the disclosures above, as per ING\u2019s 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. In 3Q 2022, following up an ECB request, a
new backstop trigger was implemented. The new trigger forces Stage 2 classification in case the lifetime PD
at reporting date has increased more than three times with respect to the origination, regardless of the
actual staging thresholds in force for a given portfolio. The new requirement entails that the threshold ratio
in the table above is effectively capped at a threefold increase for December 2022. The effect of this trigger
is especially apparent in the average thresholds ratio for investment grade facilities when confronting 2021
and 2022 figures. Since for investment grade assets thresholds tend to be looser given the good quality of
underlying counterparties ratings, the backstop trigger is more impactful.
In terms of impact on ING portfolio, the application of the new backstop trigger resulted in an increase of
Stage 2 exposure. However, since the trigger impacts mainly good quality assets for which regular staging
thresholds are typically above a threefold increase in PD, the corresponding impact in provisions was
limited.
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 Bank level, the total model ECL, which is the ECL collective-assessment without taking
management adjustments into account, is \u20ac3,209 million (2021:\u00a0 \u20ac2,408 million) of which performing assets
constitute \u20ac1,884 million (2021: \u20ac1,003 million) . To demonstrate the sensitivity of the ECL to these PD
thresholds bands, an analysis was run on all collectively-assessed assets, which assumed all assets were
below the threshold (Stage 1) and apportioned a 12-month ECL. On the same asset base, analysis was run
which assumed all performing assets were above the threshold (Stage 2) and apportioned a lifetime ECL.
This gave rise to hypothetical collective-assessment ECLs of \u20ac1,348 million (2021: \u20ac634 million) and \u20ac3,391
million (2021: \u20ac2,232 million) respectively. Please note that in this analysis, all other ECL risk parameters
(except for the stage) were kept equal.
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Market risk
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\u2019s 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. This means that financial instruments in
the trading books should be free of trade restrictions. 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.
ING recognises the importance of sound market risk management and bases its market risk management
framework on the need to identify, assess, control and manage market risks. The approach consists of five
recurring activities: risk identification, risk assessment, risk control, risk monitoring and risk reporting.
Governance (*)
A governance framework has been established defining specific roles and responsibilities of business
management units, market risk management units, and internal approval bodies per activity.
Supervision of market risk falls under the responsibility of the EB/MBB and is delegated to the ALCO function,
where ALCO Bank is the highest approval authority and sets the market risk appetite. ALCO Bank monitors
ING\u2019s adherence to the risk appetite for market risk and sets additional limits where appropriate. These limits
are cascaded through the organisation through lower level ALCOs. This ALCO structure facilitates top-down
risk management, limit setting, and the monitoring and control of market risk.\u00a0
FR maintains a limit framework in line with ING\u2019s Risk Appetite Framework. The businesses are responsible
for adhering to the limits which are reviewed on an annual basis and are ultimately approved by the ALCO
Bank. Limit excesses are reported to senior management in line with the ALM Limit excess reporting
procedure upon which the business needs to act accordingly. To adhere to the established limit framework,
ING implements hedging and risk mitigation strategies that range from the use of traditional market
instruments, such as interest rate swaps, to more sophisticated hedging strategies.
The organisational structure facilitates top-down risk management by recognising that risk taking and risk
management occur to a large extent at the regional/local level. Bottom-up reporting from regional/local
units to head office units allows each management level to assess the market risks relevant at the
respective levels.
Several committees govern communication between the parties involved in market risk management:
\u2022The Market Risk Model Committee (MRMC, reporting to ALCO Bank), is the dedicated authority within ING
for the approval of all funding and liquidity risk, banking and trading risk and counterparty credit risk
models, methodologies and related parameters. This is comparable with the CTRC, which reports into the
GCTP.
\u2022The Valuation Model Committee approves pricing models for trading and banking books.
Financial Risk provides risk reporting to the EB and MBB, the ALCO Bank and the senior executive
management of related business functions.
The following sections elaborate on the various elements of the risk management framework for:
\u2022Market risk economic capital (trading and banking books).
\u2022Market risks in banking books.
\u2022Market risks in trading books.
Market risk in banking books (*)
ING makes a distinction 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 it is centrally managed. The scheme below presents the transfer and
management process of market risks in the banking books:
Risk measurement (*)
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\u2019s earnings, capital, and market
value to adverse movements in interest rates originated from positions in the banking book.
Governance (*)
The management of interest rate risk follows the Interest Rate Risk in the Banking Book (IRRBB) framework
as approved by ALCO Bank. This framework describes roles, responsibilities, risk metrics, and the policies and
procedures related to interest rate risk management. Furthermore, ALCO Bank reviews and sets the risk
appetite for interest rate risk, on an annual basis. The risk appetite is translated into limits for the interest
rate risk metrics.
As a result of this framework, 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:
\u2022Investment of own funds.
\u2022Commercial business.
\u2022Group 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. The
main objective is to maximise the economic value of the capital investment book while having stable
earnings.
Commercial activities can result in linear interest rate risk, for example, tenors and duration of new
production and re-pricing of assets differ from those of liabilities. Also, interest rate risk can arise from
customer behaviour and/or convexity risk, depending on the nature of the underlying product
characteristics.
Customer behaviour risk is defined as the potential future (value) loss due to deviations in the actual
behaviour of clients versus the modelled behaviour towards the embedded options in commercial products.
General sources of customer behaviour risk, among other things, include 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 three main product
types: funds entrusted as savings and demand deposits, mortgages and loans.
Savings and demand deposits are generally invested in such a way that both the value is hedged\u00a0 and the
sensitivity of the margin to market interest rates is minimised. Interest rate risk can arise when there is a
misalignment between the change in market rates and adjustment of savings rates, which can either have
a positive or negative impact on the income as a consequence of the potential misalignment to the related
(assumption based) investment strategy of ING\u2019s savings. Interest rate risk is modelled based on the stability
of the deposit 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. Savings volumes are typically
assumed to be relatively stable and less sensitive to rate changes.
Interest rate risk for mortgages arises due to prepayment possibilities in these mortgages. In modelling this
risk, both interest rate dependent pre-payments and constant prepayments are considered. Next to a
dependence on interest rates, modelled prepayments may include other effects such as loan-to-value,
seasonality and the reset date of the loan. In addition, the interest sensitivity of embedded offered rate
options may be considered.\u00a0
Wholesale Banking loans typically do not experience interest rate dependent prepayment behaviour, 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 research. However, the substantial change in the interest rate environment makes extensive
research more challenging than before and may increase model risk. Models are backtested and updated
when deemed necessary in an annual procedure. Model parameters and the resulting risk measures are
approved by (local) ALCO.
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 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. However, 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 transferred from the
commercial books to treasury books using cap/floor contracts.
In the following sections, the interest rate risk exposures in the banking books are presented. ING uses risk
measures based on both an earnings and a value perspective. Net interest income (NII)-at-risk is used to
provide the earnings perspective and the net present value (NPV)-at-risk figures provide the value
perspective. Please note that the expected interest rate risk coming forward from the business is assumed
to be linearly hedged but no additional corrective management actions are taken into account in the NPV-
at-Risk measure. In the NII-at-Risk measure, a more dynamic hedging process is taken into account.
During 2022, the following activities related to the risk measurement for IRRBB were performed:
\u2022Annual review of the risk appetite for Market Risks in the Banking Book including further enhancement.
\u2022Further assessment and development of sub-risk types, such as tenor basis risk, vega optionality risk and
client behaviour risk.
\u2022Set up of standardised risk measurement related to climate risk.
\u2022Annual review of the interest rates scenarios used for calculating NII-at-Risk and NPV-at-Risk.
\u2022Annual savings/current account model updates.
\u2022Annual update of parameters of prepayment models for market developments.
\u2022A specific, internal firm-wide stress test relating to climate risk.
\u2022Further enhancement of the IRRBB framework in relation to upcoming regulatory requirements (e.g.
anticipation on implementation and measurement of the upcoming regulatory metric NII SOT,
development of additional requirements coming forward from latest EBA guidelines).
\u2022Improvement of the FX framework.
Net interest income (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 are included in this risk metric. NII-at-Risk is a metric
that helps provide insight to what extent ING's NII under our Dynamic Plan deviates from the interest rates
development assumed.
In its risk management, ING monitors the NII-at-Risk under a three-year timeframe. Interest rates are
stressed during the first year versus the prevailing curve, taking gradual changes over the first year. The rate
changes considered comprise both upward and downward scenarios, as well as parallel (equal movements
across the yield curve) and non-parallel scenarios.
The impact of changing interest rates on ING\u2019s NII is predominantly caused by the following factors:
\u2022Change in returns of (re-)investments of client deposits.
\u2022Change in deposits client rates (mainly savings), (partially) tracking changes in market interest rates.
\u2022Change in funding profile of mortgages, due to an expected increase or decrease in expected
prepayments.
\u2022Higher/lower returns of (re-)investments of capital investment.
\u2022Open interest rate positions, leading to changes in return because of different market rates.
\u2022Assumed 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 to
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,
amongst others, actual interest rate and savings client rate evolution, as well as changes to ING\u2019s 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 tables below reflect a parallel, linear interest rate movement during a year
('ramped') under the assumption of balance sheet developments in line with the ING's Dynamic Plan with a
time horizon of one year.
NII-at-Risk banking books per business\u00a0 - year one (*)
in \u20ac million
2022
2021
Ramped, unfloored
Ramped, unfloored
parallel \u25bc
parallel \u25b2
parallel \u25bc
parallel \u25b2
By business
Wholesale Banking
4
-47
46
-33
Retail Banking Benelux
-88
59
-122
132
Retail Challengers & Growth Markets
-41
113
-93
75
Corporate Line Banking
-18
18
-58
58
Total
-142
142
-226
232
EUR ramped (unfloored) is at +/- 100bps in 1 year
USD ramped (unfloored) is at +/- 120bps in 1 year
The NII-at-Risk is primarily driven by the difference in sensitivity of client liabilities, mainly savings, versus
the sensitivity of client assets and investments to rate changes. The investment of own funds only impacts
the earnings sensitivity marginally, as only a relatively small part has to be (re)invested within the one-year
horizon.
NII-at-Risk banking book per currency - year one (*)
in \u20ac million
2022
2021
Ramped, unfloored
Ramped, unfloored
parallel \u25bc
parallel \u25b2
parallel \u25bc
parallel \u25b2
By currency
Euro
-119
114
-181
179
US Dollar
-1
2
-23
23
Other
-23
27
-23
30
Total
-142
142
-226
232
NII. However, the main drivers in a potential change of NII sensitivity are balance sheet developments,
specifically relating to mortgages, loans and savings. In the eurozone, mortgage production was impacted
by an increase in interest rates. Next to the impact on new production, the prepayment incentive decreased
due to the increase in interest rates. The funds entrusted volume did not change significantly, The impact of
explicit and implicit floors on both rates of client assets and savings phased out in the course of the year on
the back of the interest rate increases. Pre-existing hedges, as executed by Group Treasury, were also
adjusted continuously throughout the year to hedge any interest rate risk coming from higher interest
rates. Given that Group Treasury is included in the Wholesale Banking risk numbers, these adjustments
changed the Wholesale Banking NII-at-Risk. Furthermore, ING\u2019s investment of own funds took place against
a lower duration reducing sensitivity. Excluding Model Risk, the total NII-at-Risk remains relatively limited in
comparison to ING\u2019s total interest income.\u00a0
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. This does not include positive earnings in our commercial books. The NPV-at-Risk is defined as the
outcome of an instantaneous increase or decrease in interest rates from applying currency-specific
scenarios. The NPV-at-Risk asymmetry between the downward and upward shock is mainly caused by
convexity risk in the mortgage and savings portfolio.
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.
NPV-at-Risk banking books per business (*)
in \u20ac million
2022
2021
unfloored
unfloored
parallel \u25bc
parallel \u25b2
parallel \u25bc
parallel \u25b2
By business
Wholesale Banking
-1,474
1,299
-1,477
1,444
Retail Banking Benelux
-307
-76
-953
-202
Retail Challengers & Growth Markets
1,327
-1,373
832
-1,111
Corporate Line Banking
1,049
-1,003
1,820
-1,712
Total
594
-1,153
223
-1,580
EUR (unfloored) +/- 100bp shock scenario
USD (unfloored) +/- 120bp shock scenario \u00a0
Year-on-year variance analysis (*)
The overall NPV sensitivity for the rates-up scenario decreased in 2022. This is mainly due to the shorter
duration at which ING strategically invests its own funds. These investments are done in the Corporate Line
Banking.
The changes in NPV-at-Risk in the segments Retail Benelux and Retail Challengers & Growth Markets were
partly offsetting, whereby the higher interest rates reduced the overall convexity. The resulting impact on
retail sensitivity of the increase in interest rates was hedged by Group Treasury in line with the internal ALM
practices. The Group Treasury exposure is reported under business line Wholesale Banking.
IBOR transition (*)
In line with the recommendations from the Financial Stability Board, a fundamental review of benchmarks
for important interest rates has been undertaken. Some interest benchmarks have been reformed, while
others have or will be replaced by risk-free rates (RFR) and discontinued. Following the cessation of GBP, CHF,
JPY, and EUR LIBOR rates on 31 December 2021, USD LIBOR will cease on 30 June 2023.
In 2022, the focus shifted to USD LIBOR, with new USD lending now using the recommended alternative
rates based on SOFR. This is consistent with guidance issued to limit the use of USD LIBOR from
1 January 2022 onward. Risk reduction trades to help manage the run-off of existing USD LIBOR contracts
and positions are a permitted exception.
To enable these changes, the financial sector has issued several guidance papers and other initiatives to
help phase this transition. For example, ISDA has issued an IBOR fallback supplement to help ensure clear
fallback rates apply upon the discontinuation of key IBORs. For loans, various recommendations have been
made to help ensure the inclusion of consistent robust fallback provisions. Public authorities have also
recognised that many contracts do not contain provisions for any alternatives, contain inappropriate
alternatives, or cannot be renegotiated prior to the expected cessation date (\u2018tough legacy\u2019 contracts). For
example, the Financial Conduct Authority (FCA) is expected to ask the USD LIBOR administrator to continue
publishing a 'synthetic' LIBOR rate for 15 months beyond the cessation date to provide extra time for any
remaining contracts. A similar action was taken for GBP and JPY LIBOR. The US has also implemented the
Adjustable Interest Rate (LIBOR) Act, that will revise the contractual terms of in scope contracts to reference
a rate based on SOFR upon cessation of USD LIBOR.
Due to the discontinuation of this important rate, ING, its customers, and the financial services industry face
a number of risks. These risks include legal, financial, operational, and conduct risk. Legal risks are related to
any required changes to existing transactions. Financial risks may arise due to declining liquidity and may
impact a contract directly or the ability to hedge the risks in that contract. Operational risks arise due to the
requirement to adapt IT systems, trade reporting infrastructure and operational processes. Conduct risk also
plays a role, as renegotiation of loan contracts requires active engagement from all parties to a contract,
and may lead to negotiations concentrated in a period close to actual cessation. ING continues to reach out
to impacted clients to manage the relevant timelines.
During 2022, ING sought to ensure that a large portion of the derivative portfolio is covered by ISDA
fallbacks. Regarding the loans, many facilities have already been transitioned to alternative rates.
Additionally, for the remaining portfolio the parameters for the required changes have been communicated
to counterparties, with many now in active discussions on the remaining steps.
The ING IBOR programme has governance in place with progress being tracked by business line steering
committees reporting to a central IBOR steering committee. The programme assesses and coordinates the
actions necessary to manage the required changes to internal processes and systems, including pricing, risk
management, legal documentation, hedge arrangements, as well as the impact on customers. ING
continues to monitor market developments and reform plans for other rates, to anticipate the impact on
the programme, our customers and any related risks.
One such development concerns key Polish Zloty benchmarks. The roadmap published by the Polish
National Working Group in 2022 indicates that the plan is for the market to be ready for a cessation of
WIBOR and WIBID Reference Rates in 2025. It is expected that the reform will be completed by the end of
2024, with the offering of financial products using the new benchmark (WIRON) to progress gradually in
2023 and 2024. 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.
As at 31 December 2022, ING has exposures that have yet to transition related to USD LIBOR and WIBOR.
The tables below summarise these approximate exposures. They exclude exposures that will expire before
the transition date 30 June 2023 and 1 January 2025, respectively. The GBP LIBOR, CHF LIBOR and EONIA
contracts included as at 31 December 2021 have all transitioned or matured.
Non derivative Financial instruments to transition to alternative benchmarks (*)
in \u20ac million at 31 December 2022
Financial Assets non-
derivative
Financial Liabilities\u00a0
non-derivative
Off balance sheet
commitments
Carrying value
Carrying value
Nominal value
By benchmark rate
GBP LIBOR
USD LIBOR
30,040
1,637
7,644
CHF LIBOR
EONIA
WIBOR
22,154
1,411
Total
52,194
1,637
9,055
Non derivative Financial instruments to transition to alternative benchmarks (*)
in \u20ac million at 31 December 2021
Financial Assets non-
derivative
Financial Liabilities\u00a0
non-derivative
Off balance sheet
commitments
Carrying value
Carrying value
Nominal value
By benchmark rate1
GBP LIBOR
764
350
USD LIBOR
41,805
1,542
16,435
CHF LIBOR
1
EONIA
23
184
Total
42,570
1,565
16,969
1 WIBOR transition plans became concrete in 2022 and therefore no comparatives for 2021 are included.
For derivatives linked to USD LIBOR, the conduct risk is limited as the majority are transacted with clearing
houses, which will transition through a standardised exercise in the second quarter of 2023. For USD LIBOR
derivatives that are not centrally cleared, the main transition will occur via the ISDA IBOR fallback protocol at
30 June 2023.
Derivative Financial instruments to transition to alternative benchmarks (*)
31 December 2022
31 December 2021
in \u20ac million
Nominal value
Nominal value
By benchmark rate1
GBP LIBOR
822
USD LIBOR2
495,318
488,499
WIBOR3
136,318
Total
631,636
489,321
1 For cross-currency swaps all legs of the swap are included that are linked to a main IBOR that is significant to ING.
2 The prior period has been updated to improve consistency and comparability.
3 WIBOR transition plans became concrete in 2022 and therefore no comparatives for 2021 are included.
In addition to the amounts in the table above, ING has interest rate swaptions that refer to the USD LIBOR
ICE swap rate with a notional of \u20ac10,810 million (2021: \u20ac10,343 million) that are yet to transition. The
transition of these contracts is in general governed by a specific ISDA protocol.
Given that IBOR Reform may have various accounting implications, the International Accounting Standards
Board (IASB) has undertaken a two-phase project:
\u2022Phase 1 addresses those issues that affect financial reporting before the replacement of an existing
benchmark. Phase 1 amendments to IFRS were issued by the IASB in 2019 and were early adopted by
ING in the same year. This allows ING to apply a set of temporary exceptions to continue hedge
accounting even when there is uncertainty about contractual cash flows arising from the reform. Under
these temporary exceptions, interbank offered rates are assumed to continue unaltered for the purposes
of hedge accounting until such time as the uncertainty is resolved.
\u2022Phase 2 focuses on issues that may affect financial reporting when the existing benchmark rate is
reformed or replaced. Phase 2 amendments to IFRS were issued by the IASB in 2020 and became
effective in 2021. Phase 2 amendments to IFRS relate mainly to accounting for changes in the basis for
determining the contractual cash flows of financial assets and liabilities due to the IBOR reform and
impact on hedge accounting when an existing benchmark rate is reformed or replaced with an
alternative risk-free rate.
Specifically, Phase 2 amendments require that the effective interest rate on debt financial instruments is
adjusted, and hedge accounting continues on transition to risk free rates, but only to the extent that the
modifications made to financial instruments are those necessary to implement the IBOR Reform and that
the new basis for calculating cash flows is \u2018economically equivalent\u2019 to the previous basis. By applying these
mandatory amendments, ING avoids recognising modification gains and losses on debt instruments that
would otherwise be required in the absence of Phase 2 amendments (changes to debt instruments resulting
from IBOR Reform are treated as a reset to the instrument\u2019s variable interest rate). In addition, ING avoids
hedge accounting discontinuations when modifying both hedged items and hedging instruments (and
related hedge documentation) as a consequence of IBOR reform that would otherwise be required in the
absence of Phase 2 amendments.\u00a0
As explained above, Phase 1 and Phase 2 IBOR amendments to IFRS, amongst other changes, provide
specific hedge accounting reliefs that allow hedge accounting relationships to continue when IBOR Reform is
ongoing. Phase 1 reliefs cease to apply when uncertainty arising from IBOR Reform is no longer present with
respect to the timing and amount of the IBOR-based cash flows of the relevant instruments. It is ING\u2019s policy
to cease to apply Phase 1 reliefs when the applicable contract (either hedging instrument or hedged item) is
actually modified. As a result, for these hedge accounting relationships the applicable Phase 1 reliefs ceased
to apply and Phase 2 became applicable. For USD LIBOR exposures, and although the administrator of LIBOR
confirmed on 5 March 2021 its plans for the cessation of USD LIBOR rates at the end of June 2023, there is
still uncertainty with respect to the timing of the transition as well as the transition strategy for individual
hedged items and/or hedging instruments linked to USD LIBOR. Therefore, for USD LIBOR 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, Phase 2 reliefs will become applicable.
In addition, in 2022 ING started to apply Phase 1 reliefs to the hedge accounting relationships linked to
WIBOR as there is uncertainty arising from the WIBOR reform with respect to the timing and the amount of
the underlying cash flows to which ING is exposed.
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.
Governance \u2013 Core banking business (*)
Every business unit hedges the FX risk resulting from core banking business activities into its base currency.
Consequently, assets and liabilities are matched in terms of currency.
Governance \u2013 FX translation result (*)
ING\u2019s 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. 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 \u2013 FX translation result (*)
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 Market Risk Banking Book RAS.
Foreign currency exposures banking books (*)
in \u20ac million
Foreign Investments
Hedges
Net exposures
2022
2021
2022
2021
2022
2021
US dollar1
10,470
8,218
-2,376
-99
8,093
8,119
Pound sterling
1,364
1,593
-58
1,306
1,592
Polish zloty
2,714
2,761
-321
-142
2,393
2,620
Australian dollar
3,781
3,774
-2,673
-2,511
1,108
1,263
Turkish lira
750
729
750
729
Chinese yuan
1,871
1,976
-107
1,871
1,869
Russian rouble
391
256
-174
392
82
Other currency
5,740
5,860
-3,761
-3,453
1,979
2,407
Total
27,081
25,167
-9,189
-6,486
17,892
18,681
Hyperinflation accounting and goodwill impairment had limited impact on the Turkish lira FX exposure to the CET1 Ratio.
The structural Turkish lira exposure arising from ING Bank Turkey\u2019s assets and liabilities remains within risk limits.
Equity price risk in banking books (*)
Governance (*)
ING maintains a strategic portfolio with substantial equity exposure in its banking books. Local offices are
responsible for the management of the equity investment positions. Financial Risk is responsible for
monitoring the regulatory capital for equity investments on a monthly basis and acts independently from
ING/local management when monitoring these positions.
Risk profile (*)
Equity price risk arises from the possibility that an equity security\u2019s price will fluctuate, affecting the values
of the equity security itself as well as other instruments whose value react similarly to the particular
security, a defined basket of securities, or a securities index. ING\u2019s equity exposure mainly consists of the
investments in associates and joint ventures of \u20ac1,500 million (2021: \u20ac1,587 million) and equity securities
held at fair value through other comprehensive income (FVOCI) of \u20ac1,887 million (2021: \u20ac2,457 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.
Year-on-year variance analysis (*)
In 2022, the revaluation reserve equity securities decreased by \u20ac95 million from \u20ac1,282 million to \u20ac1,187
million. In 2022, the equity securities at fair value through OCI decreased by \u20ac570 million mainly due to
divestment of HQLA eligible equity instruments.
Revaluation reserve equity securities at fair value through other comprehensive income (*)
in \u20ac million
2022
2021
Positive re-measurement
1,190
1,291
Negative re-measurement
-4
-9
Total
1,187
1,282
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 2022, 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.
Governance (*)
The Financial Markets Risk Committee (FMRC) is the market risk committee that, within the risk appetite set
by the ALCO Bank, sets the market risk limits both on an aggregated level and on a desk level. Financial Risk/
Trading Risk Management (FR/ TRM) advises both FMRC and ALCO Bank on the market risk appetite of the
trading activities.
With respect to the trading portfolios, 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. Trading activity is
systematically reviewed and positioned against the mandates are assessed jointly by the first and second
lines of defence.
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 Event Risk (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.
As of June 2022, ING has received an official permission from the ECB to perform offsetting of positions with
the exception of Ukraine, Russia and Turkey. Hence the regulatory capital numbers reported from Q2 2022
onwards, are calculated with offsetting for all base entities excluding Ukraine, Turkey\u00a0 and Russia.
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%, 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) if 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 e.g. 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\u2019s portfolio is estimated, based on
equally weighted observed market movements of the previous year (260 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 ten-day horizon the one-day risk factor shifts are scaled by the
square root of ten 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: HVaR 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
ten 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 results (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 \u2018outlier\u2019 occurs. Based on ING\u2019s one-sided confidence level of 99%, an outlier is expected once in every
100 business days.
On an overall level in 2022, there were five outliers for hypothetical P&L and three outliers for actual P&L.
The actual and hypothetical outliers occurred during the past one year concentrated in 1Q2022 mainly due
to large moves in Russian credit default swaps and Rouble volatility.
Stressed HVaR (*)
The Stressed HVaR (SVaR) is intended to replicate the HVaR calculation that would be generated on the
bank\u2019s current portfolio with inputs calibrated to the historical data from a continuous 12-month period of
significant financial stress relevant to the bank\u2019s portfolio.
To calculate SVaR, ING uses the same model that is used for 1DHVaR, with a ten-day horizon. The data for
the historical stress period used currently includes the height of the credit crisis around the fall of Lehman
Brothers, and this choice is reviewed regularly. 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% 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 are 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.
Stress testing and event risk (*)
Stress testing and event risk are valuable risk management tools. In addition to the bank-wide stress test
framework as described in the stress-testing section, FI-FM Risk performs additional assessments, specific to
the trading book, with various frequencies: sensitivity analyses (single-risk factor and multi-risk factor), ad-
hoc stress tests (e.g. Covid-19 scenarios) and structured stressed scenario tests under the event risk
framework - to monitor market risks under extreme market conditions. Event risk evaluates the bank\u2019s
financial stability under severe but plausible stress scenarios and assists in decision-making aimed at
maintaining a financially healthy going-concern institution after a severe event occurs. Event risk is based
on historical as well as hypothetical extreme scenarios. The result is an estimate of the profit and loss
caused by a potential event and its worldwide impact for ING.
ING\u2019s event risk policy is based on a large set of possible stress scenarios per risk type. 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. For equity products, for example, both a crisis scenario
(prices decrease) as well as a bull scenario (prices increase) are assumed. Scenarios are calculated based on
events happening independently, jointly by region, or in all countries simultaneously. This way, for each risk
type, a large set of scenarios is calculated. The worst scenarios per market are combined across markets by
assessing both independent events per market, and the worst events happening in all markets at the same
time.
Sensitivities (*)
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 \u20ac million
2022
2021
Foreign exchange
Foreign exchange
US Dollar
-187
US Dollar
-160
Romanian Leu
88
Taiwan Dollar
42
Japanese Yen
86
Romanian Leu
32
Chinese Yuan
32
Japanese Yen
27
South Korean Won
28
South Korean Won
-24
Most important interest rate and credit spread sensitivities at year-end (*)
in \u20ac thousand
2022
2021
Interest Rate (BPV) 1
Interest Rate (BPV) 1
Euro
-334
Euro
-501
British Pound
-95
US Dollar
185
US Dollar
-79
British Pound
-75
Taiwan Dollar
67
Taiwan Dollar
73
Japanese Yen
63
Japanese Yen
-57
Credit Spread (CSO1) 2
Credit Spread (CSO1) 2
Netherlands
162
Netherlands
535
United States
151
Germany
408
Japan
102
United States
171
France
88
France
112
Germany
87
China
110
Funding and liquidity adequacy and risk appetite (*)
ING identifies various key drivers of future liquidity and funding needs on an ongoing basis and through the
periodic risk identification process. Taking into consideration the identified drivers, ING regularly assesses its
current and future liquidity adequacy and, if deemed necessary, takes steps to further improve ING\u2019s
liquidity position and to have sufficient counterbalancing capacity. A liquidity adequacy statement is
formulated on at least a quarterly basis to substantiate and reflect the management view on the current
funding and liquidity position as well as the potential future challenges. The quarterly liquidity adequacy
statement is an important part of ING\u2019s ILAAP process.
ING assesses its F&L adequacy through three lenses \u2013 stress, economic and normative:
\u2022Through the stress lens, ING evaluates its ability to withstand a period of prolonged F&L stress for both
normative and economic requirements or limits under idiosyncratic, market-related or a combination of
idiosyncratic and market-related scenarios, which lead to customer deposit outflows, deterioration of
access to funding markets, and lower liquidity value of counterbalancing capacity.
\u2022Through the economic lens, ING assesses the extent to which its customers, professional counterparties
and investors are comfortable in providing deposits and funding in tenors, currencies and instruments
necessary to sustainably fund the business (intraday, short-term and long-term) in a going-concern
situation.
\u2022Through the normative lens, ING ascertains that the bank is in the position to meet current and
forthcoming home and host regulatory requirements.
For each lens, ING has established a related set of risk appetite statements which define ING\u2019s risk appetite
commensurate with the principles of liquidity adequacy. These risk appetite statements are summarised in
the next graph.
The F&L risk appetite statements are translated into a number of metrics with appropriate boundaries and
instruments which are used to measure and manage ING\u2019s 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 (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\u2019s risk appetite and normative
requirements.
The macroeconomic and market environment are also important considerations in ING\u2019s funding and
liquidity framework. The macroeconomic environment comprises various exogenous factors over which ING
has no control, but which may have a material impact on ING\u2019s F&L position. The main macroeconomic
factors analysed on a regular basis include:
\u2022Global and local economic performance e.g. shifts in GDP, inflation rates, unemployment rates and public
deficit/surplus.
\u2022Changing geopolitical trends.
\u2022Monetary policy with a focus on the unconventional monetary measures employed by central banks in
recent years including the measures taken since the start of the Covid-19 crisis and the more recent
period of increased inflation.
\u2022Regulatory requirements, e.g. understanding the changing regulatory landscape as well as the impact of
ING\u2019s 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.
Liquidity stress-testing (*)
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\u2019s 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 Bank, 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 and combined (idiosyncratic and market-
wide) stress scenarios. The design of the framework is based on empirical evidence supplemented by expert
judgement. 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\u2019s F&L risk framework and F&L risk
management, including:
\u2022Risk Appetite Framework (through risk appetite statements).
\u2022Risk identification and assessment.
\u2022Monitoring of the liquidity and funding position.
\u2022Business actions (if needed).
\u2022Contingency funding plan.
\u2022Early 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\u2019s liquidity position is stress tested at least monthly 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 regular 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
2022, this included stress-test scenarios dedicated to the war in Ukraine, inflation, and the impact of
monetary tightening. The internal stress scenarios also serve as input for decision making on additional
contingency measures.
Contingent F&L risks are addressed in the Contingency Capital and Funding Plan with a focus on early
warning indicators as well as organisation and planning of liquidity management in times of stress. The
contingency funding measures are developed in conjunction with the ING Recovery Plan and are tested on a
regular basis.
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As at 31\u00a0December 2022, Cash and cash equivalents includes cash and balances with central banks of EUR
87,614 million (2021: EUR 106,520 million; 2020: EUR 111,087 million). Reference is made to Note 33 'Cash
and cash equivalents'.
References relate to the accompanying notes. These are an integral part of the Consolidated financial
statements.
The table below presents the Interest and dividend received and paid.
in EUR million
2022
2021
2020
Interest received
28,110
21,515
23,365
Interest paid
-14,201
-8,723
-9,690
13,909
12,792
13,675
Dividend received 1
229
172
144
Dividend paid
-6,319
-3,165
-46
1\u00a0 Includes dividends received as recognized within Investment Income, from equity securities included in the Financial assets at fair
value through profit or loss, Financial assets at fair value through OCI, and from Investments in associates and joint ventures. Dividend
paid and received from trading positions have been included.
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.
28\u00a0 Net cash flow from operating activities
The table below shows a detailed overview of the net cash flow from operating activities.
Cash flows from operating activities
in EUR million
2022
2021
2020
Cash flows from operating activities
Result before tax
5,493
6,774
3,810
Adjusted for:
- Depreciation and amortisation
711
834
829
-\u00a0 Addition to loan loss provisions
1,861
516
2,675
-\u00a0 Other non-cash items included in result before tax
5,519
413
1,259
Taxation paid
-1,489
-1,871
-1,735
Changes in:
\u2013\u00a0\u00a0Loans and advances to banks, not available on demand
-5,836
262
10,031
\u2013\u00a0\u00a0Deposits from banks, not payable on demand
-26,976
8,438
43,044
Net change in loans and advances to/ from banks, not available/
payable on demand
-32,813
8,700
53,076
\u2013\u00a0\u00a0Trading assets
-5,485
-29
-2,095
\u2013\u00a0 Trading liabilities
11,975
-5,596
4,667
Net change in Trading assets and Trading liabilities
6,490
-5,624
2,571
Loans and advances to customers
-19,306
-27,772
2,888
Customer deposits
34,005
18,339
40,576
\u2013\u00a0\u00a0Non\u2013trading derivatives
-5,469
290
-1,420
\u2013\u00a0\u00a0Assets designated at fair value through profit or loss
56
-1,905
-1,371
\u2013\u00a0\u00a0Assets mandatorily at fair value through profit or loss
-4,143
1,650
-1,963
\u2013\u00a0\u00a0Other assets
-2,861
-121
1,092
\u2013\u00a0\u00a0Other financial liabilities at fair value through profit or loss
9,843
-6,795
1,190
\u2013\u00a0\u00a0Provisions and other liabilities
-667
-1,298
-298
Other
-3,241
-8,179
-2,770
Net cash flow from/(used in) operating activities
-2,769
-7,869
103,179
in unrealised revaluations' represent fair value adjustments to the hedged item attributable to the hedged
interest rate risk. Reference is made to paragraph 'fair value hedge accounting' in Note 36 'Derivatives and
hedge accounting'.
30\u00a0 Cash and cash equivalents
Cash and cash equivalents
in EUR million
2022
2021
2020
Treasury bills and other eligible bills
1
23
Deposits from banks/Loans and advances to banks
7,775
1,121
477
Cash and balances with central banks
87,614
106,520
111,087
Cash and cash equivalents at end of year
95,390
107,664
111,565
Treasury bills and other eligible bills included in cash and cash equivalents
in EUR million
2022
2021
2020
Treasury bills and other eligible bills included in trading assets
0
0
0
Treasury bills and other eligible bills included in FVOCI
0
0
0
Treasury bills and other eligible bills included in securities at AC
0
23
0
1
23
0
Deposits from banks/Loans and advances to banks
in EUR million
2022
2021
2020
Included in cash and cash equivalents:
\u2013\u00a0 Deposits from banks
-6,172
-7,059
-8,788
\u2013\u00a0 Loans and advances to banks
13,947
8,180
9,265
7,775
1,121
477
Not included in cash and cash equivalents:
\u2013\u00a0 Deposits from banks
-50,460
-78,033
-69,310
\u2013\u00a0 Loans and advances to banks
21,156
15,411
16,098
-29,304
-62,621
-53,212
Total as included in the statement of financial position:
\u2013\u00a0 Deposits from banks
-56,632
-85,092
-78,098
\u2013\u00a0 Loans and advances to banks
35,103
23,591
25,363
-21,529
-61,501
-52,734
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1\u00a0 Basis of preparation and significant accounting policies
1.1\u00a0 Reporting entity and authorisation of the Consolidated financial statements
ING Bank N.V. (Naamloze vennootschap) is a company domiciled in Amsterdam, the Netherlands.
Commercial Register of Amsterdam, number 33031431. ING Bank N.V. is a wholly-owned subsidiary of ING
Groep N.V. domiciled in Amsterdam, the Netherlands. These Consolidated financial statements, as at and for
the year ended 31 December 2022, comprise ING Bank N.V. (the Parent company) and its subsidiaries,
together referred to as ING Bank. ING Bank is a global financial institution with a strong European base,
offering a wide range of retail and wholesale banking services to customers in over 40 countries.\u00a0 \u00a0\u00a0
The ING Bank Consolidated financial statements, as at and for the year ended 31 December 2022, were
authorised for issue in accordance with a resolution of the Management Board Banking on 6 March 2023.
The General Meeting of the Shareholder may decide not to adopt the financial statements, but may not
amend these.
1.2\u00a0 Basis of preparation of the Consolidated financial statements
The ING Bank Consolidated financial statements have been prepared in accordance with International
Financial Reporting Standards (IFRS) as adopted by the European Union (EU) and the relevant articles of Part
9 of Book 2 of the Dutch Civil Code.
IFRS as adopted by the EU are IFRS Standards and IFRS Interpretations as issued by the International
Accounting Standards Board (IASB) and the IFRS Interpretations Committee (IFRIC) with some limited
modifications such as the temporary \u2018carve-out\u2019 from IAS 39 \u2018Financial Instruments: Recognition and
Measurement\u2019 (herein, referred to as IFRS).
Under the EU carve-out, ING Bank applies fair value hedge accounting to portfolio hedges of interest rate risk
(macro hedging). For further information, reference is made to paragraph 1.7.4 \u2018Derivatives and hedge
accounting\u2019 of this note and to Note 36 'Derivatives and hedge accounting'.
The ING Bank Consolidated financial statements have been prepared on a going concern basis and there are
no significant doubts about the ability of ING Bank 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.
1.2.1\u00a0 Presentation of Risk management disclosures
To improve transparency, reduce duplication and present related information in one place, certain
disclosures of the nature and extent of risks related to financial instruments required by IFRS 7 \u2018Financial
instruments: Disclosures\u2019 are included in the \u2018Risk management\u2019 section of the Annual Report.
These disclosures are an integral part of ING Bank Consolidated financial statements and are indicated in the
\u2018Risk management\u2019 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.
1.3\u00a0 Impact of Russian invasion in Ukraine
The war in Ukraine had, besides an immense impact on the lives of millions of people, a negative impact on
the global economy. While businesses and households were still recovering from the economic
consequences of Covid-19, developments in Ukraine further distorted supply chains, caused higher energy
costs and aggravated an already high inflation rate environment. This, in combination with central bank
rate hikes, worsened the macroeconomic outlook.
As a result of the economic effects of Russian invasion and second order effects uncertainty and level of
management judgement remains at an elevated level in 2022, particularly in the estimation of loan loss
provisions (including the need for management adjustments), the determination of fair values and\u00a0
impairment assessment of an investment in an associate.\u00a0
Reference is made to the notes of the financial statements as well as Risk Management chapter for further
information on the impact of the Russian invasion of Ukraine and second order impacts.
.
1.4\u00a0 Changes to accounting policies and presentation
ING Bank has consistently applied its accounting policies to all periods presented in these Consolidated
financial statements.
In 2022, ING Bank updated the presentation in note 7 \u2018Loans and advances to customers\u2019 to improve
consistency and comparability. Comparative figures for 2021 have been updated accordingly.
1.4.1\u00a0 Changes in IFRS effective in 2022
The following amended standards became effective in 2022:
\u2022Amendments to IFRS 3 \u2018Business Combinations\u2019: Reference to the Conceptual Framework (issued in May
2020).
\u2022Amendments to IAS 16 \u2018Property, Plant and Equipment\u2019: Proceeds before Intended Use (issued in May
2020).
\u2022Amendments to IAS 37 \u2018Provisions, Contingent Liabilities and Contingent Assets\u2019:\u00a0 Onerous Contracts \u2014
Cost of Fulfilling a Contract (issued in May 2020).
\u2022Annual improvements to IFRS Standards 2018-2020 Cycle: Amendments to IFRS 1 \u2018First-time Adoption of
International Financial Reporting Standards\u2019, amendments to IFRS 9 \u2018Financial Instruments\u2019 and
amendments to IFRS 16 \u2018Leases\u2019 (issued in May 2020).
The above changes did not have significant impact on ING Bank\u2019s Consolidated financial statements. ING
Bank has not early adopted any standard, interpretation or amendment in 2022 which has been issued, but
is not yet effective.
1.4.2\u00a0 Upcoming changes in IFRS after 2022
The following published amendments are not mandatory for 2022 and have not been early adopted by ING
Bank
Effective in 2023 (endorsed by the EU):
\u2022IFRS 17 'Insurance Contracts' (issued in May 2017), including amendments to IFRS 17 (issued in June
2020).
IFRS 17 \u2018Insurance Contracts\u2019 is a new accounting standard for insurance contracts covering recognition and
measurement, presentation and disclosure. Once effective, IFRS 17 will replace IFRS 4 \u2018Insurance Contracts\u2019,
which allowed diversity in accounting practices for insurance contracts. In June 2020, the IASB published
amendments to IFRS 17 including a scope exclusion for credit card contracts and similar contracts that
provide insurance coverage, and an optional scope exclusion for loans with death waivers. ING does not
have an insurance business, but on a limited basis sells insurance products as a broker where it does not run
the insurance risk. ING Bank performed an impact assessment which revealed that a portfolio of loans with
death waivers in the Netherlands with a net carrying amount of approximately of EUR 750 million might be
in scope of IFRS 17. Following the above mentioned amendments to IFRS 17 in 2020 which allow an
accounting policy choice, ING Bank intends to account for assets in this portfolio in their entirety, including
death waiver features, using IFRS 9 \u2019Financial Instruments\u2019 and not IFRS 17. As a result, this portfolio will no
longer meet the \u2018solely payments of principal and interest\u2019 (SPPI) criterion, causing the portfolio to no longer
be recognised at amortised cost but rather at fair value through profit or loss. This reclassification is not
expected to have a material impact on equity or result of ING Bank, as the fair value is expected not to differ
materially from the current book value. Hence, the financial impact of IFRS 17 on ING Bank is expected to be
limited.
The following amendments will also be effective in 2023. However, the implementation of these
amendments is expected to have no significant impact on NG Bank's Consolidated financial statements.
\u2022Amendments to IAS 1 \u2018Presentation of Financial Statements\u2019: Disclosure of Accounting Policies (issued in
February 2021).
\u2022Amendments to IAS 8 \u2018Accounting Policies, Changes in Accounting Estimates and Errors\u2019: Definition of
Accounting Estimates (issued in February 2021).
\u2022Amendments to IAS 12 \u2018Income Taxes\u2019: Deferred Tax Related to Assets and Liabilities Arising From a
Single Transaction (issued in May 2021).
Effective in 2024 (not yet endorsed by the EU):
\u2022Amendments to IFRS 16 'Leases': Lease Liability in a Sale and Leaseback (issued in September 2022).
\u2022Amendments to IAS 1 \u2018Presentation of Financial Statements\u2019: Classification of Liabilities as Current or
Non-current (issued in January 2020).
1.5\u00a0 Significant judgements and critical accounting estimates and assumptions
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 Bank 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:
\u2022Loan loss provisions (financial assets);
\u2022The determination of the fair values of financial assets and liabilities;\u00a0
\u2022Impairment assessment of an investment in associate;
\u2022Provisions; and
\u2022Accounting for Targeted Longer-Term Refinancing Operations (TLTRO).
For further discussion of the significant judgements and critical accounting estimates and assumptions in
these areas, reference is made to the relevant parts in paragraph 1.7 \u2018Financial instruments\u2019 (specifically
1.7.8 \u2018Impairment of financial assets\u2019, 1.7.3 for \u2018Fair values of financial assets and liabilities\u2019, 1.11
\u2018Investments in associates and joint ventures\u2019, 1.18 \u2018Provisions, contingent liabilities and contingent assets\u2019
and 1.7.9 \u2018Accounting for Targeted Longer-Term Refinancing Operations (TLTRO)\u2019) of this note and the
applicable notes to the Consolidated financial statements.
1.6\u00a0 Other developments
Application of IAS 29 \u2018Financial Reporting in Hyperinflationary Economies\u2019
During the second quarter of 2022 Turkey became a hyperinflationary economy for accounting purposes.
As ING Bank has a subsidiary in Turkey, ING Bank applied IAS 29 \u2018Financial Reporting in Hyperinflationary
Economies\u2019 to its operations as if the economy in Turkey had always been hyperinflationary. Given that ING
Bank presents its results in EUR, comparatives were not restated and IAS 29 was applied from 1 January
2022 with the impact of the first-time application and the effect for the period both shown in these
Consolidated financial statements for the year ended 31 December 2022.
Under IAS 29, the results of the operations in Turkey 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 development of the CPI during the year ended 31 December 2022 was as follows (2003=100):
1 January 2022\u00a0 686.95
31 December 2022 1,128.45
Change for the period\u00a0 64.27%
To state all the items in the financial statements in terms of their current purchasing power at the reporting
date, ING Bank restated the non-monetary items of ING Turkey (such as properties and equipment,
intangibles, right-of use assets and shareholder\u2019s equity) for the changes in CPI up to the reporting date.
Monetary items (such as cash and balances with banks, loans and advances and deposits) are not restated
as they are already expressed in the current purchasing power. Furthermore, all items in the statement of
comprehensive income were also restated for the effects of inflation based on the developments in CPI
during the 12 month period to reflect the purchasing power as at 31 December 2022.
The effect of such restatement of the statement of comprehensive income and the balance sheet for
inflation in the current period has been recognised in the statement of profit or loss within \u2018Other net
income\u2019 as a \u2018Net monetary gain or loss\u2019. 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
Turkey.
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 Turkey are translated and presented in EUR at the exchange rate on 31
December 2022. 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 Bank selected to present both the restatement effect resulting from restating
ING Bank\u2019s interest in the equity of ING Turkey as required by IAS 29; and the translation effect from
translating at a closing rate that differs from the previous closing rate, in the Currency translation reserve.
Refer to Note 19 \u2018Equity\u2019 for the impact of applying IAS 29 during the year ended 31 December 2022.
1.7\u00a0 Financial instruments
ING Bank applies IFRS 9 \u2018Financial Instruments\u2019 to the recognition, classification and measurement, and
derecognition of financial assets and financial liabilities and the impairment of financial assets. The Group
applies the requirements of IAS 39 \u2018Financial Instruments: Recognition and Measurement\u2019 for hedge
accounting purposes.
1.7.1\u00a0 Recognition and derecognition of financial instruments
Recognition of financial assets
Financial assets are recognised in the balance sheet when ING Bank 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 Bank 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 Bank 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.
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.
1.7.2\u00a0 Classification and measurement of financial instruments
Financial assets
ING Bank classifies its financial assets in the following measurement categories:
\u2022those to be measured subsequently at fair value (either through OCI, or through profit or loss); and
\u2022those to be measured at amortised cost (AC).
At initial recognition, ING Bank 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\u2019s 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 Bank\u2019s 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 Bank 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\u2019s business model for managing the financial assets and the contractual terms of the
cash flows, there are three measurement categories into which ING Bank classifies its debt instruments:
\u2022Amortised 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.
\u2022FVOCI:
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\u2019 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.
\u2022FVPL:
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 Bank 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 repo\u2019s) 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 Interest income or 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
Interest income or Interest expense in the period in which it arises.
ING Bank 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 Bank applies the fair value through OCI option to
investments which are considered strategic, consisting of investments that add value to ING Bank\u2019s 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\u2019s 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:
\u2022the 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
\u2022the remaining amount of change in the fair value is presented in profit or loss in \u2018Valuation results and
net trading income\u2019. 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 \u2018Interest income
(expense).
A financial guarantee contract is a contract that requires ING Bank 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 \u2018Financial instruments\u2019 (see section \u201cImpairment of financial assets\u201d) and (b)
the amount initially recognised less, when appropriate, cumulative amortisation recognised in accordance
with the revenue recognition principle of IFRS 15 \u2018Revenue from contracts with customers\u2019.
1.7.3\u00a0 Fair values of financial assets and liabilities
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 \u2018Day One Profit or Loss\u2019) is deferred. ING Bank 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 Bank 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.
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 Bank 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 Bank 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 Bank\u2019s own credit risk by means of a DVA. Additionally, derivatives
valued at fair value are adjusted for credit risk by a BVA. The BVA is of a bilateral nature as both the credit
risk on the counterparty (CVA) as well as the credit risk on ING Bank (DVA) are included in the adjustment. All
input data that is used in the determination of the BVA is based on market implied data. Additionally,
wrong-way risk (when exposure to a counterparty is increasing and the credit quality of that counterparty
deteriorates) and right-way risk (when exposure to a counterparty is increasing and the credit quality of
that counterparty improves) are taken into account in the measurement of the valuation adjustment.
To include the funding risk, ING Bank applies an additional \u2018Funding Valuation Adjustment\u2019 (FVA) to the
uncollateralised derivatives based on the market price of funding liquidity. ING Bank also applies to certain
positions other valuation adjustments to arrive at the fair value: Bid-Offer adjustments, Model Risk
Adjustments and Collateral Valuation Adjustments (CollVA).
Significant judgements and critical accounting estimates and assumptions:
\u2022Even 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.\u00a0
\u2022Valuation 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.\u00a0
\u2022Price 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.
\u2022Assessing whether a market is active, and whether an input is observable and significant, requires
judgement. ING Bank 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.
\u2022Reference is made to Note 35 'Fair value of assets and liabilities ' and to the \u2018Market risk\u2019 paragraph in
the \u2018Risk management\u2019 section of the Annual Report for the basis of the determination of the fair value
of financial instruments and related sensitivities.
1.7.4\u00a0 Derivatives and hedge accounting
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 Bank decided to exercise this accounting policy choice
and did not adopt IFRS 9 hedge accounting as of 1 January 2018. Furthermore, ING Bank applies fair value
hedge accounting for portfolio hedges of interest rate risk (macro fair value hedges) in accordance with the
EU carve-out version of IAS 39.
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 and 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 Bank\u2019s risk management strategy.
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 Bank 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 Bank documents the relationship between hedging instruments and
hedged items, its risk management objective, together with the methods selected to assess hedge
effectiveness. ING Bank 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.
IBOR Transition - specific policies applicable from 1 January 2019 for hedges directly
affected by IBOR reform
As further explained in the \u2018IBOR Transition\u2019 paragraph of the \u2018Risk management\u2019 section, the financial
markets are going through a significant reform of interbank offered rates (IBOR) and financial institutions
are obligated to implement a replacement of major interest rate reference rates.
Given that IBOR reform may have various accounting implications, the International Accounting Standards
Board (IASB) has undertaken a two phase project. Phase 1 addresses those issues that affect financial
reporting before the replacement of an existing benchmark. Phase 1 amendments to IFRS were issued by
the IASB in 2019. Phase 2 focuses on issues that may affect financial reporting when the existing benchmark
rate is reformed or replaced. Phase 2 amendments to IFRS were issued by the IASB in 2020.
Phase 1 amendments to IFRS allow ING Bank to apply a set of temporary exceptions to continue hedge
accounting even when there is uncertainty about contractual cash flows arising from the reform. Under
these temporary exceptions, interbank offered rates are assumed to continue unaltered for the purposes of
hedge accounting until such time as the uncertainty is resolved.
More specifically, the following temporary reliefs are part of the Phase 1 amendments:
\u2022Highly probable requirement for cash flow hedges
When determining whether a forecast transaction is highly probable, it is assumed that the interest rate
benchmark on which the hedged cash flows are based is not altered as a result of the reform.
\u2022Prospective assessment of hedge effectiveness
When performing the prospective assessment it is assumed that the interest rate benchmark on which
the hedged cash flows are based is not altered as a result of the reform.
\u2022Retrospective assessment of hedge effectiveness
When performing the retrospective assessment hedges are allowed to pass the assessment even if
actual results are outside the 80-125% range, during the period of uncertainty arising from the IBOR
reform.
\u2022Designation of a component of an item as a hedged item
For hedges of the benchmark component of interest rate risk affected by the reform, the separately
identifiable requirement only needs to be demonstrated at the inception of such hedging relationships
(including macro hedges).
The amendments are relevant given that ING Bank hedges and applies hedge accounting to benchmark
interest rate exposure part of IBOR reform. ING Bank hedges are being progressively amended, where
necessary, to incorporate the new benchmark rates. Temporary exceptions under Phase 1 continued to be
relevant for ING Bank as at 31 December 2022 (for USD and WIBOR).
ING Bank will completely cease to apply the amendments when this uncertainty is no longer present or
when the hedging relationship is discontinued. Refer to Note 36 'Derivatives and hedge accounting' for the
disclosures relating to the application of the amendments as part of Phase 1. Refer to note \u2018Risk
management/ IBOR Transition\u2019 for more information regarding the end of Phase 1 reliefs for ING Bank\u2019s
hedging relationships.
Phase 2 amendments require that hedge accounting continues on transition to risk free rates provided that
the modifications made to financial instruments are those necessary to implement the IBOR Reform and
that the new basis for calculating cash flows is \u2018economically equivalent\u2019 to the previous basis. Particularly,\u00a0
Phase 2 amendments allow the continuation of hedging relationships, subject to amending their
documentation to reflect changes in hedged instruments, hedging instruments, hedged risk, and/or the
method for measuring effectiveness during the transition to the new benchmark rates. During 2022, Phase 2
continued to be relevant for ING Bank when ING actually transitioned its financial instruments (designated in
hedge accounting relationships) to the new benchmark rates (mainly, USD LIBOR).
More specifically, the following temporary reliefs are part of the Phase 2 amendments:
Relief from discontinuing hedging relationships
\u2022Amendments in the hedge documentation as a consequence of changes required by the IBOR reform do
not result in the discontinuation of the hedge relationship nor the designation of a new hedge
relationship. The changes can be in form of designating an alternative benchmark rate as a hedged risk,
the description of the hedging instrument, the description of the hedged item, or the method to measure
the effectiveness.
\u2022When the hedged item is amended as a consequence of the IBOR reform (or if the hedge has previously
been discontinued), amounts accumulated in the cash flow hedge reserve are deemed to be based on
the Risk-Free Rate (RFR). This results in the release of the cash flow hedge reserve to profit or loss in the
same period or periods in which the hedged cash flows that are now based on the RFR affect profit or
loss.
\u2022When the items within a designated group of hedged items are amended as a consequence of the IBOR
reform, the hedging strategy remains and is not discontinued. As items within the hedged group
transition at different times from IBORs to RFRs, they are transferred to sub-groups of instruments that
reference RFRs as the hedged risk. The existing IBORs remain designated as the hedged risk for the other
sub-group of hedged items, until they are also updated to reference the new RFR. The usual hedge
accounting requirements are applied to the hedge relationship in its entirety.
\u2022For the assessment of retrospective hedge effectiveness, the cumulative fair value changes may be reset
to zero when the exception to the retrospective assessment of the Phase 1 reliefs ends. This election is
made separately for each hedging relationship (i.e., on a hedge-by-hedge basis).
\u2022Temporary relief from having to meet the separately identifiable requirement: a RFR is considered a
separately identifiable risk component if it is reasonably expected to meet the separately identifiable
requirement within 24 months from the date it is first designated as a non-contractually specified risk
component (i.e. when the entity first designates the RFR as a non-contractually specified risk
component). This relief applies to each RFR on a rate-by-rate basis.
Non-trading derivatives that do not qualify for hedge accounting
Derivative instruments that are used by ING Bank as part of its risk management strategies, but which do
not qualify for hedge accounting under ING Bank\u2019s 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.
1.7.5\u00a0 Offsetting of financial assets and financial liabilities
Financial assets and financial liabilities are offset, and the net amount is reported in the statement of
financial position when ING Bank 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 certain interest rate swaps for which the services of a central clearing house are
used.
1.7.6\u00a0 Repurchase transactions and reverse repurchase transactions
Securities sold subject to repurchase agreements (repos), securities lending and similar agreements
continue to be recognised in the Consolidated statement of financial position. The counterparty liability is
measured at FVPL (designated) and included in Other financial liabilities at FVPL if the asset is measured at
FVPL. Otherwise, the counterparty liability is included in Deposits from banks, Customer deposits, or Trading,
as appropriate.
Securities purchased under agreements to resell (reverse repos), securities borrowings and similar
agreements are not recognised in the Consolidated statement of financial position. The consideration paid
to purchase securities is recognised as Loans and advances to customers, Loans and advances to banks,
Other financial assets at FVPL or Trading assets, as appropriate. The difference between the sale and
repurchase price is treated as interest and amortised over the life of the agreement using the effective
interest method for instruments that are not measured at FVPL.
1.7.7\u00a0 Credit risk management classification and maximum credit risk exposure
Credit risk management disclosures are provided in the \u2018Credit risk\u2019 paragraph \u2018Credit risk categories\u2019 of the
\u2018Risk management\u2019 section in the Annual Report.
The maximum credit risk exposure for items in the statement of financial position is generally the carrying
value for the relevant financial assets. For the off-balance sheet items, the maximum credit exposure is the
maximum amount that could be required to be paid. Reference is made to Note 41 \u2018Contingent liabilities
and commitments\u2019 for these off-balance sheet items. Collateral received is not taken into account when
determining the maximum credit risk exposure.
Credit risk management disclosures are provided in the \u2018Credit risk\u2019 paragraph \u2018Credit risk categories\u2019 of the
\u2018Risk management\u2019 section in the Annual Report. The manner in which ING Bank manages credit risk and
determines credit risk exposures for that purpose is explained in the Credit risk paragraph \u2018Credit Risk
Appetite and Concentration Risk Framework\u2019 of the \u2018Risk management\u2019 section in the Annual Report.
1.7.8Impairment of financial assets
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 Bank calculates the expected credit losses (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. ING Bank\u2019s approach leverages the Advanced Internal Ratings Based (AIRB)
models that are used for regulatory purposes. Adjustments are applied to make these models suitable for
determining ECL. 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:
\u2022Stage 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);
\u2022Stage 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
\u2022Stage 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 Bank 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.
The main determinate of SICR is a quantitative test, whereby the lifetime Probability of Default (PD) of an
asset at each reporting date is compared against its lifetime PD determined at the date of initial recognition.
If the delta is above pre-defined absolute or relative thresholds the item is considered to have experienced a
SICR. Furthermore, any facility which shows an increase of 200% 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. Refer to \u2018Criteria for
identifying a significant increase in credit risk\u2019 in the \u2018Risk Management\u2019 section of the Annual Report for
more details on relative and absolute PD thresholds, including quantitative disclosures on those thresholds.
Consequently, if the above quantitative SICR thresholds are exceeded, the item moves from Stage 1 to Stage
2 (unless the item is credit-impaired). In these instances, items are no longer assigned a 12 month ECL and
instead are assigned a lifetime ECL. Items can return to Stage 1 if there is sufficient evidence that there is no
longer a significant increase in credit risk.
ING Bank also relies on a number of qualitative indicators to identify and assess SICR. These include:
\u2022Forbearance status;
\u2022Watch List status;
\u2022Intensive care management;
\u2022Collective SICR assessment;
\u2022Substandard Internal rating; and
\u2022Arrears status (including 30 days past due used as a backstop).
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 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 Bank 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 Bank has established a quarterly process whereby forward-looking macroeconomics scenarios and
probability weightings are developed for the purpose of ECL. ING Bank applies data predominantly from a
leading service provider (Oxford Economics (OE))\u00a0 enriched with the internal ING Bank view. A baseline, up-
scenario and a down-scenario are determined to reflect an unbiased and probability-weighted ECL amount.
As a baseline scenario, ING Bank 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.
Measurement of ECL
ING Bank 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 Bank 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 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\u2019 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 purpose of ECL, ING Bank\u2019s 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 Bank 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 Bank\u2019s 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 others, 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 is no longer recognised based on the accrual income
based on the gross carrying amount of the asset. Rather, interest income is calculated by applying the
original EIR to the AC 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 even if the lifetime ECL at the reporting date is lower than the estimated lifetime ECL at
origination.
Modifications
In certain circumstances ING Bank 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 is executed based on credit concerns it is also referred to as forbearance (refer to the \u2018Risk
Management\u2019 section of the Annual Report for more details). In such cases, the net present value of the
postponement, reduction of loan principal and/or interest payments is taken into account in the
determination of the appropriate level of ECL. If the forbearance 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. ING Bank determines whether there has been a substantial modification using both
quantitative and qualitative factors.
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:
\u2022After a restructuring has been completed and there is a high improbability of recovery of part of the
remaining loan exposure (including partial debt forgiveness);
\u2022In a bankruptcy liquidation scenario;
\u2022After divestment or sale of a credit facility at a discount;
\u2022Specific 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 \u2018Addition to loan loss provisions\u2019 in the Consolidated
statement of profit or loss..
Debt forgiveness (or debt settlement) involves write-off but additionally involves the forgiveness of a legal
obligation, in whole or in part. This means that ING Bank forfeits the legal right to recover the debt. As a
result, the financial asset needs to be derecognised. Distinction is made in situations where ING Bank ends
the relationship with the client and situations where ING Bank (partially) continues the financing of the
client.
Presentation of ECL
ECL for financial assets measured at AC are deducted from the gross carrying amount of the assets. For
debt instruments at FVOCI, the ECL is recognised in OCI, instead of deducted 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, are 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:
Considerable management judgement is exercised in determining the amount of ECL for financial assets
assessed on both a collective and an individual basis. In particular, this judgement requires ING Bank to
make various assumptions about the risk of default, the credit loss rates in case of a default and expected
future cash flows. These assumptions are based on a combination of ING Bank\u2019s past history, existing
market conditions and forward-looking estimates at the end of each reporting period. Changes in these
assumptions may lead to changes in the ECL over time. Given they are subjective and complex in nature,
and because the ECL and the underlying exposures subject to ECL are material, these assumptions are
considered critical accounting assumptions. The sensitivity of these assumptions is assessed in the credit
risk section of the \u2018Risk Management\u2019 section in the Annual Report.
\u2022The use of forward-looking macroeconomic scenarios in both collective and individual impairment
assessments
Forward-looking macroeconomic scenarios are uncertain in nature. The process ING Bank follows involves
two internal groups, the Macroeconomics Scenarios Team and the Macroeconomics Scenarios Expert
Panel. The latter team consists of senior management representatives from the Business, Risk and
Finance. These groups review inputs obtained from a third party provider and subject these to internal
expert challenge to ensure the inputs used in the models reflect ING Bank\u2019s view on the macro economy.
The use of alternate forward-looking macroeconomic scenarios can produce significantly different
estimates of ECL. This is demonstrated in the sensitivity analysis in the \u2018Risk Management\u2019 section of the
Annual Report, where the un-weighted ECL under each of the three scenarios for some significant
portfolios is disclosed.
\u2022The probability weights applied to each of the three scenarios
ING Bank uses three macroeconomic scenarios when determining IFRS 9 ECL (baseline, upside and
downside). Management judgement is applied in the design of the approach used to determine the
weights of each scenario and in selecting the parts of the distribution of forecast errors from which the
weights are derived. Reference is made to the \u2018Alternative scenarios and probability weights\u2019 and the
sensitivity analysis in the \u2018Risk Management\u2019 section of the Annual Report for further details.
\u2022The criteria for identifying a significant increase in credit risk
When determining whether the credit risk on a financial asset has increased significantly, ING Bank\u00a0
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\u2019s 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 constitute a significant judgement. Analysis
of the sensitivity associated with the assessment of significant increase in credit risk is presented in the
\u2018Risk Management\u2019 section of the Annual Report.
\u2022The definition of default
Judgement is exercised in management\u2019s evaluation of whether there is objective evidence that larger
exposures are credit-impaired. Management judgement is required in assessing evidence of credit-
impairment.
\u2022Management adjustments applied as at 31 December 2022
To reflect the risks that are not properly captured by the ECL models, a number of management
adjustments to the model-based ECL were necessary as at 31 December 2022. Reference is made to the
\u2018Management adjustments applied this year\u2019 paragraph in the \u2018Risk management\u2019 section of the Annual
Report.
1.7.9\u00a0 Accounting for Targeted Longer-Term Refinancing Operations (TLTRO)
ING Bank participates in Targeted Longer-Term Refinancing Operations (TLTRO III), reference is made to Note
12 \u2018Deposits from banks\u2019.
ING Bank considers 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 is considered to be a market conforming rate and TLTRO funding is
recognized fully as a financial liability.
ING Bank interprets 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 results in discrete rates for discrete interest
periods over the life of TLTRO. The change in the applicable rate between interest periods is seen as a
change in the floating rate and is accounted for prospectively. Similarly, if the ECB announces changes in
the rate for the amounts already drawn under the existing TLTRO, then such changes also represent a
change in a floating rate. Following this, such changes lead 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 relates to the
periods already passed, the impact for those past periods is recognised in profit or loss immediately.
Furthermore, the change in the TLTRO rate driven by changes in expectations of meeting the targets
impacts interest income. As a result, interest income which relates to the period that already passed until
the moment when the change in expectations occurs, is recognised as a catch up adjustment in
Consolidated statement of profit or loss. This change occurs only when ING Bank has a reasonable
expectation that the lending targets will be met.
ING Bank views \u2018reasonable expectation\u2019 in case of TLTRO funding as a high hurdle. This is the moment when
it becomes highly probable, i.e. the probability of meeting the lending targets is substantially greater than
the probability that it will not. As a result, if interest income is recognised during the period based on the
expectation of meeting the targets, there should only be a limited possibility that the interest may need to
be reversed in future reporting periods. Reference is made to note 12 \u2018Deposits from banks\u2019 and to note 20
\u2018Net interest income\u2019 for the presentation of ING Bank\u2019s participation in TLTRO programmes.
