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Risk management
Basis of disclosures (*)
The risk management section contains information relating to the nature and extent of the risks of
financial instruments as required by International Financial Reporting Standards (IFRS) 7 'Financial
Instruments: Disclosures'. These disclosures are an integral part of the ING 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 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. 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.
Credit risk
Credit & counterparty risk categories (*)
In the following table the different types of credit and counterparty risk categories are described and a
reconciliation with the notes in the financial statements is also included:
Reconciliation between credit & counterparty risk categories and financial position (*)
Credit risk categories
Notes in the financial statements
Lending risk: The risk that the client (counterparty, corporate or individual) does not pay the principal interest or fees on a loan when they are due,
or on demand for letters of credit (LCs) and guarantees provided by ING.
2
Cash and balances with central banks
3
Loans and advances to banks
4
Financial assets at fair value through profit or loss
5
Financial assets at fair value through other comprehensive income
7
Loans and advances to customers
38
Contingent liabilities and commitments
Investment risk: 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.
4
Financial assets at fair value through profit or loss
5
Financial assets at fair value through other comprehensive income
6
Debt securities
Money market risk: This arises when ING places short-term deposits with a counterparty in order to manage excess liquidity. In the event of a
counterparty default, ING may lose the deposit placed.
2
Cash and balances with central banks
3
Loans and advances to banks
7
Loans and advances to customers
Pre-settlement risk: This arises when a client defaults on a transaction before settlement and ING must replace the contract by a trade with another
counterparty at the then prevailing (possibly unfavourable) market price. This credit risk category is associated with derivatives transactions
(exchange-traded derivatives, over-the-counter (OTC) derivatives and securities financing transactions).
4
Financial assets at fair value through profit or loss
14
Financial liabilities at fair value through profit or loss
37
Offsetting financial assets and liabilities
Settlement risk: This arises when there is an exchange of value (funds or instruments) and receipt from its counterparty is not verified or expected
until after ING has given irrevocable instructions to pay or has paid or delivered its side of the trade. The risk is that ING delivers but does not receive
delivery from its counterparty.
4
Financial assets at fair value through profit or loss
11
Other assets
14
Financial liabilities at fair value through profit or loss
16
Other liabilities
Credit risk appetite and concentration risk framework (*)
The credit risk appetite and concentration risk framework is designed to prevent undesired high levels of
credit risk and credit concentrations within various levels of the ING portfolio. It is derived from the concepts
of boundaries and instruments as described in the ING RAF.
Credit risk appetite is the maximum level of credit