Significant judgements:
Significant management judgement is exercised in determining the accounting treatment of TLTRO
transactions. In particular, ING Bank\u00a0 applied judgement in:
\u2022assessing and concluding that in ING Bank'\u2019s view the rate under TLTRO is considered to be a market
conforming rate and, hence, accounting for TLTRO in accordance with IFRS 9; and
\u2022selecting accounting policies regarding the calculation of the effective interest rate under TLTRO.
Treatment of changes in expectations of meeting the lending targets was an area of significant
judgment in the comparative periods but no longer relevant in 2022.
1.8\u00a0 Consolidation
ING Bank comprises ING Bank N.V. (the Parent Company) and all other subsidiaries. Subsidiaries are entities
controlled by ING Bank N.V. Control exists if ING Bank N.V. is exposed or has rights to variable returns and
has the ability to affect those returns through the power over the subsidiary. Control is usually achieved
through situations including, but not limited to:
\u2022Ownership, directly or indirectly, of more than half of the voting power;\u00a0
\u2022Ability to appoint or remove the majority of the board of directors;\u00a0
\u2022Power to govern operating and financial policies under statute or agreement; and\u00a0
\u2022Power over more than half of the voting rights through an agreement with other investors.\u00a0
The existence and effect of potential voting rights that are currently exercisable or convertible are
considered in assessing whether ING Bank controls another entity.
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.
A list of principal subsidiaries is included in Note 44 \u2018Principal subsidiaries\u2019 and a description of ING's activities
involving structured entities is included in Note 45 '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.
The results of the operations and the net assets of subsidiaries are included in the statement of profit or loss
and the statement of financial position from the date control is obtained until the date control is lost. On
disposal, the difference between the sales proceeds, net of directly attributable transaction costs, and the
net assets is included in net result.
A subsidiary which ING Bank has agreed to sell but is still legally owned by ING Bank may still be controlled
by ING Bank at the balance sheet date and therefore, still be included in the consolidation. Such a subsidiary
may be presented as a held for sale disposal group if certain conditions are met.
All intercompany transactions, balances and unrealised surpluses and deficits on transactions between
group companies are eliminated. Where necessary, the accounting policies used by subsidiaries are
changed to ensure consistency with group policies. In general, the reporting dates of subsidiaries are the
same as the reporting date of ING Bank N.V.
ING Bank 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\u2019s 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 in respect of minimum capital requirements that are imposed by
industry regulators in the countries in which the subsidiaries operate, other limitations exist in certain
countries.
1.9\u00a0 Segment reporting
An operating segment is a distinguishable component of ING Bank, engaged in providing products or
services, whose operating results are regularly reviewed by the Management Board Banking of ING Bank
(the Chief Operating Decision Maker (CODM)) to make decisions about resources to be allocated to the
segments and assess its performance. A geographical area is a distinguishable component of ING Bank
engaged in providing products or services within a particular economic environment that is subject to risks
and returns that differ from those of segments operating in other economic environments.
The CODM examines ING Bank\u2019s performance both by line of business and geographic perspective and has
identified five reportable segments by line of business. The geographical analyses are based on the location
of the office from which the transactions are originated.
1.10\u00a0 Foreign currency translation
Functional and presentation currency
Items included in the financial statements of each of ING Bank\u2019s 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 Bank\u2019s 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 \u2018Valuation results and
net trading income\u2019. Reference is made to Note 22 \u2018Valuation results and net trading income\u2019, 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 \u2018Result on disposal of group companies\u2019. Reference is also made to Note 19 \u2018Equity\u2019, 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:
\u2022Assets and liabilities are translated at the closing rate at the date of the statement of financial position;\u00a0
\u2022Income 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 and expenses are translated at the dates of the transactions). However, under hyperinflation
accounting, income and expenses of ING Turkey are translated at the closing rate; and\u00a0
\u2022All resulting exchange rate differences are recognised in a separate component of equity.\u00a0
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\u2019 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 liabilities of the foreign operation and translated at the exchange rate prevailing at the balance sheet
date.
1.11\u00a0 Investments in associates and joint ventures
Associates are all entities over which ING Bank 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:
\u2022Representation on the board of directors;\u00a0
\u2022Participation in the policymaking process; and\u00a0
\u2022Interchange of managerial personnel.\u00a0
Joint ventures are entities over which ING Bank has joint control. Joint control is the contractually agreed
sharing of control over an arrangement or entity, which exists only when decisions about the relevant
activities require the unanimous consent of the parties sharing control. Joint control means that no party to
the agreement is able to act unilaterally to control the activity of the entity. The parties to the agreement
must act together to control the entity and therefore exercise the joint control.
Investments in associates and joint ventures are initially recognised at cost and subsequently accounted for
using the equity method of accounting.
ING Bank\u2019s investment in associates and joint ventures (net of any accumulated impairment loss) includes
goodwill identified on acquisition. ING Bank\u2019s 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 Bank\u2019s 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 Bank
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 Bank and its associates and joint ventures are eliminated to
the extent of ING Bank\u2019s 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 Bank.
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. 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. 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.
Significant judgements and critical accounting estimates and assumptions:
The most significant estimates and assumptions relate to the assessment of (reversal of) impairment of
the investment in TMBThanachart Bank Public Company Limited (hereafter: TTB) which involves estimation
of value in use.
Management's best estimate of the expected future earnings of TTB is based on forecasts derived from
broker consensus over the short to medium term and reasonable and supportable assumptions capturing
a combination of TTB specific and market data points for longer term and steady state expectations into
perpetuity. A capital maintenance charge is applied, which is management\u2019s forecast of the earnings that
need to be withheld in order for TTB to meet target regulatory requirements over the forecast period. Both
of these factors are subject to a high degree of uncertainty.
Key assumptions used in estimating TTB\u2019s value in use and the sensitivity of the value in use calculations
to different assumptions are described in note 8 \u2018Investments in associates and joint ventures\u2019.
1.12\u00a0 Property and equipment
Property in own use
Land and buildings held for own use are stated at fair value at the balance sheet date. Increases in the
carrying amount arising on revaluation of land and buildings held for own use are credited to the
revaluation reserve in shareholders\u2019 equity. Decreases in the carrying amount that offset previous increases
of the same asset are charged against the revaluation reserve directly in equity; all other decreases are
charged to the statement of profit or loss. Increases that reverse a revaluation decrease on the same asset
previously recognised in net result are recognised in the statement of profit or loss. Depreciation is
recognised based on the fair value and the estimated useful life (in general 20\u201350 years). Depreciation is
calculated on a straight-line basis. On disposal, the related revaluation reserve is transferred to retained
earnings.
In principle, the fair values of land and buildings are appraised annually by independent qualified valuers.
Subsequent expenditure is included in the asset\u2019s carrying amount when it is probable that future economic
benefits associated with the item will flow to ING Bank and the cost of the item can be measured reliably.
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:
for data processing equipment two to five years, and four to ten years for fixtures and fittings. Expenditure
incurred on maintenance and repairs is recognised in the statement of profit or loss as incurred. Expenditure
incurred on major improvements is capitalised and depreciated.
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 Bank 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 Bank. 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\u2019s 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:
\u2022Fixed payments (including in-substance fixed payments), less any lease incentives receivable;
\u2022Variable lease payments that are based on an index or a rate;
\u2022Amounts expected to be payable by the lessee under residual value guarantees;
\u2022The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and
\u2022Payments 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\u2019s 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. This rate is approximated by using the risk free rate applicable to the
lease term, the currency of the lease payment and jurisdiction, with the Fund Transfer Pricing (FTP) rate as
an add-on. The FTP rate is used to transfer interest rate risk and funding and liquidity risk positions between
the ING Bank business and treasury departments. It is determined by either ING Bank or Local Asset and
Liability Committee (ALCO). Reference is made to the \u2018Risk management\u2019 section of the Annual Report.
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.
Payments associated with short-term leases and leases of low-value assets are recognised on a straight-
line basis as an expense in profit or loss. Short-term leases are leases with a lease term of 12 months or less.
Low-value assets comprise mainly IT-equipment (for example mobile phones or laptops) and small items of
office furniture.
The right-of-use asset is included in the statement of financial position line-item \u2018Property and equipment\u2019,
the lease liability is included in the statement of financial position line-item \u2018Other liabilities\u2019. Refer to note 9
\u2018Property and equipment\u2019 and to note 16 \u2018Other liabilities\u2019.
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
decrease 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.
1.13\u00a0 ING Bank as lessor
When ING Bank acts as a lessor, a distinction should be made between finance leases and operating leases.
For ING Bank 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.
1.14\u00a0 Acquisitions, goodwill and other intangible assets
Goodwill resulting from a business combination
ING Bank\u2019s business combinations are accounted for using the acquisition method of accounting. The
consideration for each business combination is measured at the aggregate of the fair values (at the date of
exchange) of assets given, liabilities incurred or assumed, and equity instruments issued in exchange for
control of the acquiree. Goodwill, being the difference between the cost of the acquisition (including
assumed debt) and the Group\u2019s interest in the fair value of the investee's identifiable assets, liabilities and
contingent liabilities as at the date of acquisition, is capitalised as an intangible asset. Goodwill is only
recognised separately on acquisitions. The results of the operations of the acquired companies are included
in the statement of profit or loss from the date control is obtained.
Where applicable, the consideration for the business combination includes any asset or liability resulting
from a contingent consideration arrangement, the contingent consideration is measured at its acquisition-
date fair value. Contingent consideration arrangements classified as an asset or a liability, are subsequently
measured at fair value and the changes in fair value are recognised in the statement of profit or loss.
Changes in the fair value of the contingent consideration classified as equity, are not recognised.
Where a business combination is achieved in stages, ING Bank\u2019s previously held interests in the assets and
liabilities of the acquired entity are remeasured to fair value at the acquisition date (i.e. the date ING Bank
obtains control) and the resulting gain or loss, if any, is recognised in the statement of profit or loss.
Amounts arising from interests in the acquiree prior to the acquisition date that have previously been
recognised in other comprehensive income are reclassified to the statement of profit or loss, where such
treatment would be appropriate if that interest were disposed of. Acquisition related costs are recognised in
the statement of profit or loss as incurred and presented in the statement of profit or loss as Other
operating expenses.
The initial accounting for the fair value of the net assets of the companies acquired during the year may be
determined only provisionally as the determination of the fair value can be complex and the time between
the acquisition and the preparation of the Financial statements can be limited. The initial accounting shall
be completed within a year after acquisition. Adjustments to the fair value as at the date of acquisition of
acquired assets and liabilities, that are identified within one year after acquisition are recognised as an
adjustment to goodwill; any subsequent adjustment is recognised as income or expense. On disposal of
group companies where control is lost, the difference between the sale proceeds and carrying value
(including goodwill) and the unrealised results (including the currency translation reserve in equity) is
included in the statement of profit or loss.
Impairment of goodwill and other non-financial assets
ING Bank 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. The carrying value is
determined on a basis that is consistent with the way in which the recoverable amount of the CGU is
determined. The recoverable amount is estimated as the higher of fair value less costs of disposal and value
in use. 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. This period will generally not exceed five years. Amortisation is included in Other operating expenses.
Other intangible assets
Other intangible assets are capitalised and amortised over their expected economic life, which is generally
between three and ten years.
1.15\u00a0 Taxation
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.
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 Bank 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 equity and is subsequently recognised in the statement of profit or loss together with the
deferred gain or loss.
Uncertain tax positions are assessed continually by ING Bank and in case it is probable that there will be a
cash outflow, a current tax liability is recognised.
1.16\u00a0 Other assets
Investment property
Investment properties are recognised at fair value at the balance sheet date. The fair values of investment
properties are appraised annually by independent qualified valuers. Changes in the carrying amount
resulting from revaluations are recognised in the statement of profit or loss. On disposal, the difference
between the sale proceeds and carrying value is recognised in the statement of profit or loss.
Property obtained from foreclosures
Property obtained from foreclosures is stated at the lower of cost and net realisable value. Net realisable
value is the estimated selling price, less applicable variable selling expenses. Property obtained from
foreclosures is included in Other assets - Property development and obtained from foreclosures.
Property development
Property developed and under development is included in Other assets \u2013 Property development and
obtained from foreclosures. Depending on the intention of ING Bank after completion of the development,
the property is measured as follows:
\u2022Intention to sell: at the lower of cost and net realisable value;
\u2022Intention to use as a real estate investment: at fair value.
1.17\u00a0 Disposal groups held for sale and discontinued operations
Disposal groups (and non-current assets) are classified as held for sale if their carrying amount will be
recovered principally through a sale transaction rather than through continuing use. This is only the case
when the sale is highly probable and the disposal group (or non-current assets) is available for immediate
sale in its present condition; including management must be committed to the sale, which is expected to
occur within one year from the date of classification as held for sale.
Upon classification as held for sale, the disposal group is measured at the lower of its carrying amount and
fair value less costs to sell, except where specifically exempt from IFRS 5 \u2018Non-current Assets Held for Sale
and Discontinued Operations. An impairment loss is recognised for any initial or subsequent write-down of
the disposal group to fair value less costs to sell. A gain is recognised for any subsequent increases in fair
value less costs to sell of the disposal group, but not in excess of any cumulative impairment loss previously
recognised. A gain or loss not previously recognised by the date of the sale of the disposal group is
recognised at the date of derecognition. Assets within the disposal group are not depreciated or amortised
while they are classified as held for sale. Interest and other net income/expenses attributable to the
liabilities of a disposal group classified as held for sale continue to be recognised. The assets of the disposal
group classified as held for sale are presented separately from the other assets in the balance sheet. The
liabilities of a disposal group classified as held for sale are presented separately from other liabilities in the
balance sheet.
When a group of assets that is classified as held for sale represents a major line of business or geographical
area the disposal group is classified as discontinued operations. Upon classification of a business as held for
sale and discontinued operations the individual income and expenses are presented within the Total net
result from discontinued operations instead of being presented in the usual line items in the Consolidated
statement of profit or loss. All comparative years in the Consolidated statement of profit or loss are restated
and presented as discontinued operations for all periods presented. Furthermore, the individual assets and
liabilities are presented in the Consolidated statement of financial position as Assets and liabilities held for
sale and are no longer included in the usual line items in the Consolidated statement of financial position.
Changes in assets and liabilities as a result of classification as held for sale are included in the notes in the
line \u2018Changes in composition of the group and other changes\u2019.
1.18\u00a0 Provisions, contingent liabilities and contingent assets
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 Bank 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 Bank; 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 Bank. 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.
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 Bank\u00a0 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 Bank
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 Bank consults with internal and external legal experts. Even taking into
consideration legal experts\u2019 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'.
1.19\u00a0 Other liabilities
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.
Plan assets are measured at fair value at the balance sheet date. For determining the pension expense, the
return on plan assets is determined using a high quality corporate bond rate identical to the discount rate
used in determining the defined benefit obligation.
Changes in plan assets that effect Shareholders\u2019 equity and/or Net result, include mainly:
\u2022Return on plan assets using a high quality corporate bond rate at the start of the reporting period which
are recognised as staff costs in the statement of profit or loss; and\u00a0
\u2022Remeasurements which are recognised in Other comprehensive income.\u00a0
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. The actuarial assumptions may differ
significantly from the 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 the defined
benefit plan obligation and future pension costs.
Changes in the defined benefit obligation that effect Shareholders\u2019 equity and/or Net result, include mainly:
\u2022Service cost which is recognised as staff costs in the statement of profit or loss;\u00a0
\u2022Interest expenses using a high quality corporate bond rate at the start of the period which are
recognised as staff costs in the Statement of profit or loss; and\u00a0
\u2022Remeasurements which are recognised in Other comprehensive income (equity).\u00a0
Remeasurements recognised in other comprehensive income are not recycled to 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. 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.
Defined contribution plans
For defined contribution plans, ING Bank pays contributions to publicly or privately administered pension
insurance plans on a mandatory, contractual or voluntary basis. ING Bank 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 accounting methodology similar to that for defined benefit pension plans.
1.20\u00a0 Income recognition
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 Bank
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 is presented in \u2018Interest income (expense) using effective interest rate
method\u2019. 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 \u2018Other interest income
(expense)\u2019. Interest result on all other financial assets and liabilities at FVTPL is recognised in \u2018Valuation
results and net trading income\u2019.
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 Bank 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 \u2013 such as the arrangement of the acquisition of shares or other securities or the
purchase or sale of businesses \u2013 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 Bank is the
lessor are divided into an interest component (recognised as interest income) and a repayment component
based on a pattern reflecting a constant periodic rate of return on the lessor\u2019s net investment in the lease.
1.21\u00a0 Expense recognition
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 are generally a result from a contract with ING service
providers in order to perform the service for ING Bank\u2019s customers. Costs are generally presented as
\u2018Commission expenses\u2019 if they are specific, incremental, directly attributable and identifiable to generate
commission income.\u00a0
Share-based payments
ING Bank 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 of service.
1.22\u00a0 Statement of cash flows
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 comprise balances with less
than three months\u2019 maturity from the date of acquisition, including cash and balances with central banks,
treasury bills and other eligible bills, amounts due from other banks, and deposits from banks. 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.
1.23\u00a0 Parent company accounts
The parent company accounts of ING Bank N.V. are prepared in accordance with the financial reporting
requirements included in Part 9 of Book 2 of the Dutch Civil Code. In accordance with subsection 8 of section
362, Book 2 of the Dutch Civil Code, the recognition and measurement principles applied in the Parent
company accounts are the same as those applied in the Consolidated financial statements.
", "dimensions": { "concept": "ifrs-full:DisclosureOfSummaryOfSignificantAccountingPoliciesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfODI0NjMzNzQ3MTk4MQ_21ada7b4-94c8-431c-b7ae-834cd0158e0f": { "value": "
1.1\u00a0 Reporting entity and authorisation of the Consolidated financial statements
ING Bank N.V. (Naamloze vennootschap) is a company domiciled in Amsterdam, the Netherlands.
Commercial Register of Amsterdam, number 33031431. ING Bank N.V. is a wholly-owned subsidiary of ING
Groep N.V. domiciled in Amsterdam, the Netherlands. These Consolidated financial statements, as at and for
the year ended 31 December 2022, comprise ING Bank N.V. (the Parent company) and its subsidiaries,
together referred to as ING Bank. ING Bank is a global financial institution with a strong European base,
offering a wide range of retail and wholesale banking services to customers in over 40 countries.\u00a0 \u00a0\u00a0
The ING Bank Consolidated financial statements, as at and for the year ended 31 December 2022, were
authorised for issue in accordance with a resolution of the Management Board Banking on 6 March 2023.
The General Meeting of the Shareholder may decide not to adopt the financial statements, but may not
amend these.
", "dimensions": { "concept": "ifrs-full:DisclosureOfGeneralInformationAboutFinancialStatementsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzU5_1ecfb2a5-2d01-4e92-bca1-f12949aec0e2": { "value": "ING Bank N.V.", "dimensions": { "concept": "ifrs-full:NameOfReportingEntityOrOtherMeansOfIdentification", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2Nzc1NjU1MA_b97c7ce9-4c3e-417a-a9ca-136f9712a3ab": { "value": "Naamloze vennootschap", "dimensions": { "concept": "ifrs-full:LegalFormOfEntity", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2Nzc1NjU1MQ_a2a8eb18-d235-4792-bc68-98fb7c9c23fc": { "value": "Amsterdam, the Netherlands", "dimensions": { "concept": "ifrs-full:DomicileOfEntity", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfODI0NjMzNzUyNjE5Mg_bb63bf77-b559-44e2-bdb0-cd46978009e7": { "value": "the Netherlands", "dimensions": { "concept": "ifrs-full:CountryOfIncorporation", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2Nzc1NjU0OQ_33fcee43-655f-4bb7-ac3e-8917b120536e": { "value": "ING Groep N.V.", "dimensions": { "concept": "ifrs-full:NameOfUltimateParentOfGroup", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2Nzc1NjU0OQ_bef32dc3-c8ab-4128-a233-05fdeecf8494": { "value": "ING Groep N.V.", "dimensions": { "concept": "ifrs-full:NameOfParentEntity", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2Nzc0NjU2OA_2a2db318-7b05-48a3-a34f-31758b30ad8d": { "value": "ING Bank is a global financial institution with a strong European base, offering a wide range of retail and wholesale banking services to customers in over 40 countries.", "dimensions": { "concept": "ifrs-full:DescriptionOfNatureOfEntitysOperationsAndPrincipalActivities", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTA5OTUxMTY1ODI2NDY_44d13e1a-d639-4a1d-bb83-13cefe1a438f": { "value": "
The ING Bank Consolidated financial statements, as at and for the year ended 31 December 2022, were
authorised for issue in accordance with a resolution of the Management Board Banking on 6 March 2023.
The General Meeting of the Shareholder may decide not to adopt the financial statements, but may not
amend these.
", "dimensions": { "concept": "ifrs-full:DisclosureOfAuthorisationOfFinancialStatementsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMjE5OTAyMzI3NzAzMDY_b275adbb-42a1-4a6f-94fd-ee55883623cc": { "value": "
The ING Bank Consolidated financial statements have been prepared in accordance with International
Financial Reporting Standards (IFRS) as adopted by the European Union (EU) and the relevant articles of Part
9 of Book 2 of the Dutch Civil Code.
IFRS as adopted by the EU are IFRS Standards and IFRS Interpretations as issued by the International
Accounting Standards Board (IASB) and the IFRS Interpretations Committee (IFRIC) with some limited
modifications such as the temporary \u2018carve-out\u2019 from IAS 39 \u2018Financial Instruments: Recognition and
Measurement\u2019 (herein, referred to as IFRS).
", "dimensions": { "concept": "ifrs-full:StatementOfIFRSCompliance", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzc4_bd7d5751-79fa-474f-a78c-0c4512185ccc": { "value": "
1.4\u00a0 Changes to accounting policies and presentation
ING Bank has consistently applied its accounting policies to all periods presented in these Consolidated
financial statements.
In 2022, ING Bank updated the presentation in note 7 \u2018Loans and advances to customers\u2019 to improve
consistency and comparability. Comparative figures for 2021 have been updated accordingly.
1.4.1\u00a0 Changes in IFRS effective in 2022
The following amended standards became effective in 2022:
\u2022Amendments to IFRS 3 \u2018Business Combinations\u2019: Reference to the Conceptual Framework (issued in May
2020).
\u2022Amendments to IAS 16 \u2018Property, Plant and Equipment\u2019: Proceeds before Intended Use (issued in May
2020).
\u2022Amendments to IAS 37 \u2018Provisions, Contingent Liabilities and Contingent Assets\u2019:\u00a0 Onerous Contracts \u2014
Cost of Fulfilling a Contract (issued in May 2020).
\u2022Annual improvements to IFRS Standards 2018-2020 Cycle: Amendments to IFRS 1 \u2018First-time Adoption of
International Financial Reporting Standards\u2019, amendments to IFRS 9 \u2018Financial Instruments\u2019 and
amendments to IFRS 16 \u2018Leases\u2019 (issued in May 2020).
The above changes did not have significant impact on ING Bank\u2019s Consolidated financial statements. ING
Bank has not early adopted any standard, interpretation or amendment in 2022 which has been issued, but
is not yet effective.
1.4.2\u00a0 Upcoming changes in IFRS after 2022
The following published amendments are not mandatory for 2022 and have not been early adopted by ING
Bank
Effective in 2023 (endorsed by the EU):
\u2022IFRS 17 'Insurance Contracts' (issued in May 2017), including amendments to IFRS 17 (issued in June
2020).
IFRS 17 \u2018Insurance Contracts\u2019 is a new accounting standard for insurance contracts covering recognition and
measurement, presentation and disclosure. Once effective, IFRS 17 will replace IFRS 4 \u2018Insurance Contracts\u2019,
which allowed diversity in accounting practices for insurance contracts. In June 2020, the IASB published
amendments to IFRS 17 including a scope exclusion for credit card contracts and similar contracts that
provide insurance coverage, and an optional scope exclusion for loans with death waivers. ING does not
have an insurance business, but on a limited basis sells insurance products as a broker where it does not run
the insurance risk. ING Bank performed an impact assessment which revealed that a portfolio of loans with
death waivers in the Netherlands with a net carrying amount of approximately of EUR 750 million might be
in scope of IFRS 17. Following the above mentioned amendments to IFRS 17 in 2020 which allow an
accounting policy choice, ING Bank intends to account for assets in this portfolio in their entirety, including
death waiver features, using IFRS 9 \u2019Financial Instruments\u2019 and not IFRS 17. As a result, this portfolio will no
longer meet the \u2018solely payments of principal and interest\u2019 (SPPI) criterion, causing the portfolio to no longer
be recognised at amortised cost but rather at fair value through profit or loss. This reclassification is not
expected to have a material impact on equity or result of ING Bank, as the fair value is expected not to differ
materially from the current book value. Hence, the financial impact of IFRS 17 on ING Bank is expected to be
limited.
The following amendments will also be effective in 2023. However, the implementation of these
amendments is expected to have no significant impact on NG Bank's Consolidated financial statements.
\u2022Amendments to IAS 1 \u2018Presentation of Financial Statements\u2019: Disclosure of Accounting Policies (issued in
February 2021).
\u2022Amendments to IAS 8 \u2018Accounting Policies, Changes in Accounting Estimates and Errors\u2019: Definition of
Accounting Estimates (issued in February 2021).
\u2022Amendments to IAS 12 \u2018Income Taxes\u2019: Deferred Tax Related to Assets and Liabilities Arising From a
Single Transaction (issued in May 2021).
Effective in 2024 (not yet endorsed by the EU):
\u2022Amendments to IFRS 16 'Leases': Lease Liability in a Sale and Leaseback (issued in September 2022).
\u2022Amendments to IAS 1 \u2018Presentation of Financial Statements\u2019: Classification of Liabilities as Current or
Non-current (issued in January 2020).", "dimensions": { "concept": "ifrs-full:DisclosureOfChangesInAccountingPoliciesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfODI0NjMzNzUyNjE5OA_cbad357d-373e-4959-8c27-b7dc2010a792": { "value": "
1.4\u00a0 Changes to accounting policies and presentation
ING Bank has consistently applied its accounting policies to all periods presented in these Consolidated
financial statements.
In 2022, ING Bank updated the presentation in note 7 \u2018Loans and advances to customers\u2019 to improve
consistency and comparability. Comparative figures for 2021 have been updated accordingly.
", "dimensions": { "concept": "ifrs-full:DisclosureOfReclassificationsOrChangesInPresentationExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzgz_919ed70e-a13e-465a-8041-adeba57f7d61": { "value": "
1.5\u00a0 Significant judgements and critical accounting estimates and assumptions
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 Bank 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:
\u2022Loan loss provisions (financial assets);
\u2022The determination of the fair values of financial assets and liabilities;\u00a0
\u2022Impairment assessment of an investment in associate;
\u2022Provisions; and
\u2022Accounting for Targeted Longer-Term Refinancing Operations (TLTRO).
For further discussion of the significant judgements and critical accounting estimates and assumptions in
these areas, reference is made to the relevant parts in paragraph 1.7 \u2018Financial instruments\u2019 (specifically
1.7.8 \u2018Impairment of financial assets\u2019, 1.7.3 for \u2018Fair values of financial assets and liabilities\u2019, 1.11
\u2018Investments in associates and joint ventures\u2019, 1.18 \u2018Provisions, contingent liabilities and contingent assets\u2019
and 1.7.9 \u2018Accounting for Targeted Longer-Term Refinancing Operations (TLTRO)\u2019) of this note and the
applicable notes to the Consolidated financial statements.
", "dimensions": { "concept": "ifrs-full:DisclosureOfAccountingJudgementsAndEstimatesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMjE5OTAyMzI3NzAyODE_599a01fa-b825-4643-a28a-7f5842b6457e": { "value": "
1.6\u00a0 Other developments
Application of IAS 29 \u2018Financial Reporting in Hyperinflationary Economies\u2019
During the second quarter of 2022 Turkey became a hyperinflationary economy for accounting purposes.
As ING Bank has a subsidiary in Turkey, ING Bank applied IAS 29 \u2018Financial Reporting in Hyperinflationary
Economies\u2019 to its operations as if the economy in Turkey had always been hyperinflationary. Given that ING
Bank presents its results in EUR, comparatives were not restated and IAS 29 was applied from 1 January
2022 with the impact of the first-time application and the effect for the period both shown in these
Consolidated financial statements for the year ended 31 December 2022.
Under IAS 29, the results of the operations in Turkey 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 development of the CPI during the year ended 31 December 2022 was as follows (2003=100):
1 January 2022\u00a0 686.95
31 December 2022 1,128.45
Change for the period\u00a0 64.27%
To state all the items in the financial statements in terms of their current purchasing power at the reporting
date, ING Bank restated the non-monetary items of ING Turkey (such as properties and equipment,
intangibles, right-of use assets and shareholder\u2019s equity) for the changes in CPI up to the reporting date.
Monetary items (such as cash and balances with banks, loans and advances and deposits) are not restated
as they are already expressed in the current purchasing power. Furthermore, all items in the statement of
comprehensive income were also restated for the effects of inflation based on the developments in CPI
during the 12 month period to reflect the purchasing power as at 31 December 2022.
The effect of such restatement of the statement of comprehensive income and the balance sheet for
inflation in the current period has been recognised in the statement of profit or loss within \u2018Other net
income\u2019 as a \u2018Net monetary gain or loss\u2019. 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
Turkey.
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 Turkey are translated and presented in EUR at the exchange rate on 31
December 2022. 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 Bank selected to present both the restatement effect resulting from restating
ING Bank\u2019s interest in the equity of ING Turkey as required by IAS 29; and the translation effect from
translating at a closing rate that differs from the previous closing rate, in the Currency translation reserve.
Refer to Note 19 \u2018Equity\u2019 for the impact of applying IAS 29 during the year ended 31 December 2022.
", "dimensions": { "concept": "ifrs-full:DisclosureOfHyperinflationaryReportingExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMjE5OTAyMzI3NzAzMDQ_1380c740-f1e2-418e-b33b-05d5a5d13a5e": { "value": "
1.6\u00a0 Other developments
Application of IAS 29 \u2018Financial Reporting in Hyperinflationary Economies\u2019
During the second quarter of 2022 Turkey became a hyperinflationary economy for accounting purposes.
As ING Bank has a subsidiary in Turkey, ING Bank applied IAS 29 \u2018Financial Reporting in Hyperinflationary
Economies\u2019 to its operations as if the economy in Turkey had always been hyperinflationary. Given that ING
Bank presents its results in EUR, comparatives were not restated and IAS 29 was applied from 1 January
2022 with the impact of the first-time application and the effect for the period both shown in these
Consolidated financial statements for the year ended 31 December 2022.
Under IAS 29, the results of the operations in Turkey 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 development of the CPI during the year ended 31 December 2022 was as follows (2003=100):
1 January 2022\u00a0 686.95
31 December 2022 1,128.45
Change for the period\u00a0 64.27%
To state all the items in the financial statements in terms of their current purchasing power at the reporting
date, ING Bank restated the non-monetary items of ING Turkey (such as properties and equipment,
intangibles, right-of use assets and shareholder\u2019s equity) for the changes in CPI up to the reporting date.
Monetary items (such as cash and balances with banks, loans and advances and deposits) are not restated
as they are already expressed in the current purchasing power. Furthermore, all items in the statement of
comprehensive income were also restated for the effects of inflation based on the developments in CPI
during the 12 month period to reflect the purchasing power as at 31 December 2022.
The effect of such restatement of the statement of comprehensive income and the balance sheet for
inflation in the current period has been recognised in the statement of profit or loss within \u2018Other net
income\u2019 as a \u2018Net monetary gain or loss\u2019. 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
Turkey.
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 Turkey are translated and presented in EUR at the exchange rate on 31
December 2022. 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 Bank selected to present both the restatement effect resulting from restating
ING Bank\u2019s interest in the equity of ING Turkey as required by IAS 29; and the translation effect from
translating at a closing rate that differs from the previous closing rate, in the Currency translation reserve.
Refer to Note 19 \u2018Equity\u2019 for the impact of applying IAS 29 during the year ended 31 December 2022.
", "dimensions": { "concept": "ifrs-full:DescriptionOfOtherAccountingPoliciesRelevantToUnderstandingOfFinancialStatements", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzY3_3435a4db-4320-4417-93c7-72b79a5f76cd": { "value": "
1.7\u00a0 Financial instruments
ING Bank applies IFRS 9 \u2018Financial Instruments\u2019 to the recognition, classification and measurement, and
derecognition of financial assets and financial liabilities and the impairment of financial assets. The Group
applies the requirements of IAS 39 \u2018Financial Instruments: Recognition and Measurement\u2019 for hedge
accounting purposes.
1.7.1\u00a0 Recognition and derecognition of financial instruments
Recognition of financial assets
Financial assets are recognised in the balance sheet when ING Bank 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 Bank 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 Bank 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.
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.
1.7.2\u00a0 Classification and measurement of financial instruments
Financial assets
ING Bank classifies its financial assets in the following measurement categories:
\u2022those to be measured subsequently at fair value (either through OCI, or through profit or loss); and
\u2022those to be measured at amortised cost (AC).
At initial recognition, ING Bank 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\u2019s 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 Bank\u2019s 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 Bank 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\u2019s business model for managing the financial assets and the contractual terms of the
cash flows, there are three measurement categories into which ING Bank classifies its debt instruments:
\u2022Amortised 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.
\u2022FVOCI:
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\u2019 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.
\u2022FVPL:
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 Bank 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 repo\u2019s) 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 Interest income or 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
Interest income or Interest expense in the period in which it arises.
ING Bank 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 Bank applies the fair value through OCI option to
investments which are considered strategic, consisting of investments that add value to ING Bank\u2019s 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\u2019s 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:
\u2022the 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
\u2022the remaining amount of change in the fair value is presented in profit or loss in \u2018Valuation results and
net trading income\u2019. 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 \u2018Interest income
(expense).
A financial guarantee contract is a contract that requires ING Bank 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 \u2018Financial instruments\u2019 (see section \u201cImpairment of financial assets\u201d) and (b)
the amount initially recognised less, when appropriate, cumulative amortisation recognised in accordance
with the revenue recognition principle of IFRS 15 \u2018Revenue from contracts with customers\u2019.
1.7.3\u00a0 Fair values of financial assets and liabilities
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 \u2018Day One Profit or Loss\u2019) is deferred. ING Bank 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 Bank 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.
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 Bank 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 Bank 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 Bank\u2019s own credit risk by means of a DVA. Additionally, derivatives
valued at fair value are adjusted for credit risk by a BVA. The BVA is of a bilateral nature as both the credit
risk on the counterparty (CVA) as well as the credit risk on ING Bank (DVA) are included in the adjustment. All
input data that is used in the determination of the BVA is based on market implied data. Additionally,
wrong-way risk (when exposure to a counterparty is increasing and the credit quality of that counterparty
deteriorates) and right-way risk (when exposure to a counterparty is increasing and the credit quality of
that counterparty improves) are taken into account in the measurement of the valuation adjustment.
To include the funding risk, ING Bank applies an additional \u2018Funding Valuation Adjustment\u2019 (FVA) to the
uncollateralised derivatives based on the market price of funding liquidity. ING Bank also applies to certain
positions other valuation adjustments to arrive at the fair value: Bid-Offer adjustments, Model Risk
Adjustments and Collateral Valuation Adjustments (CollVA).
Significant judgements and critical accounting estimates and assumptions:
\u2022Even 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.\u00a0
\u2022Valuation 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.\u00a0
\u2022Price 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.
\u2022Assessing whether a market is active, and whether an input is observable and significant, requires
judgement. ING Bank 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.
\u2022Reference is made to Note 35 'Fair value of assets and liabilities ' and to the \u2018Market risk\u2019 paragraph in
the \u2018Risk management\u2019 section of the Annual Report for the basis of the determination of the fair value
of financial instruments and related sensitivities.
1.7.4\u00a0 Derivatives and hedge accounting
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 Bank decided to exercise this accounting policy choice
and did not adopt IFRS 9 hedge accounting as of 1 January 2018. Furthermore, ING Bank applies fair value
hedge accounting for portfolio hedges of interest rate risk (macro fair value hedges) in accordance with the
EU carve-out version of IAS 39.
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 and 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 Bank\u2019s risk management strategy.
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 Bank 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 Bank documents the relationship between hedging instruments and
hedged items, its risk management objective, together with the methods selected to assess hedge
effectiveness. ING Bank 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.
IBOR Transition - specific policies applicable from 1 January 2019 for hedges directly
affected by IBOR reform
As further explained in the \u2018IBOR Transition\u2019 paragraph of the \u2018Risk management\u2019 section, the financial
markets are going through a significant reform of interbank offered rates (IBOR) and financial institutions
are obligated to implement a replacement of major interest rate reference rates.
Given that IBOR reform may have various accounting implications, the International Accounting Standards
Board (IASB) has undertaken a two phase project. Phase 1 addresses those issues that affect financial
reporting before the replacement of an existing benchmark. Phase 1 amendments to IFRS were issued by
the IASB in 2019. Phase 2 focuses on issues that may affect financial reporting when the existing benchmark
rate is reformed or replaced. Phase 2 amendments to IFRS were issued by the IASB in 2020.
Phase 1 amendments to IFRS allow ING Bank to apply a set of temporary exceptions to continue hedge
accounting even when there is uncertainty about contractual cash flows arising from the reform. Under
these temporary exceptions, interbank offered rates are assumed to continue unaltered for the purposes of
hedge accounting until such time as the uncertainty is resolved.
More specifically, the following temporary reliefs are part of the Phase 1 amendments:
\u2022Highly probable requirement for cash flow hedges
When determining whether a forecast transaction is highly probable, it is assumed that the interest rate
benchmark on which the hedged cash flows are based is not altered as a result of the reform.
\u2022Prospective assessment of hedge effectiveness
When performing the prospective assessment it is assumed that the interest rate benchmark on which
the hedged cash flows are based is not altered as a result of the reform.
\u2022Retrospective assessment of hedge effectiveness
When performing the retrospective assessment hedges are allowed to pass the assessment even if
actual results are outside the 80-125% range, during the period of uncertainty arising from the IBOR
reform.
\u2022Designation of a component of an item as a hedged item
For hedges of the benchmark component of interest rate risk affected by the reform, the separately
identifiable requirement only needs to be demonstrated at the inception of such hedging relationships
(including macro hedges).
The amendments are relevant given that ING Bank hedges and applies hedge accounting to benchmark
interest rate exposure part of IBOR reform. ING Bank hedges are being progressively amended, where
necessary, to incorporate the new benchmark rates. Temporary exceptions under Phase 1 continued to be
relevant for ING Bank as at 31 December 2022 (for USD and WIBOR).
ING Bank will completely cease to apply the amendments when this uncertainty is no longer present or
when the hedging relationship is discontinued. Refer to Note 36 'Derivatives and hedge accounting' for the
disclosures relating to the application of the amendments as part of Phase 1. Refer to note \u2018Risk
management/ IBOR Transition\u2019 for more information regarding the end of Phase 1 reliefs for ING Bank\u2019s
hedging relationships.
Phase 2 amendments require that hedge accounting continues on transition to risk free rates provided that
the modifications made to financial instruments are those necessary to implement the IBOR Reform and
that the new basis for calculating cash flows is \u2018economically equivalent\u2019 to the previous basis. Particularly,\u00a0
Phase 2 amendments allow the continuation of hedging relationships, subject to amending their
documentation to reflect changes in hedged instruments, hedging instruments, hedged risk, and/or the
method for measuring effectiveness during the transition to the new benchmark rates. During 2022, Phase 2
continued to be relevant for ING Bank when ING actually transitioned its financial instruments (designated in
hedge accounting relationships) to the new benchmark rates (mainly, USD LIBOR).
More specifically, the following temporary reliefs are part of the Phase 2 amendments:
Relief from discontinuing hedging relationships
\u2022Amendments in the hedge documentation as a consequence of changes required by the IBOR reform do
not result in the discontinuation of the hedge relationship nor the designation of a new hedge
relationship. The changes can be in form of designating an alternative benchmark rate as a hedged risk,
the description of the hedging instrument, the description of the hedged item, or the method to measure
the effectiveness.
\u2022When the hedged item is amended as a consequence of the IBOR reform (or if the hedge has previously
been discontinued), amounts accumulated in the cash flow hedge reserve are deemed to be based on
the Risk-Free Rate (RFR). This results in the release of the cash flow hedge reserve to profit or loss in the
same period or periods in which the hedged cash flows that are now based on the RFR affect profit or
loss.
\u2022When the items within a designated group of hedged items are amended as a consequence of the IBOR
reform, the hedging strategy remains and is not discontinued. As items within the hedged group
transition at different times from IBORs to RFRs, they are transferred to sub-groups of instruments that
reference RFRs as the hedged risk. The existing IBORs remain designated as the hedged risk for the other
sub-group of hedged items, until they are also updated to reference the new RFR. The usual hedge
accounting requirements are applied to the hedge relationship in its entirety.
\u2022For the assessment of retrospective hedge effectiveness, the cumulative fair value changes may be reset
to zero when the exception to the retrospective assessment of the Phase 1 reliefs ends. This election is
made separately for each hedging relationship (i.e., on a hedge-by-hedge basis).
\u2022Temporary relief from having to meet the separately identifiable requirement: a RFR is considered a
separately identifiable risk component if it is reasonably expected to meet the separately identifiable
requirement within 24 months from the date it is first designated as a non-contractually specified risk
component (i.e. when the entity first designates the RFR as a non-contractually specified risk
component). This relief applies to each RFR on a rate-by-rate basis.
Non-trading derivatives that do not qualify for hedge accounting
Derivative instruments that are used by ING Bank as part of its risk management strategies, but which do
not qualify for hedge accounting under ING Bank\u2019s 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.
1.7.5\u00a0 Offsetting of financial assets and financial liabilities
Financial assets and financial liabilities are offset, and the net amount is reported in the statement of
financial position when ING Bank 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 certain interest rate swaps for which the services of a central clearing house are
used.
1.7.6\u00a0 Repurchase transactions and reverse repurchase transactions
Securities sold subject to repurchase agreements (repos), securities lending and similar agreements
continue to be recognised in the Consolidated statement of financial position. The counterparty liability is
measured at FVPL (designated) and included in Other financial liabilities at FVPL if the asset is measured at
FVPL. Otherwise, the counterparty liability is included in Deposits from banks, Customer deposits, or Trading,
as appropriate.
Securities purchased under agreements to resell (reverse repos), securities borrowings and similar
agreements are not recognised in the Consolidated statement of financial position. The consideration paid
to purchase securities is recognised as Loans and advances to customers, Loans and advances to banks,
Other financial assets at FVPL or Trading assets, as appropriate. The difference between the sale and
repurchase price is treated as interest and amortised over the life of the agreement using the effective
interest method for instruments that are not measured at FVPL.
1.7.7\u00a0 Credit risk management classification and maximum credit risk exposure
Credit risk management disclosures are provided in the \u2018Credit risk\u2019 paragraph \u2018Credit risk categories\u2019 of the
\u2018Risk management\u2019 section in the Annual Report.
The maximum credit risk exposure for items in the statement of financial position is generally the carrying
value for the relevant financial assets. For the off-balance sheet items, the maximum credit exposure is the
maximum amount that could be required to be paid. Reference is made to Note 41 \u2018Contingent liabilities
and commitments\u2019 for these off-balance sheet items. Collateral received is not taken into account when
determining the maximum credit risk exposure.
Credit risk management disclosures are provided in the \u2018Credit risk\u2019 paragraph \u2018Credit risk categories\u2019 of the
\u2018Risk management\u2019 section in the Annual Report. The manner in which ING Bank manages credit risk and
determines credit risk exposures for that purpose is explained in the Credit risk paragraph \u2018Credit Risk
Appetite and Concentration Risk Framework\u2019 of the \u2018Risk management\u2019 section in the Annual Report.
1.7.8Impairment of financial assets
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 Bank calculates the expected credit losses (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. ING Bank\u2019s approach leverages the Advanced Internal Ratings Based (AIRB)
models that are used for regulatory purposes. Adjustments are applied to make these models suitable for
determining ECL. 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:
\u2022Stage 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);
\u2022Stage 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
\u2022Stage 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 Bank 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.
The main determinate of SICR is a quantitative test, whereby the lifetime Probability of Default (PD) of an
asset at each reporting date is compared against its lifetime PD determined at the date of initial recognition.
If the delta is above pre-defined absolute or relative thresholds the item is considered to have experienced a
SICR. Furthermore, any facility which shows an increase of 200% 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. Refer to \u2018Criteria for
identifying a significant increase in credit risk\u2019 in the \u2018Risk Management\u2019 section of the Annual Report for
more details on relative and absolute PD thresholds, including quantitative disclosures on those thresholds.
Consequently, if the above quantitative SICR thresholds are exceeded, the item moves from Stage 1 to Stage
2 (unless the item is credit-impaired). In these instances, items are no longer assigned a 12 month ECL and
instead are assigned a lifetime ECL. Items can return to Stage 1 if there is sufficient evidence that there is no
longer a significant increase in credit risk.
ING Bank also relies on a number of qualitative indicators to identify and assess SICR. These include:
\u2022Forbearance status;
\u2022Watch List status;
\u2022Intensive care management;
\u2022Collective SICR assessment;
\u2022Substandard Internal rating; and
\u2022Arrears status (including 30 days past due used as a backstop).
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 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 Bank 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 Bank has established a quarterly process whereby forward-looking macroeconomics scenarios and
probability weightings are developed for the purpose of ECL. ING Bank applies data predominantly from a
leading service provider (Oxford Economics (OE))\u00a0 enriched with the internal ING Bank view. A baseline, up-
scenario and a down-scenario are determined to reflect an unbiased and probability-weighted ECL amount.
As a baseline scenario, ING Bank 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.
Measurement of ECL
ING Bank 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 Bank 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 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\u2019 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 purpose of ECL, ING Bank\u2019s 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 Bank 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 Bank\u2019s 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 others, 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 is no longer recognised based on the accrual income
based on the gross carrying amount of the asset. Rather, interest income is calculated by applying the
original EIR to the AC 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 even if the lifetime ECL at the reporting date is lower than the estimated lifetime ECL at
origination.
Modifications
In certain circumstances ING Bank 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 is executed based on credit concerns it is also referred to as forbearance (refer to the \u2018Risk
Management\u2019 section of the Annual Report for more details). In such cases, the net present value of the
postponement, reduction of loan principal and/or interest payments is taken into account in the
determination of the appropriate level of ECL. If the forbearance 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. ING Bank determines whether there has been a substantial modification using both
quantitative and qualitative factors.
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:
\u2022After a restructuring has been completed and there is a high improbability of recovery of part of the
remaining loan exposure (including partial debt forgiveness);
\u2022In a bankruptcy liquidation scenario;
\u2022After divestment or sale of a credit facility at a discount;
\u2022Specific 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 \u2018Addition to loan loss provisions\u2019 in the Consolidated
statement of profit or loss..
Debt forgiveness (or debt settlement) involves write-off but additionally involves the forgiveness of a legal
obligation, in whole or in part. This means that ING Bank forfeits the legal right to recover the debt. As a
result, the financial asset needs to be derecognised. Distinction is made in situations where ING Bank ends
the relationship with the client and situations where ING Bank (partially) continues the financing of the
client.
Presentation of ECL
ECL for financial assets measured at AC are deducted from the gross carrying amount of the assets. For
debt instruments at FVOCI, the ECL is recognised in OCI, instead of deducted 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, are 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:
Considerable management judgement is exercised in determining the amount of ECL for financial assets
assessed on both a collective and an individual basis. In particular, this judgement requires ING Bank to
make various assumptions about the risk of default, the credit loss rates in case of a default and expected
future cash flows. These assumptions are based on a combination of ING Bank\u2019s past history, existing
market conditions and forward-looking estimates at the end of each reporting period. Changes in these
assumptions may lead to changes in the ECL over time. Given they are subjective and complex in nature,
and because the ECL and the underlying exposures subject to ECL are material, these assumptions are
considered critical accounting assumptions. The sensitivity of these assumptions is assessed in the credit
risk section of the \u2018Risk Management\u2019 section in the Annual Report.
\u2022The use of forward-looking macroeconomic scenarios in both collective and individual impairment
assessments
Forward-looking macroeconomic scenarios are uncertain in nature. The process ING Bank follows involves
two internal groups, the Macroeconomics Scenarios Team and the Macroeconomics Scenarios Expert
Panel. The latter team consists of senior management representatives from the Business, Risk and
Finance. These groups review inputs obtained from a third party provider and subject these to internal
expert challenge to ensure the inputs used in the models reflect ING Bank\u2019s view on the macro economy.
The use of alternate forward-looking macroeconomic scenarios can produce significantly different
estimates of ECL. This is demonstrated in the sensitivity analysis in the \u2018Risk Management\u2019 section of the
Annual Report, where the un-weighted ECL under each of the three scenarios for some significant
portfolios is disclosed.
\u2022The probability weights applied to each of the three scenarios
ING Bank uses three macroeconomic scenarios when determining IFRS 9 ECL (baseline, upside and
downside). Management judgement is applied in the design of the approach used to determine the
weights of each scenario and in selecting the parts of the distribution of forecast errors from which the
weights are derived. Reference is made to the \u2018Alternative scenarios and probability weights\u2019 and the
sensitivity analysis in the \u2018Risk Management\u2019 section of the Annual Report for further details.
\u2022The criteria for identifying a significant increase in credit risk
When determining whether the credit risk on a financial asset has increased significantly, ING Bank\u00a0
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\u2019s 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 constitute a significant judgement. Analysis
of the sensitivity associated with the assessment of significant increase in credit risk is presented in the
\u2018Risk Management\u2019 section of the Annual Report.
\u2022The definition of default
Judgement is exercised in management\u2019s evaluation of whether there is objective evidence that larger
exposures are credit-impaired. Management judgement is required in assessing evidence of credit-
impairment.
\u2022Management adjustments applied as at 31 December 2022
To reflect the risks that are not properly captured by the ECL models, a number of management
adjustments to the model-based ECL were necessary as at 31 December 2022. Reference is made to the
\u2018Management adjustments applied this year\u2019 paragraph in the \u2018Risk management\u2019 section of the Annual
Report.
1.7.9\u00a0 Accounting for Targeted Longer-Term Refinancing Operations (TLTRO)
ING Bank participates in Targeted Longer-Term Refinancing Operations (TLTRO III), reference is made to Note
12 \u2018Deposits from banks\u2019.
ING Bank considers 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 is considered to be a market conforming rate and TLTRO funding is
recognized fully as a financial liability.
ING Bank interprets 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 results in discrete rates for discrete interest
periods over the life of TLTRO. The change in the applicable rate between interest periods is seen as a
change in the floating rate and is accounted for prospectively. Similarly, if the ECB announces changes in
the rate for the amounts already drawn under the existing TLTRO, then such changes also represent a
change in a floating rate. Following this, such changes lead 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 relates to the
periods already passed, the impact for those past periods is recognised in profit or loss immediately.
Furthermore, the change in the TLTRO rate driven by changes in expectations of meeting the targets
impacts interest income. As a result, interest income which relates to the period that already passed until
the moment when the change in expectations occurs, is recognised as a catch up adjustment in
Consolidated statement of profit or loss. This change occurs only when ING Bank has a reasonable
expectation that the lending targets will be met.
ING Bank views \u2018reasonable expectation\u2019 in case of TLTRO funding as a high hurdle. This is the moment when
it becomes highly probable, i.e. the probability of meeting the lending targets is substantially greater than
the probability that it will not. As a result, if interest income is recognised during the period based on the
expectation of meeting the targets, there should only be a limited possibility that the interest may need to
be reversed in future reporting periods. Reference is made to note 12 \u2018Deposits from banks\u2019 and to note 20
\u2018Net interest income\u2019 for the presentation of ING Bank\u2019s participation in TLTRO programmes.
Significant judgements:
Significant management judgement is exercised in determining the accounting treatment of TLTRO
transactions. In particular, ING Bank\u00a0 applied judgement in:
\u2022assessing and concluding that in ING Bank'\u2019s view the rate under TLTRO is considered to be a market
conforming rate and, hence, accounting for TLTRO in accordance with IFRS 9; and
\u2022selecting accounting policies regarding the calculation of the effective interest rate under TLTRO.
Treatment of changes in expectations of meeting the lending targets was an area of significant
judgment in the comparative periods but no longer relevant in 2022.
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1.7.1\u00a0 Recognition and derecognition of financial instruments
Recognition of financial assets
Financial assets are recognised in the balance sheet when ING Bank 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 Bank 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 Bank 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.
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.
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1.7.2\u00a0 Classification and measurement of financial instruments
Financial assets
ING Bank classifies its financial assets in the following measurement categories:
\u2022those to be measured subsequently at fair value (either through OCI, or through profit or loss); and
\u2022those to be measured at amortised cost (AC).
At initial recognition, ING Bank 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\u2019s 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 Bank\u2019s 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 Bank 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\u2019s business model for managing the financial assets and the contractual terms of the
cash flows, there are three measurement categories into which ING Bank classifies its debt instruments:
\u2022Amortised 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.
\u2022FVOCI:
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\u2019 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.
\u2022FVPL:
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 Bank 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 repo\u2019s) 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 Interest income or 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
Interest income or Interest expense in the period in which it arises.
ING Bank 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 Bank applies the fair value through OCI option to
investments which are considered strategic, consisting of investments that add value to ING Bank\u2019s 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\u2019s 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:
\u2022the 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
\u2022the remaining amount of change in the fair value is presented in profit or loss in \u2018Valuation results and
net trading income\u2019. 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 \u2018Interest income
(expense).
A financial guarantee contract is a contract that requires ING Bank 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 \u2018Financial instruments\u2019 (see section \u201cImpairment of financial assets\u201d) and (b)
the amount initially recognised less, when appropriate, cumulative amortisation recognised in accordance
with the revenue recognition principle of IFRS 15 \u2018Revenue from contracts with customers\u2019.
1.7.3\u00a0 Fair values of financial assets and liabilities
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 \u2018Day One Profit or Loss\u2019) is deferred. ING Bank 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 Bank 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.
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 Bank 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 Bank 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 Bank\u2019s own credit risk by means of a DVA. Additionally, derivatives
valued at fair value are adjusted for credit risk by a BVA. The BVA is of a bilateral nature as both the credit
risk on the counterparty (CVA) as well as the credit risk on ING Bank (DVA) are included in the adjustment. All
input data that is used in the determination of the BVA is based on market implied data. Additionally,
wrong-way risk (when exposure to a counterparty is increasing and the credit quality of that counterparty
deteriorates) and right-way risk (when exposure to a counterparty is increasing and the credit quality of
that counterparty improves) are taken into account in the measurement of the valuation adjustment.
To include the funding risk, ING Bank applies an additional \u2018Funding Valuation Adjustment\u2019 (FVA) to the
uncollateralised derivatives based on the market price of funding liquidity. ING Bank also applies to certain
positions other valuation adjustments to arrive at the fair value: Bid-Offer adjustments, Model Risk
Adjustments and Collateral Valuation Adjustments (CollVA).
Significant judgements and critical accounting estimates and assumptions:
\u2022Even 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.\u00a0
\u2022Valuation 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.\u00a0
\u2022Price 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.
\u2022Assessing whether a market is active, and whether an input is observable and significant, requires
judgement. ING Bank 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.
\u2022Reference is made to Note 35 'Fair value of assets and liabilities ' and to the \u2018Market risk\u2019 paragraph in
the \u2018Risk management\u2019 section of the Annual Report for the basis of the determination of the fair value
of financial instruments and related sensitivities.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForFairValueMeasurementExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMjE5OTAyMzI3NzAzMTE_b1836647-9097-4191-9dbc-5fec05804ed0": { "value": "
Financial assets
ING Bank classifies its financial assets in the following measurement categories:
\u2022those to be measured subsequently at fair value (either through OCI, or through profit or loss); and
\u2022those to be measured at amortised cost (AC).
At initial recognition, ING Bank 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\u2019s 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 Bank\u2019s 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 Bank 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\u2019s business model for managing the financial assets and the contractual terms of the
cash flows, there are three measurement categories into which ING Bank classifies its debt instruments:
\u2022Amortised 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.
\u2022FVOCI:
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\u2019 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.
\u2022FVPL:
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 Bank 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 repo\u2019s) 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 Interest income or 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
Interest income or Interest expense in the period in which it arises.
ING Bank 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 Bank applies the fair value through OCI option to
investments which are considered strategic, consisting of investments that add value to ING Bank\u2019s 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\u2019s 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.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForFinancialAssetsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfODI0NjMzNzUxMzIxMA_38f7d961-a418-4a3c-8c0c-4b6eca1d5e2c": { "value": "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 Bank 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 repo\u2019s) 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 Interest income or 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
Interest income or Interest expense in the period in which it arises.
Financial assets - Equity instruments
All equity investments are measured at fair value. ING Bank applies the fair value through OCI option to
investments which are considered strategic, consisting of investments that add value to ING Bank\u2019s 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\u2019s 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:
\u2022the 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
\u2022the remaining amount of change in the fair value is presented in profit or loss in \u2018Valuation results and
net trading income\u2019. 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 \u2018Interest income
(expense).
A financial guarantee contract is a contract that requires ING Bank 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 \u2018Financial instruments\u2019 (see section \u201cImpairment of financial assets\u201d) and (b)
the amount initially recognised less, when appropriate, cumulative amortisation recognised in accordance
with the revenue recognition principle of IFRS 15 \u2018Revenue from contracts with customers\u2019.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForFinancialInstrumentsAtFairValueThroughProfitOrLossExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMjMwODk3NDQzOTgwODg_cbe84847-190e-4242-b882-3414ab357c9c": { "value": "
ING Bank 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.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForReclassificationOfFinancialInstrumentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMjMwODk3NDQzOTgwODk_3653ac4b-73b9-4fa6-ba12-cd81a9464230": { "value": "
Financial assets - Equity instruments
All equity investments are measured at fair value. ING Bank applies the fair value through OCI option to
investments which are considered strategic, consisting of investments that add value to ING Bank\u2019s 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\u2019s 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.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForInvestmentsOtherThanInvestmentsAccountedForUsingEquityMethodExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMjMwODk3NDQzOTgwOTM_78c7160a-46b3-4199-8b48-b7b172e4528d": { "value": "
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:
\u2022the 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
\u2022the remaining amount of change in the fair value is presented in profit or loss in \u2018Valuation results and
net trading income\u2019. 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 \u2018Interest income
(expense).
A financial guarantee contract is a contract that requires ING Bank 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 \u2018Financial instruments\u2019 (see section \u201cImpairment of financial assets\u201d) and (b)
the amount initially recognised less, when appropriate, cumulative amortisation recognised in accordance
with the revenue recognition principle of IFRS 15 \u2018Revenue from contracts with customers\u2019.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForFinancialGuaranteesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfODI0NjMzNzUxMzIxNA_14d99071-3c0b-4e39-8ef1-7d4f314089f3": { "value": "
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:
\u2022the 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
\u2022the remaining amount of change in the fair value is presented in profit or loss in \u2018Valuation results and
net trading income\u2019. 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 \u2018Interest income
(expense).
A financial guarantee contract is a contract that requires ING Bank 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 \u2018Financial instruments\u2019 (see section \u201cImpairment of financial assets\u201d) and (b)
the amount initially recognised less, when appropriate, cumulative amortisation recognised in accordance
with the revenue recognition principle of IFRS 15 \u2018Revenue from contracts with customers\u2019.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForFinancialLiabilitiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfODI0NjMzNzUxMzIxNg_a082525f-3081-416a-970d-5379e08bc6bc": { "value": "
1.7.3\u00a0 Fair values of financial assets and liabilities
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 \u2018Day One Profit or Loss\u2019) is deferred. ING Bank 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 Bank 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.
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 Bank 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 Bank 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 Bank\u2019s own credit risk by means of a DVA. Additionally, derivatives
valued at fair value are adjusted for credit risk by a BVA. The BVA is of a bilateral nature as both the credit
risk on the counterparty (CVA) as well as the credit risk on ING Bank (DVA) are included in the adjustment. All
input data that is used in the determination of the BVA is based on market implied data. Additionally,
wrong-way risk (when exposure to a counterparty is increasing and the credit quality of that counterparty
deteriorates) and right-way risk (when exposure to a counterparty is increasing and the credit quality of
that counterparty improves) are taken into account in the measurement of the valuation adjustment.
To include the funding risk, ING Bank applies an additional \u2018Funding Valuation Adjustment\u2019 (FVA) to the
uncollateralised derivatives based on the market price of funding liquidity. ING Bank also applies to certain
positions other valuation adjustments to arrive at the fair value: Bid-Offer adjustments, Model Risk
Adjustments and Collateral Valuation Adjustments (CollVA).
Significant judgements and critical accounting estimates and assumptions:
\u2022Even 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.\u00a0
\u2022Valuation 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.\u00a0
\u2022Price 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.
\u2022Assessing whether a market is active, and whether an input is observable and significant, requires
judgement. ING Bank 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.
\u2022Reference is made to Note 35 'Fair value of assets and liabilities ' and to the \u2018Market risk\u2019 paragraph in
the \u2018Risk management\u2019 section of the Annual Report for the basis of the determination of the fair value
of financial instruments and related sensitivities.
1.7.8Impairment of financial assets
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 Bank calculates the expected credit losses (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. ING Bank\u2019s approach leverages the Advanced Internal Ratings Based (AIRB)
models that are used for regulatory purposes. Adjustments are applied to make these models suitable for
determining ECL. 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:
\u2022Stage 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);
\u2022Stage 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
\u2022Stage 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 Bank 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.
The main determinate of SICR is a quantitative test, whereby the lifetime Probability of Default (PD) of an
asset at each reporting date is compared against its lifetime PD determined at the date of initial recognition.
If the delta is above pre-defined absolute or relative thresholds the item is considered to have experienced a
SICR. Furthermore, any facility which shows an increase of 200% 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. Refer to \u2018Criteria for
identifying a significant increase in credit risk\u2019 in the \u2018Risk Management\u2019 section of the Annual Report for
more details on relative and absolute PD thresholds, including quantitative disclosures on those thresholds.
Consequently, if the above quantitative SICR thresholds are exceeded, the item moves from Stage 1 to Stage
2 (unless the item is credit-impaired). In these instances, items are no longer assigned a 12 month ECL and
instead are assigned a lifetime ECL. Items can return to Stage 1 if there is sufficient evidence that there is no
longer a significant increase in credit risk.
ING Bank also relies on a number of qualitative indicators to identify and assess SICR. These include:
\u2022Forbearance status;
\u2022Watch List status;
\u2022Intensive care management;
\u2022Collective SICR assessment;
\u2022Substandard Internal rating; and
\u2022Arrears status (including 30 days past due used as a backstop).
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 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 Bank 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 Bank has established a quarterly process whereby forward-looking macroeconomics scenarios and
probability weightings are developed for the purpose of ECL. ING Bank applies data predominantly from a
leading service provider (Oxford Economics (OE))\u00a0 enriched with the internal ING Bank view. A baseline, up-
scenario and a down-scenario are determined to reflect an unbiased and probability-weighted ECL amount.
As a baseline scenario, ING Bank 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.
Measurement of ECL
ING Bank 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 Bank 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 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\u2019 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 purpose of ECL, ING Bank\u2019s 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 Bank 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 Bank\u2019s 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 others, 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 is no longer recognised based on the accrual income
based on the gross carrying amount of the asset. Rather, interest income is calculated by applying the
original EIR to the AC 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 even if the lifetime ECL at the reporting date is lower than the estimated lifetime ECL at
origination.
Modifications
In certain circumstances ING Bank 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 is executed based on credit concerns it is also referred to as forbearance (refer to the \u2018Risk
Management\u2019 section of the Annual Report for more details). In such cases, the net present value of the
postponement, reduction of loan principal and/or interest payments is taken into account in the
determination of the appropriate level of ECL. If the forbearance 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. ING Bank determines whether there has been a substantial modification using both
quantitative and qualitative factors.
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:
\u2022After a restructuring has been completed and there is a high improbability of recovery of part of the
remaining loan exposure (including partial debt forgiveness);
\u2022In a bankruptcy liquidation scenario;
\u2022After divestment or sale of a credit facility at a discount;
\u2022Specific 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 \u2018Addition to loan loss provisions\u2019 in the Consolidated
statement of profit or loss..
Debt forgiveness (or debt settlement) involves write-off but additionally involves the forgiveness of a legal
obligation, in whole or in part. This means that ING Bank forfeits the legal right to recover the debt. As a
result, the financial asset needs to be derecognised. Distinction is made in situations where ING Bank ends
the relationship with the client and situations where ING Bank (partially) continues the financing of the
client.
Presentation of ECL
ECL for financial assets measured at AC are deducted from the gross carrying amount of the assets. For
debt instruments at FVOCI, the ECL is recognised in OCI, instead of deducted 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, are 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:
Considerable management judgement is exercised in determining the amount of ECL for financial assets
assessed on both a collective and an individual basis. In particular, this judgement requires ING Bank to
make various assumptions about the risk of default, the credit loss rates in case of a default and expected
future cash flows. These assumptions are based on a combination of ING Bank\u2019s past history, existing
market conditions and forward-looking estimates at the end of each reporting period. Changes in these
assumptions may lead to changes in the ECL over time. Given they are subjective and complex in nature,
and because the ECL and the underlying exposures subject to ECL are material, these assumptions are
considered critical accounting assumptions. The sensitivity of these assumptions is assessed in the credit
risk section of the \u2018Risk Management\u2019 section in the Annual Report.
\u2022The use of forward-looking macroeconomic scenarios in both collective and individual impairment
assessments
Forward-looking macroeconomic scenarios are uncertain in nature. The process ING Bank follows involves
two internal groups, the Macroeconomics Scenarios Team and the Macroeconomics Scenarios Expert
Panel. The latter team consists of senior management representatives from the Business, Risk and
Finance. These groups review inputs obtained from a third party provider and subject these to internal
expert challenge to ensure the inputs used in the models reflect ING Bank\u2019s view on the macro economy.
The use of alternate forward-looking macroeconomic scenarios can produce significantly different
estimates of ECL. This is demonstrated in the sensitivity analysis in the \u2018Risk Management\u2019 section of the
Annual Report, where the un-weighted ECL under each of the three scenarios for some significant
portfolios is disclosed.
\u2022The probability weights applied to each of the three scenarios
ING Bank uses three macroeconomic scenarios when determining IFRS 9 ECL (baseline, upside and
downside). Management judgement is applied in the design of the approach used to determine the
weights of each scenario and in selecting the parts of the distribution of forecast errors from which the
weights are derived. Reference is made to the \u2018Alternative scenarios and probability weights\u2019 and the
sensitivity analysis in the \u2018Risk Management\u2019 section of the Annual Report for further details.
\u2022The criteria for identifying a significant increase in credit risk
When determining whether the credit risk on a financial asset has increased significantly, ING Bank\u00a0
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\u2019s 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 constitute a significant judgement. Analysis
of the sensitivity associated with the assessment of significant increase in credit risk is presented in the
\u2018Risk Management\u2019 section of the Annual Report.
\u2022The definition of default
Judgement is exercised in management\u2019s evaluation of whether there is objective evidence that larger
exposures are credit-impaired. Management judgement is required in assessing evidence of credit-
impairment.
\u2022Management adjustments applied as at 31 December 2022
To reflect the risks that are not properly captured by the ECL models, a number of management
adjustments to the model-based ECL were necessary as at 31 December 2022. Reference is made to the
\u2018Management adjustments applied this year\u2019 paragraph in the \u2018Risk management\u2019 section of the Annual
Report.
1.7.9\u00a0 Accounting for Targeted Longer-Term Refinancing Operations (TLTRO)
ING Bank participates in Targeted Longer-Term Refinancing Operations (TLTRO III), reference is made to Note
12 \u2018Deposits from banks\u2019.
ING Bank considers 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 is considered to be a market conforming rate and TLTRO funding is
recognized fully as a financial liability.
ING Bank interprets 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 results in discrete rates for discrete interest
periods over the life of TLTRO. The change in the applicable rate between interest periods is seen as a
change in the floating rate and is accounted for prospectively. Similarly, if the ECB announces changes in
the rate for the amounts already drawn under the existing TLTRO, then such changes also represent a
change in a floating rate. Following this, such changes lead 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 relates to the
periods already passed, the impact for those past periods is recognised in profit or loss immediately.
Furthermore, the change in the TLTRO rate driven by changes in expectations of meeting the targets
impacts interest income. As a result, interest income which relates to the period that already passed until
the moment when the change in expectations occurs, is recognised as a catch up adjustment in
Consolidated statement of profit or loss. This change occurs only when ING Bank has a reasonable
expectation that the lending targets will be met.
ING Bank views \u2018reasonable expectation\u2019 in case of TLTRO funding as a high hurdle. This is the moment when
it becomes highly probable, i.e. the probability of meeting the lending targets is substantially greater than
the probability that it will not. As a result, if interest income is recognised during the period based on the
expectation of meeting the targets, there should only be a limited possibility that the interest may need to
be reversed in future reporting periods. Reference is made to note 12 \u2018Deposits from banks\u2019 and to note 20
\u2018Net interest income\u2019 for the presentation of ING Bank\u2019s participation in TLTRO programmes.
Significant judgements:
Significant management judgement is exercised in determining the accounting treatment of TLTRO
transactions. In particular, ING Bank\u00a0 applied judgement in:
\u2022assessing and concluding that in ING Bank'\u2019s view the rate under TLTRO is considered to be a market
conforming rate and, hence, accounting for TLTRO in accordance with IFRS 9; and
\u2022selecting accounting policies regarding the calculation of the effective interest rate under TLTRO.
Treatment of changes in expectations of meeting the lending targets was an area of significant
judgment in the comparative periods but no longer relevant in 2022.
1.11\u00a0 Investments in associates and joint ventures
Associates are all entities over which ING Bank 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:
\u2022Representation on the board of directors;\u00a0
\u2022Participation in the policymaking process; and\u00a0
\u2022Interchange of managerial personnel.\u00a0
Joint ventures are entities over which ING Bank has joint control. Joint control is the contractually agreed
sharing of control over an arrangement or entity, which exists only when decisions about the relevant
activities require the unanimous consent of the parties sharing control. Joint control means that no party to
the agreement is able to act unilaterally to control the activity of the entity. The parties to the agreement
must act together to control the entity and therefore exercise the joint control.
Investments in associates and joint ventures are initially recognised at cost and subsequently accounted for
using the equity method of accounting.
ING Bank\u2019s investment in associates and joint ventures (net of any accumulated impairment loss) includes
goodwill identified on acquisition. ING Bank\u2019s 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 Bank\u2019s 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 Bank
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 Bank and its associates and joint ventures are eliminated to
the extent of ING Bank\u2019s 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 Bank.
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. 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. 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.
Significant judgements and critical accounting estimates and assumptions:
The most significant estimates and assumptions relate to the assessment of (reversal of) impairment of
the investment in TMBThanachart Bank Public Company Limited (hereafter: TTB) which involves estimation
of value in use.
Management's best estimate of the expected future earnings of TTB is based on forecasts derived from
broker consensus over the short to medium term and reasonable and supportable assumptions capturing
a combination of TTB specific and market data points for longer term and steady state expectations into
perpetuity. A capital maintenance charge is applied, which is management\u2019s forecast of the earnings that
need to be withheld in order for TTB to meet target regulatory requirements over the forecast period. Both
of these factors are subject to a high degree of uncertainty.
Key assumptions used in estimating TTB\u2019s value in use and the sensitivity of the value in use calculations
to different assumptions are described in note 8 \u2018Investments in associates and joint ventures\u2019.
1.18\u00a0 Provisions, contingent liabilities and contingent assets
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 Bank 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 Bank; 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 Bank. 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.
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 Bank\u00a0 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 Bank
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 Bank consults with internal and external legal experts. Even taking into
consideration legal experts\u2019 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'.
Cash and balances with central banks
in EUR million
2022
2021
Amounts held at central banks 1
85,934\u00a0
104,870\u00a0
Cash and bank balances
1,681\u00a0
1,650\u00a0
87,614
106,520
1 Amounts held at central banks include an amount of EUR -12 million (2021: EUR -6 million) of Loan loss provisions.
3\u00a0 Loans and advances to banks
Loans and advances to banks
Netherlands
Rest of the world
Total
in EUR million
2022
2021
2022
2021
2022
2021
Loans and advances to banks
23,462
7,018
11,679
16,595
35,140
23,613
Loan loss provisions
-12
-10
-26
-13
-37
-22
23,450
7,009
11,653
16,582
35,103
23,591
Loans include balances (mainly reverse repos) with central banks amounting to EUR 19,395 million (2021:
EUR 3,403 million). 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\u00a0December 2022 and at 31 December 2021, all loans and advances to banks are non-subordinated.
Financial assets at fair value through other comprehensive income by type
in EUR million
2022
2021
Equity securities
1,887
2,457
Debt securities 1
29,095
27,340
Loans and advances 1
643
838
31,625
30,635
1 Debt securities include an amount of EUR -21\u00a0million (2021: EUR -12 million) and the Loans and advances includes EUR
-1\u00a0million(2021: EUR -1 million) of Loan loss provisions.
Debt securities by type of exposure
Debt Securities at
FVPL
Debt Securities at
FVOCI
Debt Securities at
AC
Total
in EUR million
2022
2021
2022
2021
2022
2021
2022
2021
Government bonds
63
48
16,016
16,271
24,629
26,588
40,708
42,908
Sub-sovereign, Supranationals
and Agencies
2,343
3,115
8,529
7,587
14,210
13,752
25,082
24,454
Covered bonds
2,663
1,729
5,543
5,063
8,206
6,792
Corporate bonds
857
778
108
156
26
90
991
1,024
Financial institutions' bonds
2,237
1,993
772
798
2,551
1,932
5,561
4,724
ABS portfolio
758
723
1,028
810
1,217
913
3,003
2,445
6,258
6,658
29,116
27,352
48,177
48,338
83,551
82,347
Loan loss provisions
-21
-12
-17
-19
-39
-31
Debt securities portfolio
6,258
6,658
29,095
27,340
48,160
48,319
83,513
82,316
Loans and advances to customers by type 1
Netherlands
Rest of the world
Total
in EUR million
2022
2021
2022
2021
2022
2021
Loans to public authorities
837
1,153
11,840
9,672
12,677
10,824
Residential mortgages
107,952
110,283
205,511
203,529
313,463
313,813
Other personal lending
5,835
6,551
30,345
31,511
36,180
38,063
Corporate Lending
68,128
68,104
211,092
202,020
279,220
270,124
182,752
186,091
458,789
446,733
641,541
632,824
Loan loss provisions
-993
-1,119
-4,990
-4,156
-5,984
-5,274
181,759
184,972
453,798
442,577
635,557
627,550
8\u00a0 Investment in associates and joint ventures
Investments in associates and joint ventures
in EUR million
2022
Interest
held (%)
Fair value of
listed invest-
ments
Balance
sheet
value
Total
assets
Total
liabilities
Total
income
Total
expenses
TMBThanachart Bank Public
Company Limited
23%
849
1,109
49,506
43,677
1,303
957
Other investments in associates and
joint ventures
391
1,500
Investments in associates and joint ventures
in EUR million
2021
Interest
held (%)
Fair value of
listed invest-
ments
Balance
sheet value
Total
assets
Total
liabilities
Total
income
Total
expenses
TMBThanachart Bank Public
Company Limited
23%
866
1,208
46,478
40,957
1,286
1,038
Other investments in associates
and joint ventures
379
1,587
TMBThanachart Bank Public Company Limited
ING Bank has a 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 shareholding and representation on the Board.
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 represents a number of
associates and joint ventures that are individually not significant to ING Bank.
Significant influence for associates in which the interest held is below 20%, is based on the combination of
ING Bank\u2019s 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, rating agency and regulatory
views, which can change over time.
Changes in Investments in associates and joint ventures
in EUR million
2022
2021
Opening balance
1,587
1,475
Additions
48
91
Revaluations
-8
-24
Share of results
92
141
Dividends received
-48
-34
Disposals
-10
-23
Impairments
-192
-3
Exchange rate differences
27
-31
Other
4
-5
Closing balance
1,500
1,587
Share of results from associates and joint ventures of EUR 92 million (2021: EUR 141 million) as included in
the table above is mainly attributable to results of TTB of EUR 81\u00a0million (2021: EUR 61 million). In 2021,
share of results from associates includes additional EUR 28 million gain on our stake in Ebusco.
Impairments
In 2022, Impairments of EUR 192 million is predominantly attributable to TTB of EUR 165 million. TTB is part
of the Retail Other segment.
Impairment testing TTB
The fair value of TTB has been below the purchase cost of the investment for a prolonged period of time
(since 1Q 2020). This is considered to be objective evidence of impairment. As a result ING performed
quarterly impairment tests that led to impairment loss of EUR 165 million (2021: EUR nil).
The impairment test performed in 2022 led to an impairment at 31 March 2022 of EUR 150 million and EUR
15 million at 30 September 2022, as the recoverable amount as determined by a Value in Use calculation,
was below the carrying amount\u00a0 at that point in time. The impairment test at year end resulted in no further
impairments.
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and Value in Use
(\u2018VIU\u2019). Fair value less costs of disposal is based on observable share price. The VIU calculation uses
discounted cash flow projections based on management\u2019s 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:
\u2022the estimation of future earnings over a 5 year forecast period; and
\u2022the 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 2022 (and as at 30 September 2022
resulting in impairment)
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:
\u2022Expected 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\u00a0 assumptions capturing a combination of TTB specific and market data
points. A capital maintenance charge is applied, which is management\u2019s forecast of the earnings that
need to be withheld in order for TTB to meet target regulatory requirements over the forecast period;
\u2022Discount rate (cost of equity): 9.71% (30 September 2022: 10.54%), based on the capital asset pricing
model (CAPM) calculated for TTB using current market data.
\u2022Terminal growth rate: 3.05% (30 September 2022: 3.82%) consistent with current long term government
bond yield in Thailand as a proxy for a risk-free rate;
To assess the risk of further impairment at 31 December 2022, 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. Holding the other key assumptions constant, a reduction in all of the forecasted
annual cash flows, including terminal value, of 836bps would reduce the recoverable amount to the carrying
amount. An increase of 55bps in terminal growth rate and discount rate would cause the VIU to equal the
carrying amount.
Reversal of the impairment loss recognised was not considered appropriate as at 31 December 2022 mainly
due to the lack of sufficiently positive changes observed in the underlying performance of TTB since the
impairment loss as reflected in the broker consensus. Furthermore, the share price remains below the
original cost of the investment for a prolonged period of time.
Deposits from banks includes ING\u2019s participation in the Targeted Longer-Term Refinancing Operations
(TLTRO) of EUR 36.0 billion (2021: EUR 65.5 billion). 2022 includes the impact of an early repayment of EUR
29.5 billion of ING's TLTRO III participation. For the details of the applicable rates and impact on net interest
income reference is made to Note 20 'Net interest income'.
Provisions by type
in EUR million
2022
2021
Reorganisation provisions
418
421
Litigation provisions
150
132
Other provisions
462
420
1,030
973
Changes in provisions
Reorganisation
Litigation
Other
Total
in EUR million
2022
2021
2022
2021
2022
2021
2022
2021
Opening balance
421
381
132
105
420
180
973
666
Additions
217
310
59
50
227
354
503
715
Interest
-2
-2
-2
-2
Releases
-46
-96
-8
-11
-166
-79
-221
-186
Utilised
-170
-172
-33
-18
-15
-25
-218
-215
Exchange rate differences
-3
-2
-1
-4
Other changes
-4
-3
9
-1
-7
-4
-1
Closing balance
418
421
150
132
462
420
1,030
973
The USD appreciates against EURO and various currencies during the year. These main factors drive the
market-to-market movements across different asset classes and spread movement through the year.
Overall in 2022, financial assets and liabilities, including Level 3, continued to be valued using agreed
methodologies and ING continued to limit the unobservable input to arrive at the most appropriate Fair
Market value.
b) Valuation Control framework
The valuation control framework covers the product approval process (PARP), pricing, market data
assessment and independent price verification (IPV), valuation adjustments, model use, fair value hierarchy
and day one profit or loss. Valuation processes are governed by various governance bodies, including Local
Parameter Committees, Global Valuation and Impairment Committee, Market Data Committee and
Valuation Model Committee. All relevant committees meet on a regular basis (monthly/quarterly), where
agenda covers the aforementioned valuation controls.
The Global Valuation and Impairment Committee is responsible for the oversight and the approval of the
outcome of impairments (other than loan loss provisions) and valuation processes. It oversees the quality
and coherence of valuation methodologies and performance. The Valuation Model Committee is responsible
for the approval of all valuation models used for the Fair valuation (IFRS) and Prudent Valuation (CRR) of
positions measured at fair value. The Local Parameter Committee discusses the valuation results and
monitors the performance of the valuation activities carried out on local or regional level. The Market Data
Committee is responsible for the approval of the market data used in valuation.\u00a0
c) Valuation Adjustments
Valuation adjustments are an integral part of the fair value. They are the adjustments to the output from a
valuation technique in order to appropriately determine a fair value in accordance with IFRS13. ING
considers various fair value adjustments including Bid-Offer adjustments, Model Risk adjustments, Bilateral
Valuation Adjustments (BVA, consisting of Credit Valuation Adjustments or CVA, and Debit valuation
Adjustments or DVA), Collateral Valuation Adjustment (CollVA) and Funding Valuation Adjustment (FVA).
For financial instruments where the fair value at initial recognition is based on one or more significant
unobservable inputs, a difference between the transaction price and the fair value resulting from the
internal valuation process can occur. Such difference is referred to as Day One Profit or Day One Loss (DOP).
ING defers material Day One Profit or Loss of instruments with significant unobservable valuation inputs,
which are the financial instruments classified as Level 3 and financial instruments with material
unobservable inputs into CVA which are not necessarily classified as Level 3. The Day One Profit or Loss is
amortised over the life of the instrument, or until the significant unobservable inputs become observable, or
until the significant unobservable inputs become non-significant. Both the impact on the profit and loss in
2022 and the Day One Profit or Loss reserve is disclosed in the below table.
The following table presents the models reserves for financial assets and liabilities.
Valuation adjustment reserves on financial assets and liabilities
in EUR million
2022
2021
Deferred Day One Profit or Loss 1
-108
-7
Own credit adjustments 2
75
-95
Bid/Offer
-216
-143
Model Risk
-13
-11
CVA
-192
-159
DVA 2
99
30
CollVA
-8
-8
FVA
-78
-95
Total Valuation Adjustments
-441
-489
1.In 2022, the presentation of Day One Profit or Loss reserve has been included in the table above
2. The change in the DVA as of 2022 entails the split into DVA on derivatives and Own credit adjustments on own issued liabilities.
Comparatives figures for 2021 have been updated accordingly.\u00a0
Overall, the fair value adjustments balance move down compared to last year end explained by own credit
adjustments on own issued liabilities, mainly driven by the widening of ING CDS curve spread across all
tenors, and for DVA on derivatives.
Deferred Day One Profit or Loss Reserve
The table below summarizes the movement in the aggregate profit not recognised when financial
instruments were initially recognised (Day One Profit or Loss), because of the use of valuation techniques for
which not all the inputs were market observable data.
As at 31 December 2022 ING further refined the thresholds to identify trades with significant unobservable
CVA which triggered more Day One Profit or Loss deferral. Reference is made to the table below.
Deferred day one profit or loss reserve
in EUR million
2022
2021
Opening balance at 1 January
-7
-5
DOP deferred on new transactions during the period
-107
-8
DOP recognised in the statement of profit or loss during the period
6
6
Closing balance at 31 December
-108
-7
The following methods and assumptions were used by ING Bank to estimate the fair value of the financial
instruments:
Equity securities
Instrument description: Equity securities include stocks and shares, corporate investments and private
equity investments.
Valuation: If available, the fair values of publicly traded equity securities and private equity securities are
based on quoted market prices. In absence of active markets, fair values are estimated by analysing the
investee\u2019s financial position, result, risk profile, prospect, price, earnings comparisons and revenue multiples.
Additionally, reference is made to valuations of peer entities where quoted prices in active markets are
available. For equity securities best market practice will be applied using the most relevant valuation
method. All non-listed equity investments, including investments in private equity funds, are subject to a
standard review framework which ensures that valuations reflect the fair values.
Fair value hierarchy: The majority of equity securities are publicly traded and quoted prices are readily and
regularly available. Hence, these securities are classified as Level 1.\u00a0 Equity securities which are not traded in
active markets mainly include corporate investments, fund investments and other equity securities and are
classified as Level 3.
Debt securities
Instrument description: Debt securities include government bonds, financial institutions bonds and Asset-
backed securities (ABS).
Valuation: Where available, fair values for debt securities are generally based on quoted market prices.
Quoted market prices are obtained from an exchange market, dealer, broker, industry group, pricing service,
or regulatory service. The quoted prices from non-exchange sources are reviewed on their tradability of
market prices. If quoted prices in an active market are not available, fair value is based on an analysis of
available market inputs, which includes consensus prices obtained from one or more pricing services.
Furthermore, fair values are determined by valuation techniques discounting expected future cash flows
using market interest rate curves, referenced credit spreads, maturity of the investment, and estimated
prepayment rates where applicable.
Fair value hierarchy: Government bonds and financial institutions bonds are generally traded in active
markets, where quoted prices are readily and regularly available and are hence, classified as Level 1. The
remaining positions are classified as Level 2 or Level 3.\u00a0 Asset backed securities for which no active market is
available and a wide discrepancy in quoted prices exists, are classified as Level 3.
Derivatives
Instrument description: Derivatives contracts can either be exchange-traded or over the counter (OTC).
Derivatives include interest rate derivatives, FX derivatives, Credit derivatives, Equity derivatives and
commodity derivatives.
Valuation: The fair value of exchange-traded derivatives is determined using quoted market prices in an
active market and are classified as Level 1 of the fair value hierarchy. For instruments that are not actively
traded, fair values are estimated based on valuation techniques. OTC derivatives and derivatives trading in
an inactive market are valued using valuation techniques. The valuation techniques and inputs depend on
the type of derivatives and the nature of the underlying instruments. The principal techniques used to value
these instruments are based on (amongst others) discounted cash flows, option pricing models and Monte
Carlo simulations. These valuation models calculate the present value of expected future cash flows, based
on \u2018no-arbitrage\u2019 principles. The models are commonly used in the financial industry and inputs to the
validation models are determined from observable market data where possible. Certain inputs may not be
observable in the market, but can be determined from observable prices via valuation model calibration
procedures. These inputs include prices available from exchanges, dealers, brokers or providers of pricing,
yield curves, credit spreads, default rates, recovery rates, dividend rates, volatility of underlying interest
rates, equity prices, and foreign currency exchange rates and reference is made to quoted prices, recently
executed trades, independent market quotes and consensus data, where available.
For uncollateralised OTC derivatives, ING applies Credit Valuation Adjustment to correctly reflect the
counterparty credit risk in the valuation and Debit Valuation Adjustments to reflect the credit risk of ING for
its counterparty. In addition, for these derivatives ING applies Funding Valuation Adjustment. See sections
CVA/DVA and FVA in section c) Valuation Adjustments for more details regarding the calculation.
Fair value hierarchy: The majority of the derivatives are priced using observable inputs and are classified as
Level 2. Derivatives for which the input cannot be implied from observable market data are classified as
Level 3.
Loans and receivables
Instrument description: Loans and receivables are non-derivative financial assets with fixed or determinable
payments that are not quoted in an active market. Loans and receivables carried at fair value includes
trading loans, being securities lending and similar agreement comparable to collateralised lending,
syndicated loans, loans expected to be sold and receivables with regards to reverse repurchase
transactions.
Valuation: The fair value of loans and receivables is generally estimated by discounting expected future cash
flows using a discount rate that reflects credit risk, liquidity, and other current market conditions. The fair
value of mortgage loans is estimated by taking into account prepayment behaviour. Fair value hierarchy:
Loans and receivables are predominantly classified as Level 2. Loans and receivables for which current
market information about similar assets to use as observable, corroborated data for all significant inputs
into a valuation model is not available, are classified as Level 3.
Financial liabilities at fair value through profit and loss
Instrument description: Financial liabilities at fair value through profit and loss include debt securities, debt
instruments, primarily comprised of structured notes, which are held at fair value under the fair value
option. Besides that, it includes derivative contracts and repurchase agreements.
Valuation: The fair values of securities in the trading portfolio and other liabilities at fair value through profit
or loss are based on quoted market prices, where available. For those securities not actively traded, fair
values are estimated based on internal discounted cash flow valuation techniques using interest rates and
credit spreads that apply to similar instruments.
Fair value hierarchy: The majority of the derivatives and debt instruments are classified as Level 2.
Derivatives and debt instruments for which the input cannot be derived from observable market data are
classified as Level 3.
e) Transfers between Level 1 and 2
As a consequence of change in observable inputs, ING recorded an EUR 1.8 billion transfer from Level 2 to
Level 1 in debt securities measured at fair value through other comprehensive income. No significant
transfers from Level 1 to Level 2 were recorded in the reporting period 2022.
f) Level 3: Valuation techniques and inputs used
Financial assets and liabilities in Level 3 include both assets and liabilities for which the fair value was
determined using (i) valuation techniques that incorporate unobservable inputs as well as (ii) quoted prices
which have been adjusted to reflect that the market was not actively trading at or around the balance sheet
date. Unobservable inputs are inputs which are based on ING\u2019s own assumptions about the factors that
market participants would use in pricing an asset or liability, developed based on the best information
available in the circumstances. Unobservable inputs may include volatility, correlation, spreads to discount
rates, default rates and recovery rates, prepayment rates, and certain credit spreads. Valuation techniques
that incorporate unobservable inputs are sensitive to the inputs used.
Of the total amount of financial assets classified as Level 3 as at 31\u00a0December 2022 of EUR 7.5 billion
(31\u00a0December 2021: EUR 6.2 billion), an amount of EUR 2.2 billion (29.2%) (31\u00a0December 2021: EUR 2.0
billion, being 32.5%) is based on unadjusted quoted prices in inactive markets. As ING does not generally
adjust quoted prices using its own inputs, there is no significant sensitivity to ING\u2019s own unobservable inputs.
Furthermore, Level 3 financial assets includes approximately EUR 4.2 billion (31\u00a0December 2021: EUR 2.9
billion) which relates to financial assets that are part of structures that are designed to be fully neutral in
terms of market risk. Such structures include various financial assets and liabilities for which the overall
sensitivity to market risk is insignificant. Whereas the fair value of individual components of these structures
may be determined using different techniques and the fair value of each of the components of these
structures may be sensitive to unobservable inputs, the overall sensitivity is by design not significant.
The remaining EUR 1.1 billion (31\u00a0December 2021: EUR 1.3 billion of the fair value classified in Level 3
financial assets is established using valuation techniques that incorporates certain inputs that are
unobservable.
Of the total amount of financial liabilities classified as Level 3 as at 31\u00a0December 2022 of EUR 0.7 billion
(31\u00a0December 2021: EUR 0.3 billion), an amount of EUR 0.02 billion (2.5%) (31\u00a0December 2021: EUR 0.1
billion, being 42.0%) is based on unadjusted quoted prices in inactive markets. As ING does not generally
adjust quoted prices using its own inputs, there is no significant sensitivity to ING\u2019s own unobservable inputs.
Furthermore, Level 3 financial liabilities includes approximately EUR 0.6 billion (31\u00a0December 2021: EUR 0.1
billion) which relates to financial liabilities that are part of structures that are designed to be fully neutral in
terms of market risk. As explained above, the fair value of each of the components of these structures may
be sensitive to unobservable inputs, but the overall sensitivity is by design not significant.
The remaining EUR 0.1 billion (31\u00a0December 2021: EUR 0.1 billion of the fair value classified in Level 3
financial liabilities is established using valuation techniques that incorporates certain inputs that are
unobservable.
The table below provides a summary of the valuation techniques, key unobservable inputs and the lower
and upper range of such unobservable inputs, by type of Level 3 asset/liability. The lower and upper range
mentioned in the overview represent the lowest and highest variance of the respective valuation input as
actually used in the valuation of the different financial instruments. Amounts and percentages stated are
unweighted. The range can vary from period to period subject to market movements and change in Level\u00a03
position. Lower and upper bounds reflect the variability of Level 3 positions and their underlying valuation
inputs in the portfolio, but do not adequately reflect their level of valuation uncertainty. For valuation
uncertainty assessment, reference is made to section Sensitivity analysis of unobservable inputs (Level 3).
Valuation techniques and range of unobservable inputs (Level 3)
Assets
Liabilities
Valuation techniques
Significant unobservable inputs
Lower range
Upper range
In EUR million
2022
2021
2022
2021
2022
2021
2022
2021
At fair value through profit or loss
Debt securities
3,447
2,643
1
1
Price based
Price (%)
0%
0%
125%
121%
Price (price per share)
208
208
Present value techniques
Credit spread (bps)
60
100
Price (%)
97%
100%
Equity securities
156
134
Price based
Price (price per share)
0
0
5,457
5,475
Loans and advances
1,485
1,598
Price based
Price (%)
0%
0%
100%
100%
Present value techniques
Credit spread (bps)
2
0
12
250
(Reverse) repo's
1,062
650
Present value techniques
Interest rate (%)
3%
0%
5%
1%
Structured notes
3
0
53
135
Price based
Price (%)
84%
84%
107%
125%
Option pricing model
Equity volatility (%)
13%
13%
42%
30%
Equity/Equity correlation
0.5
n.a.
1.0
n.a.
Equity/FX correlation
-0.4
0.0
0.6
0.0
Dividend yield (%)
0%
3%
8%
4%
Present value techniques
Credit spreads (bps)
96
96
Derivatives
\u2013\u00a0\u00a0Rates
431
5
476
35
Option pricing model
Interest rate volatility (bps)
49
43
148
82
Present value techniques
Reset spread (%)
0%
2%
1%
2%
Interest rate (%)
2%
2%
Prepayment rate (%)
5%
13%
\u2013\u00a0\u00a0FX
5
27
4
30
Present value techniques
FX volatility (%)
1%
16%
Option pricing model
Implied volatility (%)
6%
1%
20%
22%
\u2013\u00a0\u00a0Credit
13
75
175
94
Present value techniques
Credit spread (bps)
5
1
623
359
Price based
Price (%)
0%
0%
100%
100%
\u2013\u00a0\u00a0Equity
33
30
22
27
Option pricing model
Equity volatility (%)
0%
11%
77%
119%
Equity/Equity correlation
0.5
0.5
0.9
0.8
Equity/FX correlation
-0.5
-0.7
0.1
0.1
Dividend yield (%)
1%
0%
14%
18%
Price based
Price (%)
n.a
0%
n.a
0%
\u2013\u00a0\u00a0Other
1
3
9
Option pricing model
Commodity volatility (%)
0%
20%
63%
89%
At fair value through other comprehensive income
\u2013\u00a0\u00a0Loans and advances
643
838
Present value techniques
Prepayment rate (%)
6%
9%
6%
9%
Price based
Price (%)
67%
99%
99%
100%
\u2013\u00a0\u00a0Equity
247
225
Present value techniques
Credit spread (bps)
6.7
1.9
6.7
1.9
Interest rate (%)
4%
3%
4%
3%
Price based
Price (%)
n.a
1%
n.a
1%
Price based
Other (EUR)
70
63
90
80
Total
7,526
6,228
732
330
Price
For securities where market prices are not available, fair value is measured by comparison with observable
pricing data from similar instruments. Prices of 0% are distressed to the point that no recovery is expected,
while prices significantly in excess of 100% or par are expected to pay a yield above current market rates.
Credit spreads
Credit spread is the premium above a benchmark interest rate required by the market participant to accept
a lower credit quality. Higher credit spreads indicate lower credit quality and a lower value of an asset.
Volatility
Volatility is a measure for variation of the price of a financial instrument or other valuation input over time.
Volatility is one of the key inputs in option pricing models. Typically, the higher the volatility, the higher
value of the option. Volatility varies by the underlying reference (equity, commodity, foreign currency and
interest rates), by strike, and maturity of the option. The minimum level of volatility is 0% and there is no
theoretical maximum.
Correlation
Correlation is a measure of dependence between two underlying references which is relevant for valuing
derivatives and other instruments having more than one underlying reference. High positive correlation
(close to 1) indicates strong positive (statistical) relationship, where underliers move, everything else equal,
into the same direction. The same holds for a high negative correlation.
Reset spread
Reset spreads are key inputs to mortgage linked prepayment swaps valuation. Reset spread is the future
spread at which mortgages will re-price at interest rate reset dates.
Inflation rate Inflation rate is a key input to inflation linked instruments. Inflation linked instruments protect
against price inflation and are denominated and indexed to investment units. Interest payments would be
based on the inflation index and nominal rate in order to receive/pay the real rate of return. A rise in
nominal coupon payments is a result of an increase in inflation expectations, real rates, or both.
Dividend yield
Dividend yield is an important input for equity option pricing models showing how much dividends a
company is expected to pay out each year relative to its share price. Dividend yields are generally expressed
as an annualised percentage of share price.
Jump rate
Jump rates simulate abrupt changes in valuation models. The rate is an added component to the discount
rate in the model to include default risks.
Prepayment rate
Prepayment rate is a key input to mortgage and loan valuation. Prepayment rate is the estimated rate at
which mortgage borrowers will repay their mortgages early, e.g. 5% per year. Prepayment rate and reset
spread are key inputs to mortgage linked prepayment swaps valuation.
Level 3: Changes during the period
Changes in Level 3 Financial assets
Trading assets
Non-trading
derivatives
Financial assets
mandatorily at FVPL
Financial assets
designated at FVPL
Financial assets at
FVOCI
Total
in EUR million
2022
2021
2022
2021
2022
2021
2022
2021
2022
2021
2022
2021
Opening balance
822
882
1
1
1,862
1,191
2,480
796
1,063
1,231
6,228
4,101
Realised gain/loss\u00a0 recognised in the statement of profit or loss during the period 1
53
22
52
-57
32
122
-80
8
-12
178
-37
Revaluation recognised in other comprehensive income during the period 2
0
-84
22
-84
22
Purchase of assets
694
453
15
3
1,586
1,496
772
1,919
221
165
3,288
4,036
Sale of assets
-49
-48
-4
-3
-669
-612
-191
-141
-275
-234
-1,187
-1,037
Maturity/settlement
-511
-14
-2
-617
-163
-13
-59
-109
-1,188
-299
Reclassifications
0
-18
-5
10
-6
-8
-11
Transfers into Level 3
288
43
474
605
-1
322
-43
-1
1,646
42
Transfers out of Level 3
-442
-517
-115
-1
-856
-98
-1,414
-615
Exchange rate differences
18
0
14
20
-12
49
9
68
29
Changes in the composition of the group and other changes
0
-2
-2
Closing balance
873
822
421
1
1,849
1,862
3,492
2,480
891
1,063
7,526
6,228
i) Financial instruments not measured at fair value
The following table presents the estimated fair values of the financial instruments not measured at fair
value in the statement of financial position. The aggregation of the fair values presented below does not
represent, and should not be construed as representing, the underlying value of ING Bank.
Methods applied in determining fair values of financial assets and liabilities (carried at amortised cost)
Carrying Amount
Carrying amount
approximates fair value
Level 1
Level 2
Level 3
Total fair value
in EUR million
2022
2021
2022
2021
2022
2021
2022
2021
2022
2021
2022
2021
Financial Assets
Loans and advances to banks 1
35,103
23,591
2,858
1,674
1
29,459
17,033
2,786
4,926
35,103
23,634
Loans and advances to customers
635,557
627,550
19,101
16,943
15,264
18,465
575,805
600,253
610,170
635,661
Securities at amortised cost
48,160
48,319
39,787
40,314
3,160
7,327
1,406
681
44,353
48,323
718,820
699,459
21,959
18,617
39,788
40,316
47,883
42,825
579,996
605,860
689,626
707,618
Financial liabilities
Deposits from banks
56,632
85,092
3,696
4,298
48,524
75,847
3,954
5,890
56,174
86,035
Customer deposits
686,341
657,831
590,321
586,151
80,305
61,158
15,511
11,861
686,136
659,171
Debt securities in issue
58,075
57,443
20,308
15,320
20,501
27,718
17,577
14,756
58,385
57,794
Subordinated loans
15,789
16,719
15,548
17,203
15,548
17,203
816,838
817,085
594,016
590,449
20,308
15,321
164,878
181,926
37,041
32,507
816,243
820,203
1 The prior period has been updated to improve consistency and comparability of level 3 and 2.
The following methods and assumptions were used by ING Bank to estimate the fair value of the financial
instruments which are nor recorded and measured at fair value. These fair values were calculated for
disclosure purposes only. The carrying amount of financial instruments presented in the above table
includes the fair value hedge adjustment, this explains why the carrying amount approximates fair value.
Loans and advances to banks
For short term receivables from banks carrying amounts represent a reasonable estimate of the fair value.
The fair value of long term receivables from banks is estimated by discounting expected future cash flows
using a discount rate based on specific available market data, such as interest rates and appropriate
spreads that reflects current credit risk or quoted bonds.
Loans and advances to customers
For short term loans carrying amounts represent a reasonable estimate of the fair value. The fair value of
long term loans is estimated by discounting expected future cash flows using a discount rate that reflects
current credit risk, current interest rates, and other current market conditions where applicable. The fair
value of mortgage loans is estimated by taking into account prepayment behaviour. Loans with similar
characteristics are aggregated for calculation purposes.
Deposits from banks
For short term payables to banks carrying amounts represent a reasonable estimate of the fair value. The
fair value of long term payables to banks is estimated by discounting expected future cash flows using a
discount rate based on available market interest rates and appropriate spreads that reflects ING\u2019s own
credit risk.
Customer deposits
The carrying values of customer deposits with an immediate on demand features approximate their fair
values. The fair values of deposits with fixed contractual terms have been estimated based on discounting
future cash flows using the interest rates currently applicable to deposits of similar maturities.
Debt securities in issue
The fair value of debt securities in issue is generally based on quoted market prices, or if not available, on
estimated prices by discounting expected future cash flows using a current market interest rate and credit
spreads applicable to the yield, credit quality and maturity.
Subordinated loans
The fair value of publicly traded subordinated loans are based on quoted market prices when available.
Where no quoted market prices are available, fair value of the subordinated loans is estimated using
discounted cash flows based on interest rates and credit spreads that apply to similar instruments.
", "dimensions": { "concept": "ifrs-full:DisclosureOfAssetsAndLiabilitiesWithSignificantRiskOfMaterialAdjustmentExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2NzcwNTMzMw_c5ad4aa9-3559-44b4-975a-a320f52a3e5e": { "value": "
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 \u2018Day One Profit or Loss\u2019) is deferred. ING Bank 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 Bank recognises the difference as a gain
or loss at inception.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForRecognisingDifferenceBetweenFairValueAtInitialRecognitionAndAmountDeterminedUsingValuationTechniqueExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzc5_e233d1d6-b3d2-45c8-a66d-76e859705bd7": { "value": "Significant judgements and critical accounting estimates and assumptions: \u2022Even 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.\u00a0 \u2022Valuation 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.\u00a0 \u2022Price 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. \u2022Assessing whether a market is active, and whether an input is observable and significant, requires judgement. ING Bank 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. \u2022Reference is made to Note 35 'Fair value of assets and liabilities ' and to the \u2018Market risk\u2019 paragraph in the \u2018Risk management\u2019 section of the Annual Report for the basis of the determination of the fair value of financial instruments and related sensitivities.Significant judgements and critical accounting estimates and assumptions:Considerable management judgement is exercised in determining the amount of ECL for financial assets assessed on both a collective and an individual basis. In particular, this judgement requires ING Bank to make various assumptions about the risk of default, the credit loss rates in case of a default and expected future cash flows. These assumptions are based on a combination of ING Bank\u2019s past history, existing market conditions and forward-looking estimates at the end of each reporting period. Changes in these assumptions may lead to changes in the ECL over time. Given they are subjective and complex in nature, and because the ECL and the underlying exposures subject to ECL are material, these assumptions are considered critical accounting assumptions. The sensitivity of these assumptions is assessed in the credit risk section of the \u2018Risk Management\u2019 section in the Annual Report.\u2022The use of forward-looking macroeconomic scenarios in both collective and individual impairment assessmentsForward-looking macroeconomic scenarios are uncertain in nature. The process ING Bank follows involves two internal groups, the Macroeconomics Scenarios Team and the Macroeconomics Scenarios Expert Panel. The latter team consists of senior management representatives from the Business, Risk and Finance. These groups review inputs obtained from a third party provider and subject these to internal expert challenge to ensure the inputs used in the models reflect ING Bank\u2019s view on the macro economy. The use of alternate forward-looking macroeconomic scenarios can produce significantly different estimates of ECL. This is demonstrated in the sensitivity analysis in the \u2018Risk Management\u2019 section of the Annual Report, where the un-weighted ECL under each of the three scenarios for some significant portfolios is disclosed.\u2022The probability weights applied to each of the three scenariosING Bank uses three macroeconomic scenarios when determining IFRS 9 ECL (baseline, upside and downside). Management judgement is applied in the design of the approach used to determine the weights of each scenario and in selecting the parts of the distribution of forecast errors from which the weights are derived. Reference is made to the \u2018Alternative scenarios and probability weights\u2019 and the sensitivity analysis in the \u2018Risk Management\u2019 section of the Annual Report for further details.\u2022The criteria for identifying a significant increase in credit riskWhen determining whether the credit risk on a financial asset has increased significantly, ING Bank\u00a0 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\u2019s 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 constitute a significant judgement. Analysis of the sensitivity associated with the assessment of significant increase in credit risk is presented in the \u2018Risk Management\u2019 section of the Annual Report. \u2022The definition of defaultJudgement is exercised in management\u2019s evaluation of whether there is objective evidence that larger exposures are credit-impaired. Management judgement is required in assessing evidence of credit-impairment.\u2022Management adjustments applied as at 31 December 2022To reflect the risks that are not properly captured by the ECL models, a number of management adjustments to the model-based ECL were necessary as at 31 December 2022. Reference is made to the \u2018Management adjustments applied this year\u2019 paragraph in the \u2018Risk management\u2019 section of the Annual Report.Significant judgements:Significant management judgement is exercised in determining the accounting treatment of TLTRO transactions. In particular, ING Bank\u00a0 applied judgement in:\u2022assessing and concluding that in ING Bank'\u2019s view the rate under TLTRO is considered to be a market conforming rate and, hence, accounting for TLTRO in accordance with IFRS 9; and\u2022selecting accounting policies regarding the calculation of the effective interest rate under TLTRO. Treatment of changes in expectations of meeting the lending targets was an area of significant judgment in the comparative periods but no longer relevant in 2022.Significant judgements and critical accounting estimates and assumptions:The most significant estimates and assumptions relate to the assessment of (reversal of) impairment of the investment in TMBThanachart Bank Public Company Limited (hereafter: TTB) which involves estimation of value in use.Management's best estimate of the expected future earnings of TTB is based on forecasts derived from broker consensus over the short to medium term and reasonable and supportable assumptions capturing a combination of TTB specific and market data points for longer term and steady state expectations into perpetuity. A capital maintenance charge is applied, which is management\u2019s forecast of the earnings that need to be withheld in order for TTB to meet target regulatory requirements over the forecast period. Both of these factors are subject to a high degree of uncertainty. Key assumptions used in estimating TTB\u2019s value in use and the sensitivity of the value in use calculations to different assumptions are described in note 8 \u2018Investments in associates and joint ventures\u2019.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 Bank\u00a0 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 Bank 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 Bank consults with internal and external legal experts. Even taking into consideration legal experts\u2019 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'.", "dimensions": { "concept": "ifrs-full:ExplanationOfAssumptionAboutFutureWithSignificantRiskOfResultingInMaterialAdjustments", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzY4_c9da5c79-55b4-44cb-9fd1-470d509684da": { "value": "
1.7.4\u00a0 Derivatives and hedge accounting
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 Bank decided to exercise this accounting policy choice
and did not adopt IFRS 9 hedge accounting as of 1 January 2018. Furthermore, ING Bank applies fair value
hedge accounting for portfolio hedges of interest rate risk (macro fair value hedges) in accordance with the
EU carve-out version of IAS 39.
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 and 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 Bank\u2019s risk management strategy.
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 Bank 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 Bank documents the relationship between hedging instruments and
hedged items, its risk management objective, together with the methods selected to assess hedge
effectiveness. ING Bank 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.
IBOR Transition - specific policies applicable from 1 January 2019 for hedges directly
affected by IBOR reform
As further explained in the \u2018IBOR Transition\u2019 paragraph of the \u2018Risk management\u2019 section, the financial
markets are going through a significant reform of interbank offered rates (IBOR) and financial institutions
are obligated to implement a replacement of major interest rate reference rates.
Given that IBOR reform may have various accounting implications, the International Accounting Standards
Board (IASB) has undertaken a two phase project. Phase 1 addresses those issues that affect financial
reporting before the replacement of an existing benchmark. Phase 1 amendments to IFRS were issued by
the IASB in 2019. Phase 2 focuses on issues that may affect financial reporting when the existing benchmark
rate is reformed or replaced. Phase 2 amendments to IFRS were issued by the IASB in 2020.
Phase 1 amendments to IFRS allow ING Bank to apply a set of temporary exceptions to continue hedge
accounting even when there is uncertainty about contractual cash flows arising from the reform. Under
these temporary exceptions, interbank offered rates are assumed to continue unaltered for the purposes of
hedge accounting until such time as the uncertainty is resolved.
More specifically, the following temporary reliefs are part of the Phase 1 amendments:
\u2022Highly probable requirement for cash flow hedges
When determining whether a forecast transaction is highly probable, it is assumed that the interest rate
benchmark on which the hedged cash flows are based is not altered as a result of the reform.
\u2022Prospective assessment of hedge effectiveness
When performing the prospective assessment it is assumed that the interest rate benchmark on which
the hedged cash flows are based is not altered as a result of the reform.
\u2022Retrospective assessment of hedge effectiveness
When performing the retrospective assessment hedges are allowed to pass the assessment even if
actual results are outside the 80-125% range, during the period of uncertainty arising from the IBOR
reform.
\u2022Designation of a component of an item as a hedged item
For hedges of the benchmark component of interest rate risk affected by the reform, the separately
identifiable requirement only needs to be demonstrated at the inception of such hedging relationships
(including macro hedges).
The amendments are relevant given that ING Bank hedges and applies hedge accounting to benchmark
interest rate exposure part of IBOR reform. ING Bank hedges are being progressively amended, where
necessary, to incorporate the new benchmark rates. Temporary exceptions under Phase 1 continued to be
relevant for ING Bank as at 31 December 2022 (for USD and WIBOR).
ING Bank will completely cease to apply the amendments when this uncertainty is no longer present or
when the hedging relationship is discontinued. Refer to Note 36 'Derivatives and hedge accounting' for the
disclosures relating to the application of the amendments as part of Phase 1. Refer to note \u2018Risk
management/ IBOR Transition\u2019 for more information regarding the end of Phase 1 reliefs for ING Bank\u2019s
hedging relationships.
Phase 2 amendments require that hedge accounting continues on transition to risk free rates provided that
the modifications made to financial instruments are those necessary to implement the IBOR Reform and
that the new basis for calculating cash flows is \u2018economically equivalent\u2019 to the previous basis. Particularly,\u00a0
Phase 2 amendments allow the continuation of hedging relationships, subject to amending their
documentation to reflect changes in hedged instruments, hedging instruments, hedged risk, and/or the
method for measuring effectiveness during the transition to the new benchmark rates. During 2022, Phase 2
continued to be relevant for ING Bank when ING actually transitioned its financial instruments (designated in
hedge accounting relationships) to the new benchmark rates (mainly, USD LIBOR).
More specifically, the following temporary reliefs are part of the Phase 2 amendments:
Relief from discontinuing hedging relationships
\u2022Amendments in the hedge documentation as a consequence of changes required by the IBOR reform do
not result in the discontinuation of the hedge relationship nor the designation of a new hedge
relationship. The changes can be in form of designating an alternative benchmark rate as a hedged risk,
the description of the hedging instrument, the description of the hedged item, or the method to measure
the effectiveness.
\u2022When the hedged item is amended as a consequence of the IBOR reform (or if the hedge has previously
been discontinued), amounts accumulated in the cash flow hedge reserve are deemed to be based on
the Risk-Free Rate (RFR). This results in the release of the cash flow hedge reserve to profit or loss in the
same period or periods in which the hedged cash flows that are now based on the RFR affect profit or
loss.
\u2022When the items within a designated group of hedged items are amended as a consequence of the IBOR
reform, the hedging strategy remains and is not discontinued. As items within the hedged group
transition at different times from IBORs to RFRs, they are transferred to sub-groups of instruments that
reference RFRs as the hedged risk. The existing IBORs remain designated as the hedged risk for the other
sub-group of hedged items, until they are also updated to reference the new RFR. The usual hedge
accounting requirements are applied to the hedge relationship in its entirety.
\u2022For the assessment of retrospective hedge effectiveness, the cumulative fair value changes may be reset
to zero when the exception to the retrospective assessment of the Phase 1 reliefs ends. This election is
made separately for each hedging relationship (i.e., on a hedge-by-hedge basis).
\u2022Temporary relief from having to meet the separately identifiable requirement: a RFR is considered a
separately identifiable risk component if it is reasonably expected to meet the separately identifiable
requirement within 24 months from the date it is first designated as a non-contractually specified risk
component (i.e. when the entity first designates the RFR as a non-contractually specified risk
component). This relief applies to each RFR on a rate-by-rate basis.
Non-trading derivatives that do not qualify for hedge accounting
Derivative instruments that are used by ING Bank as part of its risk management strategies, but which do
not qualify for hedge accounting under ING Bank\u2019s 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.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForDerivativeFinancialInstrumentsAndHedgingExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzY4_d6b6f92c-92fc-493e-bd85-2b7b92c96f84": { "value": "
1.7.4\u00a0 Derivatives and hedge accounting
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 Bank decided to exercise this accounting policy choice
and did not adopt IFRS 9 hedge accounting as of 1 January 2018. Furthermore, ING Bank applies fair value
hedge accounting for portfolio hedges of interest rate risk (macro fair value hedges) in accordance with the
EU carve-out version of IAS 39.
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 and 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 Bank\u2019s risk management strategy.
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 Bank 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 Bank documents the relationship between hedging instruments and
hedged items, its risk management objective, together with the methods selected to assess hedge
effectiveness. ING Bank 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.
IBOR Transition - specific policies applicable from 1 January 2019 for hedges directly
affected by IBOR reform
As further explained in the \u2018IBOR Transition\u2019 paragraph of the \u2018Risk management\u2019 section, the financial
markets are going through a significant reform of interbank offered rates (IBOR) and financial institutions
are obligated to implement a replacement of major interest rate reference rates.
Given that IBOR reform may have various accounting implications, the International Accounting Standards
Board (IASB) has undertaken a two phase project. Phase 1 addresses those issues that affect financial
reporting before the replacement of an existing benchmark. Phase 1 amendments to IFRS were issued by
the IASB in 2019. Phase 2 focuses on issues that may affect financial reporting when the existing benchmark
rate is reformed or replaced. Phase 2 amendments to IFRS were issued by the IASB in 2020.
Phase 1 amendments to IFRS allow ING Bank to apply a set of temporary exceptions to continue hedge
accounting even when there is uncertainty about contractual cash flows arising from the reform. Under
these temporary exceptions, interbank offered rates are assumed to continue unaltered for the purposes of
hedge accounting until such time as the uncertainty is resolved.
More specifically, the following temporary reliefs are part of the Phase 1 amendments:
\u2022Highly probable requirement for cash flow hedges
When determining whether a forecast transaction is highly probable, it is assumed that the interest rate
benchmark on which the hedged cash flows are based is not altered as a result of the reform.
\u2022Prospective assessment of hedge effectiveness
When performing the prospective assessment it is assumed that the interest rate benchmark on which
the hedged cash flows are based is not altered as a result of the reform.
\u2022Retrospective assessment of hedge effectiveness
When performing the retrospective assessment hedges are allowed to pass the assessment even if
actual results are outside the 80-125% range, during the period of uncertainty arising from the IBOR
reform.
\u2022Designation of a component of an item as a hedged item
For hedges of the benchmark component of interest rate risk affected by the reform, the separately
identifiable requirement only needs to be demonstrated at the inception of such hedging relationships
(including macro hedges).
The amendments are relevant given that ING Bank hedges and applies hedge accounting to benchmark
interest rate exposure part of IBOR reform. ING Bank hedges are being progressively amended, where
necessary, to incorporate the new benchmark rates. Temporary exceptions under Phase 1 continued to be
relevant for ING Bank as at 31 December 2022 (for USD and WIBOR).
ING Bank will completely cease to apply the amendments when this uncertainty is no longer present or
when the hedging relationship is discontinued. Refer to Note 36 'Derivatives and hedge accounting' for the
disclosures relating to the application of the amendments as part of Phase 1. Refer to note \u2018Risk
management/ IBOR Transition\u2019 for more information regarding the end of Phase 1 reliefs for ING Bank\u2019s
hedging relationships.
Phase 2 amendments require that hedge accounting continues on transition to risk free rates provided that
the modifications made to financial instruments are those necessary to implement the IBOR Reform and
that the new basis for calculating cash flows is \u2018economically equivalent\u2019 to the previous basis. Particularly,\u00a0
Phase 2 amendments allow the continuation of hedging relationships, subject to amending their
documentation to reflect changes in hedged instruments, hedging instruments, hedged risk, and/or the
method for measuring effectiveness during the transition to the new benchmark rates. During 2022, Phase 2
continued to be relevant for ING Bank when ING actually transitioned its financial instruments (designated in
hedge accounting relationships) to the new benchmark rates (mainly, USD LIBOR).
More specifically, the following temporary reliefs are part of the Phase 2 amendments:
Relief from discontinuing hedging relationships
\u2022Amendments in the hedge documentation as a consequence of changes required by the IBOR reform do
not result in the discontinuation of the hedge relationship nor the designation of a new hedge
relationship. The changes can be in form of designating an alternative benchmark rate as a hedged risk,
the description of the hedging instrument, the description of the hedged item, or the method to measure
the effectiveness.
\u2022When the hedged item is amended as a consequence of the IBOR reform (or if the hedge has previously
been discontinued), amounts accumulated in the cash flow hedge reserve are deemed to be based on
the Risk-Free Rate (RFR). This results in the release of the cash flow hedge reserve to profit or loss in the
same period or periods in which the hedged cash flows that are now based on the RFR affect profit or
loss.
\u2022When the items within a designated group of hedged items are amended as a consequence of the IBOR
reform, the hedging strategy remains and is not discontinued. As items within the hedged group
transition at different times from IBORs to RFRs, they are transferred to sub-groups of instruments that
reference RFRs as the hedged risk. The existing IBORs remain designated as the hedged risk for the other
sub-group of hedged items, until they are also updated to reference the new RFR. The usual hedge
accounting requirements are applied to the hedge relationship in its entirety.
\u2022For the assessment of retrospective hedge effectiveness, the cumulative fair value changes may be reset
to zero when the exception to the retrospective assessment of the Phase 1 reliefs ends. This election is
made separately for each hedging relationship (i.e., on a hedge-by-hedge basis).
\u2022Temporary relief from having to meet the separately identifiable requirement: a RFR is considered a
separately identifiable risk component if it is reasonably expected to meet the separately identifiable
requirement within 24 months from the date it is first designated as a non-contractually specified risk
component (i.e. when the entity first designates the RFR as a non-contractually specified risk
component). This relief applies to each RFR on a rate-by-rate basis.
Non-trading derivatives that do not qualify for hedge accounting
Derivative instruments that are used by ING Bank as part of its risk management strategies, but which do
not qualify for hedge accounting under ING Bank\u2019s 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.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForDerivativeFinancialInstrumentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMjMwODk3NDQzOTgwOTY_c2672e15-a62d-4070-b277-cee1f750b589": { "value": "
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.
IBOR Transition - specific policies applicable from 1 January 2019 for hedges directly
affected by IBOR reform
As further explained in the \u2018IBOR Transition\u2019 paragraph of the \u2018Risk management\u2019 section, the financial
markets are going through a significant reform of interbank offered rates (IBOR) and financial institutions
are obligated to implement a replacement of major interest rate reference rates.
Given that IBOR reform may have various accounting implications, the International Accounting Standards
Board (IASB) has undertaken a two phase project. Phase 1 addresses those issues that affect financial
reporting before the replacement of an existing benchmark. Phase 1 amendments to IFRS were issued by
the IASB in 2019. Phase 2 focuses on issues that may affect financial reporting when the existing benchmark
rate is reformed or replaced. Phase 2 amendments to IFRS were issued by the IASB in 2020.
Phase 1 amendments to IFRS allow ING Bank to apply a set of temporary exceptions to continue hedge
accounting even when there is uncertainty about contractual cash flows arising from the reform. Under
these temporary exceptions, interbank offered rates are assumed to continue unaltered for the purposes of
hedge accounting until such time as the uncertainty is resolved.
More specifically, the following temporary reliefs are part of the Phase 1 amendments:
\u2022Highly probable requirement for cash flow hedges
When determining whether a forecast transaction is highly probable, it is assumed that the interest rate
benchmark on which the hedged cash flows are based is not altered as a result of the reform.
\u2022Prospective assessment of hedge effectiveness
When performing the prospective assessment it is assumed that the interest rate benchmark on which
the hedged cash flows are based is not altered as a result of the reform.
\u2022Retrospective assessment of hedge effectiveness
When performing the retrospective assessment hedges are allowed to pass the assessment even if
actual results are outside the 80-125% range, during the period of uncertainty arising from the IBOR
reform.
\u2022Designation of a component of an item as a hedged item
For hedges of the benchmark component of interest rate risk affected by the reform, the separately
identifiable requirement only needs to be demonstrated at the inception of such hedging relationships
(including macro hedges).
The amendments are relevant given that ING Bank hedges and applies hedge accounting to benchmark
interest rate exposure part of IBOR reform. ING Bank hedges are being progressively amended, where
necessary, to incorporate the new benchmark rates. Temporary exceptions under Phase 1 continued to be
relevant for ING Bank as at 31 December 2022 (for USD and WIBOR).
ING Bank will completely cease to apply the amendments when this uncertainty is no longer present or
when the hedging relationship is discontinued. Refer to Note 36 'Derivatives and hedge accounting' for the
disclosures relating to the application of the amendments as part of Phase 1. Refer to note \u2018Risk
management/ IBOR Transition\u2019 for more information regarding the end of Phase 1 reliefs for ING Bank\u2019s
hedging relationships.
Phase 2 amendments require that hedge accounting continues on transition to risk free rates provided that
the modifications made to financial instruments are those necessary to implement the IBOR Reform and
that the new basis for calculating cash flows is \u2018economically equivalent\u2019 to the previous basis. Particularly,\u00a0
Phase 2 amendments allow the continuation of hedging relationships, subject to amending their
documentation to reflect changes in hedged instruments, hedging instruments, hedged risk, and/or the
method for measuring effectiveness during the transition to the new benchmark rates. During 2022, Phase 2
continued to be relevant for ING Bank when ING actually transitioned its financial instruments (designated in
hedge accounting relationships) to the new benchmark rates (mainly, USD LIBOR).
More specifically, the following temporary reliefs are part of the Phase 2 amendments:
Relief from discontinuing hedging relationships
\u2022Amendments in the hedge documentation as a consequence of changes required by the IBOR reform do
not result in the discontinuation of the hedge relationship nor the designation of a new hedge
relationship. The changes can be in form of designating an alternative benchmark rate as a hedged risk,
the description of the hedging instrument, the description of the hedged item, or the method to measure
the effectiveness.
\u2022When the hedged item is amended as a consequence of the IBOR reform (or if the hedge has previously
been discontinued), amounts accumulated in the cash flow hedge reserve are deemed to be based on
the Risk-Free Rate (RFR). This results in the release of the cash flow hedge reserve to profit or loss in the
same period or periods in which the hedged cash flows that are now based on the RFR affect profit or
loss.
\u2022When the items within a designated group of hedged items are amended as a consequence of the IBOR
reform, the hedging strategy remains and is not discontinued. As items within the hedged group
transition at different times from IBORs to RFRs, they are transferred to sub-groups of instruments that
reference RFRs as the hedged risk. The existing IBORs remain designated as the hedged risk for the other
sub-group of hedged items, until they are also updated to reference the new RFR. The usual hedge
accounting requirements are applied to the hedge relationship in its entirety.
\u2022For the assessment of retrospective hedge effectiveness, the cumulative fair value changes may be reset
to zero when the exception to the retrospective assessment of the Phase 1 reliefs ends. This election is
made separately for each hedging relationship (i.e., on a hedge-by-hedge basis).
\u2022Temporary relief from having to meet the separately identifiable requirement: a RFR is considered a
separately identifiable risk component if it is reasonably expected to meet the separately identifiable
requirement within 24 months from the date it is first designated as a non-contractually specified risk
component (i.e. when the entity first designates the RFR as a non-contractually specified risk
component). This relief applies to each RFR on a rate-by-rate basis.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForHedgingExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMjE5OTAyMzI3NzAyODk_b75daf56-8375-4fea-b74f-adb488cd32ef": { "value": "
1.7.5\u00a0 Offsetting of financial assets and financial liabilities
Financial assets and financial liabilities are offset, and the net amount is reported in the statement of
financial position when ING Bank 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 certain interest rate swaps for which the services of a central clearing house are
used.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForOffsettingOfFinancialInstrumentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMjMwODk3NDQzOTgwOTc_9b26602d-ec9b-486c-8a01-9d0dc143b39d": { "value": "
1.7.6\u00a0 Repurchase transactions and reverse repurchase transactions
Securities sold subject to repurchase agreements (repos), securities lending and similar agreements
continue to be recognised in the Consolidated statement of financial position. The counterparty liability is
measured at FVPL (designated) and included in Other financial liabilities at FVPL if the asset is measured at
FVPL. Otherwise, the counterparty liability is included in Deposits from banks, Customer deposits, or Trading,
as appropriate.
Securities purchased under agreements to resell (reverse repos), securities borrowings and similar
agreements are not recognised in the Consolidated statement of financial position. The consideration paid
to purchase securities is recognised as Loans and advances to customers, Loans and advances to banks,
Other financial assets at FVPL or Trading assets, as appropriate. The difference between the sale and
repurchase price is treated as interest and amortised over the life of the agreement using the effective
interest method for instruments that are not measured at FVPL.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForRepurchaseAndReverseRepurchaseAgreementsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzcz_171d76ab-f216-4c58-982a-03ea336e5555": { "value": "
1.7.8Impairment of financial assets
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 Bank calculates the expected credit losses (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. ING Bank\u2019s approach leverages the Advanced Internal Ratings Based (AIRB)
models that are used for regulatory purposes. Adjustments are applied to make these models suitable for
determining ECL. 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:
\u2022Stage 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);
\u2022Stage 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
\u2022Stage 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 Bank 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.
The main determinate of SICR is a quantitative test, whereby the lifetime Probability of Default (PD) of an
asset at each reporting date is compared against its lifetime PD determined at the date of initial recognition.
If the delta is above pre-defined absolute or relative thresholds the item is considered to have experienced a
SICR. Furthermore, any facility which shows an increase of 200% 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. Refer to \u2018Criteria for
identifying a significant increase in credit risk\u2019 in the \u2018Risk Management\u2019 section of the Annual Report for
more details on relative and absolute PD thresholds, including quantitative disclosures on those thresholds.
Consequently, if the above quantitative SICR thresholds are exceeded, the item moves from Stage 1 to Stage
2 (unless the item is credit-impaired). In these instances, items are no longer assigned a 12 month ECL and
instead are assigned a lifetime ECL. Items can return to Stage 1 if there is sufficient evidence that there is no
longer a significant increase in credit risk.
ING Bank also relies on a number of qualitative indicators to identify and assess SICR. These include:
\u2022Forbearance status;
\u2022Watch List status;
\u2022Intensive care management;
\u2022Collective SICR assessment;
\u2022Substandard Internal rating; and
\u2022Arrears status (including 30 days past due used as a backstop).
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 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 Bank 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 Bank has established a quarterly process whereby forward-looking macroeconomics scenarios and
probability weightings are developed for the purpose of ECL. ING Bank applies data predominantly from a
leading service provider (Oxford Economics (OE))\u00a0 enriched with the internal ING Bank view. A baseline, up-
scenario and a down-scenario are determined to reflect an unbiased and probability-weighted ECL amount.
As a baseline scenario, ING Bank 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.
Measurement of ECL
ING Bank 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 Bank 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 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\u2019 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 purpose of ECL, ING Bank\u2019s 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 Bank 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 Bank\u2019s 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 others, 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 is no longer recognised based on the accrual income
based on the gross carrying amount of the asset. Rather, interest income is calculated by applying the
original EIR to the AC 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 even if the lifetime ECL at the reporting date is lower than the estimated lifetime ECL at
origination.
Modifications
In certain circumstances ING Bank 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 is executed based on credit concerns it is also referred to as forbearance (refer to the \u2018Risk
Management\u2019 section of the Annual Report for more details). In such cases, the net present value of the
postponement, reduction of loan principal and/or interest payments is taken into account in the
determination of the appropriate level of ECL. If the forbearance 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. ING Bank determines whether there has been a substantial modification using both
quantitative and qualitative factors.
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:
\u2022After a restructuring has been completed and there is a high improbability of recovery of part of the
remaining loan exposure (including partial debt forgiveness);
\u2022In a bankruptcy liquidation scenario;
\u2022After divestment or sale of a credit facility at a discount;
\u2022Specific 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 \u2018Addition to loan loss provisions\u2019 in the Consolidated
statement of profit or loss..
Debt forgiveness (or debt settlement) involves write-off but additionally involves the forgiveness of a legal
obligation, in whole or in part. This means that ING Bank forfeits the legal right to recover the debt. As a
result, the financial asset needs to be derecognised. Distinction is made in situations where ING Bank ends
the relationship with the client and situations where ING Bank (partially) continues the financing of the
client.
Presentation of ECL
ECL for financial assets measured at AC are deducted from the gross carrying amount of the assets. For
debt instruments at FVOCI, the ECL is recognised in OCI, instead of deducted 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, are 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:
Considerable management judgement is exercised in determining the amount of ECL for financial assets
assessed on both a collective and an individual basis. In particular, this judgement requires ING Bank to
make various assumptions about the risk of default, the credit loss rates in case of a default and expected
future cash flows. These assumptions are based on a combination of ING Bank\u2019s past history, existing
market conditions and forward-looking estimates at the end of each reporting period. Changes in these
assumptions may lead to changes in the ECL over time. Given they are subjective and complex in nature,
and because the ECL and the underlying exposures subject to ECL are material, these assumptions are
considered critical accounting assumptions. The sensitivity of these assumptions is assessed in the credit
risk section of the \u2018Risk Management\u2019 section in the Annual Report.
\u2022The use of forward-looking macroeconomic scenarios in both collective and individual impairment
assessments
Forward-looking macroeconomic scenarios are uncertain in nature. The process ING Bank follows involves
two internal groups, the Macroeconomics Scenarios Team and the Macroeconomics Scenarios Expert
Panel. The latter team consists of senior management representatives from the Business, Risk and
Finance. These groups review inputs obtained from a third party provider and subject these to internal
expert challenge to ensure the inputs used in the models reflect ING Bank\u2019s view on the macro economy.
The use of alternate forward-looking macroeconomic scenarios can produce significantly different
estimates of ECL. This is demonstrated in the sensitivity analysis in the \u2018Risk Management\u2019 section of the
Annual Report, where the un-weighted ECL under each of the three scenarios for some significant
portfolios is disclosed.
\u2022The probability weights applied to each of the three scenarios
ING Bank uses three macroeconomic scenarios when determining IFRS 9 ECL (baseline, upside and
downside). Management judgement is applied in the design of the approach used to determine the
weights of each scenario and in selecting the parts of the distribution of forecast errors from which the
weights are derived. Reference is made to the \u2018Alternative scenarios and probability weights\u2019 and the
sensitivity analysis in the \u2018Risk Management\u2019 section of the Annual Report for further details.
\u2022The criteria for identifying a significant increase in credit risk
When determining whether the credit risk on a financial asset has increased significantly, ING Bank\u00a0
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\u2019s 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 constitute a significant judgement. Analysis
of the sensitivity associated with the assessment of significant increase in credit risk is presented in the
\u2018Risk Management\u2019 section of the Annual Report.
\u2022The definition of default
Judgement is exercised in management\u2019s evaluation of whether there is objective evidence that larger
exposures are credit-impaired. Management judgement is required in assessing evidence of credit-
impairment.
\u2022Management adjustments applied as at 31 December 2022
To reflect the risks that are not properly captured by the ECL models, a number of management
adjustments to the model-based ECL were necessary as at 31 December 2022. Reference is made to the
\u2018Management adjustments applied this year\u2019 paragraph in the \u2018Risk management\u2019 section of the Annual
Report.
Impairment of goodwill and other non-financial assets
ING Bank 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. The carrying value is
determined on a basis that is consistent with the way in which the recoverable amount of the CGU is
determined. The recoverable amount is estimated as the higher of fair value less costs of disposal and value
in use. Impairment of goodwill, if applicable, is included in the statement of profit or loss in Other operating
expenses and is not subsequently reversed.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForImpairmentOfAssetsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzcz_b871838c-a74e-4091-b34c-e12a6ffd7c8a": { "value": "
1.7.8Impairment of financial assets
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 Bank calculates the expected credit losses (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. ING Bank\u2019s approach leverages the Advanced Internal Ratings Based (AIRB)
models that are used for regulatory purposes. Adjustments are applied to make these models suitable for
determining ECL. 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:
\u2022Stage 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);
\u2022Stage 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
\u2022Stage 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 Bank 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.
The main determinate of SICR is a quantitative test, whereby the lifetime Probability of Default (PD) of an
asset at each reporting date is compared against its lifetime PD determined at the date of initial recognition.
If the delta is above pre-defined absolute or relative thresholds the item is considered to have experienced a
SICR. Furthermore, any facility which shows an increase of 200% 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. Refer to \u2018Criteria for
identifying a significant increase in credit risk\u2019 in the \u2018Risk Management\u2019 section of the Annual Report for
more details on relative and absolute PD thresholds, including quantitative disclosures on those thresholds.
Consequently, if the above quantitative SICR thresholds are exceeded, the item moves from Stage 1 to Stage
2 (unless the item is credit-impaired). In these instances, items are no longer assigned a 12 month ECL and
instead are assigned a lifetime ECL. Items can return to Stage 1 if there is sufficient evidence that there is no
longer a significant increase in credit risk.
ING Bank also relies on a number of qualitative indicators to identify and assess SICR. These include:
\u2022Forbearance status;
\u2022Watch List status;
\u2022Intensive care management;
\u2022Collective SICR assessment;
\u2022Substandard Internal rating; and
\u2022Arrears status (including 30 days past due used as a backstop).
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 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 Bank 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 Bank has established a quarterly process whereby forward-looking macroeconomics scenarios and
probability weightings are developed for the purpose of ECL. ING Bank applies data predominantly from a
leading service provider (Oxford Economics (OE))\u00a0 enriched with the internal ING Bank view. A baseline, up-
scenario and a down-scenario are determined to reflect an unbiased and probability-weighted ECL amount.
As a baseline scenario, ING Bank 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.
Measurement of ECL
ING Bank 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 Bank 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 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\u2019 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 purpose of ECL, ING Bank\u2019s 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 Bank 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 Bank\u2019s 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 others, 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 is no longer recognised based on the accrual income
based on the gross carrying amount of the asset. Rather, interest income is calculated by applying the
original EIR to the AC 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 even if the lifetime ECL at the reporting date is lower than the estimated lifetime ECL at
origination.
Modifications
In certain circumstances ING Bank 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 is executed based on credit concerns it is also referred to as forbearance (refer to the \u2018Risk
Management\u2019 section of the Annual Report for more details). In such cases, the net present value of the
postponement, reduction of loan principal and/or interest payments is taken into account in the
determination of the appropriate level of ECL. If the forbearance 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. ING Bank determines whether there has been a substantial modification using both
quantitative and qualitative factors.
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:
\u2022After a restructuring has been completed and there is a high improbability of recovery of part of the
remaining loan exposure (including partial debt forgiveness);
\u2022In a bankruptcy liquidation scenario;
\u2022After divestment or sale of a credit facility at a discount;
\u2022Specific 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 \u2018Addition to loan loss provisions\u2019 in the Consolidated
statement of profit or loss..
Debt forgiveness (or debt settlement) involves write-off but additionally involves the forgiveness of a legal
obligation, in whole or in part. This means that ING Bank forfeits the legal right to recover the debt. As a
result, the financial asset needs to be derecognised. Distinction is made in situations where ING Bank ends
the relationship with the client and situations where ING Bank (partially) continues the financing of the
client.
Presentation of ECL
ECL for financial assets measured at AC are deducted from the gross carrying amount of the assets. For
debt instruments at FVOCI, the ECL is recognised in OCI, instead of deducted 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, are 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:
Considerable management judgement is exercised in determining the amount of ECL for financial assets
assessed on both a collective and an individual basis. In particular, this judgement requires ING Bank to
make various assumptions about the risk of default, the credit loss rates in case of a default and expected
future cash flows. These assumptions are based on a combination of ING Bank\u2019s past history, existing
market conditions and forward-looking estimates at the end of each reporting period. Changes in these
assumptions may lead to changes in the ECL over time. Given they are subjective and complex in nature,
and because the ECL and the underlying exposures subject to ECL are material, these assumptions are
considered critical accounting assumptions. The sensitivity of these assumptions is assessed in the credit
risk section of the \u2018Risk Management\u2019 section in the Annual Report.
\u2022The use of forward-looking macroeconomic scenarios in both collective and individual impairment
assessments
Forward-looking macroeconomic scenarios are uncertain in nature. The process ING Bank follows involves
two internal groups, the Macroeconomics Scenarios Team and the Macroeconomics Scenarios Expert
Panel. The latter team consists of senior management representatives from the Business, Risk and
Finance. These groups review inputs obtained from a third party provider and subject these to internal
expert challenge to ensure the inputs used in the models reflect ING Bank\u2019s view on the macro economy.
The use of alternate forward-looking macroeconomic scenarios can produce significantly different
estimates of ECL. This is demonstrated in the sensitivity analysis in the \u2018Risk Management\u2019 section of the
Annual Report, where the un-weighted ECL under each of the three scenarios for some significant
portfolios is disclosed.
\u2022The probability weights applied to each of the three scenarios
ING Bank uses three macroeconomic scenarios when determining IFRS 9 ECL (baseline, upside and
downside). Management judgement is applied in the design of the approach used to determine the
weights of each scenario and in selecting the parts of the distribution of forecast errors from which the
weights are derived. Reference is made to the \u2018Alternative scenarios and probability weights\u2019 and the
sensitivity analysis in the \u2018Risk Management\u2019 section of the Annual Report for further details.
\u2022The criteria for identifying a significant increase in credit risk
When determining whether the credit risk on a financial asset has increased significantly, ING Bank\u00a0
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\u2019s 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 constitute a significant judgement. Analysis
of the sensitivity associated with the assessment of significant increase in credit risk is presented in the
\u2018Risk Management\u2019 section of the Annual Report.
\u2022The definition of default
Judgement is exercised in management\u2019s evaluation of whether there is objective evidence that larger
exposures are credit-impaired. Management judgement is required in assessing evidence of credit-
impairment.
\u2022Management adjustments applied as at 31 December 2022
To reflect the risks that are not properly captured by the ECL models, a number of management
adjustments to the model-based ECL were necessary as at 31 December 2022. Reference is made to the
\u2018Management adjustments applied this year\u2019 paragraph in the \u2018Risk management\u2019 section of the Annual
Report.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForImpairmentOfFinancialAssetsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMzUxODQzNzIzNjIxMzU_95f5d93d-3d0f-4cfe-b69c-ae79680ef5bc": { "value": "
Measurement of ECL
ING Bank 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 Bank 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 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\u2019 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 purpose of ECL, ING Bank\u2019s 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 Bank 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 Bank\u2019s 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 others, 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 is no longer recognised based on the accrual income
based on the gross carrying amount of the asset. Rather, interest income is calculated by applying the
original EIR to the AC of the asset, which is the gross carrying amount less the related loan loss provision.
Financial assets received as collateral
The financial assets received as collateral that can be sold or repledged in absence of default by the owner
of the collateral consists of securities obtained through reverse repurchase transactions and securities
borrowing transactions.
These transactions are generally conducted under standard market terms for most repurchase transactions
and the recipient of the collateral has unrestricted right to sell or repledge it, provided that the collateral (or
equivalent collateral) is returned to the counterparty at term.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForCollateralExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzg1_212e3c52-8045-47c4-99fc-6e6d3d2a6285": { "value": "
1.8\u00a0 Consolidation
ING Bank comprises ING Bank N.V. (the Parent Company) and all other subsidiaries. Subsidiaries are entities
controlled by ING Bank N.V. Control exists if ING Bank N.V. is exposed or has rights to variable returns and
has the ability to affect those returns through the power over the subsidiary. Control is usually achieved
through situations including, but not limited to:
\u2022Ownership, directly or indirectly, of more than half of the voting power;\u00a0
\u2022Ability to appoint or remove the majority of the board of directors;\u00a0
\u2022Power to govern operating and financial policies under statute or agreement; and\u00a0
\u2022Power over more than half of the voting rights through an agreement with other investors.\u00a0
The existence and effect of potential voting rights that are currently exercisable or convertible are
considered in assessing whether ING Bank controls another entity.
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.
A list of principal subsidiaries is included in Note 44 \u2018Principal subsidiaries\u2019 and a description of ING's activities
involving structured entities is included in Note 45 '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.
The results of the operations and the net assets of subsidiaries are included in the statement of profit or loss
and the statement of financial position from the date control is obtained until the date control is lost. On
disposal, the difference between the sales proceeds, net of directly attributable transaction costs, and the
net assets is included in net result.
A subsidiary which ING Bank has agreed to sell but is still legally owned by ING Bank may still be controlled
by ING Bank at the balance sheet date and therefore, still be included in the consolidation. Such a subsidiary
may be presented as a held for sale disposal group if certain conditions are met.
All intercompany transactions, balances and unrealised surpluses and deficits on transactions between
group companies are eliminated. Where necessary, the accounting policies used by subsidiaries are
changed to ensure consistency with group policies. In general, the reporting dates of subsidiaries are the
same as the reporting date of ING Bank N.V.
ING Bank 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\u2019s 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 in respect of minimum capital requirements that are imposed by
industry regulators in the countries in which the subsidiaries operate, other limitations exist in certain
countries.
", "dimensions": { "concept": "ifrs-full:DisclosureOfBasisOfConsolidationExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMjMwODk3NDQzOTgwOTg_54af399a-0bcb-4cbf-9248-3e62b74ab3b7": { "value": "
1.8\u00a0 Consolidation
ING Bank comprises ING Bank N.V. (the Parent Company) and all other subsidiaries. Subsidiaries are entities
controlled by ING Bank N.V. Control exists if ING Bank N.V. is exposed or has rights to variable returns and
has the ability to affect those returns through the power over the subsidiary. Control is usually achieved
through situations including, but not limited to:
\u2022Ownership, directly or indirectly, of more than half of the voting power;\u00a0
\u2022Ability to appoint or remove the majority of the board of directors;\u00a0
\u2022Power to govern operating and financial policies under statute or agreement; and\u00a0
\u2022Power over more than half of the voting rights through an agreement with other investors.\u00a0
The existence and effect of potential voting rights that are currently exercisable or convertible are
considered in assessing whether ING Bank controls another entity.
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.
A list of principal subsidiaries is included in Note 44 \u2018Principal subsidiaries\u2019 and a description of ING's activities
involving structured entities is included in Note 45 '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.
The results of the operations and the net assets of subsidiaries are included in the statement of profit or loss
and the statement of financial position from the date control is obtained until the date control is lost. On
disposal, the difference between the sales proceeds, net of directly attributable transaction costs, and the
net assets is included in net result.
A subsidiary which ING Bank has agreed to sell but is still legally owned by ING Bank may still be controlled
by ING Bank at the balance sheet date and therefore, still be included in the consolidation. Such a subsidiary
may be presented as a held for sale disposal group if certain conditions are met.
All intercompany transactions, balances and unrealised surpluses and deficits on transactions between
group companies are eliminated. Where necessary, the accounting policies used by subsidiaries are
changed to ensure consistency with group policies. In general, the reporting dates of subsidiaries are the
same as the reporting date of ING Bank N.V.
ING Bank 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\u2019s 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 in respect of minimum capital requirements that are imposed by
industry regulators in the countries in which the subsidiaries operate, other limitations exist in certain
countries.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForSubsidiariesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfODI0NjMzNzUxMzIxOQ_d265e95e-ed61-4612-baa2-939076d78843": { "value": "
ING Bank 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\u2019s 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.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForDividendsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfODI0NjMzNzUxMzIxOA_da2e7273-76d5-4515-83ab-66a9e0dfb76c": { "value": "
Furthermore, in addition to the restrictions in respect of minimum capital requirements that are imposed by
industry regulators in the countries in which the subsidiaries operate, other limitations exist in certain
countries.
Included in Cash and cash equivalents, are minimum mandatory reserve deposits to be held with 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.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForRestrictedCashAndCashEquivalentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzYy_56a734e2-5542-481a-9077-b2ca0f43a52f": { "value": "
1.9\u00a0 Segment reporting
An operating segment is a distinguishable component of ING Bank, engaged in providing products or
services, whose operating results are regularly reviewed by the Management Board Banking of ING Bank
(the Chief Operating Decision Maker (CODM)) to make decisions about resources to be allocated to the
segments and assess its performance. A geographical area is a distinguishable component of ING Bank
engaged in providing products or services within a particular economic environment that is subject to risks
and returns that differ from those of segments operating in other economic environments.
The CODM examines ING Bank\u2019s performance both by line of business and geographic perspective and has
identified five reportable segments by line of business. The geographical analyses are based on the location
of the office from which the transactions are originated.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForSegmentReportingExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzg3_0df1b90e-76a8-4d64-a4fb-67f9e3a1148e": { "value": "
1.10\u00a0 Foreign currency translation
Functional and presentation currency
Items included in the financial statements of each of ING Bank\u2019s 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 Bank\u2019s 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 \u2018Valuation results and
net trading income\u2019. Reference is made to Note 22 \u2018Valuation results and net trading income\u2019, 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 \u2018Result on disposal of group companies\u2019. Reference is also made to Note 19 \u2018Equity\u2019, 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:
\u2022Assets and liabilities are translated at the closing rate at the date of the statement of financial position;\u00a0
\u2022Income 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 and expenses are translated at the dates of the transactions). However, under hyperinflation
accounting, income and expenses of ING Turkey are translated at the closing rate; and\u00a0
\u2022All resulting exchange rate differences are recognised in a separate component of equity.\u00a0
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\u2019 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 liabilities of the foreign operation and translated at the exchange rate prevailing at the balance sheet
date.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForForeignCurrencyTranslationExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2NzcwNTMzNQ_500a1f26-3140-4c7c-a0a6-2064e1076372": { "value": "
Functional and presentation currency
Items included in the financial statements of each of ING Bank\u2019s 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 Bank\u2019s presentation currency.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForFunctionalCurrencyExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzcw_18fd8f20-1aaa-4263-ba9d-fdd6d4039291": { "value": "
1.11\u00a0 Investments in associates and joint ventures
Associates are all entities over which ING Bank 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:
\u2022Representation on the board of directors;\u00a0
\u2022Participation in the policymaking process; and\u00a0
\u2022Interchange of managerial personnel.\u00a0
Joint ventures are entities over which ING Bank has joint control. Joint control is the contractually agreed
sharing of control over an arrangement or entity, which exists only when decisions about the relevant
activities require the unanimous consent of the parties sharing control. Joint control means that no party to
the agreement is able to act unilaterally to control the activity of the entity. The parties to the agreement
must act together to control the entity and therefore exercise the joint control.
Investments in associates and joint ventures are initially recognised at cost and subsequently accounted for
using the equity method of accounting.
ING Bank\u2019s investment in associates and joint ventures (net of any accumulated impairment loss) includes
goodwill identified on acquisition. ING Bank\u2019s 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 Bank\u2019s 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 Bank
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 Bank and its associates and joint ventures are eliminated to
the extent of ING Bank\u2019s 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 Bank.
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. 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. 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.
Significant judgements and critical accounting estimates and assumptions:
The most significant estimates and assumptions relate to the assessment of (reversal of) impairment of
the investment in TMBThanachart Bank Public Company Limited (hereafter: TTB) which involves estimation
of value in use.
Management's best estimate of the expected future earnings of TTB is based on forecasts derived from
broker consensus over the short to medium term and reasonable and supportable assumptions capturing
a combination of TTB specific and market data points for longer term and steady state expectations into
perpetuity. A capital maintenance charge is applied, which is management\u2019s forecast of the earnings that
need to be withheld in order for TTB to meet target regulatory requirements over the forecast period. Both
of these factors are subject to a high degree of uncertainty.
Key assumptions used in estimating TTB\u2019s value in use and the sensitivity of the value in use calculations
to different assumptions are described in note 8 \u2018Investments in associates and joint ventures\u2019.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForInvestmentsInJointVentures", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzcw_335203fe-b03b-4ce1-bc3d-e24603b2ebcd": { "value": "
1.11\u00a0 Investments in associates and joint ventures
Associates are all entities over which ING Bank 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:
\u2022Representation on the board of directors;\u00a0
\u2022Participation in the policymaking process; and\u00a0
\u2022Interchange of managerial personnel.\u00a0
Joint ventures are entities over which ING Bank has joint control. Joint control is the contractually agreed
sharing of control over an arrangement or entity, which exists only when decisions about the relevant
activities require the unanimous consent of the parties sharing control. Joint control means that no party to
the agreement is able to act unilaterally to control the activity of the entity. The parties to the agreement
must act together to control the entity and therefore exercise the joint control.
Investments in associates and joint ventures are initially recognised at cost and subsequently accounted for
using the equity method of accounting.
ING Bank\u2019s investment in associates and joint ventures (net of any accumulated impairment loss) includes
goodwill identified on acquisition. ING Bank\u2019s 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 Bank\u2019s 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 Bank
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 Bank and its associates and joint ventures are eliminated to
the extent of ING Bank\u2019s 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 Bank.
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. 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. 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.
Significant judgements and critical accounting estimates and assumptions:
The most significant estimates and assumptions relate to the assessment of (reversal of) impairment of
the investment in TMBThanachart Bank Public Company Limited (hereafter: TTB) which involves estimation
of value in use.
Management's best estimate of the expected future earnings of TTB is based on forecasts derived from
broker consensus over the short to medium term and reasonable and supportable assumptions capturing
a combination of TTB specific and market data points for longer term and steady state expectations into
perpetuity. A capital maintenance charge is applied, which is management\u2019s forecast of the earnings that
need to be withheld in order for TTB to meet target regulatory requirements over the forecast period. Both
of these factors are subject to a high degree of uncertainty.
Key assumptions used in estimating TTB\u2019s value in use and the sensitivity of the value in use calculations
to different assumptions are described in note 8 \u2018Investments in associates and joint ventures\u2019.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForInvestmentInAssociatesAndJointVenturesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2NzcwNTMzNg_3518561d-ebe7-4778-9326-fbdfd0b20a44": { "value": "
1.11\u00a0 Investments in associates and joint ventures
Associates are all entities over which ING Bank 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:
\u2022Representation on the board of directors;\u00a0
\u2022Participation in the policymaking process; and\u00a0
\u2022Interchange of managerial personnel.\u00a0
Joint ventures are entities over which ING Bank has joint control. Joint control is the contractually agreed
sharing of control over an arrangement or entity, which exists only when decisions about the relevant
activities require the unanimous consent of the parties sharing control. Joint control means that no party to
the agreement is able to act unilaterally to control the activity of the entity. The parties to the agreement
must act together to control the entity and therefore exercise the joint control.
Investments in associates and joint ventures are initially recognised at cost and subsequently accounted for
using the equity method of accounting.
ING Bank\u2019s investment in associates and joint ventures (net of any accumulated impairment loss) includes
goodwill identified on acquisition. ING Bank\u2019s 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 Bank\u2019s 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 Bank
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 Bank and its associates and joint ventures are eliminated to
the extent of ING Bank\u2019s 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 Bank.
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. 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. 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.
Significant judgements and critical accounting estimates and assumptions:
The most significant estimates and assumptions relate to the assessment of (reversal of) impairment of
the investment in TMBThanachart Bank Public Company Limited (hereafter: TTB) which involves estimation
of value in use.
Management's best estimate of the expected future earnings of TTB is based on forecasts derived from
broker consensus over the short to medium term and reasonable and supportable assumptions capturing
a combination of TTB specific and market data points for longer term and steady state expectations into
perpetuity. A capital maintenance charge is applied, which is management\u2019s forecast of the earnings that
need to be withheld in order for TTB to meet target regulatory requirements over the forecast period. Both
of these factors are subject to a high degree of uncertainty.
Key assumptions used in estimating TTB\u2019s value in use and the sensitivity of the value in use calculations
to different assumptions are described in note 8 \u2018Investments in associates and joint ventures\u2019.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForInvestmentInAssociates", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2Nzc0NjU0Nw_2d280518-5073-410d-9df3-ebb49ef17662": { "value": "
1.12\u00a0 Property and equipment
Property in own use
Land and buildings held for own use are stated at fair value at the balance sheet date. Increases in the
carrying amount arising on revaluation of land and buildings held for own use are credited to the
revaluation reserve in shareholders\u2019 equity. Decreases in the carrying amount that offset previous increases
of the same asset are charged against the revaluation reserve directly in equity; all other decreases are
charged to the statement of profit or loss. Increases that reverse a revaluation decrease on the same asset
previously recognised in net result are recognised in the statement of profit or loss. Depreciation is
recognised based on the fair value and the estimated useful life (in general 20\u201350 years). Depreciation is
calculated on a straight-line basis. On disposal, the related revaluation reserve is transferred to retained
earnings.
In principle, the fair values of land and buildings are appraised annually by independent qualified valuers.
Subsequent expenditure is included in the asset\u2019s carrying amount when it is probable that future economic
benefits associated with the item will flow to ING Bank and the cost of the item can be measured reliably.
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:
for data processing equipment two to five years, and four to ten years for fixtures and fittings. Expenditure
incurred on maintenance and repairs is recognised in the statement of profit or loss as incurred. Expenditure
incurred on major improvements is capitalised and depreciated.
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 Bank 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 Bank. 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\u2019s 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:
\u2022Fixed payments (including in-substance fixed payments), less any lease incentives receivable;
\u2022Variable lease payments that are based on an index or a rate;
\u2022Amounts expected to be payable by the lessee under residual value guarantees;
\u2022The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and
\u2022Payments 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\u2019s 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. This rate is approximated by using the risk free rate applicable to the
lease term, the currency of the lease payment and jurisdiction, with the Fund Transfer Pricing (FTP) rate as
an add-on. The FTP rate is used to transfer interest rate risk and funding and liquidity risk positions between
the ING Bank business and treasury departments. It is determined by either ING Bank or Local Asset and
Liability Committee (ALCO). Reference is made to the \u2018Risk management\u2019 section of the Annual Report.
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.
Payments associated with short-term leases and leases of low-value assets are recognised on a straight-
line basis as an expense in profit or loss. Short-term leases are leases with a lease term of 12 months or less.
Low-value assets comprise mainly IT-equipment (for example mobile phones or laptops) and small items of
office furniture.
The right-of-use asset is included in the statement of financial position line-item \u2018Property and equipment\u2019,
the lease liability is included in the statement of financial position line-item \u2018Other liabilities\u2019. Refer to note 9
\u2018Property and equipment\u2019 and to note 16 \u2018Other liabilities\u2019.
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
decrease 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.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForDepreciationExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2Nzc0NjU0Nw_7ed170db-b05c-447d-9d9e-267354fb004e": { "value": "
1.12\u00a0 Property and equipment
Property in own use
Land and buildings held for own use are stated at fair value at the balance sheet date. Increases in the
carrying amount arising on revaluation of land and buildings held for own use are credited to the
revaluation reserve in shareholders\u2019 equity. Decreases in the carrying amount that offset previous increases
of the same asset are charged against the revaluation reserve directly in equity; all other decreases are
charged to the statement of profit or loss. Increases that reverse a revaluation decrease on the same asset
previously recognised in net result are recognised in the statement of profit or loss. Depreciation is
recognised based on the fair value and the estimated useful life (in general 20\u201350 years). Depreciation is
calculated on a straight-line basis. On disposal, the related revaluation reserve is transferred to retained
earnings.
In principle, the fair values of land and buildings are appraised annually by independent qualified valuers.
Subsequent expenditure is included in the asset\u2019s carrying amount when it is probable that future economic
benefits associated with the item will flow to ING Bank and the cost of the item can be measured reliably.
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:
for data processing equipment two to five years, and four to ten years for fixtures and fittings. Expenditure
incurred on maintenance and repairs is recognised in the statement of profit or loss as incurred. Expenditure
incurred on major improvements is capitalised and depreciated.
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 Bank 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 Bank. 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\u2019s 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:
\u2022Fixed payments (including in-substance fixed payments), less any lease incentives receivable;
\u2022Variable lease payments that are based on an index or a rate;
\u2022Amounts expected to be payable by the lessee under residual value guarantees;
\u2022The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and
\u2022Payments 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\u2019s 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. This rate is approximated by using the risk free rate applicable to the
lease term, the currency of the lease payment and jurisdiction, with the Fund Transfer Pricing (FTP) rate as
an add-on. The FTP rate is used to transfer interest rate risk and funding and liquidity risk positions between
the ING Bank business and treasury departments. It is determined by either ING Bank or Local Asset and
Liability Committee (ALCO). Reference is made to the \u2018Risk management\u2019 section of the Annual Report.
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.
Payments associated with short-term leases and leases of low-value assets are recognised on a straight-
line basis as an expense in profit or loss. Short-term leases are leases with a lease term of 12 months or less.
Low-value assets comprise mainly IT-equipment (for example mobile phones or laptops) and small items of
office furniture.
The right-of-use asset is included in the statement of financial position line-item \u2018Property and equipment\u2019,
the lease liability is included in the statement of financial position line-item \u2018Other liabilities\u2019. Refer to note 9
\u2018Property and equipment\u2019 and to note 16 \u2018Other liabilities\u2019.
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
decrease 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.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForPropertyPlantAndEquipmentExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzg4_2ae570fe-bb90-4f6a-8028-e9ba6355cf75": { "value": "
1.14\u00a0 Acquisitions, goodwill and other intangible assets
Goodwill resulting from a business combination
ING Bank\u2019s business combinations are accounted for using the acquisition method of accounting. The
consideration for each business combination is measured at the aggregate of the fair values (at the date of
exchange) of assets given, liabilities incurred or assumed, and equity instruments issued in exchange for
control of the acquiree. Goodwill, being the difference between the cost of the acquisition (including
assumed debt) and the Group\u2019s interest in the fair value of the investee's identifiable assets, liabilities and
contingent liabilities as at the date of acquisition, is capitalised as an intangible asset. Goodwill is only
recognised separately on acquisitions. The results of the operations of the acquired companies are included
in the statement of profit or loss from the date control is obtained.
Where applicable, the consideration for the business combination includes any asset or liability resulting
from a contingent consideration arrangement, the contingent consideration is measured at its acquisition-
date fair value. Contingent consideration arrangements classified as an asset or a liability, are subsequently
measured at fair value and the changes in fair value are recognised in the statement of profit or loss.
Changes in the fair value of the contingent consideration classified as equity, are not recognised.
Where a business combination is achieved in stages, ING Bank\u2019s previously held interests in the assets and
liabilities of the acquired entity are remeasured to fair value at the acquisition date (i.e. the date ING Bank
obtains control) and the resulting gain or loss, if any, is recognised in the statement of profit or loss.
Amounts arising from interests in the acquiree prior to the acquisition date that have previously been
recognised in other comprehensive income are reclassified to the statement of profit or loss, where such
treatment would be appropriate if that interest were disposed of. Acquisition related costs are recognised in
the statement of profit or loss as incurred and presented in the statement of profit or loss as Other
operating expenses.
The initial accounting for the fair value of the net assets of the companies acquired during the year may be
determined only provisionally as the determination of the fair value can be complex and the time between
the acquisition and the preparation of the Financial statements can be limited. The initial accounting shall
be completed within a year after acquisition. Adjustments to the fair value as at the date of acquisition of
acquired assets and liabilities, that are identified within one year after acquisition are recognised as an
adjustment to goodwill; any subsequent adjustment is recognised as income or expense. On disposal of
group companies where control is lost, the difference between the sale proceeds and carrying value
(including goodwill) and the unrealised results (including the currency translation reserve in equity) is
included in the statement of profit or loss.
Impairment of goodwill and other non-financial assets
ING Bank 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. The carrying value is
determined on a basis that is consistent with the way in which the recoverable amount of the CGU is
determined. The recoverable amount is estimated as the higher of fair value less costs of disposal and value
in use. 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. This period will generally not exceed five years. Amortisation is included in Other operating expenses.
Other intangible assets
Other intangible assets are capitalised and amortised over their expected economic life, which is generally
between three and ten years.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForIntangibleAssetsAndGoodwillExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMjMwODk3NDQzOTgxMDM_04b7314d-8c29-483f-876a-114910452431": { "value": "
1.14\u00a0 Acquisitions, goodwill and other intangible assets
Goodwill resulting from a business combination
ING Bank\u2019s business combinations are accounted for using the acquisition method of accounting. The
consideration for each business combination is measured at the aggregate of the fair values (at the date of
exchange) of assets given, liabilities incurred or assumed, and equity instruments issued in exchange for
control of the acquiree. Goodwill, being the difference between the cost of the acquisition (including
assumed debt) and the Group\u2019s interest in the fair value of the investee's identifiable assets, liabilities and
contingent liabilities as at the date of acquisition, is capitalised as an intangible asset. Goodwill is only
recognised separately on acquisitions. The results of the operations of the acquired companies are included
in the statement of profit or loss from the date control is obtained.
Where applicable, the consideration for the business combination includes any asset or liability resulting
from a contingent consideration arrangement, the contingent consideration is measured at its acquisition-
date fair value. Contingent consideration arrangements classified as an asset or a liability, are subsequently
measured at fair value and the changes in fair value are recognised in the statement of profit or loss.
Changes in the fair value of the contingent consideration classified as equity, are not recognised.
Where a business combination is achieved in stages, ING Bank\u2019s previously held interests in the assets and
liabilities of the acquired entity are remeasured to fair value at the acquisition date (i.e. the date ING Bank
obtains control) and the resulting gain or loss, if any, is recognised in the statement of profit or loss.
Amounts arising from interests in the acquiree prior to the acquisition date that have previously been
recognised in other comprehensive income are reclassified to the statement of profit or loss, where such
treatment would be appropriate if that interest were disposed of. Acquisition related costs are recognised in
the statement of profit or loss as incurred and presented in the statement of profit or loss as Other
operating expenses.
The initial accounting for the fair value of the net assets of the companies acquired during the year may be
determined only provisionally as the determination of the fair value can be complex and the time between
the acquisition and the preparation of the Financial statements can be limited. The initial accounting shall
be completed within a year after acquisition. Adjustments to the fair value as at the date of acquisition of
acquired assets and liabilities, that are identified within one year after acquisition are recognised as an
adjustment to goodwill; any subsequent adjustment is recognised as income or expense. On disposal of
group companies where control is lost, the difference between the sale proceeds and carrying value
(including goodwill) and the unrealised results (including the currency translation reserve in equity) is
included in the statement of profit or loss.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForBusinessCombinationsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2NzcwNTMzNw_3b58ab52-350e-4ee9-a045-798d5b93068b": { "value": "
Goodwill resulting from a business combination
ING Bank\u2019s business combinations are accounted for using the acquisition method of accounting. The
consideration for each business combination is measured at the aggregate of the fair values (at the date of
exchange) of assets given, liabilities incurred or assumed, and equity instruments issued in exchange for
control of the acquiree. Goodwill, being the difference between the cost of the acquisition (including
assumed debt) and the Group\u2019s interest in the fair value of the investee's identifiable assets, liabilities and
contingent liabilities as at the date of acquisition, is capitalised as an intangible asset. Goodwill is only
recognised separately on acquisitions. The results of the operations of the acquired companies are included
in the statement of profit or loss from the date control is obtained.
Where applicable, the consideration for the business combination includes any asset or liability resulting
from a contingent consideration arrangement, the contingent consideration is measured at its acquisition-
date fair value. Contingent consideration arrangements classified as an asset or a liability, are subsequently
measured at fair value and the changes in fair value are recognised in the statement of profit or loss.
Changes in the fair value of the contingent consideration classified as equity, are not recognised.
Where a business combination is achieved in stages, ING Bank\u2019s previously held interests in the assets and
liabilities of the acquired entity are remeasured to fair value at the acquisition date (i.e. the date ING Bank
obtains control) and the resulting gain or loss, if any, is recognised in the statement of profit or loss.
Amounts arising from interests in the acquiree prior to the acquisition date that have previously been
recognised in other comprehensive income are reclassified to the statement of profit or loss, where such
treatment would be appropriate if that interest were disposed of. Acquisition related costs are recognised in
the statement of profit or loss as incurred and presented in the statement of profit or loss as Other
operating expenses.
The initial accounting for the fair value of the net assets of the companies acquired during the year may be
determined only provisionally as the determination of the fair value can be complex and the time between
the acquisition and the preparation of the Financial statements can be limited. The initial accounting shall
be completed within a year after acquisition. Adjustments to the fair value as at the date of acquisition of
acquired assets and liabilities, that are identified within one year after acquisition are recognised as an
adjustment to goodwill; any subsequent adjustment is recognised as income or expense. On disposal of
group companies where control is lost, the difference between the sale proceeds and carrying value
(including goodwill) and the unrealised results (including the currency translation reserve in equity) is
included in the statement of profit or loss.
Impairment of goodwill and other non-financial assets
ING Bank 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. The carrying value is
determined on a basis that is consistent with the way in which the recoverable amount of the CGU is
determined. The recoverable amount is estimated as the higher of fair value less costs of disposal and value
in use. Impairment of goodwill, if applicable, is included in the statement of profit or loss in Other operating
expenses and is not subsequently reversed.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForGoodwillExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2NzcwNTMzNw_4e115696-3b66-4b16-94a5-af2a03ebc605": { "value": "
Goodwill resulting from a business combination
ING Bank\u2019s business combinations are accounted for using the acquisition method of accounting. The
consideration for each business combination is measured at the aggregate of the fair values (at the date of
exchange) of assets given, liabilities incurred or assumed, and equity instruments issued in exchange for
control of the acquiree. Goodwill, being the difference between the cost of the acquisition (including
assumed debt) and the Group\u2019s interest in the fair value of the investee's identifiable assets, liabilities and
contingent liabilities as at the date of acquisition, is capitalised as an intangible asset. Goodwill is only
recognised separately on acquisitions. The results of the operations of the acquired companies are included
in the statement of profit or loss from the date control is obtained.
Where applicable, the consideration for the business combination includes any asset or liability resulting
from a contingent consideration arrangement, the contingent consideration is measured at its acquisition-
date fair value. Contingent consideration arrangements classified as an asset or a liability, are subsequently
measured at fair value and the changes in fair value are recognised in the statement of profit or loss.
Changes in the fair value of the contingent consideration classified as equity, are not recognised.
Where a business combination is achieved in stages, ING Bank\u2019s previously held interests in the assets and
liabilities of the acquired entity are remeasured to fair value at the acquisition date (i.e. the date ING Bank
obtains control) and the resulting gain or loss, if any, is recognised in the statement of profit or loss.
Amounts arising from interests in the acquiree prior to the acquisition date that have previously been
recognised in other comprehensive income are reclassified to the statement of profit or loss, where such
treatment would be appropriate if that interest were disposed of. Acquisition related costs are recognised in
the statement of profit or loss as incurred and presented in the statement of profit or loss as Other
operating expenses.
The initial accounting for the fair value of the net assets of the companies acquired during the year may be
determined only provisionally as the determination of the fair value can be complex and the time between
the acquisition and the preparation of the Financial statements can be limited. The initial accounting shall
be completed within a year after acquisition. Adjustments to the fair value as at the date of acquisition of
acquired assets and liabilities, that are identified within one year after acquisition are recognised as an
adjustment to goodwill; any subsequent adjustment is recognised as income or expense. On disposal of
group companies where control is lost, the difference between the sale proceeds and carrying value
(including goodwill) and the unrealised results (including the currency translation reserve in equity) is
included in the statement of profit or loss.
Impairment of goodwill and other non-financial assets
ING Bank 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. The carrying value is
determined on a basis that is consistent with the way in which the recoverable amount of the CGU is
determined. The recoverable amount is estimated as the higher of fair value less costs of disposal and value
in use. Impairment of goodwill, if applicable, is included in the statement of profit or loss in Other operating
expenses and is not subsequently reversed.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForBusinessCombinationsAndGoodwillExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2Nzc0NjU2Nw_48e9e709-c71d-4e1a-b7a6-920c1d142add": { "value": "
Impairment of goodwill and other non-financial assets
ING Bank 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. The carrying value is
determined on a basis that is consistent with the way in which the recoverable amount of the CGU is
determined. The recoverable amount is estimated as the higher of fair value less costs of disposal and value
in use. Impairment of goodwill, if applicable, is included in the statement of profit or loss in Other operating
expenses and is not subsequently reversed.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForImpairmentOfNonfinancialAssetsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2NzcwNTMzOQ_3fb57527-9fd0-440a-873f-8ed0384dc2d8": { "value": "
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. This period will generally not exceed five years. Amortisation is included in Other operating expenses.
Other intangible assets
Other intangible assets are capitalised and amortised over their expected economic life, which is generally
between three and ten years.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForIntangibleAssetsOtherThanGoodwillExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzY0_a963b88e-0f0b-467c-8ceb-84f36dc9b95f": { "value": "
1.15\u00a0 Taxation
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.
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 Bank 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 equity and is subsequently recognised in the statement of profit or loss together with the
deferred gain or loss.
Uncertain tax positions are assessed continually by ING Bank and in case it is probable that there will be a
cash outflow, a current tax liability is recognised.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForIncomeTaxExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfODI0NjMzNzUxMzIwOA_a41d2006-31fa-4001-97e7-ac0bf83eb851": { "value": "
1.15\u00a0 Taxation
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.
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 Bank 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 equity and is subsequently recognised in the statement of profit or loss together with the
deferred gain or loss.
Uncertain tax positions are assessed continually by ING Bank and in case it is probable that there will be a
cash outflow, a current tax liability is recognised.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForDeferredIncomeTaxExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfODI0NjMzNzUxMzIwNw_7ef37ff6-355f-4e63-8bdc-39b302786d47": { "value": "
Investment property
Investment properties are recognised at fair value at the balance sheet date. The fair values of investment
properties are appraised annually by independent qualified valuers. Changes in the carrying amount
resulting from revaluations are recognised in the statement of profit or loss. On disposal, the difference between the sale proceeds and carrying value is recognised in the statement of profit or loss.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForInvestmentPropertyExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzgw_c5d356e5-ddd2-4e9f-9501-ce8b2608a5a4": { "value": "
1.17\u00a0 Disposal groups held for sale and discontinued operations
Disposal groups (and non-current assets) are classified as held for sale if their carrying amount will be
recovered principally through a sale transaction rather than through continuing use. This is only the case
when the sale is highly probable and the disposal group (or non-current assets) is available for immediate
sale in its present condition; including management must be committed to the sale, which is expected to
occur within one year from the date of classification as held for sale.
Upon classification as held for sale, the disposal group is measured at the lower of its carrying amount and
fair value less costs to sell, except where specifically exempt from IFRS 5 \u2018Non-current Assets Held for Sale
and Discontinued Operations. An impairment loss is recognised for any initial or subsequent write-down of
the disposal group to fair value less costs to sell. A gain is recognised for any subsequent increases in fair
value less costs to sell of the disposal group, but not in excess of any cumulative impairment loss previously
recognised. A gain or loss not previously recognised by the date of the sale of the disposal group is
recognised at the date of derecognition. Assets within the disposal group are not depreciated or amortised
while they are classified as held for sale. Interest and other net income/expenses attributable to the
liabilities of a disposal group classified as held for sale continue to be recognised. The assets of the disposal
group classified as held for sale are presented separately from the other assets in the balance sheet. The
liabilities of a disposal group classified as held for sale are presented separately from other liabilities in the
balance sheet.
When a group of assets that is classified as held for sale represents a major line of business or geographical
area the disposal group is classified as discontinued operations. Upon classification of a business as held for
sale and discontinued operations the individual income and expenses are presented within the Total net
result from discontinued operations instead of being presented in the usual line items in the Consolidated
statement of profit or loss. All comparative years in the Consolidated statement of profit or loss are restated
and presented as discontinued operations for all periods presented. Furthermore, the individual assets and
liabilities are presented in the Consolidated statement of financial position as Assets and liabilities held for
sale and are no longer included in the usual line items in the Consolidated statement of financial position.
Changes in assets and liabilities as a result of classification as held for sale are included in the notes in the
line \u2018Changes in composition of the group and other changes\u2019.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForDiscontinuedOperationsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMjMwODk3NDQzOTgxMDY_a554809d-3ed1-42fd-bfd6-d088dac9a4e2": { "value": "
1.17\u00a0 Disposal groups held for sale and discontinued operations
Disposal groups (and non-current assets) are classified as held for sale if their carrying amount will be
recovered principally through a sale transaction rather than through continuing use. This is only the case
when the sale is highly probable and the disposal group (or non-current assets) is available for immediate
sale in its present condition; including management must be committed to the sale, which is expected to
occur within one year from the date of classification as held for sale.
Upon classification as held for sale, the disposal group is measured at the lower of its carrying amount and
fair value less costs to sell, except where specifically exempt from IFRS 5 \u2018Non-current Assets Held for Sale
and Discontinued Operations. An impairment loss is recognised for any initial or subsequent write-down of
the disposal group to fair value less costs to sell. A gain is recognised for any subsequent increases in fair
value less costs to sell of the disposal group, but not in excess of any cumulative impairment loss previously
recognised. A gain or loss not previously recognised by the date of the sale of the disposal group is
recognised at the date of derecognition. Assets within the disposal group are not depreciated or amortised
while they are classified as held for sale. Interest and other net income/expenses attributable to the
liabilities of a disposal group classified as held for sale continue to be recognised. The assets of the disposal
group classified as held for sale are presented separately from the other assets in the balance sheet. The
liabilities of a disposal group classified as held for sale are presented separately from other liabilities in the
balance sheet.
When a group of assets that is classified as held for sale represents a major line of business or geographical
area the disposal group is classified as discontinued operations. Upon classification of a business as held for
sale and discontinued operations the individual income and expenses are presented within the Total net
result from discontinued operations instead of being presented in the usual line items in the Consolidated
statement of profit or loss. All comparative years in the Consolidated statement of profit or loss are restated
and presented as discontinued operations for all periods presented. Furthermore, the individual assets and
liabilities are presented in the Consolidated statement of financial position as Assets and liabilities held for
sale and are no longer included in the usual line items in the Consolidated statement of financial position.
Changes in assets and liabilities as a result of classification as held for sale are included in the notes in the
line \u2018Changes in composition of the group and other changes\u2019.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForNoncurrentAssetsOrDisposalGroupsClassifiedAsHeldForSaleExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMjMwODk3NDQzOTgxMDY_fda09d3e-47eb-499f-a41b-19825e7bc69d": { "value": "
1.17\u00a0 Disposal groups held for sale and discontinued operations
Disposal groups (and non-current assets) are classified as held for sale if their carrying amount will be
recovered principally through a sale transaction rather than through continuing use. This is only the case
when the sale is highly probable and the disposal group (or non-current assets) is available for immediate
sale in its present condition; including management must be committed to the sale, which is expected to
occur within one year from the date of classification as held for sale.
Upon classification as held for sale, the disposal group is measured at the lower of its carrying amount and
fair value less costs to sell, except where specifically exempt from IFRS 5 \u2018Non-current Assets Held for Sale
and Discontinued Operations. An impairment loss is recognised for any initial or subsequent write-down of
the disposal group to fair value less costs to sell. A gain is recognised for any subsequent increases in fair
value less costs to sell of the disposal group, but not in excess of any cumulative impairment loss previously
recognised. A gain or loss not previously recognised by the date of the sale of the disposal group is
recognised at the date of derecognition. Assets within the disposal group are not depreciated or amortised
while they are classified as held for sale. Interest and other net income/expenses attributable to the
liabilities of a disposal group classified as held for sale continue to be recognised. The assets of the disposal
group classified as held for sale are presented separately from the other assets in the balance sheet. The
liabilities of a disposal group classified as held for sale are presented separately from other liabilities in the
balance sheet.
When a group of assets that is classified as held for sale represents a major line of business or geographical
area the disposal group is classified as discontinued operations. Upon classification of a business as held for
sale and discontinued operations the individual income and expenses are presented within the Total net
result from discontinued operations instead of being presented in the usual line items in the Consolidated
statement of profit or loss. All comparative years in the Consolidated statement of profit or loss are restated
and presented as discontinued operations for all periods presented. Furthermore, the individual assets and
liabilities are presented in the Consolidated statement of financial position as Assets and liabilities held for
sale and are no longer included in the usual line items in the Consolidated statement of financial position.
Changes in assets and liabilities as a result of classification as held for sale are included in the notes in the
line \u2018Changes in composition of the group and other changes\u2019.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForNoncurrentAssetsOrDisposalGroupsClassifiedAsHeldForSaleAndDiscontinuedOperationsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzc0_05b101da-0f25-4fb1-bf1b-c294cd652f3d": { "value": "
1.18\u00a0 Provisions, contingent liabilities and contingent assets
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 Bank 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 Bank; 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 Bank. 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.
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 Bank\u00a0 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 Bank
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 Bank consults with internal and external legal experts. Even taking into
consideration legal experts\u2019 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'.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForContingentLiabilitiesAndContingentAssetsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2Nzc0NjIzOA_3be67af4-5c34-42b3-aa01-bbd0a633ad17": { "value": "
1.18\u00a0 Provisions, contingent liabilities and contingent assets
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 Bank 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 Bank; 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 Bank. 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.
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 Bank\u00a0 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 Bank
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 Bank consults with internal and external legal experts. Even taking into
consideration legal experts\u2019 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'.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForProvisionsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfODI0NjMzNzUxMzIyMg_e551c3e9-ac49-4755-aa7c-7a085b3e3307": { "value": "
Reorganisation provisions include employee termination benefits when ING Bank 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.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForTerminationBenefits", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMjMwODk3NDQzOTgxMDg_99021ff4-919d-49e0-9d09-f591b39d1030": { "value": "
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.
Plan assets are measured at fair value at the balance sheet date. For determining the pension expense, the
return on plan assets is determined using a high quality corporate bond rate identical to the discount rate
used in determining the defined benefit obligation.
Changes in plan assets that effect Shareholders\u2019 equity and/or Net result, include mainly:
\u2022Return on plan assets using a high quality corporate bond rate at the start of the reporting period which
are recognised as staff costs in the statement of profit or loss; and\u00a0
\u2022Remeasurements which are recognised in Other comprehensive income.\u00a0
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. The actuarial assumptions may differ
significantly from the 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 the defined
benefit plan obligation and future pension costs.
Changes in the defined benefit obligation that effect Shareholders\u2019 equity and/or Net result, include mainly:
\u2022Service cost which is recognised as staff costs in the statement of profit or loss;\u00a0
\u2022Interest expenses using a high quality corporate bond rate at the start of the period which are
recognised as staff costs in the Statement of profit or loss; and\u00a0
\u2022Remeasurements which are recognised in Other comprehensive income (equity).\u00a0
Remeasurements recognised in other comprehensive income are not recycled to 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. 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.
Defined contribution plans
For defined contribution plans, ING Bank pays contributions to publicly or privately administered pension
insurance plans on a mandatory, contractual or voluntary basis. ING Bank 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 accounting methodology similar to that for defined benefit pension plans.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForEmployeeBenefitsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMjMwODk3NDQzOTgxMDk_4a832dce-c890-4f2b-92e8-94de8671d586": { "value": "
1.20\u00a0 Income recognition
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 Bank
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 is presented in \u2018Interest income (expense) using effective interest rate
method\u2019. 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 \u2018Other interest income
(expense)\u2019. Interest result on all other financial assets and liabilities at FVTPL is recognised in \u2018Valuation
results and net trading income\u2019.
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 Bank 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 \u2013 such as the arrangement of the acquisition of shares or other securities or the
purchase or sale of businesses \u2013 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 Bank is the
lessor are divided into an interest component (recognised as interest income) and a repayment component
based on a pattern reflecting a constant periodic rate of return on the lessor\u2019s net investment in the lease.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForRecognitionOfRevenue", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2Nzc1NjUyNA_ebe716b1-4449-4515-8aa9-2e0f2473cbb6": { "value": "
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 Bank
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 is presented in \u2018Interest income (expense) using effective interest rate
method\u2019. 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 \u2018Other interest income
(expense)\u2019. Interest result on all other financial assets and liabilities at FVTPL is recognised in \u2018Valuation
results and net trading income\u2019.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForInterestIncomeAndExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2Nzc1NjUyNQ_19b7db3d-a49c-472d-9283-f45931152e5a": { "value": "
Interest results on instruments classified at Amortised Cost, assets measured at FVOCI and derivatives in a
formal hedge accounting relationship is presented in \u2018Interest income (expense) using effective interest rate
method\u2019. 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 \u2018Other interest income
(expense)\u2019. Interest result on all other financial assets and liabilities at FVTPL is recognised in \u2018Valuation
results and net trading income\u2019.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForTradingIncomeAndExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2Nzc1NjUyNg_8925b927-cd1c-4b07-a001-f17fb43c2779": { "value": "
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 Bank 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 \u2013 such as the arrangement of the acquisition of shares or other securities or the
purchase or sale of businesses \u2013 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.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForFeeAndCommissionIncomeAndExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2Nzc1NjUyMw_2a211dc5-6e65-4c19-b43e-c4c9a911ff53": { "value": "
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 Bank is the
lessor are divided into an interest component (recognised as interest income) and a repayment component
based on a pattern reflecting a constant periodic rate of return on the lessor\u2019s net investment in the lease.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForLeasesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMjMwODk3NDQzOTgxMTA_fe34a20a-31e7-4bc5-ad05-df44ac8fa683": { "value": "
1.21\u00a0 Expense recognition
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 are generally a result from a contract with ING service
providers in order to perform the service for ING Bank\u2019s customers. Costs are generally presented as
\u2018Commission expenses\u2019 if they are specific, incremental, directly attributable and identifiable to generate
commission income.\u00a0
Share-based payments
ING Bank 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 of service.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForExpensesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTY0OTI2NzcwNTM0NQ_01122f05-8912-4e3c-ac11-41610ddaf025": { "value": "
Share-based payments
ING Bank 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 of service.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForSharebasedPaymentTransactionsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85NC9mcmFnOjUyMmE4Nzg2YzZmODQxNzFiNmViNzc3MjY0NzEyYzE0L3RleHRyZWdpb246NTIyYTg3ODZjNmY4NDE3MWI2ZWI3NzcyNjQ3MTJjMTRfMTEwNzYz_f64176f9-181d-446a-a072-b89ba386ff6d": { "value": "
1.22\u00a0 Statement of cash flows
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 comprise balances with less
than three months\u2019 maturity from the date of acquisition, including cash and balances with central banks,
treasury bills and other eligible bills, amounts due from other banks, and deposits from banks. 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.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForCashFlowsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85Ny9mcmFnOjdkZGFlOGFiMDA3YzQwY2E5YmJhM2JkMTk3NjU3YTE0L3RleHRyZWdpb246N2RkYWU4YWIwMDdjNDBjYTliYmEzYmQxOTc2NTdhMTRfODM_f000285f-9508-4a88-b79a-756fab6250f2": { "value": "
2\u00a0 Cash and balances with central banks
Cash and balances with central banks
in EUR million
2022
2021
Amounts held at central banks 1
85,934\u00a0
104,870\u00a0
Cash and bank balances
1,681\u00a0
1,650\u00a0
87,614
106,520
1 Amounts held at central banks include an amount of EUR -12 million (2021: EUR -6 million) of Loan loss provisions.
The movement in Cash and balances with central banks reflects ING\u2019s active liquidity management.
Amounts held at central banks reflect on demand balances.
Reference is made to Note 39 'Transfer of financial assets, assets pledged and received as collateral' for
restrictions on amounts held at central banks.
3\u00a0 Loans and advances to banks
Loans and advances to banks
Netherlands
Rest of the world
Total
in EUR million
2022
2021
2022
2021
2022
2021
Loans and advances to banks
23,462
7,018
11,679
16,595
35,140
23,613
Loan loss provisions
-12
-10
-26
-13
-37
-22
23,450
7,009
11,653
16,582
35,103
23,591
Loans include balances (mainly reverse repos) with central banks amounting to EUR 19,395 million (2021:
EUR 3,403 million). 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\u00a0December 2022 and at 31 December 2021, all loans and advances to banks are non-subordinated.
4\u00a0 Financial assets at fair value through profit or loss
Financial assets at fair value through profit or loss
in EUR million
2022
2021
Trading assets
56,875
51,389
Non-trading derivatives
3,893
1,536
Designated at fair value through profit or loss
6,159
6,355
Mandatorily measured at fair value through profit or loss
46,844
42,684
113,770
101,964
Securities purchased under agreements to resell (reverse repos), securities borrowings and similar
agreements are not recognised in the consolidated statement of financial position. 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, Other financial assets 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. The counterparty liability is
measured at FVPL (designated) and included in Other financial liabilities at FVPL if the asset is measured at
FVPL. Otherwise, the counterparty liability is included in Deposits from banks, or Trading, as appropriate.
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.
Trading assets
Trading assets by type
in EUR million
2022
2021
Equity securities
11,741
17,574
Debt securities
4,189
5,319
Derivatives
30,841
19,764
Loans and receivables
10,103
8,733
56,875
51,389
for information on
trading liabilities.
Non-trading derivatives
Non-trading derivatives by type
in EUR million
2022
2021
Derivatives used in
-\u00a0 fair value hedges
836
365
-\u00a0 cash flow hedges
814
300
-\u00a0 hedges of net investments in foreign operations
119
18
Other non-trading derivatives
2,124
852
3,893
1,536
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 and foreign exchange 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
2022
2021
Debt securities
5,437
5,870
Loans and receivables
722
485
6,159
6,355
\u2018Financial assets designated at fair value through profit or loss\u2019 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 \u2018Financial assets designated at fair value through profit or loss\u2019
approximates its carrying value and amounts to EUR 6,159 million (2021: EUR 6,355 million). The cumulative
change in fair value of the loans and debt securities attributable to changes in credit risk is EUR 345 million
(2021: EUR 99 million)
The notional value of the related credit derivatives is EUR 3,370\u00a0million (2021: EUR 2,640 million). The
cumulative change in fair value of the credit derivatives attributable to changes in credit risk since the
financial assets were first designated, amounts to EUR 3\u00a0million (2021: EUR -69 million) and the change for
the current year is EUR 72\u00a0million (2021: EUR -53 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
2022
2021
Equity securities
203
161
Debt securities
821
787
Loans and receivables
45,820
41,735
46,844
42,684
Equity securities are individually insignificant for ING Bank. For debt securities ING Bank total exposure
reference is made to Note 6 'Securities at amortised cost'. Loans and receivables include mainly reverse
repurchase agreements.
5\u00a0 Financial assets at fair value through other comprehensive income
Financial assets at fair value through other comprehensive income by type
in EUR million
2022
2021
Equity securities
1,887
2,457
Debt securities 1
29,095
27,340
Loans and advances 1
643
838
31,625
30,635
1 Debt securities include an amount of EUR -21\u00a0million (2021: EUR -12 million) and the Loans and advances includes EUR
-1\u00a0million(2021: EUR -1 million) of Loan loss provisions.
Exposure to equity securities
Equity securities designated as at fair value through other comprehensive income
Carrying
value
Carrying
value
Dividend
income
Dividend
income
in EUR million
2022
2021
2022
2021
Investment in Bank of Beijing
1,614
1,700
111
97
Other Investments
273
757
38
25
1,887
2,457
149
122
1Fair value through other comprehensive income debt instruments includes both debt securities and loans and advances.
2Changes in unrealized revaluations of FVOCI debt instruments include changes on hedged items which are recognized in the
statement of profit or loss. Reference is made to .Note 19 'Equity' for details on the changes in revaluation reserve.
FVOCI equity securities
In 2022, disposals of EUR 492 million mainly relate to the sale in the second quarter of HQLA eligible equity
instruments triggered by the changing interest rate environment and deteriorating market sentiment. This
portfolio was built up in early 2021 (additions in 2021: EUR 499 million) and was a relatively small part of the
HQLA portfolio. This was a diversified buy-and-hold portfolio aimed at generating stable dividend income
stream.
In 2022, exchange rate differences of EUR -39 million are mainly related to the stake in Bank of Beijing
following the depreciation of CNY vs EUR. Furthermore, changes in unrealised revaluations of equity
securities are mainly related to negative revaluation of the stake in Bank of Beijing following a decline in
share price (EUR -49 million).
FVOCI debt instruments
In 2022, changes in unrealised revaluations of EUR -3,230 million relate to increased yield curves.
Reference is made to Note 6 'Securities at amortised cost' for details on ING Bank\u2019s total exposure to debt
securities.
6\u00a0 Securities at amortised cost
Securities at amortised cost fully consist of Debt securities. ING Bank\u2019s exposure to debt securities is
included in the following lines in the statement of financial position:
Exposure to debt securities
in EUR million
2022
2021
Debt securities at fair value through other comprehensive income
29,095
27,340
Debt securities at amortised cost
48,160
48,319
Debt securities at fair value through other comprehensive income and amortised cost
77,255
75,659
Trading assets
4,189
5,319
Debt securities at fair value through profit or loss
6,258
6,658
Total debt securities at fair value through profit or loss
10,447
11,976
87,703
87,635
ING Bank\u2019s total exposure to debt securities (excluding debt securities held in the trading portfolio) of EUR
83,513 million (31\u00a0December 2021: EUR 82,316 million) is specified as follows:
Debt securities by type of exposure
Debt Securities at
FVPL
Debt Securities at
FVOCI
Debt Securities at
AC
Total
in EUR million
2022
2021
2022
2021
2022
2021
2022
2021
Government bonds
63
48
16,016
16,271
24,629
26,588
40,708
42,908
Sub-sovereign, Supranationals
and Agencies
2,343
3,115
8,529
7,587
14,210
13,752
25,082
24,454
Covered bonds
2,663
1,729
5,543
5,063
8,206
6,792
Corporate bonds
857
778
108
156
26
90
991
1,024
Financial institutions' bonds
2,237
1,993
772
798
2,551
1,932
5,561
4,724
ABS portfolio
758
723
1,028
810
1,217
913
3,003
2,445
6,258
6,658
29,116
27,352
48,177
48,338
83,551
82,347
Loan loss provisions
-21
-12
-17
-19
-39
-31
Debt securities portfolio
6,258
6,658
29,095
27,340
48,160
48,319
83,513
82,316
7\u00a0 Loans and advances to customers
Loans and advances to customers by type 1
Netherlands
Rest of the world
Total
in EUR million
2022
2021
2022
2021
2022
2021
Loans to public authorities
837
1,153
11,840
9,672
12,677
10,824
Residential mortgages
107,952
110,283
205,511
203,529
313,463
313,813
Other personal lending
5,835
6,551
30,345
31,511
36,180
38,063
Corporate Lending
68,128
68,104
211,092
202,020
279,220
270,124
182,752
186,091
458,789
446,733
641,541
632,824
Loan loss provisions
-993
-1,119
-4,990
-4,156
-5,984
-5,274
181,759
184,972
453,798
442,577
635,557
627,550
As at 31\u00a0December 2022 EUR 635,361 million (2021: EUR 627,390 million) of loans and advances to
customers are non-subordinated.
No individual loan or advance has terms and conditions that significantly affect the amount, timing or
certainty of the consolidated cash flows of ING Bank.
Loans and advances to customers and to banks include finance lease receivables and are detailed as
follows:
Finance lease receivables 1
in EUR million
2022
2021
Maturities of gross investment in finance lease receivables
-\u00a0 within 1 year
3,452
3,204
-\u00a0 between 1-2 years
2,463
2,311
-\u00a0 between 2-3 years
1,870
1,716
-\u00a0 between 3-4 years
1,294
1,178
-\u00a0 between 4-5 years
747
734
-\u00a0 more than 5 years
1,423
1,495
11,251
10,637
Unearned future finance income on finance leases
-792
-525
Net investment in finance leases
10,459
10,112
Included in Loans and advances to banks
6
5
Included in Loans and advances to customers
10,453
10,106
10,459
10,112
1The total loan loss provision of EUR 160 million (2021: EUR\u00a0167 million) for finance lease receivables is classified into the following loan
loss provision stages: Stage 1: EUR 9 million (2021: EUR 8 million), Stage 2: EUR 28 million (2021: EUR 30 million) and Stage 3: EUR 123
million (2021: EUR 129 million).
The finance lease receivables mainly relate to the financing of equipment and are mainly part of corporate
lending. To a lesser extent, the finance lease receivables relate to real estate for third parties, where ING is
the lessor. Interest income in 2022 on finance lease receivables amounts to EUR 292 million (2021: EUR 217
million).
12\u00a0 Deposits from banks
Deposits from banks includes non-subordinated deposits and repurchase agreements from banks.
Deposits from banks by type
Netherlands
Rest of the world
Total
in EUR million
2022
2021
2022
2021
2022
2021
Non-interest bearing
86
570
315
321
400
891
Interest bearing
32,858
51,893
23,374
32,307
56,232
84,201
32,943
52,463
23,689
32,629
56,632
85,092
For the details of the applicable rates and impact on net interest
income reference is made to Note 20 'Net interest income'.
13\u00a0 Customer deposits
Customer deposits
in EUR million
2022
2021
Savings accounts
321,005
314,893
Credit balances on customer accounts
283,886
280,028
Corporate deposits
43,308
28,183
Other
38,143
34,727
686,341
657,831
Trading liabilities
Trading liabilities by type
in EUR million
2022
2021
Equity securities
935
322
Debt securities
1,291
753
Funds on deposit
5,993
7,513
Derivatives
30,869
18,525
39,088
27,113
Reference is made to Note 36 'Derivatives and hedge accounting' for information on derivatives used for
hedge accounting.
Other non-trading derivatives mainly includes interest rate swaps and foreign currency swaps for hedging
purposes, but 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
2022
2021
Debt securities
6,069
5,585
Funds entrusted
44,731
35,993
Subordinated liabilities
82
230
50,883
41,808
As at 31\u00a0December 2022, 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 -75 million (2021: EUR\u00a095 million) on a cumulative
basis. 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 Bank 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 8,408 million (2021: EUR\u00a06,853 million).
Funds entrusted include mainly repurchase agreements. In 2022, the balance increased to EUR 44,731
million as a result of rising customer demand.
17\u00a0 Debt securities in issue
Debt securities in issue relates 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 Bank, except for subordinated items. Debt securities in issue does not include debt securities
presented as Financial liabilities at fair value through profit or loss. ING Bank does not have debt securities
that are issued on terms other than those available in the normal course of business.
Debt securities in issue \u2013 maturities
In EUR million
2022
2021
Fixed rate debt securities
Within 1 year
18,044
31,785
More than 1 year but less than 2 years
1,217
3,135
More than 2 years but less than 3 years
4,702
1,235
More than 3 years but less than 4 years
2,903
1,729
More than 4 years but less than 5 years
2,880
2,914
More than 5 years
13,221
13,133
Total fixed rate debt securities
42,969
53,930
Floating rate debt securities
Within 1 year
13,856
2,266
More than 1 year but less than 2 years
307
130
More than 2 years but less than 3 years
256
137
More than 3 years but less than 4 years
494
194
More than 4 years but less than 5 years
97
192
More than 5 years
96
593
Total floating rate debt securities
15,106
3,513
Total debt securities
58,075
57,443
Reference is made to Note 29 'Changes in liabilities arising from financing activities' for further information
on issuances, redemptions and non-cash movements.
18\u00a0 Subordinated loans
Subordinated loans
In EUR million
2022
2021
Subordinated loans
15,789
16,719
15,789
16,719
Subordinated loans relate to subordinated capital debentures and private loans which may be included in
the calculation of the capital ratio.\u00a0
Subordinated loans include loans that qualify as Tier 1 and Tier 2 (CRD IV eligible) capital. Subordinated loans
of EUR 16,364 million (2021: EUR 15,879 million) have been placed with ING Bank N.V. by ING Groep N.V.
Reference is made to Note 39 'Derivatives and hedge accounting' for details on fair value hedge accounting.
In 2022 ING Groep N.V. issued in August EUR 1 billion 4.13% Fixed Rate Subordinated Tier 2 Green Notes. This
issuance was subsequently placed by ING Groep N.V. with ING Bank N.V. against the same conditions.
ING Bank N.V. redeemed with ING Group N.V. in April 2022 USD 1 billion 6.875% Perpetual Additional Tier 1
Contingent Convertible Capital Securities and in May 2022 JPY 10 billion 1.10% Subordinated Tier 2 Notes on
the first call dates.
Reference is made to Note 32 'Changes in liabilities arising from financing activities' for further information
on issuances and redemptions.
The average interest rate on subordinated loans is 4.00% (2021: 3.74%). The interest expense during the
year 2022 was EUR 646 million (2021: EUR 573 million).
24\u00a0 Net result on derecognition of financial assets measured at amortised
cost
Net result on derecognition of financial assets measured at amortised cost
in EUR million
2022
2021
2020
Loans at amortised cost
1
4
Securities at amortised cost
-5
-1
185
-5
0
189
1 Includes assets on demand.
2 Includes other financial assets such as current and deferred tax assets as presented in the consolidated statement of the financial position. Additionally, non-financial assets are included in that position where maturities are not applicable as property and equipment and
investments in associates and joint ventures. Due to their nature non-financial assets consist mainly of assets expected to be recovered after more than 12 months.
38\u00a0 Liabilities and off-balance sheet commitments by maturity
The tables below include all liabilities and off-balance sheet commitments by maturity based on
contractual, undiscounted cash flows. These balances are included in the maturity analysis as follows:
\u2022Perpetual liabilities are included in the column \u2018Maturity not applicable\u2019.
\u2022Derivative liabilities are included on a net basis if cash flows are settled net. For other derivative liabilities
the contractual gross cash flow payable is included.
\u2022Undiscounted future coupon interest on financial liabilities payable is included in a separate line and in
the relevant maturity bucket.
\u2022Non-financial liabilities are included based on a breakdown of the amounts per statement of financial
position, per expected maturity.
\u2022Loans and other credit-related commitments are classified on the basis of the earliest date they can be
drawn down.
ING Bank\u2019s expected cash flows on some financial liabilities vary significantly from contractual cash flows.
Principal differences are in demand deposits from customers that are expected to remain stable or increase
and in unrecognised loan commitments that are not all expected to be drawn down immediately. Reference
is made to the liquidity risk paragraph in \u2018Risk Management \u2013 Funding and liquidity risk\u2019 for a description on
how liquidity risk is managed.
Liabilities and off-balance sheet commitments by maturity
in EUR million
2022
Less than 1 month 1
1\u20133 months
3\u201312 months
1\u20135 years
Over 5 years
Maturity not applicable
Adjustment\u00a0 2
Total
Deposits from banks
10,053\u00a0
2,238\u00a0
33,268\u00a0
9,878\u00a0
1,794\u00a0
\u00a0
-598\u00a0
56,632\u00a0
Customer deposits
605,706\u00a0
16,294\u00a0
22,637\u00a0
24,641\u00a0
20,304\u00a0
\u00a0
-3,240\u00a0
686,341\u00a0
Financial liabilities at fair value through profit or loss
\u2013\u00a0 Other trading liabilities
5,778\u00a0
875\u00a0
304\u00a0
771\u00a0
575\u00a0
\u00a0
-83\u00a0
8,219\u00a0
\u2013\u00a0 Trading derivatives
2,100\u00a0
2,319\u00a0
4,942\u00a0
9,330\u00a0
3,609\u00a0
\u00a0
8,570\u00a0
30,869\u00a0
\u2013\u00a0 Non-trading derivatives
345\u00a0
288\u00a0
216\u00a0
1,204\u00a0
470\u00a0
\u00a0
525\u00a0
3,048\u00a0
\u2013\u00a0 Designated at fair value through profit or loss
31,505\u00a0
11,472\u00a0
1,626\u00a0
3,177\u00a0
3,699\u00a0
21\u00a0
-618\u00a0
50,883\u00a0
Debt securities in issue
2,049\u00a0
11,227\u00a0
18,626\u00a0
12,857\u00a0
15,905\u00a0
\u00a0
-2,587\u00a0
58,075\u00a0
Subordinated loans
\u00a0
\u00a0
760\u00a0
\u00a0
9,936\u00a0
6,307\u00a0
-1,214\u00a0
15,789\u00a0
Lease liabilities
19\u00a0
43\u00a0
170\u00a0
593\u00a0
377\u00a0
\u00a0
-28\u00a0
1,174\u00a0
Financial liabilities
657,554\u00a0
44,755\u00a0
82,548\u00a0
62,450\u00a0
56,668\u00a0
6,328\u00a0
727\u00a0
911,030\u00a0
Other liabilities 3
9,659\u00a0
683\u00a0
2,395\u00a0
638\u00a0
406\u00a0
\u00a0
\u00a0
13,781\u00a0
Total liabilities
667,213\u00a0
45,438\u00a0
84,943\u00a0
63,089\u00a0
57,074\u00a0
6,328\u00a0
727\u00a0
924,811\u00a0
Coupon interest due on financial liabilities
426\u00a0
719\u00a0
3,171\u00a0
6,408\u00a0
3,166\u00a0
348\u00a0
\u00a0
14,237\u00a0
Contingent liabilities in respect of
\u2013\u00a0 Discounted bills
\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
\u2013\u00a0 Guarantees
28,304\u00a0
\u00a0
\u00a0
4\u00a0
550\u00a0
\u00a0
\u00a0
28,859\u00a0
\u2013\u00a0 Irrevocable letters of credit
15,660\u00a0
19\u00a0
3\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
15,682\u00a0
\u2013\u00a0 other
\u00a0
\u00a0
\u00a0
\u00a0
3\u00a0
\u00a0
\u00a0
3\u00a0
Irrevocable facilities
161,147\u00a0
\u00a0
194\u00a0
434\u00a0
166\u00a0
\u00a0
\u00a0
161,940\u00a0
205111.478
18.786
197.475
438.013
718.593
0\u00a0
0\u00a0
206,484\u00a0
1 Includes liabilities on demand.
2 This column reconciles the contractual undiscounted cash flows on financial liabilities to the statement of financial position values. The adjustments mainly relate to the impact of discounting and fair value hedge adjustments, and for derivatives, to the fact that the contractual
cash flows are presented on a gross basis (unless the cash flows are actually settled net).
3 Includes Other liabilities, Current and deferred tax liabilities, and Provisions as presented in the Consolidated statement of financial position.
Liabilities and off-balance sheet commitments by maturity
in EUR million
2021
Less than 1 month 1
1\u20133 month
3\u201312 months
1\u20135 years
Over 5 years
Maturity not applicable
Adjustment 2
Total
Deposits from banks
10,477
1,062
1,387
71,413
1,719
-967
85,092
Customer deposits
597,906
14,989
6,849
17,814
19,718
557
657,831
Financial liabilities at fair value through profit or loss
\u2013\u00a0 Other trading liabilities
6,965
397
322
462
438
4
8,588
\u2013\u00a0 Trading derivatives
1,689
1,608
3,674
8,295
5,731
-2,472
18,525
\u2013\u00a0 Non-trading derivatives
546
245
422
900
571
-564
2,120
\u2013\u00a0 Designated at fair value through profit or loss
24,862
10,224
771
1,850
3,719
20
362
41,808
Debt securities in issue
2,766
15,826
15,459
9,667
12,581
1,145
57,443
Subordinated loans
716
8,948
6,822
233
16,719
Lease liabilities
18
40
159
571
454
-23
1,220
Financial liabilities
645,229
44,391
29,042
111,688
53,880
6,843
-1,725
889,346
Other liabilities 3
8,810
487
2,500
591
934
13,321
Total liabilities
654,039
44,877
31,541
112,279
54,813
6,843
-1,725
902,668
Coupon interest due on financial liabilities
195
407
1,010
2,602
2,727
387
7,328
Contingent liabilities in respect of
\u2013\u00a0 Discounted bills
\u2013\u00a0 Guarantees
25,911
550
26,461
\u2013\u00a0 Irrevocable letters of credit
16,851
16,851
\u2013\u00a0 other
1
2
5
8
Irrevocable facilities4
143,891
1
13
184
78
144,167
186,653
1
15
189
628
0
0
187,486
1 Includes liabilities on demand.
2 This column reconciles the contractual undiscounted cash flows on financial liabilities to the statement of financial position values. The adjustments mainly relate to the impact of discounting and fair value hedge adjustments, and for derivatives, to the fact that the contractual
cash flows are presented on a gross basis (unless the cash flows are actually settled net).
3 Includes Other liabilities, Current and deferred tax liabilities, and Provisions as presented in the Consolidated statement of financial position.
40\u00a0 Offsetting financial assets and liabilities
The following tables include information about rights to offset and the related arrangements. The amounts
included consist of all recognised financial instruments that are presented net in the statement of financial
position under the IFRS netting criteria (legal right to offset and intention to settle net or to realise the asset
and settle the liability simultaneously) and amounts presented gross in the statement of financial position
but subject to enforceable master netting arrangements or similar arrangements.
At ING Bank amounts that are offset mainly relate to derivatives transactions, sale and repurchase
agreements, securities lending agreements and cash pooling arrangements. A significant portion of
offsetting is applied to OTC derivatives which are cleared through central clearing parties.
Related amounts not set off in the statement of financial position include transactions where:
\u2022The counterparty has an offsetting exposure and a master netting or similar arrangement is in place with
a right to set off only in the event of default, insolvency or bankruptcy, or the offsetting criteria are
otherwise not satisfied, and
\u2022In the case of derivatives and securities lending or sale and repurchase agreements, cash and non-cash
collateral has been received or pledged to cover net exposure in the event of a default or other
predetermined events. The effect of over-collateralisation is excluded.
The net amounts resulting after set off are not intended to represent ING\u2019s actual exposure to counterparty
risk, as risk management employs a number of credit risk mitigation strategies in addition to netting and
collateral arrangements. Reference is made in the Risk Management Credit risk\u2019 section \u2018Credit risk
mitigation'.
Financial assets subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million
2022
Gross amounts of
recognised financial
assets
Gross amounts of
recognised financial
liabilities offset in
the statement of
financial position
Net amounts of
financial assets
presented in the
statement of
financial position
Related amounts not offset\u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0
in the statement of financial position
Net amount
Amounts not
subject to
enforceable
netting
arrangements
Statement of
financial position
total \u00b9
Financial
instruments
Cash and financial
instruments
received as
collateral
Statement of financial position line item
Financial instrument
Loans and advances to banks 2
Reverse repurchase, securities\u00a0
borrowing and similar agreements
2,576
2,576
2,549
27
16,820
19,395
Other
1
1
1
-1
2,576
2,576
1
2,549
27
16,819
19,395
Financial assets at fair value through profit or
loss
Trading and Non-trading
Reverse repurchase, securities
borrowing and similar agreements
51,870
-21,245
30,625
102
29,813
710
22,260
52,886
Derivatives
134,253
-106,523
27,730
18,190
4,525
5,015
7,004
34,734
186,123
-127,768
58,355
18,292
34,337
5,726
29,264
87,619
Loans and advances to customers 3
Reverse repurchase, securities
borrowing and similar agreements
155
155
155
1,151
1,306
Cash pools
224,261
-222,857
1,404
74
889
441
1,404
224,416
-222,857
1,559
74
1,044
441
1,151
2,710
Other items where offsetting is applied in the
statement of financial position 4
6,750
-5,899
851
74
777
851
Total financial assets
419,865
-356,524
63,341
18,440
37,930
6,971
47,234
110,576
1\u2018The statement of financial position total\u2019 is the sum of \u2018Net amounts of financial assets presented in the statement of financial position\u2019 and \u2019Amounts not subject to enforceable master netting arrangements\u2019.
2At 31 December 2021, the total amount of \u2018Loans and advances to banks\u2019 excluding repurchase agreements is EUR 20,188 million which is not subject to offsetting.
3At 31 December 2021, the total amount of \u2018Loans and advances to customers\u2019 excluding repurchase agreements is EUR 627,063 million of which the net cash pool position of EUR 1,806 million is subject to offsetting.
4Other items mainly include amounts to be settled with Central Clearing Counterparties regarding securities and derivatives transactions and is included in \u2018Other Assets \u2013 Amounts to be settled\u2019 for EUR 2,424 million in the statement of financial position of which EUR 222 million
is subject to offsetting as at 31 December 2021.
Financial liabilities subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million
2022
Related amounts not offset in the
statement of financial position
Amounts not
subject to
enforceable
netting
arrangements
Statement of
financial
position total \u00b9
Gross amounts of
recognised financial
liabilities
Gross amounts of
recognised financial
assets offset in the
statement of
financial position
Net amounts of
financial liabilities
presented in the
statement of
financial position
Financial
instruments
Cash and financial
instruments
pledged as
collateral
Net amount
Statement of financial position line item
Financial instrument
Deposits from banks 2
Repurchase, securities lending
and similar agreements
3,809
3,809
Other
3,809
3,809
Customer deposits 3
Repurchase, securities lending
and similar agreements
Cash pools
236,219
-222,857
13,362
52
13,310
13,362
236,219
-222,857
13,362
52
13,310
13,362
Financial liabilities at fair value through profit or
loss
Trading and Non-trading
Repurchase, securities lending
and similar agreements
57,871
-21,245
36,626
102
31,868
4,655
12,220
48,846
Derivatives
127,937
-103,988
23,949
18,215
4,964
770
9,967
33,917
185,808
-125,233
60,575
18,317
36,833
5,425
22,187
82,762
Other items where offsetting is applied in the
statement of financial position 4
8,535
-8,435
100
70
30
100
Total financial liabilities
430,561
-356,524
74,037
18,440
36,833
18,765
25,996
100,033
1\u2018The statement of financial position total\u2019 is the sum of \u2018Net amounts of financial liabilities presented in the statement of financial position\u2019 and \u2019Amounts not subject to enforceable master netting arrangements\u2019.
2At 31 December 2021, the total amount of \u2018Deposits from banks\u2019 excluding repurchase agreements is EUR 80,954 million of which EUR 2 million is subject to offsetting.
3At 31 December 2021, the total amount of \u2018Customers deposits\u2019 excluding repurchase agreements is EUR 657,831 million of which the net cash pool position of EUR 13,408 million is subject to offsetting.
4Other items mainly include amounts to be settled with Central Clearing Counterparties regarding securities and derivatives transactions and is included in \u2018Other Liabilities \u2013 Amounts to be settled\u2019 for EUR 5,082 million in the statement of financial position of which EUR 250
million is subject to offsetting as at 31 December 2021.", "dimensions": { "concept": "ifrs-full:DisclosureOfFinancialInstrumentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV85Ny9mcmFnOjdkZGFlOGFiMDA3YzQwY2E5YmJhM2JkMTk3NjU3YTE0L3RleHRyZWdpb246N2RkYWU4YWIwMDdjNDBjYTliYmEzYmQxOTc2NTdhMTRfODQ_1ace7552-aae5-409d-bf57-dca78bcb1c38": { "value": "
2\u00a0 Cash and balances with central banks
Cash and balances with central banks
in EUR million
2022
2021
Amounts held at central banks 1
85,934\u00a0
104,870\u00a0
Cash and bank balances
1,681\u00a0
1,650\u00a0
87,614
106,520
1 Amounts held at central banks include an amount of EUR -12 million (2021: EUR -6 million) of Loan loss provisions.
The movement in Cash and balances with central banks reflects ING\u2019s active liquidity management.
Amounts held at central banks reflect on demand balances.
Reference is made to Note 39 'Transfer of financial assets, assets pledged and received as collateral' for
restrictions on amounts held at central banks.
", "dimensions": { "concept": "ifrs-full:DisclosureOfCashAndBankBalancesAtCentralBanksExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMDAvZnJhZzowMTA4ZjBhZDEzOTY0MmI1OTNmODY3NTAzZTU5NDM5ZC90ZXh0cmVnaW9uOjAxMDhmMGFkMTM5NjQyYjU5M2Y4Njc1MDNlNTk0MzlkXzQ1_19b43fb5-5d13-45e5-9d64-230cae92091d": { "value": "
3\u00a0 Loans and advances to banks
Loans and advances to banks
Netherlands
Rest of the world
Total
in EUR million
2022
2021
2022
2021
2022
2021
Loans and advances to banks
23,462
7,018
11,679
16,595
35,140
23,613
Loan loss provisions
-12
-10
-26
-13
-37
-22
23,450
7,009
11,653
16,582
35,103
23,591
Loans include balances (mainly reverse repos) with central banks amounting to EUR 19,395 million (2021:
EUR 3,403 million). 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\u00a0December 2022 and at 31 December 2021, all loans and advances to banks are non-subordinated.
", "dimensions": { "concept": "ifrs-full:DisclosureOfLoansAndAdvancesToBanksExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMDMvZnJhZzpjM2Q1OWU0OThkYzg0OGZhODYzMDNiMjAyNzJlZWQ2My90ZXh0cmVnaW9uOmMzZDU5ZTQ5OGRjODQ4ZmE4NjMwM2IyMDI3MmVlZDYzXzE4OQ_98dc9b0e-63ee-4af9-9566-d67ffb9d1458": { "value": "
4\u00a0 Financial assets at fair value through profit or loss
Financial assets at fair value through profit or loss
in EUR million
2022
2021
Trading assets
56,875
51,389
Non-trading derivatives
3,893
1,536
Designated at fair value through profit or loss
6,159
6,355
Mandatorily measured at fair value through profit or loss
46,844
42,684
113,770
101,964
Securities purchased under agreements to resell (reverse repos), securities borrowings and similar
agreements are not recognised in the consolidated statement of financial position. 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, Other financial assets 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. The counterparty liability is
measured at FVPL (designated) and included in Other financial liabilities at FVPL if the asset is measured at
FVPL. Otherwise, the counterparty liability is included in Deposits from banks, or Trading, as appropriate.
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.
Trading assets
Trading assets by type
in EUR million
2022
2021
Equity securities
11,741
17,574
Debt securities
4,189
5,319
Derivatives
30,841
19,764
Loans and receivables
10,103
8,733
56,875
51,389
for information on
trading liabilities.
Non-trading derivatives
Non-trading derivatives by type
in EUR million
2022
2021
Derivatives used in
-\u00a0 fair value hedges
836
365
-\u00a0 cash flow hedges
814
300
-\u00a0 hedges of net investments in foreign operations
119
18
Other non-trading derivatives
2,124
852
3,893
1,536
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 and foreign exchange 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
2022
2021
Debt securities
5,437
5,870
Loans and receivables
722
485
6,159
6,355
\u2018Financial assets designated at fair value through profit or loss\u2019 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 \u2018Financial assets designated at fair value through profit or loss\u2019
approximates its carrying value and amounts to EUR 6,159 million (2021: EUR 6,355 million). The cumulative
change in fair value of the loans and debt securities attributable to changes in credit risk is EUR 345 million
(2021: EUR 99 million)
The notional value of the related credit derivatives is EUR 3,370\u00a0million (2021: EUR 2,640 million). The
cumulative change in fair value of the credit derivatives attributable to changes in credit risk since the
financial assets were first designated, amounts to EUR 3\u00a0million (2021: EUR -69 million) and the change for
the current year is EUR 72\u00a0million (2021: EUR -53 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
2022
2021
Equity securities
203
161
Debt securities
821
787
Loans and receivables
45,820
41,735
46,844
42,684
Equity securities are individually insignificant for ING Bank. For debt securities ING Bank total exposure
reference is made to Note 6 'Securities at amortised cost'. Loans and receivables include mainly reverse
repurchase agreements.
14\u00a0 Financial liabilities at fair value through profit or loss
Financial liabilities at fair value through profit or loss
in EUR million
2022
2021
Trading liabilities
39,088
27,113
Non-trading derivatives
3,048
2,120
Designated at fair value through profit or loss
50,883
41,808
93,019
71,042
Trading liabilities
Trading liabilities by type
in EUR million
2022
2021
Equity securities
935
322
Debt securities
1,291
753
Funds on deposit
5,993
7,513
Derivatives
30,869
18,525
39,088
27,113
Reference is made to Note 36 'Derivatives and hedge accounting' for information on derivatives used for
hedge accounting.
Other non-trading derivatives mainly includes interest rate swaps and foreign currency swaps for hedging
purposes, but 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
2022
2021
Debt securities
6,069
5,585
Funds entrusted
44,731
35,993
Subordinated liabilities
82
230
50,883
41,808
As at 31\u00a0December 2022, 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 -75 million (2021: EUR\u00a095 million) on a cumulative
basis. 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 Bank 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 8,408 million (2021: EUR\u00a06,853 million).
Funds entrusted include mainly repurchase agreements. In 2022, the balance increased to EUR 44,731
million as a result of rising customer demand.", "dimensions": { "concept": "ifrs-full:DisclosureOfFinancialInstrumentsAtFairValueThroughProfitOrLossExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMDMvZnJhZzpjM2Q1OWU0OThkYzg0OGZhODYzMDNiMjAyNzJlZWQ2My90ZXh0cmVnaW9uOmMzZDU5ZTQ5OGRjODQ4ZmE4NjMwM2IyMDI3MmVlZDYzXzE4OQ_c87553f9-c393-4a83-863a-fc8c0b167808": { "value": "
4\u00a0 Financial assets at fair value through profit or loss
Financial assets at fair value through profit or loss
in EUR million
2022
2021
Trading assets
56,875
51,389
Non-trading derivatives
3,893
1,536
Designated at fair value through profit or loss
6,159
6,355
Mandatorily measured at fair value through profit or loss
46,844
42,684
113,770
101,964
Securities purchased under agreements to resell (reverse repos), securities borrowings and similar
agreements are not recognised in the consolidated statement of financial position. 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, Other financial assets 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. The counterparty liability is
measured at FVPL (designated) and included in Other financial liabilities at FVPL if the asset is measured at
FVPL. Otherwise, the counterparty liability is included in Deposits from banks, or Trading, as appropriate.
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.
Trading assets
Trading assets by type
in EUR million
2022
2021
Equity securities
11,741
17,574
Debt securities
4,189
5,319
Derivatives
30,841
19,764
Loans and receivables
10,103
8,733
56,875
51,389
for information on
trading liabilities.
Non-trading derivatives
Non-trading derivatives by type
in EUR million
2022
2021
Derivatives used in
-\u00a0 fair value hedges
836
365
-\u00a0 cash flow hedges
814
300
-\u00a0 hedges of net investments in foreign operations
119
18
Other non-trading derivatives
2,124
852
3,893
1,536
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 and foreign exchange 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
2022
2021
Debt securities
5,437
5,870
Loans and receivables
722
485
6,159
6,355
\u2018Financial assets designated at fair value through profit or loss\u2019 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 \u2018Financial assets designated at fair value through profit or loss\u2019
approximates its carrying value and amounts to EUR 6,159 million (2021: EUR 6,355 million). The cumulative
change in fair value of the loans and debt securities attributable to changes in credit risk is EUR 345 million
(2021: EUR 99 million)
The notional value of the related credit derivatives is EUR 3,370\u00a0million (2021: EUR 2,640 million). The
cumulative change in fair value of the credit derivatives attributable to changes in credit risk since the
financial assets were first designated, amounts to EUR 3\u00a0million (2021: EUR -69 million) and the change for
the current year is EUR 72\u00a0million (2021: EUR -53 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
2022
2021
Equity securities
203
161
Debt securities
821
787
Loans and receivables
45,820
41,735
46,844
42,684
Equity securities are individually insignificant for ING Bank. For debt securities ING Bank total exposure
reference is made to Note 6 'Securities at amortised cost'. Loans and receivables include mainly reverse
repurchase agreements.
5\u00a0 Financial assets at fair value through other comprehensive income
Financial assets at fair value through other comprehensive income by type
in EUR million
2022
2021
Equity securities
1,887
2,457
Debt securities 1
29,095
27,340
Loans and advances 1
643
838
31,625
30,635
1 Debt securities include an amount of EUR -21\u00a0million (2021: EUR -12 million) and the Loans and advances includes EUR
-1\u00a0million(2021: EUR -1 million) of Loan loss provisions.
Exposure to equity securities
Equity securities designated as at fair value through other comprehensive income
Carrying
value
Carrying
value
Dividend
income
Dividend
income
in EUR million
2022
2021
2022
2021
Investment in Bank of Beijing
1,614
1,700
111
97
Other Investments
273
757
38
25
1,887
2,457
149
122
1Fair value through other comprehensive income debt instruments includes both debt securities and loans and advances.
2Changes in unrealized revaluations of FVOCI debt instruments include changes on hedged items which are recognized in the
statement of profit or loss. Reference is made to .Note 19 'Equity' for details on the changes in revaluation reserve.
FVOCI equity securities
In 2022, disposals of EUR 492 million mainly relate to the sale in the second quarter of HQLA eligible equity
instruments triggered by the changing interest rate environment and deteriorating market sentiment. This
portfolio was built up in early 2021 (additions in 2021: EUR 499 million) and was a relatively small part of the
HQLA portfolio. This was a diversified buy-and-hold portfolio aimed at generating stable dividend income
stream.
In 2022, exchange rate differences of EUR -39 million are mainly related to the stake in Bank of Beijing
following the depreciation of CNY vs EUR. Furthermore, changes in unrealised revaluations of equity
securities are mainly related to negative revaluation of the stake in Bank of Beijing following a decline in
share price (EUR -49 million).
FVOCI debt instruments
In 2022, changes in unrealised revaluations of EUR -3,230 million relate to increased yield curves.
Reference is made to Note 6 'Securities at amortised cost' for details on ING Bank\u2019s total exposure to debt
securities.
14\u00a0 Financial liabilities at fair value through profit or loss
Financial liabilities at fair value through profit or loss
in EUR million
2022
2021
Trading liabilities
39,088
27,113
Non-trading derivatives
3,048
2,120
Designated at fair value through profit or loss
50,883
41,808
93,019
71,042
Trading liabilities
Trading liabilities by type
in EUR million
2022
2021
Equity securities
935
322
Debt securities
1,291
753
Funds on deposit
5,993
7,513
Derivatives
30,869
18,525
39,088
27,113
Reference is made to Note 36 'Derivatives and hedge accounting' for information on derivatives used for
hedge accounting.
Other non-trading derivatives mainly includes interest rate swaps and foreign currency swaps for hedging
purposes, but 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
2022
2021
Debt securities
6,069
5,585
Funds entrusted
44,731
35,993
Subordinated liabilities
82
230
50,883
41,808
As at 31\u00a0December 2022, 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 -75 million (2021: EUR\u00a095 million) on a cumulative
basis. 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 Bank 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 8,408 million (2021: EUR\u00a06,853 million).
Funds entrusted include mainly repurchase agreements. In 2022, the balance increased to EUR 44,731
million as a result of rising customer demand.
22\u00a0 Valuation results and net trading income
Valuation results and net trading income
in EUR million
2022
2021
2020
Securities trading results
-356
787
-500
Derivatives trading results
11
-554
701
Other trading results
71
84
72
Change in fair value of derivatives relating to
\u2013\u00a0 fair value hedges
5,265
-85
246
\u2013\u00a0 cash flow hedges (ineffective portion)
20
1
-5
\u2013\u00a0 other non-trading derivatives
1,164
-53
222
Change in fair value of assets and liabilities (hedged items)
-5,150
113
-183
Valuation results on assets and liabilities designated at FVPL (excluding trading)
444
-12
-121
Foreign exchange transactions results
33
566
422
1,503
847
852
and Note 14
'Financial liabilities at fair value through profit or loss' for information on trading assets and trading liabilities
respectively.
\u2018Valuation results and net trading income\u2019 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. During 2022, the interest rate movements
significantly affected the fair value changes of other non-trading derivatives as well as 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 is 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 CollVA). Spreads widened in 2022 compared to 2021 and the fair value changes increased.
In 2022, Derivatives trading results include EUR\u00a043 million CVA/DVA adjustments on trading derivatives
(2021: EUR 98 million; 2020: EUR 17 million).
Valuation results on assets and liabilities designated at fair value through profit or loss (excluding trading)\u2019
include fair value changes on financial assets and financial liabilities driven by changed market conditions.
Refer to Note 4 'Financial assets at fair value through profit or loss' and to Note 14 'Financial liabilities at fair
value through profit or loss'.
In addition, \u2018Valuation results on assets and liabilities designated at fair value through profit or loss
(excluding trading)\u2019 include fair value adjustments on own issued notes amounting to EUR 709 million (2021:
EUR 56 million; 2020: EUR 8 million).
Interest income from trading assets in 2022 amounted to EUR 18,593 million (2021: EUR 13,737 million;
2020: EUR 13,412 million). Interest expense from trading liabilities in 2022 amounted to EUR 18,765 million
(2021: EUR 14,079 million; 2020: EUR 13,052 million).
", "dimensions": { "concept": "ifrs-full:DisclosureOfFairValueOfFinancialInstrumentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMDMvZnJhZzpjM2Q1OWU0OThkYzg0OGZhODYzMDNiMjAyNzJlZWQ2My90ZXh0cmVnaW9uOmMzZDU5ZTQ5OGRjODQ4ZmE4NjMwM2IyMDI3MmVlZDYzXzIzMDg5NzQ0MTg1MTQ0_69220368-82ee-47f5-8311-d521ce79bcbc": { "value": "
(Reverse) repurchase transactions
Financial assets at fair value through profit or loss includes securities lending and sales and repurchase
transactions which were not derecognised, because ING Bank continues to be exposed to substantially all
risks and rewards of the transferred financial asset. For repurchase agreements the gross amount of assets
must be considered together with the gross amount of related liabilities, which are presented separately on
the statement of financial position since IFRS does not always allow netting of these positions in the
statement of financial position.
ING Bank\u2019s exposure to (reverse) repurchase transactions is included in the following lines in the statement
of financial position:
Exposure to (reverse) repurchase agreements
in EUR million
2022
2021
Reverse repurchase transactions
Loans and advances to banks
19,395
3,403
Loans and advances to customers
1,306
71
Trading assets, loans and receivables
9,732
8,026
Loans and receivables mandatorily measured at fair value through profit or loss
43,153
39,823
73,587
51,322
Repurchase transactions
Deposits from banks
3,809
4,138
Trading liabilities, funds on deposit
5,715
7,127
Funds entrusted designated and measured at fair value through profit or loss
43,131
34,608
52,654
45,873
Securities purchased under agreements to resell (reverse repos), securities borrowings and similar
agreements are not recognised in the consolidated statement of financial position. 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, Other financial assets 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. The counterparty liability is
measured at FVPL (designated) and included in Other financial liabilities at FVPL if the asset is measured at
FVPL. Otherwise, the counterparty liability is included in Deposits from banks, or Trading, as appropriate.
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.
", "dimensions": { "concept": "ifrs-full:DisclosureOfRepurchaseAndReverseRepurchaseAgreementsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMDMvZnJhZzpjM2Q1OWU0OThkYzg0OGZhODYzMDNiMjAyNzJlZWQ2My90ZXh0cmVnaW9uOmMzZDU5ZTQ5OGRjODQ4ZmE4NjMwM2IyMDI3MmVlZDYzXzIzMDg5NzQ0MTg1MTQ1_87abc68a-1b73-496a-8d2a-061108922026": { "value": "
Trading assets
Trading assets by type
in EUR million
2022
2021
Equity securities
11,741
17,574
Debt securities
4,189
5,319
Derivatives
30,841
19,764
Loans and receivables
10,103
8,733
56,875
51,389
for information on
trading liabilities.
", "dimensions": { "concept": "ifrs-full:DisclosureOfFinancialAssetsHeldForTradingExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMDMvZnJhZzpjM2Q1OWU0OThkYzg0OGZhODYzMDNiMjAyNzJlZWQ2My90ZXh0cmVnaW9uOmMzZDU5ZTQ5OGRjODQ4ZmE4NjMwM2IyMDI3MmVlZDYzXzIzMDg5NzQ0MTg1MTQ1_dd8d2c94-7cb4-4c26-a277-7d1e45ede2c9": { "value": "
Trading assets
Trading assets by type
in EUR million
2022
2021
Equity securities
11,741
17,574
Debt securities
4,189
5,319
Derivatives
30,841
19,764
Loans and receivables
10,103
8,733
56,875
51,389
for information on
trading liabilities.
Trading liabilities
Trading liabilities by type
in EUR million
2022
2021
Equity securities
935
322
Debt securities
1,291
753
Funds on deposit
5,993
7,513
Derivatives
30,869
18,525
39,088
27,113
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 and foreign exchange currency swaps for
which no hedge accounting is applied.
Non-trading derivatives
Non-trading derivatives by type
in EUR million
2022
2021
Derivatives used in:
-\u00a0 fair value hedges
244
270
-\u00a0 cash flow hedges
1,275
485
-\u00a0 hedges of net investments in foreign operations
83
88
Other non-trading derivatives
1,446
1,278
3,048
2,120
Reference is made to Note 36 'Derivatives and hedge accounting' for information on derivatives used for
hedge accounting.
Other non-trading derivatives mainly includes interest rate swaps and foreign currency swaps for hedging
purposes, but for which no hedge accounting is applied.
36\u00a0 Derivatives and hedge accounting
Use of derivatives
ING uses derivatives for economic hedging purposes to manage its asset and liability portfolios and
structural risk positions. The primary objective of ING\u2019s hedging activities is to manage the risks which arises
from structural imbalances in the duration and other profiles of its assets and liabilities. The objective of
economic hedging is to enter into positions with an opposite risk profile to an identified risk exposure to
reduce that exposure. The main risks which are being hedged are interest rate risk and foreign currency
exchange rate risk. These risks are primarily hedged with interest rate swaps, cross currency swaps and
foreign exchange forwards/swaps.
ING uses credit derivatives to manage its economic exposure to credit risk, including total return swaps and
credit default swaps, to sell or buy protection for credit risk exposures in the loan, investment, and trading
portfolios. Hedge accounting is not applied in relation to these credit derivatives.
Hedge accounting
Derivatives that qualify for hedge accounting under IFRS are classified and accounted for in accordance with
the nature of the instrument hedged and the type of IFRS hedge accounting model that is applicable. The
three models applicable under IFRS are: fair value hedge accounting, cash flow hedge accounting, and
hedge accounting of a net investment in a foreign operation. How and to what extent these models are
applied are described under the relevant headings below. The company\u2019s detailed accounting policies for
these three hedge models are set out in paragraph 1.7 \u2018Financial instruments\u2019 of Note 1 \u2018Basis of preparation
and significant accounting policies\u2019.
IBOR transition
Reference is made to the note Risk management/ IBOR Transition for information on how ING is managing
the transition to alternative benchmark rates and INGs progress in completing the transition.
At the reporting date, ING assessed the extent to which hedge relationships are subject to uncertainties
driven by IBOR reform.
The IBOR's in scope of ING\u2019s IBOR Transition program are a component of either the hedging instrument and/
or the hedged item where the interest rate and/or foreign currency risk are the designated hedged risk. The
hedged exposures are mainly loan portfolios, issued debt securities and purchased debt instruments.
ING early adopted the amendments to IAS 39 issued in September 2019 to these hedging relationships
directly affected by IBOR reform (Phase 1). This excludes EURIBOR hedges as EURIBOR is Benchmarks
Regulation compliant and continues to be available. Refer to section 1.7.4 of Note 1 \u2018Basis of preparation
and significant accounting policies\u2019 for more information on the Phase 1 amendments.
Phase 1 amendments to IFRS allow ING to apply a set of temporary exceptions to continue hedge
accounting even when there is uncertainty about contractual cash flows arising from IBOR reform. Phase 1
reliefs cease to apply when uncertainty arising from IBOR Reform is no longer present with respect to the
timing and amount of the IBOR-based cash flows of the relevant instruments.
In Poland the local working group (the 'National Working Group') for benchmark reform issued a roadmap to
replace the current Polish benchmark rate Warsaw Interbank Offered Rate (WIBOR) with a new rate named
Warsaw Interest Rate Overnight (WIRON). The National Working Group indicated that the plan is for the
market to be ready for a cessation of WIBOR by the start of 2025, consequently ING extended the
application of the phase 1 reliefs to those hedge accounting relationships that will be subject to WIBOR
reform.
Hedging relationships are being amended to incorporate the new benchmark rates. During 2022, ING
focussed on USD LIBOR contracts. In the coming year, ING will continue the focus on the remaining USD
LIBOR contracts as the used USD LIBOR tenors will cease to be published on 30 June 2023.
As of 31 December 2022, USD LIBOR and WIBOR indexed fair value and cash flow hedges are directly
affected by the uncertainties arising from the IBOR reform. In particular, uncertainties over the timing and
amount of the replacement rate may impact the effectiveness and highly probable assessment.
For these affected fair value and cash flow hedge relationships ING assumes that the USD LIBOR and WIBOR
based cash flows from the hedging instrument and hedged item will remain unaffected.
The same assumption is used to assess the likelihood of occurrence of the forecast transactions that are
subject to cash flow hedges. The hedged cash flows in cash flow hedges directly impacted by the IBOR
reform still meet the highly probable requirement, assuming the USD LIBOR and WIBOR benchmark on
which the hedged cash flows are based is not altered as a result of the reform.
The total gross notional amounts of hedging instruments as at 31 December that are used in the ING's
hedge accounting relationships for which the Phase 1 amendments to IAS39 were applied are:
Notional amounts of Hedging instruments in EUR mln as at 31 December
Benchmark
2022
2021
USD LIBOR
28,316
41,473
WIBOR1
57,774
1 WIBOR transition plans became concrete in 2022 and therefore no comparatives for 2021 are included.
Approximately 89% (31\u00a0December 2021: 72%) of the notional amounts for USD LIBOR have a maturity date
beyond 30 June 2023. Approximately 71% of the notional amounts for WIBOR have a maturity date beyond
1 January 2025.
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.
TLTRO
ING hedged the interest rate risk of the TLTRO-III funding with derivatives and designated this in a fair value
hedge relationship. In Q4 2022 the ECB changed the terms of the TLTRO-III, resulting in the discontinuation
of the hedging relationship. The fair value hedge adjustment was amortized to profit or loss over the revised
interest period (i.e. until the date the change in TLTRO-III terms became effective). The impact of this is
recorded in net interest income. Refer to Note 20 'Net interest income' for more details.
Fair value hedge accounting
ING\u2019s fair value hedges principally consist of interest rate swaps that are used to protect against changes in
the fair value of fixed-rate instruments due to movements in market interest rates. ING\u2019s approach to
manage market risk, including interest rate risk, is discussed in \u2018Risk management \u2013Market risk\u2019. ING\u2019s
exposure to interest rate risk is disclosed in paragraph \u2018Interest rate risk in banking book\u2019.
ING Bank designates specific non-contractual risk components of hedged items. This is usually determined
by designating benchmark interest rates such as EURIBOR, SOFR, SONIA or TONAR, between others.
By using derivative financial instruments to hedge exposures to changes in interest rates, ING also exposes
itself to credit risk of the derivative counterparty, which is not offset by the hedged item. ING minimises
counterparty credit risk in derivative instruments by clearing most of the derivatives through Central
Clearing Counterparties. In addition, ING only enters into transactions with high-quality counterparties and
requires posting collateral.
ING applies fair value hedge accounting on micro level in which one hedged item is hedged with one or
multiple hedging instruments as well as on macro level whereby a portfolio of items is hedged with multiple
hedging instruments. For these macro hedges of interest rate risk ING applies the EU carve-out. The EU
\u2018carve-out\u2019 for macro hedging enables a group of derivatives (or proportions) to be viewed in combination
and jointly designated as the hedging instrument and removes some of the limitations in fair value hedge
accounting relating to hedging core deposits and under-hedging strategies. In retail operations, exposure on
retail funding (savings and current accounts) and retail lending (mortgages) is initially offset. The remaining
exposure is hedged in a portfolio hedge, using the EU carve-out, in which a portion of the retail lending
portfolio and core deposits are designated as a hedged item for hedge accounting purposes.
For portfolio hedges the fair value is projected based on contractual terms and other variables including
prepayment expectations. These projected fair value of the portfolios form the basis for identifying the
notional amount subject to interest rate risk that is designated under fair value hedge accounting.
Micro fair value hedge accounting is mainly applied on issued debt securities and purchased debt
instruments for hedging interest rate risk.
Before fair value hedge accounting is applied, ING determines whether an economic relationship between
the hedged item and the hedging instrument exists based on an evaluation of the quantitative
characteristics of these items and the hedged risk that is supported by quantitative analysis. ING considers
whether the critical terms of the hedged item and hedging instrument closely align when assessing the
presence of an economic relationship. ING evaluates whether the fair value of the hedged item and the
hedging instrument respond similarly to similar risks. In addition, ING is mainly using regression analysis to
assess whether the hedging instrument is expected to be and has been highly effective in offsetting
changes in the fair value of the hedged item.
For the macro hedge on the loan portfolio ING follows a dynamic hedging strategy. This means that on
monthly basis, based on the new portfolio projection, the hedging relationship is renewed. From an
operational point of view, the existing hedging relationship is adjusted based on the new portfolio projection
and additional hedging instruments are added to the hedging relationship.
ING uses the following derivative financial instruments in a fair value hedge accounting relationship:
Gross carrying value of derivatives designated under fair value hedge accounting
in EUR million
Assets
2022
Liabilities
2022
Assets
2021
Liabilities
2021
As at 31 December
Hedging instrument on interest rate risk
\u2013 Interest rate swaps
40,346
32,482
6,629
5,940
\u2013 Other interest derivatives
395
39
87
83
Gains and losses on derivatives designated under fair value hedge accounting are recognised in the
statement of profit or loss. The effective portion of the fair value change on the hedged item is also
recognised in the statement of profit or loss in 'Valuation results and net trading income'. As a result, only
the net accounting ineffectiveness has an impact on the net result.
Hedged items included in a fair value hedging relationship
Carrying amount of the hedged items
Accumulated amount of fair value hedge
adjustment on the hedged item included in
the carrying amount of the hedged item
Change in fair value
used for measuring
ineffectiveness for the
period
Change in fair value
hedging instruments
Hedge ineffectiveness
recognised in the
statement of profit or
loss gain (+) / loss (-)
in EUR million
Assets
Liabilities
Assets
Liabilities
As at 31 December 2022
Interest rate risk
\u2013 Debt securities at fair value through other comprehensive income
19,816
n/a
-2,798
\u2013 Loans at FVOCI
35
n/a
-4
\u2013 Loans and advances to customers
58,673
-12,112
-11,466
\u2013 Debt instruments at amortised cost
4,098
-448
-678
\u2013 Debt securities in issue
26,040
-2,815
3,746
\u2013 Subordinated loans
15,767
-1,344
1,470
\u2013 Amounts due to banks
483
\u2013 Customer deposits and other funds on deposit
36,843
-3,373
4,099
\u2013 Discontinued hedges
2,966
34
Total
82,623
78,650
-9,594
-7,497
-5,150
5,265
115
As at 31 December 2021
Interest rate risk
\u2013 Debt securities at fair value through other comprehensive income
17,307
n/a
-798
\u2013 Loans at FVOCI
105
n/a
-2
\u2013 Loans and advances to customers
68,704
-923
-1,451
\u2013 Debt instruments at amortised cost
3,458
301
-165
\u2013 Debt securities in issue
22,553
945
962
\u2013 Subordinated loans
16,559
115
414
\u2013 Amounts due to banks
\u2013 Customer deposits and other funds on deposit
40,924
385
1,152
\u2013 Discontinued hedges
3,774
73
Total
89,574
80,037
3,153
1,518
112
-86
26
During 2022, the interest rate movements significantly affected the fair value changes of both the
derivatives and the hedged items designated in fair value hedges. Refer to note 22 \u2018Valuation results and
net trading income'.
In addition, the decrease in customer deposits is due to the discontinuation of the customer deposits
portfolio fair value hedge in Belgium. This hedge was discontinued and the related fair value adjustment
released due to changes in expected repricing of client rates as a result of the steep increase in interest
rates occurred in 2022. Discontinued hedges further mainly relate to the transfer of derivatives from UK
based clearing houses to EU based clearing houses related to Brexit in 2020.
The main sources of ineffectiveness are:
\u2022differences in maturities of the hedged item(s) and hedging instrument(s);
\u2022different interest rate curves applied to discount the hedged item(s) and hedging instrument(s);
\u2022differences in timing of cash flows of the hedged item(s) and hedging instrument(s).
Additionally, for portfolio (macro) fair value hedges of ING\u2019s fixed rate mortgage portfolio, ineffectiveness
also arises from the disparity between expected and actual prepayments (prepayment risk).
There were no other sources of significant ineffectiveness in these hedging relationships.
Cash flow hedge accounting
ING applies cash flow hedge accounting on micro and macro level. ING\u2019s cash flow hedges mainly consist of
interest rate swaps and cross-currency swaps that are used to protect against the exposure to variability in
future cash flows on non-trading assets and liabilities that bear interest at variable rates or are expected to
be refunded or reinvested in the future. The amounts and timing of future cash flows, representing both
principal and interest flows, are projected for each portfolio of financial assets and liabilities, based on
contractual terms and other variables including estimates of prepayments. These projected cash flows form
the basis for identifying the notional amount subject to interest rate risk or foreign currency exchange rate
risk that is designated under cash flow hedge accounting.
ING\u2019s approach to manage market risk, including interest rate risk and foreign currency exchange rate risk, is
discussed in \u2018Risk management \u2013 Credit risk and Market risk\u2019. ING determines the amount of the exposures
to which it applies hedge accounting by assessing the potential impact of changes in interest rates and
foreign currency exchange rates on the future cash flows from its floating-rate assets and liabilities. This
assessment is performed using analytical techniques.
As noted above for fair value hedges, by using derivative financial instruments to hedge exposures to
changes in interest rates and foreign currency exchange rates, ING exposes itself to credit risk of the
derivative counterparty, which is not offset by the hedged items. This exposure is managed similarly to that
for fair value hedges.
Gains and losses on the effective portions of derivatives designated under cash flow hedge accounting are
recognised in Other Comprehensive Income. Interest cash flows on these derivatives are recognised in the
statement of profit or loss in \u2018Net interest income\u2019 consistent with the manner in which the forecasted cash
flows affect net result. The gains and losses on ineffective portions of such derivatives are recognised
immediately in the statement of profit or loss in \u2018Valuation results and net trading income\u2019.
ING determines an economic relationship between the cash flows of the hedged item and the hedging
instrument based on an evaluation of the quantitative characteristics of these items and the hedged risk
that is supported by quantitative analysis. ING considers whether the critical terms of the hedged item and
hedging instrument closely align when assessing the presence of an economic relationship. ING evaluates
whether the cash flows of the hedged item and the hedging instrument respond similarly to the hedged
risk, such as the benchmark interest rate of foreign currency. In addition, a regression analysis is performed
to assess whether the hedging instrument is expected to be and has been highly effective in offsetting
changes in the fair value of the hedged item.
ING uses the following derivative financial instruments in a cash flow hedge accounting relationship:
Gross carrying value of derivatives used for cash flow hedge accounting
Assets
Liabilities
Assets
Liabilities
in EUR million
2022
2022
2021
2021
As at 31\u00a0December
Hedging instrument on interest rate risk
\u2013 Interest rate swaps
10,038
14,836
-437
781
Hedging instrument on combined interest and FX rate risk
\u2013 Cross currency interest rate derivatives
428
168
73
285
The derivatives used for cash flow hedge accounting are included in the statement of financial position line-
item \u2018Financial assets at fair value through profit or loss \u2013 Non-trading derivatives\u2019 EUR 814 million (2021:
EUR 300 million) respectively \u2018Financial liabilities at fair value through profit or loss \u2013 Non-trading derivatives\u2019
EUR 1,275 million (2021: EUR 485 million). The difference between the gross carrying value as presented in
the table and the net carrying value as presented in the statement of financial position is due to offsetting
with other derivatives and collaterals paid or received.
For the main currencies the average fixed rate for interest rate swaps used in cash flow hedge accounting
are 0.51% (2021: -0.16%) for EUR, 3.27% (2021: 1.73%) for PLN, 1.96% (2021: 2.09%) for USD and 1.28%
(2021: 0.55%) for AUD. The average currency exchange rates for cross currency swaps used in cash flow
hedge accounting is for EUR/USD 0.99 (2021: 1.01) and for EUR/AUD 1.58 (2021: 1.61).
The following table shows the net notional amount of derivatives designated in cash flow hedging split into
the maturity of the instruments. The net notional amounts presented in the table are a combination of
payer (+) and receiver (-) swaps.
Maturity derivatives designated in cash flow hedging
in EUR million
As at 31
December 2022
Less
than 1
month
1 to 3
months
3 to 12
months
1 to 2
year
2 to 3
years
3 to\u00a0 4
years
4 to 5
years
>5 years
Total
Hedging
instrument on
interest rate risk
\u2013 Interest rate
swaps
-562
-935
-6,730
-12,464
-8,926
-8,115
-3,620
-8,947
-50,300
Hedging
instrument on
combined interest
and FX rate risk
\u2013 Cross currency
interest rate
derivatives
-834
-1,535
-721
-2,140
-52
7
-48
-5,323
As at 31
December 2021
Hedging
instrument on
interest rate risk
\u2013 Interest rate
swaps
418
-1,075
-6,939
-5,470
-6,711
-5,825
-5,272
-18,107
-48,982
Hedging
instrument on
combined interest
and FX rate risk
\u2013 Cross currency
interest rate
derivatives
-256
-1,048
-1,760
-3,831
-2,528
-2,580
181
-56
-11,878
1 The carrying amount is the gross amount, excluding tax adjustments.
The decrease in the carrying amount of the cash flow hedge reserve is driven by increased interest rates.
The main sources of ineffectiveness for cash flow hedges are:
\u2022differences in timing of cash flows of the hedged item(s) and hedging instrument(s);
\u2022mismatches in reset frequency between hedged item and hedging instrument.
Hedges of net investments in foreign operations
A foreign currency exposure arises from a net investment in subsidiaries that have a different functional
currency from the presentation currency of ING. The risk arises from the fluctuation in spot exchange rates
between the functional currency of the subsidiaries and ING\u2019s presentation currency, which causes the
amount of the net investment to vary in the consolidated financial statements of ING. This risk may have a
significant impact on ING\u2019s financial statements. ING\u2019s policy is to hedge these exposures only when not
doing so it is expected to have a significant impact on the regulatory capital ratios of ING and its
subsidiaries.
ING\u2019s net investment hedges principally consist of derivatives (including currency forwards and swaps) and
non-derivative financial instruments such as foreign currency denominated funding. When the hedging
instrument is foreign currency denominated debt, ING assesses effectiveness by comparing past changes in
the carrying amount of the debt that are attributable to a change in the spot rate with past changes in the
investment in the foreign operation due to movement in the spot rate (the offset method).
Gains and losses on the effective portions of derivatives designated under net investment hedge accounting
are recognised in Other Comprehensive Income. The balance in equity is recognised in the statement of
profit or loss when the related foreign subsidiary is disposed. The gains and losses on ineffective portions are
recognised immediately in the statement of profit or loss in 'Valuation results and net trading income'.
ING has the following derivative financial instruments used for net investment hedging:
Gross carrying value of derivatives used for net investment hedging
Assets
Liabilities
Assets
Liabilities
in EUR million
2022
2022
2021
2021
As at 31 December
\u2013 FX forwards and Cross currency swaps
119
83
18
88
The derivatives used for net investment hedge accounting are included in the statement of financial position
line-item \u2018Financial assets at fair value through profit or loss \u2013 Non-trading derivatives\u2019 EUR 119 million
(2021: EUR 18 million) respectively \u2018Financial liabilities at fair value through profit or loss \u2013 Non trading
derivatives\u2019 EUR 83 million (2021: EUR 88 million).
For ING\u2019s main currencies the average exchange rates used in net investment hedge accounting for 2022
are EUR/USD 1.06 (2021: 1.18), EUR/PLN 4.68 (2021: 4.58), EUR/AUD 1.52 (2021: 1.58) and EUR/THB 36.87
(2021: 37.84).
The following table shows the notional amount of derivatives designated in net investment hedging split
into the maturity of the instruments:
Maturity derivatives designated in net investment hedging
in EUR million
As at 31
December 2022
Less than
1 month
1 to 3
months
3 to 12
months
1 to 2
year
2 to 3
years
3 to\u00a0 4
years
4 to 5
years
>5 years
Total
\u2013 FX forwards and
cross currency
swaps
-6,164
-2,638
-97
-8,899
As at 31
December 2021
\u2013 FX forwards and
Cross currency
swaps
-4,462
-461
-590
-5,514
The effect of the net investment hedge accounting in the statement of profit or loss and other
comprehensive income is as follows:
Net investment hedge accounting \u2013 Impact on statement of profit or loss and other comprehensive income
in EUR million
As at 31 December 2022
Change in
value used for
calculating
hedge
ineffectiveness
for the period
Carrying
amount net
investment
hedge reserve
at the end of
the reporting
period1
Hedged item
affected
statement of
profit or loss
Change in
value of
hedging
instrument
recognised in
OCI
Hedge
ineffectiveness
recognised in
the statement
of profit or loss,
gain(+) /
Loss(-)
Investment in foreign operations
0
-33
0
0
Discontinued hedges
304
-1
As at 31 December 2021
Investment in foreign operations
72
330
-72
-1
Discontinued hedges
-59
1 The carrying amount is the gross amount, excluding tax adjustments.
", "dimensions": { "concept": "ifrs-full:DisclosureOfDerivativeFinancialInstrumentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMDMvZnJhZzpjM2Q1OWU0OThkYzg0OGZhODYzMDNiMjAyNzJlZWQ2My90ZXh0cmVnaW9uOmMzZDU5ZTQ5OGRjODQ4ZmE4NjMwM2IyMDI3MmVlZDYzXzIzMDg5NzQ0MTg1MTQ3_ed30e6a1-ece7-43c8-96b9-2711824d74a6": { "value": "
Designated at fair value through profit or loss
Designated at fair value through profit or loss by type
in EUR million
2022
2021
Debt securities
5,437
5,870
Loans and receivables
722
485
6,159
6,355
\u2018Financial assets designated at fair value through profit or loss\u2019 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 \u2018Financial assets designated at fair value through profit or loss\u2019
approximates its carrying value and amounts to EUR 6,159 million (2021: EUR 6,355 million). The cumulative
change in fair value of the loans and debt securities attributable to changes in credit risk is EUR 345 million
(2021: EUR 99 million)
The notional value of the related credit derivatives is EUR 3,370\u00a0million (2021: EUR 2,640 million). The
cumulative change in fair value of the credit derivatives attributable to changes in credit risk since the
financial assets were first designated, amounts to EUR 3\u00a0million (2021: EUR -69 million) and the change for
the current year is EUR 72\u00a0million (2021: EUR -53 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.
Designated at fair value through profit or loss
Designated at fair value through profit or loss by type
in EUR million
2022
2021
Debt securities
6,069
5,585
Funds entrusted
44,731
35,993
Subordinated liabilities
82
230
50,883
41,808
As at 31\u00a0December 2022, 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 -75 million (2021: EUR\u00a095 million) on a cumulative
basis. 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 Bank 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 8,408 million (2021: EUR\u00a06,853 million).
Funds entrusted include mainly repurchase agreements. In 2022, the balance increased to EUR 44,731
million as a result of rising customer demand.", "dimensions": { "concept": "ifrs-full:DisclosureOfFinancialInstrumentsDesignatedAtFairValueThroughProfitOrLossExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMDMvZnJhZzpjM2Q1OWU0OThkYzg0OGZhODYzMDNiMjAyNzJlZWQ2My90ZXh0cmVnaW9uOmMzZDU5ZTQ5OGRjODQ4ZmE4NjMwM2IyMDI3MmVlZDYzXzM1MTg0MzcyMDkwNzI5_ed92572d-8cc9-4a72-8c78-bc1a1293605c": { "value": "
Mandatorily at fair value through profit or loss
Mandatorily at fair value through profit or loss by type
in EUR million
2022
2021
Equity securities
203
161
Debt securities
821
787
Loans and receivables
45,820
41,735
46,844
42,684
Equity securities are individually insignificant for ING Bank. For debt securities ING Bank total exposure
reference is made to Note 6 'Securities at amortised cost'. Loans and receivables include mainly reverse
repurchase agreements.
5\u00a0 Financial assets at fair value through other comprehensive income
Financial assets at fair value through other comprehensive income by type
in EUR million
2022
2021
Equity securities
1,887
2,457
Debt securities 1
29,095
27,340
Loans and advances 1
643
838
31,625
30,635
1 Debt securities include an amount of EUR -21\u00a0million (2021: EUR -12 million) and the Loans and advances includes EUR
-1\u00a0million(2021: EUR -1 million) of Loan loss provisions.
Exposure to equity securities
Equity securities designated as at fair value through other comprehensive income
Carrying
value
Carrying
value
Dividend
income
Dividend
income
in EUR million
2022
2021
2022
2021
Investment in Bank of Beijing
1,614
1,700
111
97
Other Investments
273
757
38
25
1,887
2,457
149
122
1Fair value through other comprehensive income debt instruments includes both debt securities and loans and advances.
2Changes in unrealized revaluations of FVOCI debt instruments include changes on hedged items which are recognized in the
statement of profit or loss. Reference is made to .Note 19 'Equity' for details on the changes in revaluation reserve.
FVOCI equity securities
In 2022, disposals of EUR 492 million mainly relate to the sale in the second quarter of HQLA eligible equity
instruments triggered by the changing interest rate environment and deteriorating market sentiment. This
portfolio was built up in early 2021 (additions in 2021: EUR 499 million) and was a relatively small part of the
HQLA portfolio. This was a diversified buy-and-hold portfolio aimed at generating stable dividend income
stream.
In 2022, exchange rate differences of EUR -39 million are mainly related to the stake in Bank of Beijing
following the depreciation of CNY vs EUR. Furthermore, changes in unrealised revaluations of equity
securities are mainly related to negative revaluation of the stake in Bank of Beijing following a decline in
share price (EUR -49 million).
FVOCI debt instruments
In 2022, changes in unrealised revaluations of EUR -3,230 million relate to increased yield curves.
Reference is made to Note 6 'Securities at amortised cost' for details on ING Bank\u2019s total exposure to debt
securities.
", "dimensions": { "concept": "ifrs-full:DisclosureOfInvestmentsOtherThanInvestmentsAccountedForUsingEquityMethodExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMTIvZnJhZzpmMmNjNTNlMDBkNmE0NDM3OWJmZTFmMjk1YzdiYjdlNi90ZXh0cmVnaW9uOmYyY2M1M2UwMGQ2YTQ0Mzc5YmZlMWYyOTVjN2JiN2U2Xzky_38a30e8b-024f-4f98-91ae-519a973b8775": { "value": "
7\u00a0 Loans and advances to customers
Loans and advances to customers by type 1
Netherlands
Rest of the world
Total
in EUR million
2022
2021
2022
2021
2022
2021
Loans to public authorities
837
1,153
11,840
9,672
12,677
10,824
Residential mortgages
107,952
110,283
205,511
203,529
313,463
313,813
Other personal lending
5,835
6,551
30,345
31,511
36,180
38,063
Corporate Lending
68,128
68,104
211,092
202,020
279,220
270,124
182,752
186,091
458,789
446,733
641,541
632,824
Loan loss provisions
-993
-1,119
-4,990
-4,156
-5,984
-5,274
181,759
184,972
453,798
442,577
635,557
627,550
As at 31\u00a0December 2022 EUR 635,361 million (2021: EUR 627,390 million) of loans and advances to
customers are non-subordinated.
No individual loan or advance has terms and conditions that significantly affect the amount, timing or
certainty of the consolidated cash flows of ING Bank.
Loans and advances to customers and to banks include finance lease receivables and are detailed as
follows:
Finance lease receivables 1
in EUR million
2022
2021
Maturities of gross investment in finance lease receivables
-\u00a0 within 1 year
3,452
3,204
-\u00a0 between 1-2 years
2,463
2,311
-\u00a0 between 2-3 years
1,870
1,716
-\u00a0 between 3-4 years
1,294
1,178
-\u00a0 between 4-5 years
747
734
-\u00a0 more than 5 years
1,423
1,495
11,251
10,637
Unearned future finance income on finance leases
-792
-525
Net investment in finance leases
10,459
10,112
Included in Loans and advances to banks
6
5
Included in Loans and advances to customers
10,453
10,106
10,459
10,112
1The total loan loss provision of EUR 160 million (2021: EUR\u00a0167 million) for finance lease receivables is classified into the following loan
loss provision stages: Stage 1: EUR 9 million (2021: EUR 8 million), Stage 2: EUR 28 million (2021: EUR 30 million) and Stage 3: EUR 123
million (2021: EUR 129 million).
The finance lease receivables mainly relate to the financing of equipment and are mainly part of corporate
lending. To a lesser extent, the finance lease receivables relate to real estate for third parties, where ING is
the lessor. Interest income in 2022 on finance lease receivables amounts to EUR 292 million (2021: EUR 217
million).
", "dimensions": { "concept": "ifrs-full:DisclosureOfLoansAndAdvancesToCustomersExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMTIvZnJhZzpmMmNjNTNlMDBkNmE0NDM3OWJmZTFmMjk1YzdiYjdlNi90ZXh0cmVnaW9uOmYyY2M1M2UwMGQ2YTQ0Mzc5YmZlMWYyOTVjN2JiN2U2XzIzMDg5NzQ0MTg0ODMy_f7450af0-22d9-4bee-a313-50497a4073f7": { "value": "
Finance lease receivables 1
in EUR million
2022
2021
Maturities of gross investment in finance lease receivables
-\u00a0 within 1 year
3,452
3,204
-\u00a0 between 1-2 years
2,463
2,311
-\u00a0 between 2-3 years
1,870
1,716
-\u00a0 between 3-4 years
1,294
1,178
-\u00a0 between 4-5 years
747
734
-\u00a0 more than 5 years
1,423
1,495
11,251
10,637
Unearned future finance income on finance leases
-792
-525
Net investment in finance leases
10,459
10,112
Included in Loans and advances to banks
6
5
Included in Loans and advances to customers
10,453
10,106
10,459
10,112
1The total loan loss provision of EUR 160 million (2021: EUR\u00a0167 million) for finance lease receivables is classified into the following loan
loss provision stages: Stage 1: EUR 9 million (2021: EUR 8 million), Stage 2: EUR 28 million (2021: EUR 30 million) and Stage 3: EUR 123
million (2021: EUR 129 million).
The finance lease receivables mainly relate to the financing of equipment and are mainly part of corporate
lending. To a lesser extent, the finance lease receivables relate to real estate for third parties, where ING is
the lessor. Interest income in 2022 on finance lease receivables amounts to EUR 292 million (2021: EUR 217
million).
9\u00a0 Property and equipment
Property and equipment by type
in EUR million
2022
2021
Property in own use
681
702
Equipment:
- Data processing equipment
213
207
- Other equipment
476
493
Right- of- use assets:
- ROU property
1,000
1,009
- ROU cars
64
83
- ROU other leases
12
21
2,446
2,515
1 Impairments of property and equipment are presented within 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.
Property in own use purchase costs amounted to EUR 847 million (2021: EUR\u00a0910 million). Cost or the
purchase price less accumulated depreciation and impairments would have been EUR 368 million (2021:
EUR 403 million) had property in own use been valued at cost instead of at fair value.
The reported impairment losses of EUR -35 million (2021: EUR -33 million) mainly result from a change in the
post-pandemic way of working through downscaling of physical office spaces.
16\u00a0 Other liabilities
Other liabilities by type
In EUR million
2022
2021
Net defined benefit liability
139
227
Other post-employment benefits
29
72
Other staff-related liabilities
633
612
Other taxation and social security contributions
365
409
Rents received in advance
30
19
Costs payable
2,014
2,015
Amounts to be settled
6,714
5,082
Lease liabilities
1,174
1,220
Other
2,247
3,038
13,344
12,695
Disclosures in respect of Net defined benefit liabilities are provided in Note 33 'Pensions and other post-
employment benefits'.
Other staff-related liabilities includes vacation leave provisions, variable compensation provisions, jubilee
provisions, and disability/illness provisions.
Amounts to be settled includes primarily transactions not settled at the balance sheet date. The nature of
these transactions is short term and have settled\u00a0 after the closing date of the balance sheet.
Lease liabilities relate to right-of-use assets. Disclosures in respect to right-of-use assets are provided in
Note 9 'Property and equipment'. The total cash outflow for leases in 2022 was EUR 296\u00a0million (2021: EUR
301 million).
", "dimensions": { "concept": "ifrs-full:DisclosureOfLeasesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMTUvZnJhZzoxYzNkMTIzMmJmZjU0ZmFlYThhNTU1MzIyZDc2NjkyYi90ZXh0cmVnaW9uOjFjM2QxMjMyYmZmNTRmYWVhOGE1NTUzMjJkNzY2OTJiXzE5MjE_0e6a0b7a-6ed8-4a32-a582-22eb0b28e7e2": { "value": "
8\u00a0 Investment in associates and joint ventures
Investments in associates and joint ventures
in EUR million
2022
Interest
held (%)
Fair value of
listed invest-
ments
Balance
sheet
value
Total
assets
Total
liabilities
Total
income
Total
expenses
TMBThanachart Bank Public
Company Limited
23%
849
1,109
49,506
43,677
1,303
957
Other investments in associates and
joint ventures
391
1,500
Investments in associates and joint ventures
in EUR million
2021
Interest
held (%)
Fair value of
listed invest-
ments
Balance
sheet value
Total
assets
Total
liabilities
Total
income
Total
expenses
TMBThanachart Bank Public
Company Limited
23%
866
1,208
46,478
40,957
1,286
1,038
Other investments in associates
and joint ventures
379
1,587
TMBThanachart Bank Public Company Limited
ING Bank has a 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 shareholding and representation on the Board.
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 represents a number of
associates and joint ventures that are individually not significant to ING Bank.
Significant influence for associates in which the interest held is below 20%, is based on the combination of
ING Bank\u2019s 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, rating agency and regulatory
views, which can change over time.
Changes in Investments in associates and joint ventures
in EUR million
2022
2021
Opening balance
1,587
1,475
Additions
48
91
Revaluations
-8
-24
Share of results
92
141
Dividends received
-48
-34
Disposals
-10
-23
Impairments
-192
-3
Exchange rate differences
27
-31
Other
4
-5
Closing balance
1,500
1,587
Share of results from associates and joint ventures of EUR 92 million (2021: EUR 141 million) as included in
the table above is mainly attributable to results of TTB of EUR 81\u00a0million (2021: EUR 61 million). In 2021,
share of results from associates includes additional EUR 28 million gain on our stake in Ebusco.
Impairments
In 2022, Impairments of EUR 192 million is predominantly attributable to TTB of EUR 165 million. TTB is part
of the Retail Other segment.
Impairment testing TTB
The fair value of TTB has been below the purchase cost of the investment for a prolonged period of time
(since 1Q 2020). This is considered to be objective evidence of impairment. As a result ING performed
quarterly impairment tests that led to impairment loss of EUR 165 million (2021: EUR nil).
The impairment test performed in 2022 led to an impairment at 31 March 2022 of EUR 150 million and EUR
15 million at 30 September 2022, as the recoverable amount as determined by a Value in Use calculation,
was below the carrying amount\u00a0 at that point in time. The impairment test at year end resulted in no further
impairments.
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and Value in Use
(\u2018VIU\u2019). Fair value less costs of disposal is based on observable share price. The VIU calculation uses
discounted cash flow projections based on management\u2019s 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:
\u2022the estimation of future earnings over a 5 year forecast period; and
\u2022the 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 2022 (and as at 30 September 2022
resulting in impairment)
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:
\u2022Expected 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\u00a0 assumptions capturing a combination of TTB specific and market data
points. A capital maintenance charge is applied, which is management\u2019s forecast of the earnings that
need to be withheld in order for TTB to meet target regulatory requirements over the forecast period;
\u2022Discount rate (cost of equity): 9.71% (30 September 2022: 10.54%), based on the capital asset pricing
model (CAPM) calculated for TTB using current market data.
\u2022Terminal growth rate: 3.05% (30 September 2022: 3.82%) consistent with current long term government
bond yield in Thailand as a proxy for a risk-free rate;
To assess the risk of further impairment at 31 December 2022, 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. Holding the other key assumptions constant, a reduction in all of the forecasted
annual cash flows, including terminal value, of 836bps would reduce the recoverable amount to the carrying
amount. An increase of 55bps in terminal growth rate and discount rate would cause the VIU to equal the
carrying amount.
Reversal of the impairment loss recognised was not considered appropriate as at 31 December 2022 mainly
due to the lack of sufficiently positive changes observed in the underlying performance of TTB since the
impairment loss as reflected in the broker consensus. Furthermore, the share price remains below the
original cost of the investment for a prolonged period of time.
", "dimensions": { "concept": "ifrs-full:DisclosureOfSignificantInvestmentsInAssociatesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMTUvZnJhZzoxYzNkMTIzMmJmZjU0ZmFlYThhNTU1MzIyZDc2NjkyYi90ZXh0cmVnaW9uOjFjM2QxMjMyYmZmNTRmYWVhOGE1NTUzMjJkNzY2OTJiXzE5MjE_74aaf9fe-c617-4350-92c6-862d50b4e167": { "value": "
8\u00a0 Investment in associates and joint ventures
Investments in associates and joint ventures
in EUR million
2022
Interest
held (%)
Fair value of
listed invest-
ments
Balance
sheet
value
Total
assets
Total
liabilities
Total
income
Total
expenses
TMBThanachart Bank Public
Company Limited
23%
849
1,109
49,506
43,677
1,303
957
Other investments in associates and
joint ventures
391
1,500
Investments in associates and joint ventures
in EUR million
2021
Interest
held (%)
Fair value of
listed invest-
ments
Balance
sheet value
Total
assets
Total
liabilities
Total
income
Total
expenses
TMBThanachart Bank Public
Company Limited
23%
866
1,208
46,478
40,957
1,286
1,038
Other investments in associates
and joint ventures
379
1,587
TMBThanachart Bank Public Company Limited
ING Bank has a 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 shareholding and representation on the Board.
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 represents a number of
associates and joint ventures that are individually not significant to ING Bank.
Significant influence for associates in which the interest held is below 20%, is based on the combination of
ING Bank\u2019s 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, rating agency and regulatory
views, which can change over time.
Changes in Investments in associates and joint ventures
in EUR million
2022
2021
Opening balance
1,587
1,475
Additions
48
91
Revaluations
-8
-24
Share of results
92
141
Dividends received
-48
-34
Disposals
-10
-23
Impairments
-192
-3
Exchange rate differences
27
-31
Other
4
-5
Closing balance
1,500
1,587
Share of results from associates and joint ventures of EUR 92 million (2021: EUR 141 million) as included in
the table above is mainly attributable to results of TTB of EUR 81\u00a0million (2021: EUR 61 million). In 2021,
share of results from associates includes additional EUR 28 million gain on our stake in Ebusco.
Impairments
In 2022, Impairments of EUR 192 million is predominantly attributable to TTB of EUR 165 million. TTB is part
of the Retail Other segment.
Impairment testing TTB
The fair value of TTB has been below the purchase cost of the investment for a prolonged period of time
(since 1Q 2020). This is considered to be objective evidence of impairment. As a result ING performed
quarterly impairment tests that led to impairment loss of EUR 165 million (2021: EUR nil).
The impairment test performed in 2022 led to an impairment at 31 March 2022 of EUR 150 million and EUR
15 million at 30 September 2022, as the recoverable amount as determined by a Value in Use calculation,
was below the carrying amount\u00a0 at that point in time. The impairment test at year end resulted in no further
impairments.
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and Value in Use
(\u2018VIU\u2019). Fair value less costs of disposal is based on observable share price. The VIU calculation uses
discounted cash flow projections based on management\u2019s 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:
\u2022the estimation of future earnings over a 5 year forecast period; and
\u2022the 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 2022 (and as at 30 September 2022
resulting in impairment)
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:
\u2022Expected 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\u00a0 assumptions capturing a combination of TTB specific and market data
points. A capital maintenance charge is applied, which is management\u2019s forecast of the earnings that
need to be withheld in order for TTB to meet target regulatory requirements over the forecast period;
\u2022Discount rate (cost of equity): 9.71% (30 September 2022: 10.54%), based on the capital asset pricing
model (CAPM) calculated for TTB using current market data.
\u2022Terminal growth rate: 3.05% (30 September 2022: 3.82%) consistent with current long term government
bond yield in Thailand as a proxy for a risk-free rate;
To assess the risk of further impairment at 31 December 2022, 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. Holding the other key assumptions constant, a reduction in all of the forecasted
annual cash flows, including terminal value, of 836bps would reduce the recoverable amount to the carrying
amount. An increase of 55bps in terminal growth rate and discount rate would cause the VIU to equal the
carrying amount.
Reversal of the impairment loss recognised was not considered appropriate as at 31 December 2022 mainly
due to the lack of sufficiently positive changes observed in the underlying performance of TTB since the
impairment loss as reflected in the broker consensus. Furthermore, the share price remains below the
original cost of the investment for a prolonged period of time.
", "dimensions": { "concept": "ifrs-full:DisclosureOfJointVenturesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMTUvZnJhZzoxYzNkMTIzMmJmZjU0ZmFlYThhNTU1MzIyZDc2NjkyYi90ZXh0cmVnaW9uOjFjM2QxMjMyYmZmNTRmYWVhOGE1NTUzMjJkNzY2OTJiXzIzMDg5NzQ0MTkzMDU4_6f6e0c78-fbf6-41e7-ac37-5010a87d43b1": { "value": "
8\u00a0 Investment in associates and joint ventures
Investments in associates and joint ventures
in EUR million
2022
Interest
held (%)
Fair value of
listed invest-
ments
Balance
sheet
value
Total
assets
Total
liabilities
Total
income
Total
expenses
TMBThanachart Bank Public
Company Limited
23%
849
1,109
49,506
43,677
1,303
957
Other investments in associates and
joint ventures
391
1,500
Investments in associates and joint ventures
in EUR million
2021
Interest
held (%)
Fair value of
listed invest-
ments
Balance
sheet value
Total
assets
Total
liabilities
Total
income
Total
expenses
TMBThanachart Bank Public
Company Limited
23%
866
1,208
46,478
40,957
1,286
1,038
Other investments in associates
and joint ventures
379
1,587
TMBThanachart Bank Public Company Limited
ING Bank has a 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 shareholding and representation on the Board.
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 represents a number of
associates and joint ventures that are individually not significant to ING Bank.
Significant influence for associates in which the interest held is below 20%, is based on the combination of
ING Bank\u2019s 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, rating agency and regulatory
views, which can change over time.
Changes in Investments in associates and joint ventures
in EUR million
2022
2021
Opening balance
1,587
1,475
Additions
48
91
Revaluations
-8
-24
Share of results
92
141
Dividends received
-48
-34
Disposals
-10
-23
Impairments
-192
-3
Exchange rate differences
27
-31
Other
4
-5
Closing balance
1,500
1,587
Share of results from associates and joint ventures of EUR 92 million (2021: EUR 141 million) as included in
the table above is mainly attributable to results of TTB of EUR 81\u00a0million (2021: EUR 61 million). In 2021,
share of results from associates includes additional EUR 28 million gain on our stake in Ebusco.
Impairments
In 2022, Impairments of EUR 192 million is predominantly attributable to TTB of EUR 165 million. TTB is part
of the Retail Other segment.
Impairment testing TTB
The fair value of TTB has been below the purchase cost of the investment for a prolonged period of time
(since 1Q 2020). This is considered to be objective evidence of impairment. As a result ING performed
quarterly impairment tests that led to impairment loss of EUR 165 million (2021: EUR nil).
The impairment test performed in 2022 led to an impairment at 31 March 2022 of EUR 150 million and EUR
15 million at 30 September 2022, as the recoverable amount as determined by a Value in Use calculation,
was below the carrying amount\u00a0 at that point in time. The impairment test at year end resulted in no further
impairments.
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and Value in Use
(\u2018VIU\u2019). Fair value less costs of disposal is based on observable share price. The VIU calculation uses
discounted cash flow projections based on management\u2019s 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:
\u2022the estimation of future earnings over a 5 year forecast period; and
\u2022the 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 2022 (and as at 30 September 2022
resulting in impairment)
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:
\u2022Expected 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\u00a0 assumptions capturing a combination of TTB specific and market data
points. A capital maintenance charge is applied, which is management\u2019s forecast of the earnings that
need to be withheld in order for TTB to meet target regulatory requirements over the forecast period;
\u2022Discount rate (cost of equity): 9.71% (30 September 2022: 10.54%), based on the capital asset pricing
model (CAPM) calculated for TTB using current market data.
\u2022Terminal growth rate: 3.05% (30 September 2022: 3.82%) consistent with current long term government
bond yield in Thailand as a proxy for a risk-free rate;
To assess the risk of further impairment at 31 December 2022, 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. Holding the other key assumptions constant, a reduction in all of the forecasted
annual cash flows, including terminal value, of 836bps would reduce the recoverable amount to the carrying
amount. An increase of 55bps in terminal growth rate and discount rate would cause the VIU to equal the
carrying amount.
Reversal of the impairment loss recognised was not considered appropriate as at 31 December 2022 mainly
due to the lack of sufficiently positive changes observed in the underlying performance of TTB since the
impairment loss as reflected in the broker consensus. Furthermore, the share price remains below the
original cost of the investment for a prolonged period of time.
", "dimensions": { "concept": "ifrs-full:DisclosureOfInvestmentsAccountedForUsingEquityMethodExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMTUvZnJhZzoxYzNkMTIzMmJmZjU0ZmFlYThhNTU1MzIyZDc2NjkyYi90ZXh0cmVnaW9uOjFjM2QxMjMyYmZmNTRmYWVhOGE1NTUzMjJkNzY2OTJiXzgyNDYzMzcyMjU0NDU_07dcb899-5ad7-47bb-a773-47362b14e8d8": { "value": "
Impairments
In 2022, Impairments of EUR 192 million is predominantly attributable to TTB of EUR 165 million. TTB is part
of the Retail Other segment.
Impairment testing TTB
The fair value of TTB has been below the purchase cost of the investment for a prolonged period of time
(since 1Q 2020). This is considered to be objective evidence of impairment. As a result ING performed
quarterly impairment tests that led to impairment loss of EUR 165 million (2021: EUR nil).
The impairment test performed in 2022 led to an impairment at 31 March 2022 of EUR 150 million and EUR
15 million at 30 September 2022, as the recoverable amount as determined by a Value in Use calculation,
was below the carrying amount\u00a0 at that point in time. The impairment test at year end resulted in no further
impairments.
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and Value in Use
(\u2018VIU\u2019). Fair value less costs of disposal is based on observable share price. The VIU calculation uses
discounted cash flow projections based on management\u2019s 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:
\u2022the estimation of future earnings over a 5 year forecast period; and
\u2022the 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 2022 (and as at 30 September 2022
resulting in impairment)
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:
\u2022Expected 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\u00a0 assumptions capturing a combination of TTB specific and market data
points. A capital maintenance charge is applied, which is management\u2019s forecast of the earnings that
need to be withheld in order for TTB to meet target regulatory requirements over the forecast period;
\u2022Discount rate (cost of equity): 9.71% (30 September 2022: 10.54%), based on the capital asset pricing
model (CAPM) calculated for TTB using current market data.
\u2022Terminal growth rate: 3.05% (30 September 2022: 3.82%) consistent with current long term government
bond yield in Thailand as a proxy for a risk-free rate;
To assess the risk of further impairment at 31 December 2022, 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. Holding the other key assumptions constant, a reduction in all of the forecasted
annual cash flows, including terminal value, of 836bps would reduce the recoverable amount to the carrying
amount. An increase of 55bps in terminal growth rate and discount rate would cause the VIU to equal the
carrying amount.
Reversal of the impairment loss recognised was not considered appropriate as at 31 December 2022 mainly
due to the lack of sufficiently positive changes observed in the underlying performance of TTB since the
impairment loss as reflected in the broker consensus. Furthermore, the share price remains below the
original cost of the investment for a prolonged period of time.
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 Bank tests goodwill whenever a
triggering event is identified, as with the re-allocation from Group of CGUs to country level CGUs on 1
January 2022. The re-allocated goodwill to Turkey CGU, after first being adjusted for hyperinflation
accounting for EUR 25 million, was fully impaired for the amount of EUR 32 million (based on discount rate
24.04% and terminal growth rate 10.40% as per 1 January 2022). Turkey is part of the Retail Other segment.
At the annual impairment test in the fourth quarter, the recoverable amount exceeds the carrying value of
the CGUs as at 31 December 2022 and therefore no impairment is required.
Methodology
In line with IFRS, 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 Bank. 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\u2019s judgement. The long term growth rate for EU-countries is based on long term risk-free
rate by reference to the yield of a composite index consisting of Euro generic government bonds, with a
maturity of 30 years . For other countries, the growth rate includes long term inflation rate obtained from
market sources.
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 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.
Other changes
Other changes in goodwill in 2022 relate to changes in currency exchange rates of Retail Poland and Retail
Romania goodwill.", "dimensions": { "concept": "ifrs-full:DisclosureOfImpairmentOfAssetsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMTgvZnJhZzpkYzBkMDVlZDIzMTk0ZDZmOWNmNWMxMDgwYWJkYjgyYy90ZXh0cmVnaW9uOmRjMGQwNWVkMjMxOTRkNmY5Y2Y1YzEwODBhYmRiODJjXzQ5_9d180a12-fe69-4254-b338-dc2d2f3e1dda": { "value": "
9\u00a0 Property and equipment
Property and equipment by type
in EUR million
2022
2021
Property in own use
681
702
Equipment:
- Data processing equipment
213
207
- Other equipment
476
493
Right- of- use assets:
- ROU property
1,000
1,009
- ROU cars
64
83
- ROU other leases
12
21
2,446
2,515
1 Impairments of property and equipment are presented within 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.
Property in own use purchase costs amounted to EUR 847 million (2021: EUR\u00a0910 million). Cost or the
purchase price less accumulated depreciation and impairments would have been EUR 368 million (2021:
EUR 403 million) had property in own use been valued at cost instead of at fair value.
The reported impairment losses of EUR -35 million (2021: EUR -33 million) mainly result from a change in the
post-pandemic way of working through downscaling of physical office spaces.
", "dimensions": { "concept": "ifrs-full:DisclosureOfPropertyPlantAndEquipmentExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMjEvZnJhZzo0ZDUwN2JkMWE1MDE0OTliOWRmOWVkZTE5Y2NjNmIxZi90ZXh0cmVnaW9uOjRkNTA3YmQxYTUwMTQ5OWI5ZGY5ZWRlMTljY2M2YjFmXzIzMDg5NzQ0MTkwNzMw_e29ecd86-700a-4afb-a733-eb4fcad4540f": { "value": "
10\u00a0 Intangible assets
Changes in intangible assets
Goodwill
Software
Other
Total
in EUR million
2022
2021
2022
2021
2022
2021
2022
2021
Opening balance
472
533
682
846
2
15
1,156
1,394
Opening balance adjustment
25
25
Additions
54
44
54
44
Capitalised expenses
144
135
144
135
Amortisation
-226
-260
-1
-226
-261
Impairments 1
-32
-22
-82
-12
-54
-94
Reversal of impairment
Exchange rate differences
-1
-61
4
2
-62
Disposals
-3
-3
Changes in the composition of the group and
other changes
3
-1
3
Closing balance
464
472
636
682
2
2
1,102
1,156
Gross carrying amount
464
472
2,491
2,521
8
59
2,962
3,052
Accumulated amortisation
-1,787
-1,710
-4
-9
-1,790
-1,719
Accumulated impairments
-69
-129
-2
-48
-70
-177
Net carrying value
464
472
636
682
2
2
1,102
1,156
1 Impairments of intangible assets are presented within Other operating expenses in the statement of Profit or Loss.
Goodwill
Following a change in monitoring from a centralised towards a de-centralised approach for Retail as from
the beginning of 2022, goodwill related to the group of cash generating units (CGUs) 'Retail Growth Markets'
was re-allocated to the underlying CGUs Retail Romania, Retail Poland and Retail Turkey using a relative
value approach.
Goodwill is allocated to groups of cash generating units (CGUs) as follows:
Goodwill allocation to group of CGUs
in EUR million
Method used for
recoverable amount
Discount rate
Terminal
growth rate
Goodwill
Goodwill
Group of CGU\u2019s
2022
2021
Retail Netherlands
Value in use
8.46%
2.04%
30
30
Retail Germany
Value in use
8.35%
1.82%
349
349
Retail Poland
Value in use
10.31%
2.50%
69
70
Retail Romania
Value in use
12.32%
2.60%
15
15
Retail Turkey
7
464
472
1 Impairments of intangible assets are presented within Other operating expenses in the statement of Profit or Loss.
Goodwill
Following a change in monitoring from a centralised towards a de-centralised approach for Retail as from
the beginning of 2022, goodwill related to the group of cash generating units (CGUs) 'Retail Growth Markets'
was re-allocated to the underlying CGUs Retail Romania, Retail Poland and Retail Turkey using a relative
value approach.
Goodwill is allocated to groups of cash generating units (CGUs) as follows:
Goodwill allocation to group of CGUs
in EUR million
Method used for
recoverable amount
Discount rate
Terminal
growth rate
Goodwill
Goodwill
Group of CGU\u2019s
2022
2021
Retail Netherlands
Value in use
8.46%
2.04%
30
30
Retail Germany
Value in use
8.35%
1.82%
349
349
Retail Poland
Value in use
10.31%
2.50%
69
70
Retail Romania
Value in use
12.32%
2.60%
15
15
Retail Turkey
7
464
472
1 Impairments of intangible assets are presented within Other operating expenses in the statement of Profit or Loss.
Goodwill
Following a change in monitoring from a centralised towards a de-centralised approach for Retail as from
the beginning of 2022, goodwill related to the group of cash generating units (CGUs) 'Retail Growth Markets'
was re-allocated to the underlying CGUs Retail Romania, Retail Poland and Retail Turkey using a relative
value approach.
Goodwill is allocated to groups of cash generating units (CGUs) as follows:
Goodwill allocation to group of CGUs
in EUR million
Method used for
recoverable amount
Discount rate
Terminal
growth rate
Goodwill
Goodwill
Group of CGU\u2019s
2022
2021
Retail Netherlands
Value in use
8.46%
2.04%
30
30
Retail Germany
Value in use
8.35%
1.82%
349
349
Retail Poland
Value in use
10.31%
2.50%
69
70
Retail Romania
Value in use
12.32%
2.60%
15
15
Retail Turkey
7
464
472
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 transaction 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, amongst others, short term
receivables relating to mortgage issuance and other amounts receivable from customers.", "dimensions": { "concept": "ifrs-full:DisclosureOfOtherAssetsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMjQvZnJhZzphNzAxMjQ2NDI3MmI0ZTRjOTk0NDg2MjA3MGI5ZTlkMy90ZXh0cmVnaW9uOmE3MDEyNDY0MjcyYjRlNGM5OTQ0ODYyMDcwYjllOWQzXzE3_d3731e99-7352-4188-8576-3da80609aa93": { "value": "
11\u00a0 Other assets
Other assets by type
in EUR million
2022
2021
Net defined benefit assets
617
783
Investment properties
18
26
Property development and obtained from foreclosures
34
52
Accrued assets
913
795
Amounts to be settled
5,190
2,424
Other
2,067
1,910
8,839
5,991
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 transaction 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, amongst others, short term
receivables relating to mortgage issuance and other amounts receivable from customers.", "dimensions": { "concept": "ifrs-full:DisclosureOfInvestmentPropertyExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMjcvZnJhZzoxNTA0Y2MzMTk4ZGU0ZTVjYWY5ODFkM2Q5M2MxMTI0Mi90ZXh0cmVnaW9uOjE1MDRjYzMxOThkZTRlNWNhZjk4MWQzZDkzYzExMjQyXzMw_02326152-95d5-4962-b294-cfaf002ba685": { "value": "
12\u00a0 Deposits from banks
Deposits from banks includes non-subordinated deposits and repurchase agreements from banks.
Deposits from banks by type
Netherlands
Rest of the world
Total
in EUR million
2022
2021
2022
2021
2022
2021
Non-interest bearing
86
570
315
321
400
891
Interest bearing
32,858
51,893
23,374
32,307
56,232
84,201
32,943
52,463
23,689
32,629
56,632
85,092
For the details of the applicable rates and impact on net interest
income reference is made to Note 20 'Net interest income'.
", "dimensions": { "concept": "ifrs-full:DisclosureOfDepositsFromBanksExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMzAvZnJhZzo0M2NjYzA2OWQwYTQ0M2I1ODI1ZDQ5MjJkOTZlMDIzNC90ZXh0cmVnaW9uOjQzY2NjMDY5ZDBhNDQzYjU4MjVkNDkyMmQ5NmUwMjM0XzExOQ_4bedeb75-73ae-425d-8d6b-d3416c969835": { "value": "
13\u00a0 Customer deposits
Customer deposits
in EUR million
2022
2021
Savings accounts
321,005
314,893
Credit balances on customer accounts
283,886
280,028
Corporate deposits
43,308
28,183
Other
38,143
34,727
686,341
657,831
Changes in provisions
Reorganisation
Litigation
Other
Total
in EUR million
2022
2021
2022
2021
2022
2021
2022
2021
Opening balance
421
381
132
105
420
180
973
666
Additions
217
310
59
50
227
354
503
715
Interest
-2
-2
-2
-2
Releases
-46
-96
-8
-11
-166
-79
-221
-186
Utilised
-170
-172
-33
-18
-15
-25
-218
-215
Exchange rate differences
-3
-2
-1
-4
Other changes
-4
-3
9
-1
-7
-4
-1
Closing balance
418
421
150
132
462
420
1,030
973
for developments in litigation provisions.
The additions to the Other provisions in 2022 include EUR 75 million which relates to the provision for the
compensation of Dutch retail customers for past interest charges that did not sufficiently track market rates
and largely reflects the impact of interest-on-interest compensation. This is in addition to the provision of
EUR 180 million recognised in 2021.
In 2022, Other provisions include provisions of EUR 29 million (2021: EUR 34 million) that relate to credit
replacement facilities and EUR 109 million (2021: EUR 114 million) that relate to non-credit replacement off
balance facilities. The additions and releases in 2022 include EUR 138 million (2021: EUR 109 million) and
EUR 141 million (2021: EUR 66 million) respectively related to these off balance facilities.\u00a0
As at 31\u00a0December 2022, amounts expected to be settled within twelve months in provisions amount to EUR
815\u00a0million (2021: EUR 740 million). The amounts included are based on best estimates with regard to
amounts and timing of cash flows required to settle the obligation.
Additions to provisions and unused amounts released are presented in Note 27 'Other operating expenses'.
", "dimensions": { "concept": "ifrs-full:DisclosureOfProvisionsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMzkvZnJhZzphNDc5NWZkM2M1MDE0MjAwODg1ZWExNWUzMDQzYjdkMC90ZXh0cmVnaW9uOmE0Nzk1ZmQzYzUwMTQyMDA4ODVlYTE1ZTMwNDNiN2QwXzEyOA_7f319bf0-1d71-4aca-8589-49e7600b6806": { "value": "
16\u00a0 Other liabilities
Other liabilities by type
In EUR million
2022
2021
Net defined benefit liability
139
227
Other post-employment benefits
29
72
Other staff-related liabilities
633
612
Other taxation and social security contributions
365
409
Rents received in advance
30
19
Costs payable
2,014
2,015
Amounts to be settled
6,714
5,082
Lease liabilities
1,174
1,220
Other
2,247
3,038
13,344
12,695
Disclosures in respect of Net defined benefit liabilities are provided in Note 33 'Pensions and other post-
employment benefits'.
Other staff-related liabilities includes vacation leave provisions, variable compensation provisions, jubilee
provisions, and disability/illness provisions.
Amounts to be settled includes primarily transactions not settled at the balance sheet date. The nature of
these transactions is short term and have settled\u00a0 after the closing date of the balance sheet.
Lease liabilities relate to right-of-use assets. Disclosures in respect to right-of-use assets are provided in
Note 9 'Property and equipment'. The total cash outflow for leases in 2022 was EUR 296\u00a0million (2021: EUR
301 million).
The line Other relates mainly to balances on margin accounts or amounts payable to customers.", "dimensions": { "concept": "ifrs-full:DisclosureOfAccruedExpensesAndOtherLiabilitiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xMzkvZnJhZzphNDc5NWZkM2M1MDE0MjAwODg1ZWExNWUzMDQzYjdkMC90ZXh0cmVnaW9uOmE0Nzk1ZmQzYzUwMTQyMDA4ODVlYTE1ZTMwNDNiN2QwXzEyOA_cf477c7a-5a7c-4052-8939-3bc067a90901": { "value": "
16\u00a0 Other liabilities
Other liabilities by type
In EUR million
2022
2021
Net defined benefit liability
139
227
Other post-employment benefits
29
72
Other staff-related liabilities
633
612
Other taxation and social security contributions
365
409
Rents received in advance
30
19
Costs payable
2,014
2,015
Amounts to be settled
6,714
5,082
Lease liabilities
1,174
1,220
Other
2,247
3,038
13,344
12,695
Disclosures in respect of Net defined benefit liabilities are provided in Note 33 'Pensions and other post-
employment benefits'.
Other staff-related liabilities includes vacation leave provisions, variable compensation provisions, jubilee
provisions, and disability/illness provisions.
Amounts to be settled includes primarily transactions not settled at the balance sheet date. The nature of
these transactions is short term and have settled\u00a0 after the closing date of the balance sheet.
Lease liabilities relate to right-of-use assets. Disclosures in respect to right-of-use assets are provided in
Note 9 'Property and equipment'. The total cash outflow for leases in 2022 was EUR 296\u00a0million (2021: EUR
301 million).
The line Other relates mainly to balances on margin accounts or amounts payable to customers.", "dimensions": { "concept": "ifrs-full:DisclosureOfOtherLiabilitiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNDIvZnJhZzphZTkzZmExNjU4M2Y0ZWYwYTQzNGNhN2NmMDUyNjg1ZS90ZXh0cmVnaW9uOmFlOTNmYTE2NTgzZjRlZjBhNDM0Y2E3Y2YwNTI2ODVlXzcxOA_4c61496e-79a9-4e00-bf5e-ac0defb435e0": { "value": "
17\u00a0 Debt securities in issue
Debt securities in issue relates 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 Bank, except for subordinated items. Debt securities in issue does not include debt securities
presented as Financial liabilities at fair value through profit or loss. ING Bank does not have debt securities
that are issued on terms other than those available in the normal course of business.
Debt securities in issue \u2013 maturities
In EUR million
2022
2021
Fixed rate debt securities
Within 1 year
18,044
31,785
More than 1 year but less than 2 years
1,217
3,135
More than 2 years but less than 3 years
4,702
1,235
More than 3 years but less than 4 years
2,903
1,729
More than 4 years but less than 5 years
2,880
2,914
More than 5 years
13,221
13,133
Total fixed rate debt securities
42,969
53,930
Floating rate debt securities
Within 1 year
13,856
2,266
More than 1 year but less than 2 years
307
130
More than 2 years but less than 3 years
256
137
More than 3 years but less than 4 years
494
194
More than 4 years but less than 5 years
97
192
More than 5 years
96
593
Total floating rate debt securities
15,106
3,513
Total debt securities
58,075
57,443
Reference is made to Note 29 'Changes in liabilities arising from financing activities' for further information
on issuances, redemptions and non-cash movements.
", "dimensions": { "concept": "ifrs-full:DisclosureOfDebtSecuritiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNDUvZnJhZzpkYWI5YWNlNDk4ZTE0ZmY5OTg0OGEzZjg1NjY2YzBlMC90ZXh0cmVnaW9uOmRhYjlhY2U0OThlMTRmZjk5ODQ4YTNmODU2NjZjMGUwXzE0MzM_226a7c10-ae08-401d-8d09-5482ce0894a6": { "value": "
18\u00a0 Subordinated loans
Subordinated loans
In EUR million
2022
2021
Subordinated loans
15,789
16,719
15,789
16,719
Subordinated loans relate to subordinated capital debentures and private loans which may be included in
the calculation of the capital ratio.\u00a0
Subordinated loans include loans that qualify as Tier 1 and Tier 2 (CRD IV eligible) capital. Subordinated loans
of EUR 16,364 million (2021: EUR 15,879 million) have been placed with ING Bank N.V. by ING Groep N.V.
Reference is made to Note 39 'Derivatives and hedge accounting' for details on fair value hedge accounting.
In 2022 ING Groep N.V. issued in August EUR 1 billion 4.13% Fixed Rate Subordinated Tier 2 Green Notes. This
issuance was subsequently placed by ING Groep N.V. with ING Bank N.V. against the same conditions.
ING Bank N.V. redeemed with ING Group N.V. in April 2022 USD 1 billion 6.875% Perpetual Additional Tier 1
Contingent Convertible Capital Securities and in May 2022 JPY 10 billion 1.10% Subordinated Tier 2 Notes on
the first call dates.
Reference is made to Note 32 'Changes in liabilities arising from financing activities' for further information
on issuances and redemptions.
The average interest rate on subordinated loans is 4.00% (2021: 3.74%). The interest expense during the
year 2022 was EUR 646 million (2021: EUR 573 million).
", "dimensions": { "concept": "ifrs-full:DisclosureOfSubordinatedLiabilitiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNDgvZnJhZzoyYTA5Yzk5YTYyZWE0MmNhYjFkMGQzZDI1NTAzOGY5Mi90ZXh0cmVnaW9uOjJhMDljOTlhNjJlYTQyY2FiMWQwZDNkMjU1MDM4ZjkyXzc5Mjk_a2131989-a82f-4140-87fd-28358e479789": { "value": "
19\u00a0 Equity
Total equity
In EUR million
2022
2021
2020
Share capital and share premium
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Share capital
525
525
525
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Share premium
16,542
16,542
16,542
17,067
17,067
17,067
Other reserves
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Revaluation reserve: Equity securities at FVOCI
1,187
1,282
1,181
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Revaluation reserve: Debt instruments at FVOCI
-339
92
296
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Revaluation reserve: Cash flow hedge
-3,055
-153
1,450
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Revaluation reserve: Credit liability
70
-80
-117
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Revaluation reserve: Property in own use
176
208
221
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Net defined benefit asset/liability remeasurement reserve
-232
-212
-307
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Currency translation reserve
-2,395
-3,483
-3,636
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Share of associates and joint ventures and other reserves
3,604
3,416
3,246
-984
1,069
2,334
Retained earnings
26,462
29,778
28,273
Shareholders\u2019 equity (parent)
42,546
47,914
47,675
Non-controlling interests
504
736
1,022
Total equity
43,050
48,650
48,697
No change occurred in the issued share capital and share premium in 2022, 2021 and 2020.
All ordinary shares are in registered form. No share certificates have been issued. Ordinary shares may be
transferred by means of a deed of transfer, subject to the approval of the general meeting of ING Bank. The
par value of ordinary shares is EUR 1.13.
The authorised ordinary share capital of ING Bank N.V. consists of 1,600 million shares of which as at
31\u00a0December 2022, 465 million ordinary shares were issued and fully paid.
ING Bank has 50 authorised preference shares with par value of EUR 1.13 per preference share. As at
31\u00a0December 2022, 7 preference shares were issued and fully paid (2021: 7 preference shares; 2020: 7
preference shares) amounting to EUR 8 (2021: EUR 8 and 2020: EUR 8).
Dividend restrictions
ING Bank 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\u2019s own funds over the sum of the
paid-up capital and reserves required by law. Additionally, certain Bank companies are subject to restrictions
on the amount of funds they may transfer in the form of dividends or otherwise to the parent company.
Furthermore, in addition to the restrictions in respect of minimum capital requirements that are imposed by
industry regulators in the countries in which subsidiaries operate, other limitations exist in certain countries.
Other reserves
Revaluation reserves
Changes in revaluation reserve: Equity securities and Debt instruments at FVOCI
Equity securities at FVOCI
Debt instruments at FVOCI
In EUR million
2022
2021
2020
2022
2021
2020
Opening balance
1,282
1,181
1,580
92
296
299
Unrealised revaluations
-118
94
-337
-406
-164
31
Realised gains/losses transferred to the
statement of profit or loss
-25
-40
-33
Realised revaluations transferred to
retained earnings
23
6
-1
Other changes
-62
Closing balance
1,187
1,282
1,181
-339
92
296
Equity securities at FVOCI
In 2022, the unrealised revaluation of EUR -118\u00a0million (2021: 94 million and 2020: -337 million) includes
revaluation of shares in Bank of Beijing for EUR -86 million(2021: 38 million and 2020: -339 million).
In 2020, Other changes of EUR -62 million is related to prior years revaluations of Visa shares, which are
reclassified to Financial assets at fair value through profit or loss and for which the unrealised revaluation up
until 2020 is transferred to retained earnings.
Cash flow hedge
ING mainly hedges floating rate lending with interest rate swaps. Due to an increase in yield curves in 2022
the interest rate swaps had a negative revaluation of EUR -2,901\u00a0million which is recognised in the cash flow
hedge reserve.
Changes in cash flow hedge and credit liability reserve
Cash flow hedge
Credit liability
In EUR million
2022
2021
2020
2022
2021
2020
Opening balance
-153
1,450
1,208
-80
-117
-114
Changes in credit liability reserve
165
37
-19
Unrealised revaluations
-2,901
-1,603
242
Realised revaluations transferred to retained
earnings
-15
16
Other changes
Closing balance
-3,055
-153
1,450
70
-80
-117
Changes in Property in own use reserve
Property in own use
In EUR million
2022
2021
2020
Opening balance
208
221
253
Impact IAS 29 on opening balance 1
-20
Unrealised revaluations
15
-2
-7
Realised revaluations transferred to retained earnings
-26
-11
-26
Other changes
Closing balance
176
208
221
1 Impact of application of hyperinflation accounting under IAS 29 from 1 January 2022.
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
2022
2021
2020
Opening balance
-3,483
-3,636
-2,079
Impact IAS 29 on opening balance 1
647
Unrealised revaluations
-7
-61
106
Realised gains/losses transferred to the statement of profit or loss
4
-1
Exchange rate differences
444
214
-1,662
Closing balance
-2,395
-3,483
-3,636
1 Impact of application of hyperinflation accounting under IAS 29 from 1 January 2022.
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 increase of unrealized revaluations and Exchange rate differences of EUR 437
million is related to several currencies including USD (EUR 380 million), TRY (EUR 192 million including EUR
364 million IAS 29 indexation effect), GBP (EUR -73 million), PLN (EUR -49 million), CHF (EUR 41 million), AUD
(EUR -20 million), UAH (EUR -27 million) and other currencies (EUR -7 million).
Share of associates and joint ventures and other reserves
Changes in share of associates, joint ventures and other reserves
In EUR million
2022
2021
2020
Opening balance
3,416
3,246
3,189
Result for the year
161
191
94
Transfer to/from retained earnings
26
-21
-37
Closing balance
3,604
3,416
3,246
The Share of associates, joint ventures and other reserves includes non-distributable profits from associates
and joint ventures of EUR 797 million (2021: EUR 738 million). Other reserves includes a statutory reserve of
EUR 2,264 million (2021: EUR 2,103 million) related to the former Stichting Regio Bank and the former
Stichting Vakbondsspaarbank SPN and a legal reserve of EUR 540 million (2021: EUR 573 million) related to
own developed software.
Retained earnings
Changes in retained earnings
In EUR million
2022
2021
2020
Opening balance
29,778
28,273
25,857
Impact IAS 29 on opening balance 1
-563
Transfer to/from other reserves
-8
26
108
Result for the year
3,506
4,579
2,321
Dividend and other distributions
-6,277
-3,125
-43
Employee stock options and share plans
27
28
23
Changes in composition of the group and other changes
-1
-3
7
Closing balance
26,462
29,778
28,273
No change occurred in the issued share capital and share premium in 2022, 2021 and 2020.
All ordinary shares are in registered form. No share certificates have been issued. Ordinary shares may be
transferred by means of a deed of transfer, subject to the approval of the general meeting of ING Bank. The
par value of ordinary shares is EUR 1.13.
The authorised ordinary share capital of ING Bank N.V. consists of 1,600 million shares of which as at
31\u00a0December 2022, 465 million ordinary shares were issued and fully paid.
ING Bank has 50 authorised preference shares with par value of EUR 1.13 per preference share. As at
31\u00a0December 2022, 7 preference shares were issued and fully paid (2021: 7 preference shares; 2020: 7
preference shares) amounting to EUR 8 (2021: EUR 8 and 2020: EUR 8).
", "dimensions": { "concept": "ifrs-full:DisclosureOfIssuedCapitalExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNDgvZnJhZzoyYTA5Yzk5YTYyZWE0MmNhYjFkMGQzZDI1NTAzOGY5Mi90ZXh0cmVnaW9uOjJhMDljOTlhNjJlYTQyY2FiMWQwZDNkMjU1MDM4ZjkyXzIzMDg5NzQ0MTkzNjU5_8cd90b0a-ef02-416c-b57f-b9be31eeb7ab": { "value": "
No change occurred in the issued share capital and share premium in 2022, 2021 and 2020.
All ordinary shares are in registered form. No share certificates have been issued. Ordinary shares may be
transferred by means of a deed of transfer, subject to the approval of the general meeting of ING Bank. The
par value of ordinary shares is EUR 1.13.
The authorised ordinary share capital of ING Bank N.V. consists of 1,600 million shares of which as at
31\u00a0December 2022, 465 million ordinary shares were issued and fully paid.
ING Bank has 50 authorised preference shares with par value of EUR 1.13 per preference share. As at
31\u00a0December 2022, 7 preference shares were issued and fully paid (2021: 7 preference shares; 2020: 7
preference shares) amounting to EUR 8 (2021: EUR 8 and 2020: EUR 8).
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForIssuedCapitalExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNDgvZnJhZzoyYTA5Yzk5YTYyZWE0MmNhYjFkMGQzZDI1NTAzOGY5Mi90ZXh0cmVnaW9uOjJhMDljOTlhNjJlYTQyY2FiMWQwZDNkMjU1MDM4ZjkyXzc5Mjc_786ca76f-996c-4f09-8f5f-0e6179981c34": { "value": "
Other reserves
Revaluation reserves
Changes in revaluation reserve: Equity securities and Debt instruments at FVOCI
Equity securities at FVOCI
Debt instruments at FVOCI
In EUR million
2022
2021
2020
2022
2021
2020
Opening balance
1,282
1,181
1,580
92
296
299
Unrealised revaluations
-118
94
-337
-406
-164
31
Realised gains/losses transferred to the
statement of profit or loss
-25
-40
-33
Realised revaluations transferred to
retained earnings
23
6
-1
Other changes
-62
Closing balance
1,187
1,282
1,181
-339
92
296
Equity securities at FVOCI
In 2022, the unrealised revaluation of EUR -118\u00a0million (2021: 94 million and 2020: -337 million) includes
revaluation of shares in Bank of Beijing for EUR -86 million(2021: 38 million and 2020: -339 million).
In 2020, Other changes of EUR -62 million is related to prior years revaluations of Visa shares, which are
reclassified to Financial assets at fair value through profit or loss and for which the unrealised revaluation up
until 2020 is transferred to retained earnings.
Cash flow hedge
ING mainly hedges floating rate lending with interest rate swaps. Due to an increase in yield curves in 2022
the interest rate swaps had a negative revaluation of EUR -2,901\u00a0million which is recognised in the cash flow
hedge reserve.
Changes in cash flow hedge and credit liability reserve
Cash flow hedge
Credit liability
In EUR million
2022
2021
2020
2022
2021
2020
Opening balance
-153
1,450
1,208
-80
-117
-114
Changes in credit liability reserve
165
37
-19
Unrealised revaluations
-2,901
-1,603
242
Realised revaluations transferred to retained
earnings
-15
16
Other changes
Closing balance
-3,055
-153
1,450
70
-80
-117
Changes in Property in own use reserve
Property in own use
In EUR million
2022
2021
2020
Opening balance
208
221
253
Impact IAS 29 on opening balance 1
-20
Unrealised revaluations
15
-2
-7
Realised revaluations transferred to retained earnings
-26
-11
-26
Other changes
Closing balance
176
208
221
1 Impact of application of hyperinflation accounting under IAS 29 from 1 January 2022.
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
2022
2021
2020
Opening balance
-3,483
-3,636
-2,079
Impact IAS 29 on opening balance 1
647
Unrealised revaluations
-7
-61
106
Realised gains/losses transferred to the statement of profit or loss
4
-1
Exchange rate differences
444
214
-1,662
Closing balance
-2,395
-3,483
-3,636
1 Impact of application of hyperinflation accounting under IAS 29 from 1 January 2022.
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 increase of unrealized revaluations and Exchange rate differences of EUR 437
million is related to several currencies including USD (EUR 380 million), TRY (EUR 192 million including EUR
364 million IAS 29 indexation effect), GBP (EUR -73 million), PLN (EUR -49 million), CHF (EUR 41 million), AUD
(EUR -20 million), UAH (EUR -27 million) and other currencies (EUR -7 million).
", "dimensions": { "concept": "ifrs-full:DisclosureOfReservesAndOtherEquityInterestExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNDgvZnJhZzoyYTA5Yzk5YTYyZWE0MmNhYjFkMGQzZDI1NTAzOGY5Mi90ZXh0cmVnaW9uOjJhMDljOTlhNjJlYTQyY2FiMWQwZDNkMjU1MDM4ZjkyXzIzMDg5NzQ0MTkzNjYw_14958427-25a7-432b-a344-0ed1bbf78426": { "value": "
Currency translation reserve
Changes in currency translation reserve
In EUR million
2022
2021
2020
Opening balance
-3,483
-3,636
-2,079
Impact IAS 29 on opening balance 1
647
Unrealised revaluations
-7
-61
106
Realised gains/losses transferred to the statement of profit or loss
4
-1
Exchange rate differences
444
214
-1,662
Closing balance
-2,395
-3,483
-3,636
1 Impact of application of hyperinflation accounting under IAS 29 from 1 January 2022.
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 increase of unrealized revaluations and Exchange rate differences of EUR 437
million is related to several currencies including USD (EUR 380 million), TRY (EUR 192 million including EUR
364 million IAS 29 indexation effect), GBP (EUR -73 million), PLN (EUR -49 million), CHF (EUR 41 million), AUD
(EUR -20 million), UAH (EUR -27 million) and other currencies (EUR -7 million).
22\u00a0 Valuation results and net trading income
Valuation results and net trading income
in EUR million
2022
2021
2020
Securities trading results
-356
787
-500
Derivatives trading results
11
-554
701
Other trading results
71
84
72
Change in fair value of derivatives relating to
\u2013\u00a0 fair value hedges
5,265
-85
246
\u2013\u00a0 cash flow hedges (ineffective portion)
20
1
-5
\u2013\u00a0 other non-trading derivatives
1,164
-53
222
Change in fair value of assets and liabilities (hedged items)
-5,150
113
-183
Valuation results on assets and liabilities designated at FVPL (excluding trading)
444
-12
-121
Foreign exchange transactions results
33
566
422
1,503
847
852
and Note 14
'Financial liabilities at fair value through profit or loss' for information on trading assets and trading liabilities
respectively.
\u2018Valuation results and net trading income\u2019 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. During 2022, the interest rate movements
significantly affected the fair value changes of other non-trading derivatives as well as 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 is 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 CollVA). Spreads widened in 2022 compared to 2021 and the fair value changes increased.
In 2022, Derivatives trading results include EUR\u00a043 million CVA/DVA adjustments on trading derivatives
(2021: EUR 98 million; 2020: EUR 17 million).
Valuation results on assets and liabilities designated at fair value through profit or loss (excluding trading)\u2019
include fair value changes on financial assets and financial liabilities driven by changed market conditions.
Refer to Note 4 'Financial assets at fair value through profit or loss' and to Note 14 'Financial liabilities at fair
value through profit or loss'.
In addition, \u2018Valuation results on assets and liabilities designated at fair value through profit or loss
(excluding trading)\u2019 include fair value adjustments on own issued notes amounting to EUR 709 million (2021:
EUR 56 million; 2020: EUR 8 million).
Interest income from trading assets in 2022 amounted to EUR 18,593 million (2021: EUR 13,737 million;
2020: EUR 13,412 million). Interest expense from trading liabilities in 2022 amounted to EUR 18,765 million
(2021: EUR 14,079 million; 2020: EUR 13,052 million).
", "dimensions": { "concept": "ifrs-full:DisclosureOfEffectOfChangesInForeignExchangeRatesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNDgvZnJhZzoyYTA5Yzk5YTYyZWE0MmNhYjFkMGQzZDI1NTAzOGY5Mi90ZXh0cmVnaW9uOjJhMDljOTlhNjJlYTQyY2FiMWQwZDNkMjU1MDM4ZjkyXzc5Mjg_b129d122-5d51-4708-8f86-d290e3f78c56": { "value": "
Dividend
In 2022, a cash dividend and other cash distribution of EUR 6,277 million in total\u00a0 (2021: EUR 3,125 million
and 2020: EUR 43 million) was paid to the shareholder of ING Bank.", "dimensions": { "concept": "ifrs-full:DisclosureOfDividendsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNTEvZnJhZzo5YjkxYTMwNTk4OTE0YjM0OTg2NGM0MWJjNmI1ZTViZC90ZXh0cmVnaW9uOjliOTFhMzA1OTg5MTRiMzQ5ODY0YzQxYmM2YjVlNWJkXzE4NTQ_207e0b19-6142-4144-996e-b3d1c7690102": { "value": "
20\u00a0 Net interest income
Net interest income
in EUR million
2022
2021
2020
2022
2021
2020
Interest income on loans
18,537
13,979
15,766
Interest expense on deposits from banks
903
109
177
Interest income on financial assets at fair value through OCI
510
346
512
Interest expense on customer deposits
4,133
1,999
2,022
Interest income on debt securities at amortised cost
591
468
508
Interest expense on debt securities in issue
859
597
1,145
Interest income on non-trading derivatives (hedge accounting)
4,011
2,361
3,392
Interest expense on subordinated loans
646
573
613
Negative interest on liabilities
892
1,502
686
Negative interest on assets
285
572
353
Total interest income using effective interest rate method
24,541
18,657
20,865
Interest expense on non-trading derivatives (hedge accounting)
4,144
1,700
3,198
Total interest expense using effective interest rate method
10,969
5,550
7,507
Interest income on financial assets at fair value through profit or loss
1,444
435
658
Interest income on non-trading derivatives (no hedge accounting)
2,390
2,025
1,156
Interest expense on financial liabilities at fair value through profit or loss
1,237
304
514
Interest income other
101
14
31
Interest expense on non-trading derivatives (no hedge accounting)
2,411
1,605
1,029
Total other interest income
3,935
2,474
1,846
Interest expense on lease liabilities
15
14
18
Total interest income
28,476
21,131
22,711
Interest expense other
98
43
42
Total other interest expense
3,761
1,966
1,603
Total interest expense
14,730
7,516
9,110
Net interest income
13,745
13,615
13,600
for more details).
21\u00a0 Net fee and commission income
Net fee and commission income
in EUR million
2022
2021
2020
Fee and commission income
Payment Services
1,888
1,661
1,566
Securities business
632
853
700
Insurance and other broking
682
734
705
Portfolio management
600
617
525
Lending business
556
477
368
Financial guarantees and other commitments
496
458
364
Other
232
204
286
Total fee and commission income
5,085
5,004
4,514
Fee and commission expenses
Payment Services
600
563
611
Securities business
160
164
133
Distribution of products (Externally)
555
591
548
Other
184
169
211
Total fee and commission expenses
1,499
1,487
1,503
Net fee and commission income
3,586
3,517
3,011
1 ING changed the presentation of net fee and commission income as of 2021. The comparative figure for 2020 has been updated\u00a0
accordingly. The reclassification does not affect the total amount of 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 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\u2019s products and services through external providers.
All of ING\u2019s net fee and commission income are in scope of IFRS 15 \u2018Revenue from Contracts with
Customers\u2019. Reference is made to Note 31 'Segments' which includes net fee and commission income, as
reported to the Management Board Banking, disaggregated by line of business and by geographical
segment.
22\u00a0 Valuation results and net trading income
Valuation results and net trading income
in EUR million
2022
2021
2020
Securities trading results
-356
787
-500
Derivatives trading results
11
-554
701
Other trading results
71
84
72
Change in fair value of derivatives relating to
\u2013\u00a0 fair value hedges
5,265
-85
246
\u2013\u00a0 cash flow hedges (ineffective portion)
20
1
-5
\u2013\u00a0 other non-trading derivatives
1,164
-53
222
Change in fair value of assets and liabilities (hedged items)
-5,150
113
-183
Valuation results on assets and liabilities designated at FVPL (excluding trading)
444
-12
-121
Foreign exchange transactions results
33
566
422
1,503
847
852
and Note 14
'Financial liabilities at fair value through profit or loss' for information on trading assets and trading liabilities
respectively.
\u2018Valuation results and net trading income\u2019 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. During 2022, the interest rate movements
significantly affected the fair value changes of other non-trading derivatives as well as 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 is 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 CollVA). Spreads widened in 2022 compared to 2021 and the fair value changes increased.
In 2022, Derivatives trading results include EUR\u00a043 million CVA/DVA adjustments on trading derivatives
(2021: EUR 98 million; 2020: EUR 17 million).
Valuation results on assets and liabilities designated at fair value through profit or loss (excluding trading)\u2019
include fair value changes on financial assets and financial liabilities driven by changed market conditions.
Refer to Note 4 'Financial assets at fair value through profit or loss' and to Note 14 'Financial liabilities at fair
value through profit or loss'.
In addition, \u2018Valuation results on assets and liabilities designated at fair value through profit or loss
(excluding trading)\u2019 include fair value adjustments on own issued notes amounting to EUR 709 million (2021:
EUR 56 million; 2020: EUR 8 million).
Interest income from trading assets in 2022 amounted to EUR 18,593 million (2021: EUR 13,737 million;
2020: EUR 13,412 million). Interest expense from trading liabilities in 2022 amounted to EUR 18,765 million
(2021: EUR 14,079 million; 2020: EUR 13,052 million).
23\u00a0 Investment income
Investment income
in EUR million
2022
2021
2020
Dividend income
149
122
107
Realised gains/losses on disposal of debt instruments measured at FVOCI
32
45
44
Income from and fair value gains/losses on investment properties
-1
1
181
167
152
In 2022, 2021 and 2020 dividend income mainly consists of dividend received from ING\u2019s equity stake in
Bank of Beijing.
24\u00a0 Net result on derecognition of financial assets measured at amortised
cost
Net result on derecognition of financial assets measured at amortised cost
in EUR million
2022
2021
2020
Loans at amortised cost
1
4
Securities at amortised cost
-5
-1
185
-5
0
189
20\u00a0 Net interest income
Net interest income
in EUR million
2022
2021
2020
2022
2021
2020
Interest income on loans
18,537
13,979
15,766
Interest expense on deposits from banks
903
109
177
Interest income on financial assets at fair value through OCI
510
346
512
Interest expense on customer deposits
4,133
1,999
2,022
Interest income on debt securities at amortised cost
591
468
508
Interest expense on debt securities in issue
859
597
1,145
Interest income on non-trading derivatives (hedge accounting)
4,011
2,361
3,392
Interest expense on subordinated loans
646
573
613
Negative interest on liabilities
892
1,502
686
Negative interest on assets
285
572
353
Total interest income using effective interest rate method
24,541
18,657
20,865
Interest expense on non-trading derivatives (hedge accounting)
4,144
1,700
3,198
Total interest expense using effective interest rate method
10,969
5,550
7,507
Interest income on financial assets at fair value through profit or loss
1,444
435
658
Interest income on non-trading derivatives (no hedge accounting)
2,390
2,025
1,156
Interest expense on financial liabilities at fair value through profit or loss
1,237
304
514
Interest income other
101
14
31
Interest expense on non-trading derivatives (no hedge accounting)
2,411
1,605
1,029
Total other interest income
3,935
2,474
1,846
Interest expense on lease liabilities
15
14
18
Total interest income
28,476
21,131
22,711
Interest expense other
98
43
42
Total other interest expense
3,761
1,966
1,603
Total interest expense
14,730
7,516
9,110
Net interest income
13,745
13,615
13,600
20\u00a0 Net interest income
Net interest income
in EUR million
2022
2021
2020
2022
2021
2020
Interest income on loans
18,537
13,979
15,766
Interest expense on deposits from banks
903
109
177
Interest income on financial assets at fair value through OCI
510
346
512
Interest expense on customer deposits
4,133
1,999
2,022
Interest income on debt securities at amortised cost
591
468
508
Interest expense on debt securities in issue
859
597
1,145
Interest income on non-trading derivatives (hedge accounting)
4,011
2,361
3,392
Interest expense on subordinated loans
646
573
613
Negative interest on liabilities
892
1,502
686
Negative interest on assets
285
572
353
Total interest income using effective interest rate method
24,541
18,657
20,865
Interest expense on non-trading derivatives (hedge accounting)
4,144
1,700
3,198
Total interest expense using effective interest rate method
10,969
5,550
7,507
Interest income on financial assets at fair value through profit or loss
1,444
435
658
Interest income on non-trading derivatives (no hedge accounting)
2,390
2,025
1,156
Interest expense on financial liabilities at fair value through profit or loss
1,237
304
514
Interest income other
101
14
31
Interest expense on non-trading derivatives (no hedge accounting)
2,411
1,605
1,029
Total other interest income
3,935
2,474
1,846
Interest expense on lease liabilities
15
14
18
Total interest income
28,476
21,131
22,711
Interest expense other
98
43
42
Total other interest expense
3,761
1,966
1,603
Total interest expense
14,730
7,516
9,110
Net interest income
13,745
13,615
13,600
21\u00a0 Net fee and commission income
Net fee and commission income
in EUR million
2022
2021
2020
Fee and commission income
Payment Services
1,888
1,661
1,566
Securities business
632
853
700
Insurance and other broking
682
734
705
Portfolio management
600
617
525
Lending business
556
477
368
Financial guarantees and other commitments
496
458
364
Other
232
204
286
Total fee and commission income
5,085
5,004
4,514
Fee and commission expenses
Payment Services
600
563
611
Securities business
160
164
133
Distribution of products (Externally)
555
591
548
Other
184
169
211
Total fee and commission expenses
1,499
1,487
1,503
Net fee and commission income
3,586
3,517
3,011
1 ING changed the presentation of net fee and commission income as of 2021. The comparative figure for 2020 has been updated\u00a0
accordingly. The reclassification does not affect the total amount of 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 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\u2019s products and services through external providers.
All of ING\u2019s net fee and commission income are in scope of IFRS 15 \u2018Revenue from Contracts with
Customers\u2019. Reference is made to Note 31 'Segments' which includes net fee and commission income, as
reported to the Management Board Banking, disaggregated by line of business and by geographical
segment.
", "dimensions": { "concept": "ifrs-full:DisclosureOfFeeAndCommissionIncomeExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNTQvZnJhZzo0NTIzYzgxOWJmMjI0NjQzYmNjYTA4MWEwODRlZWY5NS90ZXh0cmVnaW9uOjQ1MjNjODE5YmYyMjQ2NDNiY2NhMDgxYTA4NGVlZjk1XzMwMg_c561c90b-904c-4c36-b44a-127de7558f4c": { "value": "
21\u00a0 Net fee and commission income
Net fee and commission income
in EUR million
2022
2021
2020
Fee and commission income
Payment Services
1,888
1,661
1,566
Securities business
632
853
700
Insurance and other broking
682
734
705
Portfolio management
600
617
525
Lending business
556
477
368
Financial guarantees and other commitments
496
458
364
Other
232
204
286
Total fee and commission income
5,085
5,004
4,514
Fee and commission expenses
Payment Services
600
563
611
Securities business
160
164
133
Distribution of products (Externally)
555
591
548
Other
184
169
211
Total fee and commission expenses
1,499
1,487
1,503
Net fee and commission income
3,586
3,517
3,011
1 ING changed the presentation of net fee and commission income as of 2021. The comparative figure for 2020 has been updated\u00a0
accordingly. The reclassification does not affect the total amount of 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 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\u2019s products and services through external providers.
All of ING\u2019s net fee and commission income are in scope of IFRS 15 \u2018Revenue from Contracts with
Customers\u2019. Reference is made to Note 31 'Segments' which includes net fee and commission income, as
reported to the Management Board Banking, disaggregated by line of business and by geographical
segment.
", "dimensions": { "concept": "ifrs-full:DisclosureOfRevenueFromContractsWithCustomersExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNTcvZnJhZzplMzk1MDhjNTY4ZWM0OTJlYmIwOTMxMzBjZGNlMDVlZC90ZXh0cmVnaW9uOmUzOTUwOGM1NjhlYzQ5MmViYjA5MzEzMGNkY2UwNWVkXzE0OA_52acae93-097c-4a43-afdd-d3a2ebdc2f1d": { "value": "
22\u00a0 Valuation results and net trading income
Valuation results and net trading income
in EUR million
2022
2021
2020
Securities trading results
-356
787
-500
Derivatives trading results
11
-554
701
Other trading results
71
84
72
Change in fair value of derivatives relating to
\u2013\u00a0 fair value hedges
5,265
-85
246
\u2013\u00a0 cash flow hedges (ineffective portion)
20
1
-5
\u2013\u00a0 other non-trading derivatives
1,164
-53
222
Change in fair value of assets and liabilities (hedged items)
-5,150
113
-183
Valuation results on assets and liabilities designated at FVPL (excluding trading)
444
-12
-121
Foreign exchange transactions results
33
566
422
1,503
847
852
and Note 14
'Financial liabilities at fair value through profit or loss' for information on trading assets and trading liabilities
respectively.
\u2018Valuation results and net trading income\u2019 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. During 2022, the interest rate movements
significantly affected the fair value changes of other non-trading derivatives as well as 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 is 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 CollVA). Spreads widened in 2022 compared to 2021 and the fair value changes increased.
In 2022, Derivatives trading results include EUR\u00a043 million CVA/DVA adjustments on trading derivatives
(2021: EUR 98 million; 2020: EUR 17 million).
Valuation results on assets and liabilities designated at fair value through profit or loss (excluding trading)\u2019
include fair value changes on financial assets and financial liabilities driven by changed market conditions.
Refer to Note 4 'Financial assets at fair value through profit or loss' and to Note 14 'Financial liabilities at fair
value through profit or loss'.
In addition, \u2018Valuation results on assets and liabilities designated at fair value through profit or loss
(excluding trading)\u2019 include fair value adjustments on own issued notes amounting to EUR 709 million (2021:
EUR 56 million; 2020: EUR 8 million).
Interest income from trading assets in 2022 amounted to EUR 18,593 million (2021: EUR 13,737 million;
2020: EUR 13,412 million). Interest expense from trading liabilities in 2022 amounted to EUR 18,765 million
(2021: EUR 14,079 million; 2020: EUR 13,052 million).
", "dimensions": { "concept": "ifrs-full:DisclosureOfTradingIncomeExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNjkvZnJhZzowNzIyYjI0Y2Y5Yjg0NTI3OTE3YjhjZjY5MmVlMGI3MC90ZXh0cmVnaW9uOjA3MjJiMjRjZjliODQ1Mjc5MTdiOGNmNjkyZWUwYjcwXzU0OTc1NTgxNTg4OQ_0506b1f2-a27f-4d71-a183-88d29be39957": { "value": "-369000000", "decimals": -6, "dimensions": { "concept": "ingbank:OtherNetIncome", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00", "unit": "iso4217:EUR" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNjkvZnJhZzowNzIyYjI0Y2Y5Yjg0NTI3OTE3YjhjZjY5MmVlMGI3MC90ZXh0cmVnaW9uOjA3MjJiMjRjZjliODQ1Mjc5MTdiOGNmNjkyZWUwYjcwXzU0OTc1NTgxNTg5NA_de1cfd13-f0d9-4337-949e-2e8db21d9554": { "value": "230000000", "decimals": -6, "dimensions": { "concept": "ingbank:OtherNetIncome", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2021-01-01T00:00:00/2022-01-01T00:00:00", "unit": "iso4217:EUR" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNjkvZnJhZzowNzIyYjI0Y2Y5Yjg0NTI3OTE3YjhjZjY5MmVlMGI3MC90ZXh0cmVnaW9uOjA3MjJiMjRjZjliODQ1Mjc5MTdiOGNmNjkyZWUwYjcwXzU0OTc1NTgxNTg5OQ_d7bfd12c-e53d-418a-8651-fb3ab9717d72": { "value": "12000000", "decimals": -6, "dimensions": { "concept": "ingbank:OtherNetIncome", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2020-01-01T00:00:00/2021-01-01T00:00:00", "unit": "iso4217:EUR" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNzIvZnJhZzpjNjczNmZjMjIzMzE0MzhlOTE5ODNhOWRhYTI2OGI2MS90ZXh0cmVnaW9uOmM2NzM2ZmMyMjMzMTQzOGU5MTk4M2E5ZGFhMjY4YjYxXzMxMzY_7d6a19e8-1823-4f7a-a62f-70a1c3408d41": { "value": "
26\u00a0 Staff Expenses
Staff expenses
in EUR million
2022
2021
2020
Salaries
4,145
4,011
3,751
Pension costs and other staff-related benefit costs
390
408
395
Social security costs
584
563
538
Share-based compensation arrangements
27
28
23
External employees
738
699
881
Education
47
47
43
Other staff costs
222
182
186
6,152
5,938
5,817
Remuneration of senior management, Management Board Banking and Supervisory
Board
Reference is made to Note 46 'Related parties'.
Share plans and Stock Options
ING grants various types of share awards, namely deferred shares, performance shares 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 Management Board members of ING Bank as well as identified
staff, have a retention obligation that must be adhered to upon vesting, typically a minimum retention of 12
months applies. ING has the authority to apply a holdback to awarded but unvested shares and a clawback
to vested shares
The share awards granted in 2022 relate to the performance year 2021. In 2022, 55,651 share awards
(2021: 0; 2020: 63,837) were granted to the members of the Executive Board, and 137,506 share awards
(2021: 123,750; 2020: 186,176) were granted to the Management Board Banking. To senior\u00a0 management
and other employees\u00a0 2,913,926 share awards (2021: 3,267,372; 2020: 3,678,775) were granted.
Changes in share awards
Share awards (in numbers)
Weighted average grant date
fair values (in euros)
2022
2021
2020
2022
2021
2020
Opening balance
3,672,659
3,876,206
3,855,035
7.60
7.25
11.14
Granted
3,107,083
3,391,122
3,864,951
8.99
9.69
5.12
Vested
-2,962,698
-3,459,163
-3,690,340
8.60
9.25
9.01
Forfeited
-119,502
-135,506
-153,440
7.63
7.61
8.55
Closing balance
3,697,542
3,672,659
3,876,206
7.97
7.60
7.25
The most recent (actuarial) valuations of the plan assets and the present value of the defined benefit
obligation were carried out as at 31\u00a0December 2022. The present value of the defined benefit obligation, and
the related current service cost and past service cost, were determined using the projected unit credit
method.
The current worldwide uncertainty due to the Russian invasion in the Ukraine and the resulting increasing
interest rates and inflation has a strong negative impact on most investment markets in 2022, the effect on
the fair value of ING Bank\u2019s plan assets and defined benefit obligation is significant however the funding
status declined only by EUR -78 million mainly following the Liability Driven Investment (LDI) strategy in the
United Kingdom.
Changes in the fair value of plan assets for the period were as follows:
Changes in fair value of plan assets
in EUR million
2022
2021
Opening balance
3,671
3,583
Interest income
54
37
Remeasurements: Return on plan assets excluding amounts included in interest income
-947
2
Employer's contribution
34
26
Participants contributions
3
2
Benefits paid
-126
-136
Exchange rate differences
-53
158
Closing balance
2,637
3,671
Actual return on the plan assets
-894
39
Amounts recognised directly in Other comprehensive income were as follows:
Changes in the net defined benefit assets/liability remeasurement reserve
in EUR million
2022
2021
Opening balance
-212
-307
Remeasurement of plan assets
-947
2
Actuarial gains and losses arising from changes in demographic assumptions
5
Actuarial gains and losses arising from changes in financial assumptions
882
122
Taxation and Exchange rate differences
46
-34
Total Other comprehensive income movement for the year
-19
95
Closing balance
-232
-212
In 2022 EUR -947 million (2021: EUR 2\u00a0 million) remeasurement of plan assets, that is recognised as a loss in
other comprehensive income, is driven by higher yields on investments. Also the war in Ukraine and high
inflation had impact on the investment return. Material changes in interest rates and equity returns
impacted plan assets negatively during 2022 substantially.
The EUR 882\u00a0million (2021: EUR 122 million) actuarial gains arising from changes in financial assumptions in
the calculation of the defined benefit obligation are mainly due to an increase in discount rates.
The accumulated amount of remeasurements recognised directly in Other comprehensive income is EUR
-289\u00a0million(EUR -232 million after tax) as at 31\u00a0December 2022 (2021: EUR -296\u00a0million; EUR -212\u00a0million
after tax).
Amounts recognised in the statement of profit or loss related to pension and other staff related benefits are
as follows:
Pension and other staff-related benefit costs
Net defined benefit
asset/liability
Other post-employment
benefits
Total
in EUR million
2022
2021
2020
2022
2021
2020
2022
2021
2020
Current service cost
33
33
31
1
1
-2
34
34
29
Past service cost
2
-1
2
Net Interest cost
-8
-6
-6
1
2
2
-6
-4
-4
Effect of curtailment or settlement
-2
-2
Defined benefit plans
26
27
27
2
1
0
27
28
28
Defined contribution plans
364
369
356
Pension and other post employment
benefits
392
397
383
Other staff related benefits
-2
11
12
Pension and other staff-related benefits
390
408
395
Determination of the net defined benefit asset/liability
The net defined benefit asset/liability is reviewed and adjusted annually. The assumptions used in the
determination of the net defined benefit asset/liability and the Other post-employment benefits include
discount rates, mortality rates, expected rates of salary increases (excluding promotion increases), and
indexation. The rates used for salary developments, interest discount factors, and other adjustments reflect
country-specific conditions.
The key assumption in the determination of the net defined benefit asset/liability is the discount rate. The
discount rate is the weighted average of the discount rates that are applied in different regions where ING
Bank has defined benefit pension plans (weighted by the defined benefit obligation). The discount rate is
based on a methodology that uses market yields on high quality corporate bonds of the specific regions
with durations matching the pension liabilities as key input. Market yields of high quality corporate bonds
reflect the yield on corporate bonds with an AA rating for durations where such yields are available. An
extrapolation is applied in order to determine the yield to the longer durations for which no AA-rated
corporate bonds are available. As a result of the limited availability of long-duration AA-rated corporate
bonds, extrapolation is an important element of the determination of the discount rate. The weighted
average discount rate applied for net defined benefit asset/liability for 2022 was 4.3% (2021: 1.5%) based on
the pension plan in the Netherlands, Germany, Belgium, The United States of America, and the United
Kingdom. The average discount rate applied for Other post-employment benefits in 2022 was 5.5% (2021:
2.9%)
Sensitivity analysis of key assumptions
ING performs sensitivity analyses on the most significant assumptions: discount rates, mortality, expected
rate of salary increase, and indexation. The sensitivity analysis has been carried out under the assumption
that the changes occurred at the end of the reporting period.
The sensitivity analysis calculates the financial impact on the defined benefit obligation of an increase or
decrease of the weighted averages of each significant actuarial assumption, all other assumptions held
constant. In practice, this is unlikely to occur, and some changes of the assumptions may be correlated.
Changes to mortality, expected rate of salary increase, and indexation would have no material impact on
the defined benefit obligation. The most significant impact would be from a change in the discount rate. An
increase or decrease in the discount rate of 1.0% creates an impact on the defined benefit obligation of\u00a0 EUR
247 million (decrease) and EUR 287 million (increase), respectively.
Expected cash flows
Annual contributions are paid to the funds at a rate necessary to adequately finance the accrued liabilities
of the plans calculated in accordance with local supervisory requirements. Plans in all countries are designed
to comply with applicable local regulations governing investments and funding levels. ING Bank\u2019s
subsidiaries should fund the cost of the entitlements expected to be earned on a yearly basis.
For 2023 the expected contributions to defined benefit pension plans are EUR 33 million.
The benefit payments for defined benefit and other post-employment benefits expected to be made by the
plan between 2023-2027 are estimated to be between EUR 128 million and EUR 150 million per year. From
2028 to 2032 the total payments made by the plan are expected to be EUR 739 million.
", "dimensions": { "concept": "ifrs-full:DisclosureOfEmployeeBenefitsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNzIvZnJhZzpjNjczNmZjMjIzMzE0MzhlOTE5ODNhOWRhYTI2OGI2MS90ZXh0cmVnaW9uOmM2NzM2ZmMyMjMzMTQzOGU5MTk4M2E5ZGFhMjY4YjYxXzMxMzY_7ed7546d-ab53-4ab2-9d51-215908ac50a8": { "value": "
26\u00a0 Staff Expenses
Staff expenses
in EUR million
2022
2021
2020
Salaries
4,145
4,011
3,751
Pension costs and other staff-related benefit costs
390
408
395
Social security costs
584
563
538
Share-based compensation arrangements
27
28
23
External employees
738
699
881
Education
47
47
43
Other staff costs
222
182
186
6,152
5,938
5,817
Remuneration of senior management, Management Board Banking and Supervisory
Board
Reference is made to Note 46 'Related parties'.
Share plans and Stock Options
ING grants various types of share awards, namely deferred shares, performance shares 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 Management Board members of ING Bank as well as identified
staff, have a retention obligation that must be adhered to upon vesting, typically a minimum retention of 12
months applies. ING has the authority to apply a holdback to awarded but unvested shares and a clawback
to vested shares
The share awards granted in 2022 relate to the performance year 2021. In 2022, 55,651 share awards
(2021: 0; 2020: 63,837) were granted to the members of the Executive Board, and 137,506 share awards
(2021: 123,750; 2020: 186,176) were granted to the Management Board Banking. To senior\u00a0 management
and other employees\u00a0 2,913,926 share awards (2021: 3,267,372; 2020: 3,678,775) were granted.
Changes in share awards
Share awards (in numbers)
Weighted average grant date
fair values (in euros)
2022
2021
2020
2022
2021
2020
Opening balance
3,672,659
3,876,206
3,855,035
7.60
7.25
11.14
Granted
3,107,083
3,391,122
3,864,951
8.99
9.69
5.12
Vested
-2,962,698
-3,459,163
-3,690,340
8.60
9.25
9.01
Forfeited
-119,502
-135,506
-153,440
7.63
7.61
8.55
Closing balance
3,697,542
3,672,659
3,876,206
7.97
7.60
7.25
for (reversals of) impairments of property and
equipment and Note 10 'Intangible assets' for (reversals of) impairments of intangible assets.
For further information on addition to (unused amounts reversed of) provision for reorganisations refer to
Note 15 'Provisions' and for further 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 2022, are
contributions to DGS of EUR 425 million (2021: EUR 435 million; 2020: EUR 413 million) mainly related to the
Netherlands, Germany, Belgium, and Poland and contributions to the SRF and local resolution funds of EUR
354 million (2021: EUR 308 million; 2020: EUR 277 million). In 2022 local bank taxes decreased by EUR 51
million from EUR 522 million in 2021 to EUR 470 million (2020: EUR 414 million).
In 2022, ING Bank Slaski, together with seven other Polish banks, has established an Institutional Protection
Scheme (IPS). The fund can be used to ensure the liquidity and solvency of each of its participants, and to
assist in the resolution of participating and non-participating banks. The contribution by ING amounts to EUR
99 million and is recognized as regulatory costs (DGS).
Audit and non-audit services
Audit and non-audit services include fees for services provided by the Bank\u2019s auditors and remained stable
for 2022. The increase of audit fees in 2021 follow from the re-appointment of the current auditor that also
triggered a revision of the audit fees.
", "dimensions": { "concept": "ifrs-full:DisclosureOfExpensesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNzIvZnJhZzpjNjczNmZjMjIzMzE0MzhlOTE5ODNhOWRhYTI2OGI2MS90ZXh0cmVnaW9uOmM2NzM2ZmMyMjMzMTQzOGU5MTk4M2E5ZGFhMjY4YjYxXzIzMDg5NzQ0MTg2NDYx_d6b4773d-63c6-49b8-b58c-5076065d06ce": { "value": "
Number of employees
Netherlands
Rest of the world
Total
2022
2021
2020
2022
2021
2020
2022
2021
2020
Total average number of
internal employees at full
time equivalent basis
14,488
15,138
15,201
43,081
42,523
40,701
57,569
57,660
55,901
", "dimensions": { "concept": "ifrs-full:DisclosureOfInformationAboutEmployeesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNzIvZnJhZzpjNjczNmZjMjIzMzE0MzhlOTE5ODNhOWRhYTI2OGI2MS90ZXh0cmVnaW9uOmM2NzM2ZmMyMjMzMTQzOGU5MTk4M2E5ZGFhMjY4YjYxXzMxMzU_b05d47b3-b830-46d0-9f1d-c3a37015261e": { "value": "
Share plans and Stock Options
ING grants various types of share awards, namely deferred shares, performance shares 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 Management Board members of ING Bank as well as identified
staff, have a retention obligation that must be adhered to upon vesting, typically a minimum retention of 12
months applies. ING has the authority to apply a holdback to awarded but unvested shares and a clawback
to vested shares
The share awards granted in 2022 relate to the performance year 2021. In 2022, 55,651 share awards
(2021: 0; 2020: 63,837) were granted to the members of the Executive Board, and 137,506 share awards
(2021: 123,750; 2020: 186,176) were granted to the Management Board Banking. To senior\u00a0 management
and other employees\u00a0 2,913,926 share awards (2021: 3,267,372; 2020: 3,678,775) were granted.
Changes in share awards
Share awards (in numbers)
Weighted average grant date
fair values (in euros)
2022
2021
2020
2022
2021
2020
Opening balance
3,672,659
3,876,206
3,855,035
7.60
7.25
11.14
Granted
3,107,083
3,391,122
3,864,951
8.99
9.69
5.12
Vested
-2,962,698
-3,459,163
-3,690,340
8.60
9.25
9.01
Forfeited
-119,502
-135,506
-153,440
7.63
7.61
8.55
Closing balance
3,697,542
3,672,659
3,876,206
7.97
7.60
7.25
for (reversals of) impairments of property and
equipment and Note 10 'Intangible assets' for (reversals of) impairments of intangible assets.
For further information on addition to (unused amounts reversed of) provision for reorganisations refer to
Note 15 'Provisions' and for further 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 2022, are
contributions to DGS of EUR 425 million (2021: EUR 435 million; 2020: EUR 413 million) mainly related to the
Netherlands, Germany, Belgium, and Poland and contributions to the SRF and local resolution funds of EUR
354 million (2021: EUR 308 million; 2020: EUR 277 million). In 2022 local bank taxes decreased by EUR 51
million from EUR 522 million in 2021 to EUR 470 million (2020: EUR 414 million).
In 2022, ING Bank Slaski, together with seven other Polish banks, has established an Institutional Protection
Scheme (IPS). The fund can be used to ensure the liquidity and solvency of each of its participants, and to
assist in the resolution of participating and non-participating banks. The contribution by ING amounts to EUR
99 million and is recognized as regulatory costs (DGS).
Audit and non-audit services
Audit and non-audit services include fees for services provided by the Bank\u2019s auditors and remained stable
for 2022. The increase of audit fees in 2021 follow from the re-appointment of the current auditor that also
triggered a revision of the audit fees.
", "dimensions": { "concept": "ifrs-full:DisclosureOfOtherOperatingExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNzUvZnJhZzoyZTZhOWQ5MTgyMDg0MWMzYmE3ZTI2NzMzYTlhNmM2Yy90ZXh0cmVnaW9uOjJlNmE5ZDkxODIwODQxYzNiYTdlMjY3MzNhOWE2YzZjXzcyMg_815bc707-6b69-42e8-b468-98d334681817": { "value": "
27\u00a0 Other operating expenses
Other operating expenses
in EUR million
2022
2021
2020
Regulatory costs
1,250
1,265
1,105
Audit and non-audit services
31
34
29
IT related expenses
818
781
812
Advertising and public relations
331
305
335
External advisory fees
306
297
413
Office expenses
273
280
320
Travel and accommodation expenses
91
52
68
Contributions and subscriptions
109
112
109
Postal charges
31
38
38
Depreciation of property and equipment
485
573
578
Amortisation of intangible assets
226
261
251
(Reversals of) impairments of property and equipment
19
26
43
(Reversals of) impairments of intangible assets
60
95
515
Addition to / (unused amounts reversed of) provision for reorganisations
170
214
149
Addition to / (unused amounts reversed of) other provisions
117
254
39
Other
723
669
541
5,040
5,257
5,344
for (reversals of) impairments of property and
equipment and Note 10 'Intangible assets' for (reversals of) impairments of intangible assets.
For further information on addition to (unused amounts reversed of) provision for reorganisations refer to
Note 15 'Provisions' and for further 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 2022, are
contributions to DGS of EUR 425 million (2021: EUR 435 million; 2020: EUR 413 million) mainly related to the
Netherlands, Germany, Belgium, and Poland and contributions to the SRF and local resolution funds of EUR
354 million (2021: EUR 308 million; 2020: EUR 277 million). In 2022 local bank taxes decreased by EUR 51
million from EUR 522 million in 2021 to EUR 470 million (2020: EUR 414 million).
In 2022, ING Bank Slaski, together with seven other Polish banks, has established an Institutional Protection
Scheme (IPS). The fund can be used to ensure the liquidity and solvency of each of its participants, and to
assist in the resolution of participating and non-participating banks. The contribution by ING amounts to EUR
99 million and is recognized as regulatory costs (DGS).
Audit and non-audit services
Audit and non-audit services include fees for services provided by the Bank\u2019s auditors and remained stable
for 2022. The increase of audit fees in 2021 follow from the re-appointment of the current auditor that also
triggered a revision of the audit fees.
", "dimensions": { "concept": "ifrs-full:DisclosureOfDepreciationAndAmortisationExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNzUvZnJhZzoyZTZhOWQ5MTgyMDg0MWMzYmE3ZTI2NzMzYTlhNmM2Yy90ZXh0cmVnaW9uOjJlNmE5ZDkxODIwODQxYzNiYTdlMjY3MzNhOWE2YzZjXzcyMw_13957413-6cea-45f7-90f4-b74d5d5a77ef": { "value": "
Audit and non-audit services
Audit and non-audit services include fees for services provided by the Bank\u2019s auditors and remained stable
for 2022. The increase of audit fees in 2021 follow from the re-appointment of the current auditor that also
triggered a revision of the audit fees.
", "dimensions": { "concept": "ifrs-full:DisclosureOfAuditorsRemunerationExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xODQvZnJhZzo4MmNkZDc1M2MwMjI0MTAzOWI1NjY0YzhiNjUxM2M2My90ZXh0cmVnaW9uOjgyY2RkNzUzYzAyMjQxMDM5YjU2NjRjOGI2NTEzYzYzXzIw_2e1b4854-34a4-4ffb-8aaa-05fc22707cf7": { "value": "
30\u00a0 Cash and cash equivalents
Cash and cash equivalents
in EUR million
2022
2021
2020
Treasury bills and other eligible bills
1
23
Deposits from banks/Loans and advances to banks
7,775
1,121
477
Cash and balances with central banks
87,614
106,520
111,087
Cash and cash equivalents at end of year
95,390
107,664
111,565
Treasury bills and other eligible bills included in cash and cash equivalents
in EUR million
2022
2021
2020
Treasury bills and other eligible bills included in trading assets
0
0
0
Treasury bills and other eligible bills included in FVOCI
0
0
0
Treasury bills and other eligible bills included in securities at AC
0
23
0
1
23
0
Deposits from banks/Loans and advances to banks
in EUR million
2022
2021
2020
Included in cash and cash equivalents:
\u2013\u00a0 Deposits from banks
-6,172
-7,059
-8,788
\u2013\u00a0 Loans and advances to banks
13,947
8,180
9,265
7,775
1,121
477
Not included in cash and cash equivalents:
\u2013\u00a0 Deposits from banks
-50,460
-78,033
-69,310
\u2013\u00a0 Loans and advances to banks
21,156
15,411
16,098
-29,304
-62,621
-53,212
Total as included in the statement of financial position:
\u2013\u00a0 Deposits from banks
-56,632
-85,092
-78,098
\u2013\u00a0 Loans and advances to banks
35,103
23,591
25,363
-21,529
-61,501
-52,734
collateral' for restrictions on Cash and balances with central banks.", "dimensions": { "concept": "ifrs-full:DisclosureOfCashAndCashEquivalentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xODQvZnJhZzo4MmNkZDc1M2MwMjI0MTAzOWI1NjY0YzhiNjUxM2M2My90YWJsZTplYjc5YWMwOTFlZDk0MjU2OGU0YjdiYjRlMzVmZjAxYi90YWJsZXJhbmdlOmViNzlhYzA5MWVkOTQyNTY4ZTRiN2JiNGUzNWZmMDFiXzQtMS0xLTEtMTMyNzUw_e26a001d-c817-4175-93f9-37c9693beaa5": { "value": "87614000000", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndBankBalancesAtCentralBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00", "unit": "iso4217:EUR" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xODQvZnJhZzo4MmNkZDc1M2MwMjI0MTAzOWI1NjY0YzhiNjUxM2M2My90YWJsZTplYjc5YWMwOTFlZDk0MjU2OGU0YjdiYjRlMzVmZjAxYi90YWJsZXJhbmdlOmViNzlhYzA5MWVkOTQyNTY4ZTRiN2JiNGUzNWZmMDFiXzQtMi0xLTEtMTMyNzUw_c6d5a457-4038-469d-9d0d-ff94daf4cab3": { "value": "106520000000", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndBankBalancesAtCentralBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00", "unit": "iso4217:EUR" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xODQvZnJhZzo4MmNkZDc1M2MwMjI0MTAzOWI1NjY0YzhiNjUxM2M2My90YWJsZTplYjc5YWMwOTFlZDk0MjU2OGU0YjdiYjRlMzVmZjAxYi90YWJsZXJhbmdlOmViNzlhYzA5MWVkOTQyNTY4ZTRiN2JiNGUzNWZmMDFiXzQtMy0xLTEtMTMyNzUw_b1d73a46-2567-4330-b631-07f62b1c782e": { "value": "111087000000", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndBankBalancesAtCentralBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2021-01-01T00:00:00", "unit": "iso4217:EUR" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xODQvZnJhZzo4MmNkZDc1M2MwMjI0MTAzOWI1NjY0YzhiNjUxM2M2My90ZXh0cmVnaW9uOjgyY2RkNzUzYzAyMjQxMDM5YjU2NjRjOGI2NTEzYzYzXzM1MTg0MzcyMDg4ODU0_c79fecfe-9b72-4c48-8576-3b9492ee27fd": { "value": "
Cash and cash equivalents includes deposits from banks and loans and advances to banks that are on
demand.
Included in Cash and cash equivalents, are minimum mandatory reserve deposits to be held with 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.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyToDetermineComponentsOfCashAndCashEquivalents", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xODcvZnJhZzowZDg0ZGYzYjZhNTk0ZThlOTEzOTFkY2JhZmU0M2E5OS90ZXh0cmVnaW9uOjBkODRkZjNiNmE1OTRlOGU5MTM5MWRjYmFmZTQzYTk5XzMzOTY_b72b2e63-8f5d-4bef-bcc4-73602f53287f": { "value": "
31\u00a0 Segments
ING Bank\u2019s segments are based on the internal reporting structure by lines of business.
The Management Board Banking of ING Bank (Chief Operating Decision Maker (CODM)) set the performance
targets, 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.
Recognition and measurement of segment results are in line with the accounting policies as described in
Note 1 \u2018Basis of preparation and significant accounting policies\u2019. 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.
The following table specifies the segments by line of business and main sources of income of each of the
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 (Market Leaders)
Income from retail and private banking activities in the Netherlands, including the
SME and mid-corporate segments, and the Real Estate Finance portfolio related
to Dutch domestic mid-corporates. The main products offered are current and
savings accounts, business lending, mortgages and other consumer lending in
the Netherlands.
Retail Belgium (Market Leaders)
Income from retail and private banking activities in Belgium (including
Luxembourg), including the SME and mid-corporate segments. The main products
offered are similar to those in the Netherlands.
Retail Germany (Challengers and
Growth Markets)
Income from retail and private banking activities in Germany (including Austria
up to and including 2021, after which ING left the retail market). The main
products offered are current and savings accounts, mortgages and other
customer lending.
Retail Other (Challengers and
Growth Markets)
Income from retail banking activities in the rest of the world, including the SME
and mid-corporate segments in specific countries. The main products offered are
similar to those in the Netherlands.
Wholesale Banking
Income from wholesale banking activities. The main products are: lending, debt
capital markets, working capital solutions, export finance, daily banking solutions,
treasury and risk solutions, and corporate finance.
1 Retail Banking Austria and Retail Banking Czech Republic up to and including 2021, after which ING left the retail market
2 In 2022, ING discontinued its retail activities in France and the Philippines.
3 As from 2022, Wholesale Banking Austria as well as Wholesale Banking Czech Republic are recorded in Wholesale Banking Rest of
\u00a0 \u00a0 \u00a0 \u00a0 \u00a0 World. Previously these financials were reported in Germany and Other Challengers respectively.
ING Bank monitors and evaluates the performance of ING Bank at a consolidated level and by segment. The
Management Board Banking consider this to be relevant to an understanding of the Bank\u2019s financial
performance, because it allows investors to understand the primary method used by management to
evaluate the Bank\u2019s operating performance and make decisions about allocating resources.
ING Bank reconciles the total segment results to the total result using Corporate Line. The Corporate Line is a
reflection of capital management activities and certain income and expenses that are not allocated to the
banking businesses. Furthermore, the Corporate Line includes the isolated legacy costs (mainly negative
interest results) caused by the replacement of short-term funding with long-term funding during 2013 and
2014. 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\u2019 book equity
and the currency they operate in. In 2022, results in the Corporate Line were impacted by the application of
hyperinflation accounting in the consolidation of our subsidiary in Turkey.
Income in 2022 included a hyperinflation accounting impact of EUR -279 million and a net TLTRO impact of
EUR 16 million, while previous year was supported by a EUR 143 million net TLTRO impact and the
recognition of a EUR 72 million receivable related to the insolvency of a financial institution. The decline was
partly compensated by higher income from foreign currency ratio hedging, mainly on US dollar and the
Polish zloty. Expenses in 2022 included a hyperinflation impact of EUR 30 million and a EUR 32 million
impairment loss related to the goodwill allocated to Turkey, while previous year had included EUR 87 million
of regulatory costs due to an incidental 50% increase in the Dutch bank tax.
The information presented in this note is in line with the information presented to the Management Board
Banking of ING Bank.
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 and is therefore not readily available.
Segments by line of business
12 month period
2022
2021
2020
in EUR million
Retail
Nether-
lands
Retail
Belgium
Retail
Germany
Retail
Other 1
Wholesale
Banking
Corporate
Line
Total
Retail
Nether-
lands
Retail
Belgium
Retail
Germany
2
Retail
Other 2
Wholesale
Banking
Corporate
Line
Total
Retail
Nether-
lands
Retail
Belgium
Retail
Germany
Retail
Other
Wholesale
Banking
Corporate
Line
Total
Income
\u2013 Net interest income
2,888
1,668
1,666
2,726
4,260
539
13,745
3,290
1,747
1,447
2,712
4,151
268
13,615
3,511
1,816
1,587
2,760
3,718
208
13,600
\u2013 Net fee and commission
income
892
511
437
535
1,217
-6
3,586
771
519
497
530
1,197
3
3,517
681
413
437
412
1,069
-1
3,011
\u2013 Total investment and
other income
417
-32
69
402
849
-490
1,215
201
209
65
361
568
-51
1,354
279
145
93
89
609
-180
1,034
Total income
4,196
2,147
2,172
3,663
6,325
43
18,546
4,262
2,475
2,009
3,602
5,916
221
18,485
4,471
2,373
2,117
3,261
5,396
27
17,645
Expenditure
\u2013 Operating expenses
2,115
1,786
1,140
2,516
3,114
523
11,193
2,403
1,667
1,174
2,452
2,926
574
11,195
2,236
1,737
1,110
2,469
3,218
390
11,160
\u2013 Addition to loan loss
provisions
67
139
131
302
1,220
2
1,861
-76
225
49
202
117
516
157
514
57
593
1,351
3
2,675
Total expenses
2,182
1,924
1,271
2,818
4,334
525
13,053
2,326
1,892
1,223
2,654
3,042
574
11,711
2,393
2,251
1,167
3,063
4,568
393
13,835
Result before taxation
2,014
223
901
845
1,991
-482
5,493
1,936
583
786
949
2,874
-353
6,774
2,078
122
950
199
827
-366
3,810
Taxation
540
72
202
257
581
71
1,723
499
146
252
212
703
64
1,876
523
51
331
105
295
13
1,317
Non-controlling interests
3
47
52
1
102
4
98
26
128
-1
4
55
20
78
Net result IFRS
1,474
151
696
541
1,358
-553
3,667
1,437
437
529
639
2,144
-417
4,770
1,556
71
615
39
512
-378
2,415
1 In\u00a0 2022, ING discontinued its retail activities in France and the Philippines.
2 In the fourth quarter of 2021, ING exited from the retail banking markets in Austria and the Czech Republic.
Geographical split of the segments
12 month period
2022
2021
2020
in EUR million
Nether
-lands
Belgium
Ger-
many
Other
Challen
gers 1
Growth
markets
1
Whole-
sale
Banking
Rest of
World
Other
Total
Nether
-lands
Belgium
Ger-
many
2,3
Other
Challen
gers 2,3
Growth
markets
Whole-
sale
Banking
Rest of
World 3
Other
Total
Nether-
lands
Belgium
Ger-
many 3
Other
Challen
gers 3
Growth
markets
Whole-
sale
Banking
Rest of
World 3
Other
Total
Income
\u2013 Net interest income
3,782
2,065
2,126
1,988
1,464
1,786
534
13,745
4,068
2,109
1,938
1,833
1,532
1,866
269
13,615
4,178
2,116
2,083
1,744
1,578
1,697
204
13,600
\u2013 Net fee and
commission income
1,171
714
494
312
376
526
-6
3,586
1,070
717
523
327
351
525
3
3,517
981
583
466
271
286
425
-1
3,011
\u2013 Total investment and
other income
577
-14
94
192
416
435
-485
1,215
314
265
118
80
446
182
-51
1,354
398
196
125
28
215
244
-172
1,034
Total income
5,531
2,765
2,714
2,491
2,256
2,746
43
18,546
5,452
3,092
2,578
2,240
2,330
2,574
221
18,485
5,557
2,896
2,674
2,043
2,078
2,366
31
17,645
Expenditure
\u2013 Operating expenses
3,001
2,120
1,318
1,456
1,444
1,331
523
11,193
3,279
1,960
1,339
1,516
1,276
1,251
574
11,195
3,347
2,037
1,263
1,536
1,272
1,310
395
11,160
\u2013 Addition to loan loss
provisions
181
230
460
241
230
517
2
1,861
28
184
118
100
110
-23
516
421
589
267
297
412
685
3
2,675
Total expenses
3,182
2,350
1,778
1,696
1,674
1,847
525
13,053
3,307
2,143
1,457
1,616
1,386
1,228
574
11,711
3,769
2,627
1,530
1,833
1,684
1,995
397
13,835
Result before taxation
2,349
415
936
795
581
899
-482
5,493
2,145
948
1,121
623
944
1,346
-353
6,774
1,788
269
1,144
209
395
371
-366
3,810
Retail Banking
2,014
223
901
547
298
3,983
1,936
583
786
206
742
4,253
2,078
122
950
-27
225
3,348
Wholesale Banking
335
192
34
248
284
899
1,991
209
365
336
417
202
1,346
2,874
-290
147
194
236
169
371
827
Corporate Line
-482
-482
-353
-353
-366
-366
Result before taxation
2,349
415
936
795
581
899
-482
5,493
2,145
948
1,121
623
944
1,346
-353
6,774
1,788
269
1,144
209
395
371
-366
3,810
Taxation
658
114
297
255
156
189
55
1,723
556
240
358
185
178
296
63
1,876
518
89
380
90
141
87
12
1,317
Non-controlling
interests
3
98
1
102
4
124
128
-1
4
75
78
Net result IFRS
1,691
301
636
540
327
710
-538
3,667
1,589
708
759
438
641
1,050
-415
4,770
1,271
180
760
119
178
284
-378
2,415
1 In 2022, ING discontinued its retail activities France and the Philippines.
2 In the fourth quarter of 2021, ING exited from the retail banking markets in Austria and the Czech Republic.
3 As from 2022, Wholesale Banking Austria as well as Wholesale Banking Czech Republic are recorded in Wholesale Banking Rest of World. Previously these financials were reported in Germany and Other Challengers respectively. Historical figures have been adjusted.
", "dimensions": { "concept": "ifrs-full:DisclosureOfEntitysReportableSegmentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xOTMvZnJhZzo3ZmYzOWY5NzM2ZGI0OGYyODhiMDcyNDQ3YzA2MGE0Yi90ZXh0cmVnaW9uOjdmZjM5Zjk3MzZkYjQ4ZjI4OGIwNzI0NDdjMDYwYTRiXzIzMDg5NzQ0MTgzNjA4_2746a3cd-bac9-4611-a0dd-6f039c7d5ad5": { "value": "
Expected cash flows
Annual contributions are paid to the funds at a rate necessary to adequately finance the accrued liabilities
of the plans calculated in accordance with local supervisory requirements. Plans in all countries are designed
to comply with applicable local regulations governing investments and funding levels. ING Bank\u2019s
subsidiaries should fund the cost of the entitlements expected to be earned on a yearly basis.
For 2023 the expected contributions to defined benefit pension plans are EUR 33 million.
The benefit payments for defined benefit and other post-employment benefits expected to be made by the
plan between 2023-2027 are estimated to be between EUR 128 million and EUR 150 million per year. From
2028 to 2032 the total payments made by the plan are expected to be EUR 739 million", "dimensions": { "concept": "ifrs-full:DisclosureOfClaimsAndBenefitsPaidExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xOTYvZnJhZzphYjYyMzFkMjUyZjM0ZmRjYjdhMTVkNTU0MDEyNWNmZS90ZXh0cmVnaW9uOmFiNjIzMWQyNTJmMzRmZGNiN2ExNWQ1NTQwMTI1Y2ZlXzIzNTE_f7939fa5-0e40-45a3-9565-43618f212e97": { "value": "
34\u00a0 Taxation
Statement of financial position \u2013 Deferred tax
Deferred taxes are recognised on all temporary differences under the liability method using tax rates
applicable in the jurisdictions in which ING Bank is subject to taxation.
Changes in deferred tax
in EUR million
2022
Net
liability\u00a0(-)
Net asset\u00a0(+)
opening
balance
Change
through
equity
Change
through
net\u00a0result
Exchange
rate
differences
Changes in the
composition of
the group and
other changes
Net
liability\u00a0(-)
Net asset\u00a0(+)
ending
balance
Financial assets at FVOCI
-70
148
5
-3
80
Financial assets and liabilities at FVPL
107
-88
9
28
Depreciation
-7
-5
-2
-13
Cash flow hedges
-126
875
2
752
Pension and post-employment
benefits
-49
6
-13
8
-7
-54
Other provisions
19
44
-4
59
Loans and advances
430
177
-3
7
612
Unused tax losses carried forward
199
137
-8
327
Other
-148
-123
26
-6
-251
354
907
283
-5
0
1,539
Presented in the statement of
financial position as:
\u2013\u00a0 Deferred tax liabilities
-603
-257
\u2013\u00a0 Deferred tax assets
957
1,796
354
1,539
The above mentioned deferred tax asset of EUR 365 million (2021: EUR 300 million) and the related unused
tax losses carried forward exclude the deferred tax liability recognised in the Netherlands with respect to the
recapture of tax losses originated in the United Kingdom but previously deducted in the Netherlands for the
amount of EUR 37\u00a0million (2021: EUR 102 million).
Deferred tax assets are recognised for temporary deductible differences, for tax losses carried forward and
unused tax credits only to the extent that realisation of the related tax benefit is probable.
Breakdown of certain net deferred tax asset positions by jurisdiction
in EUR million
2022
2021
Poland
391
265
France
70
66
Philippines
0
7
China
0
12
Czech
0
2
Hong Kong
6
1
United States of America
1
1
Turkey
7
Taiwan
8
483
354
The table above includes a breakdown of certain net deferred tax asset positions by jurisdiction for which
the utilisation of the deferred tax asset is dependent on future taxable profits in excess of the profits arising
from the reversal of existing taxable temporary differences whilst the related entities have incurred losses in
either the current or the preceding year.
In 2022 and 2021 ING Bank Slaski (Poland) incurred a tax loss following the large value changes of the cash
flow hedge derivatives which are settled net via a central clearing party. This tax loss can be carried forward
for 5 years. Based on a taxable profit forecast, ING considers it probable that the future taxable profits will
compensate for this tax loss carry forward position within 2 years. Based on this a deferred tax asset on
unused tax losses carried forward (EUR 224 million) is fully recognised. The remaining deferred tax asset in
Poland of EUR 167 million relates to temporary tax differences on loans and advances and financial assets
at fair value through profit and loss.
Recognition is based on the fact that it is probable that the entity will have taxable profits and/or can utilise
tax planning opportunities before expiration of the deferred tax assets. Changes in circumstances in future
periods may adversely impact the assessment of the recoverability. The uncertainty of the recoverability is
taken into account in establishing the deferred tax assets.
At 31 December 2021 and 2022, ING Bank had no significant temporary differences associated with the
parent company\u2019s investments in subsidiaries as any economic benefit from those investments will not be
taxable at parent company level.
Statement of profit or loss \u2013 Taxation
Taxation by type
Netherlands
Rest of the world
Total
in EUR million
2022
2021
2020
2022
2021
2020
2022
2021
2020
Current taxation
496
459
428
1,510
1,447
1,015
2,006
1,906
1,442
Deferred taxation
-79
47
64
-204
-78
-189
-283
-30
-125
417
507
492
1,306
1,369
826
1,723
1,876
1,317
Reconciliation of the weighted average statutory income tax rate to ING Bank\u2019s effective income tax rate
in EUR million
2022
2021
2020
Result before tax from continuing operations
5,493
6,774
3,810
Weighted average statutory tax rate
24.8%
24.3%
25.6%
Weighted average statutory tax amount
1,363
1,645
975
Permanent differences affecting current tax
Participation exemption
-64
-68
-46
Other income not subject to tax
-40
-32
-5
Expenses not deductible for tax purposes
403
201
320
Current tax from previously unrecognised amounts
10
51
17
State and local taxes
68
64
44
Adjustments to prior periods
-29
-12
-16
Differences affecting deferred tax
Impact on deferred tax from change in tax rates
5
9
10
Deferred tax benefit from previously unrecognised amounts
-3
-18
-6
Write-off/reversal of deferred tax assets
10
37
24
Effective tax amount
1,723
1,876
1,317
Effective tax rate
31.4%
27.7%
34.6%
The weighted average statutory tax rate in 2022 ( 24.8%) increased compared to that of 2021 (24.3%).
The effective tax rate of 31.4% in 2022 is higher than the weighted average statutory tax rate. This is mainly
caused by the impact in 2022 of the following non-deductible items for income tax purposes: hyperinflation
accounting loss in Turkey, impairments on TTB and interest expenses in various countries.
The weighted average statutory tax rate in 2021 (24.3%) was lower than the rate of 25.6% in 2020.
The effective tax rate of 27.7% in 2021 was significantly higher than the weighted average statutory tax
rate. This is mainly caused by a high amount of expenses non-deductible for tax purposes like the non-
deductible bank tax and a tax charge caused by the recapture of tax losses originated in the United
Kingdom but previously deducted in the Netherlands.
The effective tax rate of 34.6% in 2020 was higher than the weighted average statutory tax rate. This is
mainly caused by a high amount of expenses non-deductible for tax purposes like the non-deductible bank
tax and non-deductible losses with respect to goodwill impairments and impairments on associates in the
Netherlands and in some other European countries.
Adjustments to prior periods in 2020 relates to a release of a tax provision of EUR 68 million after concluding
on a settlement with the Australian tax authorities with respect to\u00a0 an issue related to former insurance
activities, which issue was fully indemnified by NN Group.
Equity \u2013 Other comprehensive income
Income tax related to components of other comprehensive income
in EUR million
2022
2021
2020
Unrealised revaluations financial assets at fair value through other comprehensive
income and other revaluations
140
14
-3
Realised gains/losses transferred to the statement of profit or loss (reclassifications
from equity to profit or loss)
8
12
10
Changes in cash flow hedge reserve
875
233
-23
Remeasurement of the net defined benefit asset/liability
6
-54
-8
Changes in fair value of own credit risk of financial liabilities at fair value through
profit or loss
19
-8
-1
Exchange rate differences and other
-141
-77
63
Total income tax related to components of other comprehensive income
907
120
38
", "dimensions": { "concept": "ifrs-full:DisclosureOfIncomeTaxExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xOTYvZnJhZzphYjYyMzFkMjUyZjM0ZmRjYjdhMTVkNTU0MDEyNWNmZS90ZXh0cmVnaW9uOmFiNjIzMWQyNTJmMzRmZGNiN2ExNWQ1NTQwMTI1Y2ZlXzIzMDg5NzQ0MTg2NjY2_833cd3df-dd7e-4603-87a8-40da4d4b18f3": { "value": "
Statement of financial position \u2013 Deferred tax
Deferred taxes are recognised on all temporary differences under the liability method using tax rates
applicable in the jurisdictions in which ING Bank is subject to taxation.
Changes in deferred tax
in EUR million
2022
Net
liability\u00a0(-)
Net asset\u00a0(+)
opening
balance
Change
through
equity
Change
through
net\u00a0result
Exchange
rate
differences
Changes in the
composition of
the group and
other changes
Net
liability\u00a0(-)
Net asset\u00a0(+)
ending
balance
Financial assets at FVOCI
-70
148
5
-3
80
Financial assets and liabilities at FVPL
107
-88
9
28
Depreciation
-7
-5
-2
-13
Cash flow hedges
-126
875
2
752
Pension and post-employment
benefits
-49
6
-13
8
-7
-54
Other provisions
19
44
-4
59
Loans and advances
430
177
-3
7
612
Unused tax losses carried forward
199
137
-8
327
Other
-148
-123
26
-6
-251
354
907
283
-5
0
1,539
Presented in the statement of
financial position as:
\u2013\u00a0 Deferred tax liabilities
-603
-257
\u2013\u00a0 Deferred tax assets
957
1,796
354
1,539
The above mentioned deferred tax asset of EUR 365 million (2021: EUR 300 million) and the related unused
tax losses carried forward exclude the deferred tax liability recognised in the Netherlands with respect to the
recapture of tax losses originated in the United Kingdom but previously deducted in the Netherlands for the
amount of EUR 37\u00a0million (2021: EUR 102 million).
Deferred tax assets are recognised for temporary deductible differences, for tax losses carried forward and
unused tax credits only to the extent that realisation of the related tax benefit is probable.
Breakdown of certain net deferred tax asset positions by jurisdiction
in EUR million
2022
2021
Poland
391
265
France
70
66
Philippines
0
7
China
0
12
Czech
0
2
Hong Kong
6
1
United States of America
1
1
Turkey
7
Taiwan
8
483
354
The table above includes a breakdown of certain net deferred tax asset positions by jurisdiction for which
the utilisation of the deferred tax asset is dependent on future taxable profits in excess of the profits arising
from the reversal of existing taxable temporary differences whilst the related entities have incurred losses in
either the current or the preceding year.
In 2022 and 2021 ING Bank Slaski (Poland) incurred a tax loss following the large value changes of the cash
flow hedge derivatives which are settled net via a central clearing party. This tax loss can be carried forward
for 5 years. Based on a taxable profit forecast, ING considers it probable that the future taxable profits will
compensate for this tax loss carry forward position within 2 years. Based on this a deferred tax asset on
unused tax losses carried forward (EUR 224 million) is fully recognised. The remaining deferred tax asset in
Poland of EUR 167 million relates to temporary tax differences on loans and advances and financial assets
at fair value through profit and loss.
Recognition is based on the fact that it is probable that the entity will have taxable profits and/or can utilise
tax planning opportunities before expiration of the deferred tax assets. Changes in circumstances in future
periods may adversely impact the assessment of the recoverability. The uncertainty of the recoverability is
taken into account in establishing the deferred tax assets.
At 31 December 2021 and 2022, ING Bank had no significant temporary differences associated with the
parent company\u2019s investments in subsidiaries as any economic benefit from those investments will not be
taxable at parent company level.
", "dimensions": { "concept": "ifrs-full:DisclosureOfDeferredTaxesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xOTkvZnJhZzo1MTY1NzBlOGY3MTY0ZGNmYTFhMWRjOGM1YjdjMmJjYS90ZXh0cmVnaW9uOjUxNjU3MGU4ZjcxNjRkY2ZhMWExZGM4YzViN2MyYmNhXzc2MDM_22eb3315-6e8f-4822-8244-7712a74d90f8": { "value": "
35\u00a0 Fair value of assets and liabilities
a) Valuation Methods
The estimated fair values represent 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 is a market-
based measurement, which is based on assumptions that market participants would use and takes into
account the characteristics of the asset or liability that market participants would take into account when
pricing the asset or liability.
Fair values of financial assets and liabilities are based on quoted prices in active market where available.
When such quoted prices are not available, the fair value is determined by using valuation techniques.
In 2022 the financial market witnessed globally a higher-volatility due to a confluence of factors, such as
changing expectations about the paths of future interest rates in major advanced economies, energy crisis
and geopolitical tensions after Russia's invasion of Ukraine.\u00a0 Globally, interest rates hike across EU and US.
The USD appreciates against EURO and various currencies during the year. These main factors drive the
market-to-market movements across different asset classes and spread movement through the year.
Overall in 2022, financial assets and liabilities, including Level 3, continued to be valued using agreed
methodologies and ING continued to limit the unobservable input to arrive at the most appropriate Fair
Market value.
b) Valuation Control framework
The valuation control framework covers the product approval process (PARP), pricing, market data
assessment and independent price verification (IPV), valuation adjustments, model use, fair value hierarchy
and day one profit or loss. Valuation processes are governed by various governance bodies, including Local
Parameter Committees, Global Valuation and Impairment Committee, Market Data Committee and
Valuation Model Committee. All relevant committees meet on a regular basis (monthly/quarterly), where
agenda covers the aforementioned valuation controls.
The Global Valuation and Impairment Committee is responsible for the oversight and the approval of the
outcome of impairments (other than loan loss provisions) and valuation processes. It oversees the quality
and coherence of valuation methodologies and performance. The Valuation Model Committee is responsible
for the approval of all valuation models used for the Fair valuation (IFRS) and Prudent Valuation (CRR) of
positions measured at fair value. The Local Parameter Committee discusses the valuation results and
monitors the performance of the valuation activities carried out on local or regional level. The Market Data
Committee is responsible for the approval of the market data used in valuation.\u00a0
c) Valuation Adjustments
Valuation adjustments are an integral part of the fair value. They are the adjustments to the output from a
valuation technique in order to appropriately determine a fair value in accordance with IFRS13. ING
considers various fair value adjustments including Bid-Offer adjustments, Model Risk adjustments, Bilateral
Valuation Adjustments (BVA, consisting of Credit Valuation Adjustments or CVA, and Debit valuation
Adjustments or DVA), Collateral Valuation Adjustment (CollVA) and Funding Valuation Adjustment (FVA).
For financial instruments where the fair value at initial recognition is based on one or more significant
unobservable inputs, a difference between the transaction price and the fair value resulting from the
internal valuation process can occur. Such difference is referred to as Day One Profit or Day One Loss (DOP).
ING defers material Day One Profit or Loss of instruments with significant unobservable valuation inputs,
which are the financial instruments classified as Level 3 and financial instruments with material
unobservable inputs into CVA which are not necessarily classified as Level 3. The Day One Profit or Loss is
amortised over the life of the instrument, or until the significant unobservable inputs become observable, or
until the significant unobservable inputs become non-significant. Both the impact on the profit and loss in
2022 and the Day One Profit or Loss reserve is disclosed in the below table.
The following table presents the models reserves for financial assets and liabilities.
Valuation adjustment reserves on financial assets and liabilities
in EUR million
2022
2021
Deferred Day One Profit or Loss 1
-108
-7
Own credit adjustments 2
75
-95
Bid/Offer
-216
-143
Model Risk
-13
-11
CVA
-192
-159
DVA 2
99
30
CollVA
-8
-8
FVA
-78
-95
Total Valuation Adjustments
-441
-489
1.In 2022, the presentation of Day One Profit or Loss reserve has been included in the table above
2. The change in the DVA as of 2022 entails the split into DVA on derivatives and Own credit adjustments on own issued liabilities.
Comparatives figures for 2021 have been updated accordingly.\u00a0
Overall, the fair value adjustments balance move down compared to last year end explained by own credit
adjustments on own issued liabilities, mainly driven by the widening of ING CDS curve spread across all
tenors, and for DVA on derivatives.
Deferred Day One Profit or Loss Reserve
The table below summarizes the movement in the aggregate profit not recognised when financial
instruments were initially recognised (Day One Profit or Loss), because of the use of valuation techniques for
which not all the inputs were market observable data.
As at 31 December 2022 ING further refined the thresholds to identify trades with significant unobservable
CVA which triggered more Day One Profit or Loss deferral. Reference is made to the table below.
Deferred day one profit or loss reserve
in EUR million
2022
2021
Opening balance at 1 January
-7
-5
DOP deferred on new transactions during the period
-107
-8
DOP recognised in the statement of profit or loss during the period
6
6
Closing balance at 31 December
-108
-7
The following methods and assumptions were used by ING Bank to estimate the fair value of the financial
instruments:
Equity securities
Instrument description: Equity securities include stocks and shares, corporate investments and private
equity investments.
Valuation: If available, the fair values of publicly traded equity securities and private equity securities are
based on quoted market prices. In absence of active markets, fair values are estimated by analysing the
investee\u2019s financial position, result, risk profile, prospect, price, earnings comparisons and revenue multiples.
Additionally, reference is made to valuations of peer entities where quoted prices in active markets are
available. For equity securities best market practice will be applied using the most relevant valuation
method. All non-listed equity investments, including investments in private equity funds, are subject to a
standard review framework which ensures that valuations reflect the fair values.
Fair value hierarchy: The majority of equity securities are publicly traded and quoted prices are readily and
regularly available. Hence, these securities are classified as Level 1.\u00a0 Equity securities which are not traded in
active markets mainly include corporate investments, fund investments and other equity securities and are
classified as Level 3.
Debt securities
Instrument description: Debt securities include government bonds, financial institutions bonds and Asset-
backed securities (ABS).
Valuation: Where available, fair values for debt securities are generally based on quoted market prices.
Quoted market prices are obtained from an exchange market, dealer, broker, industry group, pricing service,
or regulatory service. The quoted prices from non-exchange sources are reviewed on their tradability of
market prices. If quoted prices in an active market are not available, fair value is based on an analysis of
available market inputs, which includes consensus prices obtained from one or more pricing services.
Furthermore, fair values are determined by valuation techniques discounting expected future cash flows
using market interest rate curves, referenced credit spreads, maturity of the investment, and estimated
prepayment rates where applicable.
Fair value hierarchy: Government bonds and financial institutions bonds are generally traded in active
markets, where quoted prices are readily and regularly available and are hence, classified as Level 1. The
remaining positions are classified as Level 2 or Level 3.\u00a0 Asset backed securities for which no active market is
available and a wide discrepancy in quoted prices exists, are classified as Level 3.
Derivatives
Instrument description: Derivatives contracts can either be exchange-traded or over the counter (OTC).
Derivatives include interest rate derivatives, FX derivatives, Credit derivatives, Equity derivatives and
commodity derivatives.
Valuation: The fair value of exchange-traded derivatives is determined using quoted market prices in an
active market and are classified as Level 1 of the fair value hierarchy. For instruments that are not actively
traded, fair values are estimated based on valuation techniques. OTC derivatives and derivatives trading in
an inactive market are valued using valuation techniques. The valuation techniques and inputs depend on
the type of derivatives and the nature of the underlying instruments. The principal techniques used to value
these instruments are based on (amongst others) discounted cash flows, option pricing models and Monte
Carlo simulations. These valuation models calculate the present value of expected future cash flows, based
on \u2018no-arbitrage\u2019 principles. The models are commonly used in the financial industry and inputs to the
validation models are determined from observable market data where possible. Certain inputs may not be
observable in the market, but can be determined from observable prices via valuation model calibration
procedures. These inputs include prices available from exchanges, dealers, brokers or providers of pricing,
yield curves, credit spreads, default rates, recovery rates, dividend rates, volatility of underlying interest
rates, equity prices, and foreign currency exchange rates and reference is made to quoted prices, recently
executed trades, independent market quotes and consensus data, where available.
For uncollateralised OTC derivatives, ING applies Credit Valuation Adjustment to correctly reflect the
counterparty credit risk in the valuation and Debit Valuation Adjustments to reflect the credit risk of ING for
its counterparty. In addition, for these derivatives ING applies Funding Valuation Adjustment. See sections
CVA/DVA and FVA in section c) Valuation Adjustments for more details regarding the calculation.
Fair value hierarchy: The majority of the derivatives are priced using observable inputs and are classified as
Level 2. Derivatives for which the input cannot be implied from observable market data are classified as
Level 3.
Loans and receivables
Instrument description: Loans and receivables are non-derivative financial assets with fixed or determinable
payments that are not quoted in an active market. Loans and receivables carried at fair value includes
trading loans, being securities lending and similar agreement comparable to collateralised lending,
syndicated loans, loans expected to be sold and receivables with regards to reverse repurchase
transactions.
Valuation: The fair value of loans and receivables is generally estimated by discounting expected future cash
flows using a discount rate that reflects credit risk, liquidity, and other current market conditions. The fair
value of mortgage loans is estimated by taking into account prepayment behaviour. Fair value hierarchy:
Loans and receivables are predominantly classified as Level 2. Loans and receivables for which current
market information about similar assets to use as observable, corroborated data for all significant inputs
into a valuation model is not available, are classified as Level 3.
Financial liabilities at fair value through profit and loss
Instrument description: Financial liabilities at fair value through profit and loss include debt securities, debt
instruments, primarily comprised of structured notes, which are held at fair value under the fair value
option. Besides that, it includes derivative contracts and repurchase agreements.
Valuation: The fair values of securities in the trading portfolio and other liabilities at fair value through profit
or loss are based on quoted market prices, where available. For those securities not actively traded, fair
values are estimated based on internal discounted cash flow valuation techniques using interest rates and
credit spreads that apply to similar instruments.
Fair value hierarchy: The majority of the derivatives and debt instruments are classified as Level 2.
Derivatives and debt instruments for which the input cannot be derived from observable market data are
classified as Level 3.
e) Transfers between Level 1 and 2
As a consequence of change in observable inputs, ING recorded an EUR 1.8 billion transfer from Level 2 to
Level 1 in debt securities measured at fair value through other comprehensive income. No significant
transfers from Level 1 to Level 2 were recorded in the reporting period 2022.
f) Level 3: Valuation techniques and inputs used
Financial assets and liabilities in Level 3 include both assets and liabilities for which the fair value was
determined using (i) valuation techniques that incorporate unobservable inputs as well as (ii) quoted prices
which have been adjusted to reflect that the market was not actively trading at or around the balance sheet
date. Unobservable inputs are inputs which are based on ING\u2019s own assumptions about the factors that
market participants would use in pricing an asset or liability, developed based on the best information
available in the circumstances. Unobservable inputs may include volatility, correlation, spreads to discount
rates, default rates and recovery rates, prepayment rates, and certain credit spreads. Valuation techniques
that incorporate unobservable inputs are sensitive to the inputs used.
Of the total amount of financial assets classified as Level 3 as at 31\u00a0December 2022 of EUR 7.5 billion
(31\u00a0December 2021: EUR 6.2 billion), an amount of EUR 2.2 billion (29.2%) (31\u00a0December 2021: EUR 2.0
billion, being 32.5%) is based on unadjusted quoted prices in inactive markets. As ING does not generally
adjust quoted prices using its own inputs, there is no significant sensitivity to ING\u2019s own unobservable inputs.
Furthermore, Level 3 financial assets includes approximately EUR 4.2 billion (31\u00a0December 2021: EUR 2.9
billion) which relates to financial assets that are part of structures that are designed to be fully neutral in
terms of market risk. Such structures include various financial assets and liabilities for which the overall
sensitivity to market risk is insignificant. Whereas the fair value of individual components of these structures
may be determined using different techniques and the fair value of each of the components of these
structures may be sensitive to unobservable inputs, the overall sensitivity is by design not significant.
The remaining EUR 1.1 billion (31\u00a0December 2021: EUR 1.3 billion of the fair value classified in Level 3
financial assets is established using valuation techniques that incorporates certain inputs that are
unobservable.
Of the total amount of financial liabilities classified as Level 3 as at 31\u00a0December 2022 of EUR 0.7 billion
(31\u00a0December 2021: EUR 0.3 billion), an amount of EUR 0.02 billion (2.5%) (31\u00a0December 2021: EUR 0.1
billion, being 42.0%) is based on unadjusted quoted prices in inactive markets. As ING does not generally
adjust quoted prices using its own inputs, there is no significant sensitivity to ING\u2019s own unobservable inputs.
Furthermore, Level 3 financial liabilities includes approximately EUR 0.6 billion (31\u00a0December 2021: EUR 0.1
billion) which relates to financial liabilities that are part of structures that are designed to be fully neutral in
terms of market risk. As explained above, the fair value of each of the components of these structures may
be sensitive to unobservable inputs, but the overall sensitivity is by design not significant.
The remaining EUR 0.1 billion (31\u00a0December 2021: EUR 0.1 billion of the fair value classified in Level 3
financial liabilities is established using valuation techniques that incorporates certain inputs that are
unobservable.
The table below provides a summary of the valuation techniques, key unobservable inputs and the lower
and upper range of such unobservable inputs, by type of Level 3 asset/liability. The lower and upper range
mentioned in the overview represent the lowest and highest variance of the respective valuation input as
actually used in the valuation of the different financial instruments. Amounts and percentages stated are
unweighted. The range can vary from period to period subject to market movements and change in Level\u00a03
position. Lower and upper bounds reflect the variability of Level 3 positions and their underlying valuation
inputs in the portfolio, but do not adequately reflect their level of valuation uncertainty. For valuation
uncertainty assessment, reference is made to section Sensitivity analysis of unobservable inputs (Level 3).
Valuation techniques and range of unobservable inputs (Level 3)
Assets
Liabilities
Valuation techniques
Significant unobservable inputs
Lower range
Upper range
In EUR million
2022
2021
2022
2021
2022
2021
2022
2021
At fair value through profit or loss
Debt securities
3,447
2,643
1
1
Price based
Price (%)
0%
0%
125%
121%
Price (price per share)
208
208
Present value techniques
Credit spread (bps)
60
100
Price (%)
97%
100%
Equity securities
156
134
Price based
Price (price per share)
0
0
5,457
5,475
Loans and advances
1,485
1,598
Price based
Price (%)
0%
0%
100%
100%
Present value techniques
Credit spread (bps)
2
0
12
250
(Reverse) repo's
1,062
650
Present value techniques
Interest rate (%)
3%
0%
5%
1%
Structured notes
3
0
53
135
Price based
Price (%)
84%
84%
107%
125%
Option pricing model
Equity volatility (%)
13%
13%
42%
30%
Equity/Equity correlation
0.5
n.a.
1.0
n.a.
Equity/FX correlation
-0.4
0.0
0.6
0.0
Dividend yield (%)
0%
3%
8%
4%
Present value techniques
Credit spreads (bps)
96
96
Derivatives
\u2013\u00a0\u00a0Rates
431
5
476
35
Option pricing model
Interest rate volatility (bps)
49
43
148
82
Present value techniques
Reset spread (%)
0%
2%
1%
2%
Interest rate (%)
2%
2%
Prepayment rate (%)
5%
13%
\u2013\u00a0\u00a0FX
5
27
4
30
Present value techniques
FX volatility (%)
1%
16%
Option pricing model
Implied volatility (%)
6%
1%
20%
22%
\u2013\u00a0\u00a0Credit
13
75
175
94
Present value techniques
Credit spread (bps)
5
1
623
359
Price based
Price (%)
0%
0%
100%
100%
\u2013\u00a0\u00a0Equity
33
30
22
27
Option pricing model
Equity volatility (%)
0%
11%
77%
119%
Equity/Equity correlation
0.5
0.5
0.9
0.8
Equity/FX correlation
-0.5
-0.7
0.1
0.1
Dividend yield (%)
1%
0%
14%
18%
Price based
Price (%)
n.a
0%
n.a
0%
\u2013\u00a0\u00a0Other
1
3
9
Option pricing model
Commodity volatility (%)
0%
20%
63%
89%
At fair value through other comprehensive income
\u2013\u00a0\u00a0Loans and advances
643
838
Present value techniques
Prepayment rate (%)
6%
9%
6%
9%
Price based
Price (%)
67%
99%
99%
100%
\u2013\u00a0\u00a0Equity
247
225
Present value techniques
Credit spread (bps)
6.7
1.9
6.7
1.9
Interest rate (%)
4%
3%
4%
3%
Price based
Price (%)
n.a
1%
n.a
1%
Price based
Other (EUR)
70
63
90
80
Total
7,526
6,228
732
330
Price
For securities where market prices are not available, fair value is measured by comparison with observable
pricing data from similar instruments. Prices of 0% are distressed to the point that no recovery is expected,
while prices significantly in excess of 100% or par are expected to pay a yield above current market rates.
Credit spreads
Credit spread is the premium above a benchmark interest rate required by the market participant to accept
a lower credit quality. Higher credit spreads indicate lower credit quality and a lower value of an asset.
Volatility
Volatility is a measure for variation of the price of a financial instrument or other valuation input over time.
Volatility is one of the key inputs in option pricing models. Typically, the higher the volatility, the higher
value of the option. Volatility varies by the underlying reference (equity, commodity, foreign currency and
interest rates), by strike, and maturity of the option. The minimum level of volatility is 0% and there is no
theoretical maximum.
Correlation
Correlation is a measure of dependence between two underlying references which is relevant for valuing
derivatives and other instruments having more than one underlying reference. High positive correlation
(close to 1) indicates strong positive (statistical) relationship, where underliers move, everything else equal,
into the same direction. The same holds for a high negative correlation.
Reset spread
Reset spreads are key inputs to mortgage linked prepayment swaps valuation. Reset spread is the future
spread at which mortgages will re-price at interest rate reset dates.
Inflation rate Inflation rate is a key input to inflation linked instruments. Inflation linked instruments protect
against price inflation and are denominated and indexed to investment units. Interest payments would be
based on the inflation index and nominal rate in order to receive/pay the real rate of return. A rise in
nominal coupon payments is a result of an increase in inflation expectations, real rates, or both.
Dividend yield
Dividend yield is an important input for equity option pricing models showing how much dividends a
company is expected to pay out each year relative to its share price. Dividend yields are generally expressed
as an annualised percentage of share price.
Jump rate
Jump rates simulate abrupt changes in valuation models. The rate is an added component to the discount
rate in the model to include default risks.
Prepayment rate
Prepayment rate is a key input to mortgage and loan valuation. Prepayment rate is the estimated rate at
which mortgage borrowers will repay their mortgages early, e.g. 5% per year. Prepayment rate and reset
spread are key inputs to mortgage linked prepayment swaps valuation.
Level 3: Changes during the period
Changes in Level 3 Financial assets
Trading assets
Non-trading
derivatives
Financial assets
mandatorily at FVPL
Financial assets
designated at FVPL
Financial assets at
FVOCI
Total
in EUR million
2022
2021
2022
2021
2022
2021
2022
2021
2022
2021
2022
2021
Opening balance
822
882
1
1
1,862
1,191
2,480
796
1,063
1,231
6,228
4,101
Realised gain/loss\u00a0 recognised in the statement of profit or loss during the period 1
53
22
52
-57
32
122
-80
8
-12
178
-37
Revaluation recognised in other comprehensive income during the period 2
0
-84
22
-84
22
Purchase of assets
694
453
15
3
1,586
1,496
772
1,919
221
165
3,288
4,036
Sale of assets
-49
-48
-4
-3
-669
-612
-191
-141
-275
-234
-1,187
-1,037
Maturity/settlement
-511
-14
-2
-617
-163
-13
-59
-109
-1,188
-299
Reclassifications
0
-18
-5
10
-6
-8
-11
Transfers into Level 3
288
43
474
605
-1
322
-43
-1
1,646
42
Transfers out of Level 3
-442
-517
-115
-1
-856
-98
-1,414
-615
Exchange rate differences
18
0
14
20
-12
49
9
68
29
Changes in the composition of the group and other changes
0
-2
-2
Closing balance
873
822
421
1
1,849
1,862
3,492
2,480
891
1,063
7,526
6,228
i) Financial instruments not measured at fair value
The following table presents the estimated fair values of the financial instruments not measured at fair
value in the statement of financial position. The aggregation of the fair values presented below does not
represent, and should not be construed as representing, the underlying value of ING Bank.
Methods applied in determining fair values of financial assets and liabilities (carried at amortised cost)
Carrying Amount
Carrying amount
approximates fair value
Level 1
Level 2
Level 3
Total fair value
in EUR million
2022
2021
2022
2021
2022
2021
2022
2021
2022
2021
2022
2021
Financial Assets
Loans and advances to banks 1
35,103
23,591
2,858
1,674
1
29,459
17,033
2,786
4,926
35,103
23,634
Loans and advances to customers
635,557
627,550
19,101
16,943
15,264
18,465
575,805
600,253
610,170
635,661
Securities at amortised cost
48,160
48,319
39,787
40,314
3,160
7,327
1,406
681
44,353
48,323
718,820
699,459
21,959
18,617
39,788
40,316
47,883
42,825
579,996
605,860
689,626
707,618
Financial liabilities
Deposits from banks
56,632
85,092
3,696
4,298
48,524
75,847
3,954
5,890
56,174
86,035
Customer deposits
686,341
657,831
590,321
586,151
80,305
61,158
15,511
11,861
686,136
659,171
Debt securities in issue
58,075
57,443
20,308
15,320
20,501
27,718
17,577
14,756
58,385
57,794
Subordinated loans
15,789
16,719
15,548
17,203
15,548
17,203
816,838
817,085
594,016
590,449
20,308
15,321
164,878
181,926
37,041
32,507
816,243
820,203
1 The prior period has been updated to improve consistency and comparability of level 3 and 2.
The following methods and assumptions were used by ING Bank to estimate the fair value of the financial
instruments which are nor recorded and measured at fair value. These fair values were calculated for
disclosure purposes only. The carrying amount of financial instruments presented in the above table
includes the fair value hedge adjustment, this explains why the carrying amount approximates fair value.
Loans and advances to banks
For short term receivables from banks carrying amounts represent a reasonable estimate of the fair value.
The fair value of long term receivables from banks is estimated by discounting expected future cash flows
using a discount rate based on specific available market data, such as interest rates and appropriate
spreads that reflects current credit risk or quoted bonds.
Loans and advances to customers
For short term loans carrying amounts represent a reasonable estimate of the fair value. The fair value of
long term loans is estimated by discounting expected future cash flows using a discount rate that reflects
current credit risk, current interest rates, and other current market conditions where applicable. The fair
value of mortgage loans is estimated by taking into account prepayment behaviour. Loans with similar
characteristics are aggregated for calculation purposes.
Deposits from banks
For short term payables to banks carrying amounts represent a reasonable estimate of the fair value. The
fair value of long term payables to banks is estimated by discounting expected future cash flows using a
discount rate based on available market interest rates and appropriate spreads that reflects ING\u2019s own
credit risk.
Customer deposits
The carrying values of customer deposits with an immediate on demand features approximate their fair
values. The fair values of deposits with fixed contractual terms have been estimated based on discounting
future cash flows using the interest rates currently applicable to deposits of similar maturities.
Debt securities in issue
The fair value of debt securities in issue is generally based on quoted market prices, or if not available, on
estimated prices by discounting expected future cash flows using a current market interest rate and credit
spreads applicable to the yield, credit quality and maturity.
Subordinated loans
The fair value of publicly traded subordinated loans are based on quoted market prices when available.
Where no quoted market prices are available, fair value of the subordinated loans is estimated using
discounted cash flows based on interest rates and credit spreads that apply to similar instruments.
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38\u00a0 Liabilities and off-balance sheet commitments by maturity
The tables below include all liabilities and off-balance sheet commitments by maturity based on
contractual, undiscounted cash flows. These balances are included in the maturity analysis as follows:
\u2022Perpetual liabilities are included in the column \u2018Maturity not applicable\u2019.
\u2022Derivative liabilities are included on a net basis if cash flows are settled net. For other derivative liabilities
the contractual gross cash flow payable is included.
\u2022Undiscounted future coupon interest on financial liabilities payable is included in a separate line and in
the relevant maturity bucket.
\u2022Non-financial liabilities are included based on a breakdown of the amounts per statement of financial
position, per expected maturity.
\u2022Loans and other credit-related commitments are classified on the basis of the earliest date they can be
drawn down.
ING Bank\u2019s expected cash flows on some financial liabilities vary significantly from contractual cash flows.
Principal differences are in demand deposits from customers that are expected to remain stable or increase
and in unrecognised loan commitments that are not all expected to be drawn down immediately. Reference
is made to the liquidity risk paragraph in \u2018Risk Management \u2013 Funding and liquidity risk\u2019 for a description on
how liquidity risk is managed.
Liabilities and off-balance sheet commitments by maturity
in EUR million
2022
Less than 1 month 1
1\u20133 months
3\u201312 months
1\u20135 years
Over 5 years
Maturity not applicable
Adjustment\u00a0 2
Total
Deposits from banks
10,053\u00a0
2,238\u00a0
33,268\u00a0
9,878\u00a0
1,794\u00a0
\u00a0
-598\u00a0
56,632\u00a0
Customer deposits
605,706\u00a0
16,294\u00a0
22,637\u00a0
24,641\u00a0
20,304\u00a0
\u00a0
-3,240\u00a0
686,341\u00a0
Financial liabilities at fair value through profit or loss
\u2013\u00a0 Other trading liabilities
5,778\u00a0
875\u00a0
304\u00a0
771\u00a0
575\u00a0
\u00a0
-83\u00a0
8,219\u00a0
\u2013\u00a0 Trading derivatives
2,100\u00a0
2,319\u00a0
4,942\u00a0
9,330\u00a0
3,609\u00a0
\u00a0
8,570\u00a0
30,869\u00a0
\u2013\u00a0 Non-trading derivatives
345\u00a0
288\u00a0
216\u00a0
1,204\u00a0
470\u00a0
\u00a0
525\u00a0
3,048\u00a0
\u2013\u00a0 Designated at fair value through profit or loss
31,505\u00a0
11,472\u00a0
1,626\u00a0
3,177\u00a0
3,699\u00a0
21\u00a0
-618\u00a0
50,883\u00a0
Debt securities in issue
2,049\u00a0
11,227\u00a0
18,626\u00a0
12,857\u00a0
15,905\u00a0
\u00a0
-2,587\u00a0
58,075\u00a0
Subordinated loans
\u00a0
\u00a0
760\u00a0
\u00a0
9,936\u00a0
6,307\u00a0
-1,214\u00a0
15,789\u00a0
Lease liabilities
19\u00a0
43\u00a0
170\u00a0
593\u00a0
377\u00a0
\u00a0
-28\u00a0
1,174\u00a0
Financial liabilities
657,554\u00a0
44,755\u00a0
82,548\u00a0
62,450\u00a0
56,668\u00a0
6,328\u00a0
727\u00a0
911,030\u00a0
Other liabilities 3
9,659\u00a0
683\u00a0
2,395\u00a0
638\u00a0
406\u00a0
\u00a0
\u00a0
13,781\u00a0
Total liabilities
667,213\u00a0
45,438\u00a0
84,943\u00a0
63,089\u00a0
57,074\u00a0
6,328\u00a0
727\u00a0
924,811\u00a0
Coupon interest due on financial liabilities
426\u00a0
719\u00a0
3,171\u00a0
6,408\u00a0
3,166\u00a0
348\u00a0
\u00a0
14,237\u00a0
Contingent liabilities in respect of
\u2013\u00a0 Discounted bills
\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
\u2013\u00a0 Guarantees
28,304\u00a0
\u00a0
\u00a0
4\u00a0
550\u00a0
\u00a0
\u00a0
28,859\u00a0
\u2013\u00a0 Irrevocable letters of credit
15,660\u00a0
19\u00a0
3\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
15,682\u00a0
\u2013\u00a0 other
\u00a0
\u00a0
\u00a0
\u00a0
3\u00a0
\u00a0
\u00a0
3\u00a0
Irrevocable facilities
161,147\u00a0
\u00a0
194\u00a0
434\u00a0
166\u00a0
\u00a0
\u00a0
161,940\u00a0
205111.478
18.786
197.475
438.013
718.593
0\u00a0
0\u00a0
206,484\u00a0
1 Includes liabilities on demand.
2 This column reconciles the contractual undiscounted cash flows on financial liabilities to the statement of financial position values. The adjustments mainly relate to the impact of discounting and fair value hedge adjustments, and for derivatives, to the fact that the contractual
cash flows are presented on a gross basis (unless the cash flows are actually settled net).
3 Includes Other liabilities, Current and deferred tax liabilities, and Provisions as presented in the Consolidated statement of financial position.
Liabilities and off-balance sheet commitments by maturity
in EUR million
2021
Less than 1 month 1
1\u20133 month
3\u201312 months
1\u20135 years
Over 5 years
Maturity not applicable
Adjustment 2
Total
Deposits from banks
10,477
1,062
1,387
71,413
1,719
-967
85,092
Customer deposits
597,906
14,989
6,849
17,814
19,718
557
657,831
Financial liabilities at fair value through profit or loss
\u2013\u00a0 Other trading liabilities
6,965
397
322
462
438
4
8,588
\u2013\u00a0 Trading derivatives
1,689
1,608
3,674
8,295
5,731
-2,472
18,525
\u2013\u00a0 Non-trading derivatives
546
245
422
900
571
-564
2,120
\u2013\u00a0 Designated at fair value through profit or loss
24,862
10,224
771
1,850
3,719
20
362
41,808
Debt securities in issue
2,766
15,826
15,459
9,667
12,581
1,145
57,443
Subordinated loans
716
8,948
6,822
233
16,719
Lease liabilities
18
40
159
571
454
-23
1,220
Financial liabilities
645,229
44,391
29,042
111,688
53,880
6,843
-1,725
889,346
Other liabilities 3
8,810
487
2,500
591
934
13,321
Total liabilities
654,039
44,877
31,541
112,279
54,813
6,843
-1,725
902,668
Coupon interest due on financial liabilities
195
407
1,010
2,602
2,727
387
7,328
Contingent liabilities in respect of
\u2013\u00a0 Discounted bills
\u2013\u00a0 Guarantees
25,911
550
26,461
\u2013\u00a0 Irrevocable letters of credit
16,851
16,851
\u2013\u00a0 other
1
2
5
8
Irrevocable facilities4
143,891
1
13
184
78
144,167
186,653
1
15
189
628
0
0
187,486
1 Includes liabilities on demand.
2 This column reconciles the contractual undiscounted cash flows on financial liabilities to the statement of financial position values. The adjustments mainly relate to the impact of discounting and fair value hedge adjustments, and for derivatives, to the fact that the contractual
cash flows are presented on a gross basis (unless the cash flows are actually settled net).
3 Includes Other liabilities, Current and deferred tax liabilities, and Provisions as presented in the Consolidated statement of financial position.
", "dimensions": { "concept": "ifrs-full:DisclosureOfCommitmentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8yMTEvZnJhZzo0OWVjNTdjODYxZjk0ZTAxODI2OGQ1Y2ZiNjNlMGRiNS90ZXh0cmVnaW9uOjQ5ZWM1N2M4NjFmOTRlMDE4MjY4ZDVjZmI2M2UwZGI1XzYy_ed3483e0-48b3-4e83-bdf2-1e88d27c7ba6": { "value": "
39\u00a0 Transfer of financial assets, assets pledged and received as collateral
Financial assets pledged as collateral
The financial assets pledged as collateral consist primarily of Loans and advances to customers pledged to
secure Debt securities in issue, deposits from the Dutch Central Bank and other banks, as well as debt
securities used in securities lending or sale and repurchase transactions. They serve to secure margin
accounts and are used for other purposes required by law. Pledges are generally conducted under terms
that are usual and customary for collateralised transactions including standard sale and repurchase
agreements, securities lending and borrowing and derivatives margining. The financial assets pledged are as
follows:
Financial assets pledged as collateral
in EUR million
2022
2021
Banks
\u2013\u00a0 Cash and balances with central banks
364
465
\u2013\u00a0 Loans and advances to banks
4,007
3,310
Financial assets at fair value through profit or loss
17,079
15,334
Financial assets at fair value through OCI
2,142
2,320
Securities at amortised cost
3,578
4,468
Loans and advances to customers
98,917
118,868
Other assets
596
796
126,682
145,560
Transfer of financial assets
The majority of ING's financial assets that have been transferred, but do not qualify for derecognition are
debt instruments used in securities lending or sale and repurchase transactions.
Transfer of financial assets not qualifying for derecognition
Securities lending
Sale and repurchase
Equity
Debt
Equity
Debt
in EUR million
2022
2021
2022
2021
2022
2021
2022
2021
Transferred assets at carrying amount
Financial assets at fair value through profit or
loss
2,087
3,109
6,357
4,384
7,178
5,863
Financial assets at fair value through other
comprehensive income
499
453
527
Loans and advances to customers
4,637
4,386
Securities at amortised cost
435
261
992
Associated liabilities at carrying amount1
Financial liabilities at fair value through profit
or loss
n/a
n/a
n/a
n/a
6,245
4,130
8,932
7,538
1The table includes the associated liabilities which are reported after offsetting, compared to the gross positions of the encumbered
assets.
2The prior period on Financial assets at fair value through other comprehensive income and Securities at amortised cost has been
updated to improve consistency and comparability
The table above does not include assets transferred to consolidated securitisation entities as the related
assets remain recognised in the consolidated statement of financial position. Transferred financial assets
that are derecognised in their entirety are mentioned in Note 45 'Structured entities'", "dimensions": { "concept": "ifrs-full:DisclosureOfCollateralExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8yMTEvZnJhZzo0OWVjNTdjODYxZjk0ZTAxODI2OGQ1Y2ZiNjNlMGRiNS90ZXh0cmVnaW9uOjQ5ZWM1N2M4NjFmOTRlMDE4MjY4ZDVjZmI2M2UwZGI1XzM1MTg0MzcyMDkwMTQx_5f15d78b-20ad-4158-8026-376b100a3e18": { "value": "
Financial assets pledged as collateral
The financial assets pledged as collateral consist primarily of Loans and advances to customers pledged to
secure Debt securities in issue, deposits from the Dutch Central Bank and other banks, as well as debt
securities used in securities lending or sale and repurchase transactions. They serve to secure margin
accounts and are used for other purposes required by law. Pledges are generally conducted under terms
that are usual and customary for collateralised transactions including standard sale and repurchase
agreements, securities lending and borrowing and derivatives margining. The financial assets pledged are as
follows:
Financial assets pledged as collateral
in EUR million
2022
2021
Banks
\u2013\u00a0 Cash and balances with central banks
364
465
\u2013\u00a0 Loans and advances to banks
4,007
3,310
Financial assets at fair value through profit or loss
17,079
15,334
Financial assets at fair value through OCI
2,142
2,320
Securities at amortised cost
3,578
4,468
Loans and advances to customers
98,917
118,868
Other assets
596
796
126,682
145,560
Guarantees relate both to credit and non-credit substitute guarantees. Credit substitute guarantees are
guarantees given by ING Bank in respect of credit granted to customers by a third party. Many of them are
expected to expire without being drawn on and therefore do not necessarily represent future cash outflows.
Irrevocable letters of credit mainly secure payments to third parties for a customer\u2019s foreign and domestic
trade transactions in order to finance a shipment of goods. ING Bank\u2019s credit risk in these transactions is
limited since these transactions are collateralized by the commodity shipped and are of a short duration.
Other contingent liabilities include acceptances of bills and are of a short-term nature. Other contingent
liabilities also include contingent liabilities resulting from the operations of the Real Estate business including
obligations under development and construction contracts.
Irrevocable facilities mainly constitute unused portions of irrevocable credit facilities granted to corporate
clients. Many of these facilities are for a fixed duration and bear interest at a floating rate. ING Bank\u2019s credit
risk and interest rate risk in these transactions is limited. The unused portion of irrevocable credit facilities is
partly secured by customers\u2019 assets or counter-guarantees by the central governments and other public
sector entities under the regulatory requirements. Irrevocable facilities also include commitments made to
purchase securities to be issued by governments and private issuers.
In addition to the items included in contingent liabilities, ING Bank has issued certain guarantees as
participant in collective arrangements of national banking funds and as a participant in required collective
guarantee schemes which apply in different countries.
ING Bank N.V. provided a guarantee to the German Deposit Guarantee Fund (\u2018Einlagensicherungsfonds\u2019 or
ESF) under section 5 (10) of the by-laws of this fund, where ING Bank N.V. indemnifies the Association of
German Banks Berlin against any losses it might incur as result of actions taken with respect to ING
Germany. The ESF is a voluntary collective guarantee scheme for retail savings and deposits in excess of EUR
100,000.
Furthermore we refer to Note 42 'Legal proceedings' for any contingent liabilities in respect of legal
proceedings.
", "dimensions": { "concept": "ifrs-full:DisclosureOfCommitmentsAndContingentLiabilitiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8yMTcvZnJhZzozZmIzY2U2MDUzZmI0NzM0YmM4ZmI4ZGM0MDA1NWI1NS90ZXh0cmVnaW9uOjNmYjNjZTYwNTNmYjQ3MzRiYzhmYjhkYzQwMDU1YjU1XzIyNzc_6eb5e9e0-479f-4435-b568-37496a6af558": { "value": "
41\u00a0 Contingent liabilities and commitments
In the normal course of business, ING Bank is party to activities where risks are not reflected in whole or in
part in the consolidated financial statements. In response to the needs of its customers, the Group offers
financial products related to loans. These products include traditional off-balance sheet credit-related
financial instruments.
Contingent liabilities and commitments
in EUR million
2022
2021
Contingent liabilities in respect of
\u2013\u00a0 Guarantees
28,859
26,461
\u2013\u00a0 Irrevocable letters of credit
15,682
16,851
\u2013\u00a0 Other
3
8
44,544
43,319
Irrevocable facilities
161,940
144,167
206,484
187,486
Guarantees relate both to credit and non-credit substitute guarantees. Credit substitute guarantees are
guarantees given by ING Bank in respect of credit granted to customers by a third party. Many of them are
expected to expire without being drawn on and therefore do not necessarily represent future cash outflows.
Irrevocable letters of credit mainly secure payments to third parties for a customer\u2019s foreign and domestic
trade transactions in order to finance a shipment of goods. ING Bank\u2019s credit risk in these transactions is
limited since these transactions are collateralized by the commodity shipped and are of a short duration.
Other contingent liabilities include acceptances of bills and are of a short-term nature. Other contingent
liabilities also include contingent liabilities resulting from the operations of the Real Estate business including
obligations under development and construction contracts.
Irrevocable facilities mainly constitute unused portions of irrevocable credit facilities granted to corporate
clients. Many of these facilities are for a fixed duration and bear interest at a floating rate. ING Bank\u2019s credit
risk and interest rate risk in these transactions is limited. The unused portion of irrevocable credit facilities is
partly secured by customers\u2019 assets or counter-guarantees by the central governments and other public
sector entities under the regulatory requirements. Irrevocable facilities also include commitments made to
purchase securities to be issued by governments and private issuers.
In addition to the items included in contingent liabilities, ING Bank has issued certain guarantees as
participant in collective arrangements of national banking funds and as a participant in required collective
guarantee schemes which apply in different countries.
ING Bank N.V. provided a guarantee to the German Deposit Guarantee Fund (\u2018Einlagensicherungsfonds\u2019 or
ESF) under section 5 (10) of the by-laws of this fund, where ING Bank N.V. indemnifies the Association of
German Banks Berlin against any losses it might incur as result of actions taken with respect to ING
Germany. The ESF is a voluntary collective guarantee scheme for retail savings and deposits in excess of EUR
100,000.
Furthermore we refer to Note 42 'Legal proceedings' for any contingent liabilities in respect of legal
proceedings.
", "dimensions": { "concept": "ifrs-full:DisclosureOfContingentLiabilitiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8yMTcvZnJhZzozZmIzY2U2MDUzZmI0NzM0YmM4ZmI4ZGM0MDA1NWI1NS90ZXh0cmVnaW9uOjNmYjNjZTYwNTNmYjQ3MzRiYzhmYjhkYzQwMDU1YjU1XzgyNDYzMzcyMTc3Nzk_1145f0b0-ed07-48e9-a51e-d6c00b046641": { "value": "
41\u00a0 Contingent liabilities and commitments
In the normal course of business, ING Bank is party to activities where risks are not reflected in whole or in
part in the consolidated financial statements. In response to the needs of its customers, the Group offers
financial products related to loans. These products include traditional off-balance sheet credit-related
financial instruments.
Contingent liabilities and commitments
in EUR million
2022
2021
Contingent liabilities in respect of
\u2013\u00a0 Guarantees
28,859
26,461
\u2013\u00a0 Irrevocable letters of credit
15,682
16,851
\u2013\u00a0 Other
3
8
44,544
43,319
Irrevocable facilities
161,940
144,167
206,484
187,486
Guarantees relate both to credit and non-credit substitute guarantees. Credit substitute guarantees are
guarantees given by ING Bank in respect of credit granted to customers by a third party. Many of them are
expected to expire without being drawn on and therefore do not necessarily represent future cash outflows.
Irrevocable letters of credit mainly secure payments to third parties for a customer\u2019s foreign and domestic
trade transactions in order to finance a shipment of goods. ING Bank\u2019s credit risk in these transactions is
limited since these transactions are collateralized by the commodity shipped and are of a short duration.
Other contingent liabilities include acceptances of bills and are of a short-term nature. Other contingent
liabilities also include contingent liabilities resulting from the operations of the Real Estate business including
obligations under development and construction contracts.
Irrevocable facilities mainly constitute unused portions of irrevocable credit facilities granted to corporate
clients. Many of these facilities are for a fixed duration and bear interest at a floating rate. ING Bank\u2019s credit
risk and interest rate risk in these transactions is limited. The unused portion of irrevocable credit facilities is
partly secured by customers\u2019 assets or counter-guarantees by the central governments and other public
sector entities under the regulatory requirements. Irrevocable facilities also include commitments made to
purchase securities to be issued by governments and private issuers.
In addition to the items included in contingent liabilities, ING Bank has issued certain guarantees as
participant in collective arrangements of national banking funds and as a participant in required collective
guarantee schemes which apply in different countries.
ING Bank N.V. provided a guarantee to the German Deposit Guarantee Fund (\u2018Einlagensicherungsfonds\u2019 or
ESF) under section 5 (10) of the by-laws of this fund, where ING Bank N.V. indemnifies the Association of
German Banks Berlin against any losses it might incur as result of actions taken with respect to ING
Germany. The ESF is a voluntary collective guarantee scheme for retail savings and deposits in excess of EUR
100,000.
Furthermore we refer to Note 42 'Legal proceedings' for any contingent liabilities in respect of legal
proceedings.
42\u00a0 Legal proceedings
ING Bank and its consolidated subsidiaries are involved in governmental, regulatory, arbitration and legal
proceedings and investigations in the Netherlands and in a number of foreign jurisdictions, including the
U.S., involving claims by and against them which arise in the ordinary course of their businesses, including in
connection with their activities as lenders, broker-dealers, underwriters, issuers of securities and investors
and their position as employers and taxpayers. In certain of such proceedings, very large or indeterminate
amounts are sought, including punitive and other damages. While it is not feasible to predict or determine
the ultimate outcome of all pending or threatened governmental, regulatory, arbitration and legal
proceedings and investigations, ING is of the opinion that some of the proceedings and investigations set
out below may have or have in the recent past had a significant effect on the financial position, profitability
or reputation of the ING and/or the ING and its consolidated subsidiaries.
Settlement agreement: On 4 September 2018, ING announced that it had entered into a settlement
agreement with the Dutch Public Prosecution Service relating to previously disclosed investigations
regarding various requirements for client on-boarding and the prevention of money laundering and corrupt
practices. Following the entry into the settlement agreement, ING has experienced heightened scrutiny
from authorities in various countries. ING is also aware, including as a result of media reports, that other
parties may, among other things, seek to commence legal proceedings against ING in connection with the
subject matter of the settlement. Certain parties filed requests with the Court of Appeal in The Netherlands
to reconsider the prosecutor\u2019s decision to enter into the settlement agreement with ING and not to
prosecute ING or (former) ING employees. In December 2020, the Court of Appeal issued its final ruling. In
this ruling the prosecutors' decision to enter into the settlement agreement with ING was upheld, making
the settlement final. However, in a separate ruling, the Court ordered the prosecution of ING\u2019s former CEO.
Findings regarding AML processes: As previously disclosed, after its September 2018 settlement with Dutch
authorities concerning anti-money laundering matters, and in the context of significantly increased
attention on the prevention of financial economic crime, ING has experienced heightened scrutiny by
authorities in various countries. The interactions with such regulatory and judicial authorities have included,
and can be expected to continue to include, onsite visits, information requests, investigations and other
enquiries. Such interactions, as well as ING\u2019s internal assessments in connection with its global
enhancement programme, have in some cases resulted in satisfactory outcomes, and also have resulted in,
and may continue to result in, findings, or other conclusions which may require appropriate remedial
actions by ING, or may have other consequences. ING intends to continue to work in close cooperation with
authorities as it seeks to improve its management of non-financial risks in terms of policies, tooling,
monitoring, governance, knowledge and behaviour.
In January 2022, a Luxembourg investigating judge informed ING Luxembourg that he intends to instruct
the relevant prosecutor to prepare a criminal indictment regarding alleged shortcomings in AML process at
ING Luxembourg. Although this matter remains at an early procedural stage and it is currently not possible
to determine how this matter will be resolved or the timing of any such resolution, ING does not expect a
financial outcome of this matter to have a material effect.
Payvision is the subject of a criminal investigation by Dutch authorities regarding money laundering and
various requirements of the Dutch act on Anti-Money Laundering and Counter Terrorist Financing, focusing
on the period from 1 January 2015 up to and including April 2020. Payvision is cooperating with such
ongoing investigation. It is currently not feasible to determine how the ongoing investigation may be
resolved or the timing of any such resolution, nor to estimate reliably the possible timing, scope or amounts
of any resulting fines, penalties and/or other outcome.
ING continues to take steps to enhance its management of compliance risks and embed stronger awareness
across the whole organisation. These steps are part of the global KYC programme and set of initiatives,
which includes enhancing KYC files and working on various structural improvements in compliance policies,
tooling, monitoring, governance, knowledge and behaviour.
Tax cases: 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 the Issuer believes that it has
adequately provided for all its tax positions, the ultimate resolution of these audits, investigations and
procedures is uncertain and may result in liabilities which are materially different from the amounts
recognised.
SIBOR \u2013 SOR litigation: In July 2016, investors in derivatives tied to the Singapore Interbank Offer Rate
(\u201cSIBOR\u201d) filed a U.S. class action complaint in the New York District Court alleging that several banks,
including ING, conspired to rig the prices of derivatives tied to SIBOR and the Singapore Swap Offer Rate
(\u201cSOR\u201d). The lawsuit refers to investigations by the Monetary Authority of Singapore (\u201cMAS\u201d) and other
regulators, including the U.S. Commodity Futures Trading Commission (\u201cCFTC\u201d), in relation to rigging prices
of SIBOR- and SOR based derivatives. In October 2018, the New York District Court issued a decision
dismissing all claims against ING Group and ING Capital Markets LLC, but leaving ING Bank, together with
several other banks, in the case, and directing plaintiffs to file an amended complaint consistent with the
Court's rulings. In October 2018, plaintiffs filed such amended complaint, which asserts claims against a
number of defendants but none against ING Bank (or any other ING entity), effectively dismissing ING Bank
from the case. In December 2018, plaintiffs sought permission from the Court to file a further amended
complaint that names ING Bank as a defendant. In July 2019, the New York District Court granted the
defendants\u2019 motion to dismiss and denied leave to further amend the complaint, effectively dismissing all
remaining claims against ING Bank. In March 2021, the Second Circuit court vacated the District Court\u2019s
ruling. The case was remanded to the District Court to reconsider the amended complaint that would add
ING Bank N.V. back to the case. In April 2021, the defendants filed a petition for rehearing with the Second
Circuit court. In May 2021, the Second Circuit court denied the defendants\u2019 petition. In March 2022, plaintiffs
and ING executed a formal class settlement agreement. On 29 November 2022, the Court entered its final
judgement, approving ING\u2019s settlement (and those of all other defendants) with plaintiffs. The case is now
closed.
Claims regarding accounts with predecessors of ING Bank Turkey: ING Bank Turkey has received numerous
claims from (former) customers of legal predecessors of ING Bank Turkey. The claims are based on offshore
accounts held with these banks, which banks were seized by the Savings Deposit Insurance Fund (\u201cSDIF\u201d)
prior to the acquisition of ING Bank Turkey in 2007 from OYAK. Pursuant to the acquisition contract, ING can
claim compensation from SDIF if a court orders ING to pay amounts to the offshore account holders. SDIF
has made payments to ING pursuant to such compensation requests, but filed various lawsuits to receive
those amounts back. These lawsuits are ongoing. In April 2022 the Turkish Supreme Court decided that the
prescription period for the offshore account holders\u2019 compensation claims starts on the transfer date of the
account holders to the offshore accounts. The exact impact of this decision on the ongoing cases is not clear
yet. At this moment it is not possible to assess the outcome of these procedures nor to provide an estimate
of the (potential) financial effect of these claims.
Interest rate derivatives claims: ING is involved in several legal proceedings in the Netherlands with respect
to interest rate derivatives that were sold to clients in connection with floating interest rate loans in order to
hedge the interest rate risk of the loans. These proceedings are based on several legal grounds, depending
on the facts and circumstances of each specific case, inter alia alleged breach of duty of care, insufficient
information provided to the clients on the product and its risks and other elements related to the interest
rate derivatives that were sold to clients. In some cases, the court has ruled in favour of the claimants and
awarded damages, annulled the interest rate derivative or ordered repayment of certain amounts to the
claimants.
Interest surcharges claims: ING received complaints and was involved in litigation with certain individuals in
the Netherlands regarding increases in interest surcharges with respect to several credit products, including
but not limited to commercial property. ING has reviewed the relevant product portfolio. The provision
previously taken has been reversed for certain of these complaints. All claims are dealt with individually.
Thus far, the courts have ruled in favour of ING in each case, ruling that ING was allowed to increase the
interest surcharge based upon the essential obligations in the contract. In a relevant case the Dutch
Supreme Court ruled in favor of another Dutch bank, addressing the question whether or not a bank is
allowed to increase interest surcharges unilaterally. The Supreme Court ruled affirmative and referred the
case to the Court of Appeal in The Hague. The Court of Appeal also ruled in favour of the Dutch bank in
October 2022. ING will continue to deal with all claims individually.
Mortgage expenses claims: ING Spain has received claims and is involved in procedures with customers
regarding reimbursement of expenses associated with the formalisation of mortgages. In most court
proceedings in first instance the expense clause of the relevant mortgage contract has been declared null
and ING Spain has been ordered to reimburse all or part of the applicable expenses. Since 2018, the Spanish
Supreme Court and the European Court of Justice have issued rulings setting out which party should bear
notary, registration, agency, and stamp duty costs. In January 2021, the Spanish Supreme Court ruled that
valuation costs of mortgages, signed prior to 16 June 2019, the date the new mortgage law entered into
force, should be borne by the bank. Media attention for the statute of limitations applicable to the right to
claim reimbursement of costs resulted in an increased number of claims at the beginning of 2021. In June
2021, the Supreme Court published a press release informing of its decision to ask the European Court of
Justice for a preliminary ruling regarding the criteria that should be applied to determine the date from
which the action for claiming the reimbursement of mortgage expenses is considered to be expired.\u00a0 ING
Spain has also been included, together with other Spanish banks, in three class actions filed by customer
associations. In one of the class actions an agreement was reached with the association. In another class
action ING filed an appeal asking the Spanish Court of Appeal to determine that the ruling of the court of
first instance is only applicable to the consumers that were part of the case. The National Court has revoked
the ruling and declared that the consumers will not be able to initiate an action for compensation based on
the first instance ruling, as the claimant association intended. This last decision is not yet final, as it could be
appealed in the Supreme Court. A provision has been established in the past and has been adjusted where
appropriate.
Imtech claim: In January 2018, ING Bank received a claim from Stichting ImtechClaim.nl and Imtech
Shareholders Action Group B.V. on behalf of certain (former) shareholders of Imtech N.V. (\u201cImtech\u201d).
Furthermore, in March 2018, ING Bank received another claim on the same subject matter from the Dutch
Association of Stockholders (Vereniging van Effectenbezitters, \u201cVEB\u201d). In June 2022, VEB reiterated and
further substantiated its claim in a letter to ING. Each of the claimants allege inter alia that shareholders
were misled by the prospectus of the rights issues of Imtech in July 2013 and October 2014. ING Bank, being
one of the underwriters of the rights issues, is held liable by the claimants for the damages that investors in
Imtech would have suffered. ING Bank responded to the claimants denying any and all responsibility in
relation to the allegations made in the relevant letters. In September 2018, the trustees in the bankruptcy of
Imtech claimed from various financing parties, including ING, payment of what the security agent has
collected following bankruptcy or intends to collect, repayment of all that was repaid to the financing
parties, as well as compensation for the repayment of the bridge financing. At this moment it is not possible
to assess the outcome of these claims nor to provide an estimate of the (potential) effect of these claims.
Claims regarding mortgage loans in Swiss franc in Poland: ING Poland is a defendant in several lawsuits
with retail customers who took out mortgage loans indexed to the Swiss franc. Such customers have alleged
that the mortgage loan contract contains abusive clauses. One element that the court is expected to
consider in determining whether such contracts contain abusive clauses is whether the rules to determine
the exchange rate used for the conversion of the loan from Polish zloty to Swiss franc are unambiguous and
verifiable. In December 2020, the Polish Financial Supervision Authority (PFSA) proposed that lenders offer
borrowers voluntary out-of-court settlements on foreign-currency mortgage disputes, with mortgages
indexed to Swiss franc serving as a reference point. In February 2021, ING Poland announced its support for
this initiative and in October 2021 began offering the settlements to the borrowers following the PFSA\u2019s
proposal. ING has recorded a portfolio provision with respect to the claims and the PFSA proposal. The Polish
Supreme Court was expected to provide further clarity on this topic in a ruling scheduled for November
2021, however the court\u2019s session on this matter was postponed and the date of the next session has not
yet been announced. In October 2022, a hearing of the European Court of Justice (CJEU) was held inter alia
on the question whether, after cancellation of a contract regarding a Swiss franc loan by a court, banks may
still charge interests for the amount borrowed under such loan prior to cancellation.
On 16 February 2023, the Advocate General (AG) of the CJEU provided his opinion on the matter. The AG
opined that banks cannot claim any remuneration (i.e. interest) for the duration the principal amount was
available to the customer. The customer, however, may assert claims against banks in addition to
reimbursement of interest and instalments previously paid to the bank. The AG\u2019s opinion is not binding on
the CJEU. His role is to propose to the CJEU a legal solution to this case. Should the CJEU follow the opinion
of the AG, this will have negative effect for banks in Poland. The CJEU\u2019s ruling is expected within a few
months.
Certain Consumer Credit Products: In October 2021, ING announced that it would offer compensation to
certain of its Dutch retail customers in connection with certain revolving consumer loans with variable
interest rates that allegedly did not sufficiently follow market rates. This announcement was made in
response to a number of rulings by the Dutch Institute for Financial Disputes (Kifid) regarding similar
products at other banks. ING currently expects that any such compensation will be paid before the end of
2022. ING has recognized a provision of EUR 180 million in 2021 for compensation and costs in connection
with this matter. On 22 December 2021, ING announced that it has reached an agreement with the Dutch
Consumers\u2019 Association (Consumentenbond) on the compensation methodology for revolving credits. Based
on a recent Kifid ruling regarding similar products, ING will amend its previously announced compensation
scheme by also compensating interest on interest. In the third quarter of 2022, ING increased its provision
for this matter by EUR 75 million. In the fourth quarter of 2022, ING and the Dutch Consumers\u2019 Association
reached an agreement on the compensation of customers who have had an overdraft or a revolving credit
card with a variable interest rate. ING will compensate such customers according to Kifid jurisprudence
about revolving credits including \u2018interest-on-interest\u2019-effect. Compensation will start in the first half of
2023.
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43\u00a0 Consolidated companies and businesses acquired and divested
Acquisitions
There were no significant acquisitions in 2022, 2021 or 2020.
Divestments 2022
ING announced at 13 December 2022 that it has sold their interest (80%) in Intersoftware Holding BV to the
Sky Group/ DIAS and realised a transaction result of EUR 11.0 million which consists of a profit of EUR 7.0 on
sale of InterSoftware Holding BV and the release of the redemption liability of EUR 3.0 million.
Divestments 2021
On 18 February 2021 ING announced the intention to withdraw from the retail banking market in the Czech
Republic. \u00a0The decision to discontinue Czech Retail Banking entails the closure of retail customer accounts /
mutual funds and the sale of assets comprising the related government bond portfolio. ING\u2019s retail
customers in the Czech Republic have received a welcome offer from Raiffeisenbank Czech Republic. ING\u2019s
departure from the Czech Retail banking market resulted in EUR 2.5 billion saving accounts being transferred
to Raiffeisenbank and the government bond portfolio with a carrying amount of EUR 0.5 billion being sold in
the second quarter of 2021.
At 12 July 2021, ING announced that it has reached an agreement to transfer ING\u2019s Retail Banking
operations in Austria to Bank99. Under the terms of the agreement, approximately EUR 1.7 billion of savings
deposits and approximately EUR 1.0 billion of mortgages, approximately EUR 0.4 billion other personal
lending and approximately EUR 0.4 billion loans to banks of ING Austria have been transferred to Bank99. In
December 2021 the transaction was completed and a loss on disposal of EUR 26 million was realised. In
2022 some final closing activities resulted in an additional loss of EUR 1 million. ING Austria was included in
the segment Retail Challengers & Growth Markets.
In 2021, ING and the board of Makelaarsland agreed to continue Makelaarsland independently. The new
board will take over all clients and employees, and services to clients will continue unchanged. The negative
result on disposal of group companies from this management buyout amounted to approximately EUR 3
million.
On 28 October 2021 ING announced that its subsidiary Payvision will start phasing out its services as a
payment service provider and acquirer. In 2021, Payvision recognised\u00a0an impairment loss of\u00a0intangible
assets of\u00a0EUR 44 million, mainly with respect to Brand, IT and Customer relationships\u00a0and an impairment
loss of\u00a0the deferred tax asset of EUR 14 million.
ING has been active in the French retail banking market since 2000 as an online bank. In December 2021 ING
announced that it will leave the retail banking market in France in order to sharpen the focus of its business
portfolio. ING and Boursorama (a subsidiary of Soci\u00e9t\u00e9 G\u00e9n\u00e9rale) have signed an agreement to offer the
attractive services to retail customers of ING in France.
The contract allows ING customers to join Boursorama and benefit from a simplified account opening
process and exclusive offers. The agreement also includes the transfer to Boursorama of
\u2018assurance'vie\u2019 (investment products) contracts, for which ING acts as a broker with Generali Vie. Home loans
and consumer loans are not included in the agreement and the portfolio will continue to be managed by
ING.
The agreement follows ING\u2019s announcement in December 2021 to exit the French retail banking market. The
exit is finalised end of 2022. ING\u2019s departure from the France retail banking market is proceeding well with
EUR 9.7 billion saving accounts already transferred to Boursorama. ING will continue its Wholesale Banking
activities in France, with a focus on strengthening its position and the ambition to be the go-to bank for
sustainable finance.
Most significant companies disposed in 2021
in EUR million
Makelaarsland
BV & Above BV
ING Austria
Retail Banking
Total divested
Sales Proceeds
Sales proceeds
29
29
Non-cash proceeds
Cash proceeds
29
29
Cash outflow / inflow on disposal
29
29
Assets
Cash assets
3
3
Loans and advances to customers
1,404
1,404
Amounts due from banks
378
378
Miscalleneous other assets
8
8
Liabilities
Customer deposits and other funds on deposit
1,725
1,725
Miscallaneous other liabilities
1
8
9
Net assets
3
56
58
% disposed
100%
100%
Net assets disposed
3
56
58
Result on disposal
-3
-26
-29
In 2020 there were no significant divestments.
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44\u00a0 Principal subsidiaries, investments in associates and joint ventures
For the majority of ING\u2019s principal subsidiaries, ING Bank 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\u2019s financial interest and its rights from other contractual
arrangements which result in control over the operating and financial policies of the entity.
For each of the subsidiaries listed, the voting rights held equal the proportion of ownership interest and
consolidation by ING is based on the majority of ownership.
For the principal investments in associates and joint ventures ING Bank has significant influence but not
control. Significant influence generally results from a shareholding of between 20% and 50% of the voting
rights, but also the ability to participate in the financial and operating policies through situations including,
but not limited to one or more of the following:
\u2022Representation on the board of directors;
\u2022Participation in the policymaking process; and
\u2022Interchange of managerial personnel.
The principal subsidiaries, investments in associates and joint ventures of ING Bank N.V. and their statutory
place of incorporation or primary place of business are as follows:
Principal subsidiaries, investments in associates and joint ventures
Proportion of
ownership and
interest held
by the group
2022
2021
Subsidiary
Statutory place of
Incorporation
Country of operation
Bank Mendes Gans N.V.
Amsterdam
the Netherlands
100%
100%
ING Belgium S.A./N.V.
Brussels
Belgium
100%
100%
ING Luxembourg S.A.
Luxembourg City
Luxembourg
100%
100%
ING-DiBa AG
Frankfurt am Main
Germany
100%
100%
ING Bank Slaski S.A.1
Katowice
Poland
75%
75%
ING Financial Holdings Corporation
Delaware
United States of America
100%
100%
ING Bank A.S.
Istanbul
Turkey
100%
100%
ING Bank (Australia) Ltd
Sydney
Australia
100%
100%
ING Commercial Finance B.V.
Amsterdam
the Netherlands
100%
100%
ING Groenbank N.V.
Amsterdam
the Netherlands
100%
100%
Investments in associates and joint
ventures
TMBThanachart Bank Public Company
Ltd2
Bangkok
Thailand
23%
23%
1 The shares of the non-controlling interest stake of 25% are listed on the Warsaw Stock Exchange, for summarised financial
\u00a0 \u00a0 \u00a0 \u00a0 \u00a0 information we refer to \u2018Note 33 \u2018Information on geographical areas.
2 Reference is made to Note 8 Investments in Associates and Joint Ventures.
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44\u00a0 Principal subsidiaries, investments in associates and joint ventures
For the majority of ING\u2019s principal subsidiaries, ING Bank 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\u2019s financial interest and its rights from other contractual
arrangements which result in control over the operating and financial policies of the entity.
For each of the subsidiaries listed, the voting rights held equal the proportion of ownership interest and
consolidation by ING is based on the majority of ownership.
For the principal investments in associates and joint ventures ING Bank has significant influence but not
control. Significant influence generally results from a shareholding of between 20% and 50% of the voting
rights, but also the ability to participate in the financial and operating policies through situations including,
but not limited to one or more of the following:
\u2022Representation on the board of directors;
\u2022Participation in the policymaking process; and
\u2022Interchange of managerial personnel.
The principal subsidiaries, investments in associates and joint ventures of ING Bank N.V. and their statutory
place of incorporation or primary place of business are as follows:
Principal subsidiaries, investments in associates and joint ventures
Proportion of
ownership and
interest held
by the group
2022
2021
Subsidiary
Statutory place of
Incorporation
Country of operation
Bank Mendes Gans N.V.
Amsterdam
the Netherlands
100%
100%
ING Belgium S.A./N.V.
Brussels
Belgium
100%
100%
ING Luxembourg S.A.
Luxembourg City
Luxembourg
100%
100%
ING-DiBa AG
Frankfurt am Main
Germany
100%
100%
ING Bank Slaski S.A.1
Katowice
Poland
75%
75%
ING Financial Holdings Corporation
Delaware
United States of America
100%
100%
ING Bank A.S.
Istanbul
Turkey
100%
100%
ING Bank (Australia) Ltd
Sydney
Australia
100%
100%
ING Commercial Finance B.V.
Amsterdam
the Netherlands
100%
100%
ING Groenbank N.V.
Amsterdam
the Netherlands
100%
100%
Investments in associates and joint
ventures
TMBThanachart Bank Public Company
Ltd2
Bangkok
Thailand
23%
23%
1 The shares of the non-controlling interest stake of 25% are listed on the Warsaw Stock Exchange, for summarised financial
\u00a0 \u00a0 \u00a0 \u00a0 \u00a0 information we refer to \u2018Note 33 \u2018Information on geographical areas.
2 Reference is made to Note 8 Investments in Associates and Joint Ventures.
45\u00a0 Structured entities
ING Bank\u2019s activities involve transactions with various structured entities (SE) in the normal course of its
business. A structured entity is an entity that has been designed so that voting or similar rights are not the
dominant factor in deciding who controls the entity, such as when any voting rights relate to administrative
tasks only and the relevant activities are directed by means of contractual arrangements. ING Bank\u2019s
involvement in these entities varies and includes both debt financing and equity financing of these entities
as well as other relationships. Based on its accounting policies, as disclosed in the section Principles of
valuation and determination of results of these financial statements, ING establishes whether these
involvements result in no significant influence, significant influence, joint control or control over the
structured entity.
The structured entities over which ING can exercise control are consolidated. ING may provide support to
these consolidated structured entities as and when appropriate. However, this is fully reflected in the
consolidated financial statements of ING Bank as all assets and liabilities of these entities are included and
off-balance sheet commitments are disclosed.
ING\u2019s activities involving structured entities are explained below in the following categories:
1.Consolidated ING originated securitisation programmes;
2.Consolidated ING originated Covered bond programme (CBC);
3.Consolidated ING sponsored Securitisation programme (Mont Blanc);
4.Unconsolidated Securitisation programme; and
5.Other structured entities.
1. Consolidated ING originated securitisation programmes
ING Bank enters into liquidity management securitisation programmes in order to obtain funding and
improve liquidity. Within the programme ING Bank sells ING originated assets to a structured entity. The
underlying exposures include residential mortgages and SME loans in the Netherlands, Belgium, Spain, Italy,
Australia and Germany.
The structured entity issues securitised notes (traditional securitisations) which are eligible collateral for
central bank liquidity purposes. In most programmes ING Bank acts as investor of the securitised notes. ING
Bank continues to consolidate these structured entities if it is deemed to control the entities.
The structured entity issues securitisation notes in two or more tranches, of which the senior tranche
obtains a high rating (AAA or AA) by a rating agency. The tranche can subsequently be used by ING Bank as
collateral in the money market for secured borrowings.
ING Bank originated various securitisations, as at 31\u00a0December 2022, these consisted of approximately EUR
65 billion (2021: EUR 74 billion) of senior and subordinated notes, of which approximately EUR 1 billion
(2021: EUR 1 billion) were issued externally. The underlying exposures are residential mortgages and SME
loans. Apart from the third party funding, these securitisations did not impact ING Bank\u2019s Consolidated
statement of financial position and profit or loss.
In 2022, there are no non-controlling interests as part of the securitisation structured entities that are
significant to ING Bank. ING Bank for the majority of the securitisation vehicles provides the funding for the
entity except for EUR 1 billion (2021: EUR 1 billion).
In addition ING Bank originated various securitisations for liquidity management optimisation purposes. As
at 31\u00a0December 2022, these consisted of EUR 444 million (2021: EUR 662 million) of senior secured portfolio
loans, which have been issued to ING subsidiaries in Germany. The underlying exposures are senior loans to
large corporations and financial institutions, and real estate finance loans, mainly in the Netherlands. These
securitisations did not impact ING Bank\u2019s consolidated statement of financial position and profit or loss.
2. Consolidated ING originated Covered bond programme (CBC)
ING Bank has entered into a covered bond programme. Under the covered bond programme ING issues
bonds. The payment of interest and principal is guaranteed by the ING administered structured entities, ING
Covered Bond Company B.V., and ING SB Covered Bond Company B.V. In order for these entities to fulfil their
guarantee, ING legally transfers mainly Dutch mortgage loans originated by ING. Furthermore ING offers
protection against deterioration of the mortgage loans. The entities are consolidated by ING Bank.
Covered bond programme
Fair value pledged
mortgage loans
in EUR million
2022
2021
Dutch Covered Bond Companies
21,379
16,586
21,379
16,586
In addition, subsidiaries of ING in Germany, Belgium and Australia also issued covered bonds with pledged
mortgages loans of approximately EUR 24,880 million (2021: EUR 22,597 million) in total.
For the covered bond programme, third-party investors in securities issued by the structured entity have
recourse to the assets of the entity and to the assets of ING Bank.
3. Consolidated ING sponsored Securitisation programme (Mont Blanc)
In the normal course of business, ING Bank structures financing transactions for its clients by assisting them
in obtaining sources of liquidity by selling the clients\u2019 receivables or other financial assets to a Special
Purpose Vehicle (SPV). The senior positions in these transactions may be funded by the ING administered
multi seller Asset Backed Commercial Paper (ABCP) conduit Mont Blanc Capital Corp. (rated A-1/P-1). Mont
Blanc Capital Corp. funds itself externally\u00a0 in the ABCP markets.
In its role as administrative agent, ING Bank facilitates these transactions by acting as administrative agent,
swap counterparty and liquidity provider to Mont Blanc Capital Corp. ING Bank also provides support facilities
(i.e. liquidity) backing the transactions funded by the conduit. The types of asset currently in the Mont Blanc
conduit include trade receivables, consumer finance receivables, car leases and residential mortgages.
ING Bank supports the commercial paper programmes by providing Mont Blanc Capital Corp. with short-
term liquidity facilities. Once drawn these facilities bear normal credit risk.
The liquidity facilities, provided to Mont Blanc are EUR 2,446 million (2021: EUR 2,581 million). The drawn
liquidity amount is nil as at 31\u00a0December 2022 (2021: nil).
The standby liquidity facilities are reported under irrevocable facilities. All facilities, which vary in risk profile,
are granted to the Mont Blanc Capital Corp. subject to normal ING Bank credit and liquidity risk analysis
procedures. The fees received for services provided and for facilities are charged subject to market
conditions.
4. Unconsolidated Securitisation programme
In 2013 ING transferred financial assets (mortgage loans) for an amount of approximately EUR 2 billion to a
special purpose vehicle (SPV). The transaction resulted in full derecognition of the financial assets from ING\u2019s
statement of financial position. Following this transfer ING continues to have two types of on-going
involvement in the transferred assets: as counterparty to the SPE of a non-standard interest rate swap and
as servicer of the transferred assets. ING has an option to unwind the transaction by redeeming all notes at
their principal outstanding amount, in the unlikely event of changes in accounting and/or regulatory
requirements that significantly impact the transaction. The fair value of the swap held by ING at
31\u00a0December 2022 amounted to EUR -40\u00a0million (2021: EUR -34\u00a0million); fair value changes on this swap
recognised in the statement of profit or loss in 2022 were EUR -6 million (2021: EUR 0 million). Service fee
income recognised, for the role as administrative agent, in the statement of profit or loss in 2022 amounted
to EUR 1 million (2021: EUR 1 million). The cumulative income recognised in profit or loss since derecognition
amounts to EUR 18 million (2021: EUR 17 million).
5. Other structured entities
In the normal course of business, ING Bank enters into transactions with structured entities as counterparty.
Predominantly in its structured finance operations, ING can be instrumental in facilitating the creation of
these structured entity counterparties. These entities are generally not included in the consolidated
financial statements of ING Bank, as ING facilitates these transactions as administrative agent by providing
structuring, accounting, funding, lending, and operation services.
ING Bank offers various investment fund products to its clients. ING Bank does not invest in these investment
funds for its own account nor acts as the fund manager.
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46\u00a0 Related parties
In the normal course of business, ING Bank 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 Bank include, among others, its
subsidiaries, associates, joint ventures, key management personnel, and various defined benefit and
contribution plans. For post-employment benefit plans, reference is made to Note 33 'Pensions and other
post-employment benefits'. Transactions between related parties include rendering or receiving of services,
leases, transfers under finance arrangements and provisions of guarantees or collateral. All transactions
with related parties took place at conditions customary in the market. There are no significant provisions for
doubtful debts or individually significant bad debt expenses recognised on outstanding balances with
related parties.
ING Bank forms part of ING Group and also enters into transactions with ING Group. These transactions vary
from financing activities to regular purchase and sales transactions. Disclosed in the table below, are the
transactions with ING Groep N.V.
Parent Company
Transactions with ING Groep N.V.
in EUR million
2022
2021
Assets
56
55
Liabilities
65,704
56,349
Income received
4
15
Expenses paid
1,426
1,158
Assets, liabilities, commitments, and income related to Associates and joint ventures result from
transactions which are executed as part of the normal Banking business.
Key management personnel compensation
The Executive Board of ING Groep N.V., the Management Board Banking and the Supervisory Board are
considered Key Management personnel of ING Group. In 2022 and 2021, the three members of the
Executive Board of ING Groep N.V. were also members of the Management Board Banking.
Transactions with key management personnel, including their compensation are included in the tables
below.
Key management personnel compensation (Executive Board and Management Board Banking)
2022
in EUR thousands
Executive
Board of ING
Groep N.V.
Management
Board Banking 1
Total
Fixed Compensation
\u2013\u00a0 Base salary
4,220
4,969
9,189
\u2013\u00a0 Collective fixed allowances 2
1,011
1,073
2,084
\u2013\u00a0 Pension costs
70
116
186
\u2013\u00a0 Severance benefits
932
932
Variable compensation
\u2013\u00a0 Upfront cash
803
803
\u2013\u00a0 Upfront shares
268
803
1,071
\u2013\u00a0 Deferred cash
1,204
1,204
\u2013\u00a0 Deferred shares
401
1,204
1,605
\u2013\u00a0 Other emoluments 3
296
638
934
Total compensation
6,266
11,742
18,008
1Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.
2The collective fixed allowances consist of two savings allowances applicable to employees in the Netherlands; an individual savings
allowance of 3.5% and a collective savings allowance to compensate for loss of pension benefits with respect to salary in excess of
EUR 114,866.
3This includes amongst others: housing, school/tuition fees, international health insurance, relocation costs and tax and financial
planning.
Key management personnel compensation (Executive Board and Management Board Banking)
Executive
Board of ING
Groep N.V. 3
Managemen
t Board
Banking 1,4
Total
2021
in EUR thousands
Fixed Compensation
\u2013\u00a0 Base salary
3,836
5,024
8,860
\u2013\u00a0 Collective fixed allowances 2
954
1,214
2,168
\u2013\u00a0 Pension costs
64
116
180
\u2013\u00a0 Severance benefits
1,075
1,075
Variable compensation
\u2013\u00a0 Upfront cash
664
664
\u2013\u00a0 Upfront shares
265
691
956
\u2013\u00a0 Deferred cash
997
997
\u2013\u00a0 Deferred shares
398
1,036
1,434
\u2013\u00a0 Other emoluments 5
274
959
1,233
Total compensation
5,791
11,776
17,567
Loans and advance to key management personnel
As at 31 December 2022 Loans and advances outstanding to key management personnel amounted to EUR
2.7 million (2021: EUR 2.4 million) and loan commitments to key management personnel amounted to EUR
203 thousand (2021: EUR 197\u00a0thousand). Total interest received in 2022 on these loans and advances
amounted to EUR 62 thousand (EUR 37 thousand).
These loans and advances and loan commitments (1) were made in the ordinary course of business, (2)
were granted on conditions that are comparable to those of loans and advances granted to all employees
and (3) did not involve more than the normal risk of collectability or present other unfavourable features.
Loans and advances to members of the Executive Board and Management Board Banking are compliant
with the standards set out in the DNB guidelines for loans to officers and directors of a regulated entity,
such as ING.
Deposits outstanding to key management personnel
As at 31 December 2022 Deposits outstanding from key management personnel amounted to EUR 11.5
million (2021: EUR 6.1 million). Total interest paid in 2022 on these deposits amounted to EUR 36\u00a0thousand
(2021: EUR 14 thousand).
Number of ING Groep N.V. shares and stock options to key management personnel
ING Groep N.V. shares
in numbers
2022
2021
Executive Board members
108,217
91,853
Management Board Banking
294,574
237,525
Supervisory Board members
5,295
5,295
Total number of shares and stock options
408,086
334,673
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46\u00a0 Related parties
In the normal course of business, ING Bank 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 Bank include, among others, its
subsidiaries, associates, joint ventures, key management personnel, and various defined benefit and
contribution plans. For post-employment benefit plans, reference is made to Note 33 'Pensions and other
post-employment benefits'. Transactions between related parties include rendering or receiving of services,
leases, transfers under finance arrangements and provisions of guarantees or collateral. All transactions
with related parties took place at conditions customary in the market. There are no significant provisions for
doubtful debts or individually significant bad debt expenses recognised on outstanding balances with
related parties.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForTransactionsWithRelatedPartiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8xNzE0L2ZyYWc6MzM5Nzk1NzQyYzExNDNiYWJkY2I3NzFiNGE0YmNmNTgvdGV4dHJlZ2lvbjozMzk3OTU3NDJjMTE0M2JhYmRjYjc3MWI0YTRiY2Y1OF84MjQ2MzM3MjExODgy_3d22365b-3c31-44e3-b17e-176896744888": { "value": "
Key management personnel compensation
The Executive Board of ING Groep N.V., the Management Board Banking and the Supervisory Board are
considered Key Management personnel of ING Group. In 2022 and 2021, the three members of the
Executive Board of ING Groep N.V. were also members of the Management Board Banking.
Transactions with key management personnel, including their compensation are included in the tables
below.
Key management personnel compensation (Executive Board and Management Board Banking)
2022
in EUR thousands
Executive
Board of ING
Groep N.V.
Management
Board Banking 1
Total
Fixed Compensation
\u2013\u00a0 Base salary
4,220
4,969
9,189
\u2013\u00a0 Collective fixed allowances 2
1,011
1,073
2,084
\u2013\u00a0 Pension costs
70
116
186
\u2013\u00a0 Severance benefits
932
932
Variable compensation
\u2013\u00a0 Upfront cash
803
803
\u2013\u00a0 Upfront shares
268
803
1,071
\u2013\u00a0 Deferred cash
1,204
1,204
\u2013\u00a0 Deferred shares
401
1,204
1,605
\u2013\u00a0 Other emoluments 3
296
638
934
Total compensation
6,266
11,742
18,008
1Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.
2The collective fixed allowances consist of two savings allowances applicable to employees in the Netherlands; an individual savings
allowance of 3.5% and a collective savings allowance to compensate for loss of pension benefits with respect to salary in excess of
EUR 114,866.
3This includes amongst others: housing, school/tuition fees, international health insurance, relocation costs and tax and financial
planning.
Key management personnel compensation (Executive Board and Management Board Banking)
Executive
Board of ING
Groep N.V. 3
Managemen
t Board
Banking 1,4
Total
2021
in EUR thousands
Fixed Compensation
\u2013\u00a0 Base salary
3,836
5,024
8,860
\u2013\u00a0 Collective fixed allowances 2
954
1,214
2,168
\u2013\u00a0 Pension costs
64
116
180
\u2013\u00a0 Severance benefits
1,075
1,075
Variable compensation
\u2013\u00a0 Upfront cash
664
664
\u2013\u00a0 Upfront shares
265
691
956
\u2013\u00a0 Deferred cash
997
997
\u2013\u00a0 Deferred shares
398
1,036
1,434
\u2013\u00a0 Other emoluments 5
274
959
1,233
Total compensation
5,791
11,776
17,567
Loans and advance to key management personnel
As at 31 December 2022 Loans and advances outstanding to key management personnel amounted to EUR
2.7 million (2021: EUR 2.4 million) and loan commitments to key management personnel amounted to EUR
203 thousand (2021: EUR 197\u00a0thousand). Total interest received in 2022 on these loans and advances
amounted to EUR 62 thousand (EUR 37 thousand).
These loans and advances and loan commitments (1) were made in the ordinary course of business, (2)
were granted on conditions that are comparable to those of loans and advances granted to all employees
and (3) did not involve more than the normal risk of collectability or present other unfavourable features.
Loans and advances to members of the Executive Board and Management Board Banking are compliant
with the standards set out in the DNB guidelines for loans to officers and directors of a regulated entity,
such as ING.
Deposits outstanding to key management personnel
As at 31 December 2022 Deposits outstanding from key management personnel amounted to EUR 11.5
million (2021: EUR 6.1 million). Total interest paid in 2022 on these deposits amounted to EUR 36\u00a0thousand
(2021: EUR 14 thousand).
Number of ING Groep N.V. shares and stock options to key management personnel
ING Groep N.V. shares
in numbers
2022
2021
Executive Board members
108,217
91,853
Management Board Banking
294,574
237,525
Supervisory Board members
5,295
5,295
Total number of shares and stock options
408,086
334,673
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47\u00a0 Capital management
Objectives
Group Treasury (\u201cGT\u201d) Balance Sheet & Capital Management, is responsible for maintaining the adequate
capitalisation of ING Group and ING Bank entities, to manage the risk associated with ING\u2019s business
activities. This involves not only managing, planning and allocating capital within ING Group, ING Bank and
its various entities, but also helping to execute necessary capital market transactions, term (capital) funding
and risk management transactions. ING takes an integrated approach to assess the adequacy of its capital
position in relation to its risk profile and operating environment. This means GT Balance Sheet & Capital
Management takes into account both regulatory and internal, economic based metrics and requirements as
well as the interests of key stakeholders such as shareholders and rating agencies.
ING Bank applies the following main capital definitions:
\u2022Common Equity Tier 1 capital (CET1) - is defined as shareholders\u2019 equity less regulatory adjustments.
CET1 capital divided by risk-weighted assets equals the CET1 ratio.
\u2022Tier 1 capital \u2013 is defined as CET1 capital plus Additional Tier 1 (hybrid) securities and other regulatory
adjustments. Tier 1 capital divided by risk-weighted assets equals the Tier 1 capital ratio.
\u2022Total capital \u2013 is Tier 1 capital plus subordinated Tier 2 liabilities and regulatory adjustments. Total capital
divided by risk-weighted assets equals the Total capital ratio.
\u2022Leverage ratio \u2013 is defined as Tier 1 capital divided by the leverage exposure.
Capital developments
ING Bank\u2019s capital ratios at the end of the year decreased compared to 2021 primarily due to higher risk-
weighted assets and as most of the net profit of the year with EUR 2.75 billion additional distributions were
up streamed to ING Group. Risk-weighted assets were mainly impacted by rating downgrades on Russia-
related exposure, currency movements, the implementation of EBA guidelines on the treatment of
structural FX positions, and model impacts. Model impacts reflect the introduction of a risk-weight floor on
Dutch residential mortgages by the Dutch Central Bank as well as ongoing redevelopment of internal
models and EBA guidelines.
ING Bank paid EUR 3.5 billion of dividend to ING Group in relation to the 2022 profit and an additional EUR
2.75 billion for distribution to shareholders by the Group.
ING Bank N.V. has a CET1 ratio of 12.6% versus an overall CET1 requirement (including buffer requirements)
of 7.10%. The Bank\u2019s Tier 1 ratio decreased from 16.5% to 14.5% compared to last year. The Banks\u2019s Total
capital ratio decreased to 17.5%.
ING Bank capital position according to CRR II / CRD V
in EUR million
2022
2021
Shareholders\u2019 equity 1
42,546
47,914
-Interim profits not included in CET 1 capital
-913
-934
- Other adjustments
332
-2,130
Regulatory adjustments
-580
-3,064
Available common equity Tier 1 capital
41,966
44,850
Additional Tier 1 securities
6,280
6,792
Regulatory adjustments additional Tier 1
78
78
Available Tier 1 capital
48,324
51,720
Supplementary capital Tier 2 bonds\u00a0 2
10,046
9,341
Regulatory adjustments Tier 2
41
21
Available Total capital
58,411
61,081
Risk weighted assets
332,853
312,616
Common equity Tier 1 ratio
12.61%
14.35%
Tier 1 ratio
14.52%
16.54%
Total capital ratio
17.55%
19.54%
2All T2 securities are CRR/CRD V-compliant for 2022 (2021: EUR 153 million was subject to CRR/CRD IV grandfathering rules).
In accordance with the applicable regulation, credit and operational risk models used in the capital ratios
calculations are not audited.
Processes for managing capital
GT Balance Sheet & Capital Management ensures adherence to ING\u2019s solvency risk appetite statements by
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 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 assesses continuously 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\u2019s risk management framework. Contingency capital
measures and early warning indicators are in place in conjunction with ING\u2019s 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\u2019s risk and capital management framework. It allows to (i) identify and assess potential
vulnerabilities in ING\u2019s businesses, business model, portfolios or operating environment; (ii) understand the
sensitivities of the core assumptions used in ING\u2019s 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.
Regulatory requirements
Capital adequacy and the use of required regulatory capital are based on the guidelines developed by the
Basel Committee on Banking Supervision (The Basel Committee) and the European Union Directives, as
implemented by the Dutch Central Bank and the ECB for supervisory purposes. In 2010, the Basel Committee
issued new solvency and liquidity requirements that superseded Basel II, implemented in the EU via CRR /
CRD. In accordance with the CRR the minimum Pillar 1 capital requirements applicable to ING Bank are: a
CET1 ratio of 4.5%, a Tier 1 ratio of 6.0% and a Total capital ratio of 8.0% of risk-weighted assets.
The overall CET1 requirement (including buffer requirements) for ING Bank N.V. at a consolidated level was
7.10% in 2022. This requirement is the sum of a 4.5% Pillar I requirement, a 2.5% Capital Conservation Buffer
(CCB) and a 0.10% Countercyclical Buffer (CCyB) (based on December 2022 positions).
Ratings
ING\u2019s credit ratings and outlook are shown in the table below. Each of these ratings reflects only the view of
the applicable rating agency at the time the rating was issued, and any explanation of the significance of a
rating may be obtained only from the rating agency.
Main credit ratings of ING Bank N.V. at 31 December 2022
S&P
Moody\u2019s
Fitch
GBB-Rating
ING Bank N.V.
Issuer rating
Long-term
A+
A1
AA-
A+
Short-term
A-1
P-1
F1+
n/a
Outlook
Stable
Stable
Stable
Indeterminate
Senior unsecured rating
A+
A1
AA-
A security rating is not a recommendation to buy, sell or hold securities and 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 a rating will not be lowered, suspended or withdrawn entirely by the
rating agency if, in the rating agency\u2019s judgment, circumstances so warrant. ING accepts no responsibility
for the accuracy or reliability of the ratings.
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48\u00a0 Subsequent events
On 6 February 2023, a devastating earthquake with multiple aftershocks struck southern and central Turkey
and northern and western Syria causing a significant tragedy for the people and is causing disruption to
business and economic activity in the region. This qualifies as a non-adjusting subsequent event.", "dimensions": { "concept": "ifrs-full:DisclosureOfEventsAfterReportingPeriodExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8yNTYvZnJhZzplZWUzNDEzNDk1YTM0NTk3ODlmNWQxZGY1MDg4OTQyMC90ZXh0cmVnaW9uOmVlZTM0MTM0OTVhMzQ1OTc4OWY1ZDFkZjUwODg5NDIwXzE2NDkyNjc0NDQ5OTg_20575d43-a8ef-48e9-96b1-2568252130e0": { "value": "Bijlmerdreef 106, 1102 CT Amsterdam, the Netherlands", "dimensions": { "concept": "ifrs-full:AddressOfRegisteredOfficeOfEntity", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } }, "id3VybDovL2RvY3MudjEvZG9jOmE2ZmIyOGI2NzNiNDRmMWU5MzRmZDRjNWRlMTA0NGMxL3NlYzphNmZiMjhiNjczYjQ0ZjFlOTM0ZmQ0YzVkZTEwNDRjMV8yNTYvZnJhZzplZWUzNDEzNDk1YTM0NTk3ODlmNWQxZGY1MDg4OTQyMC90ZXh0cmVnaW9uOmVlZTM0MTM0OTVhMzQ1OTc4OWY1ZDFkZjUwODg5NDIwXzE2NDkyNjc0NDQ5OTg_895e48f0-7252-46fe-a996-3580210990f9": { "value": "Bijlmerdreef 106, 1102 CT Amsterdam, the Netherlands", "dimensions": { "concept": "ifrs-full:PrincipalPlaceOfBusiness", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00" } } } }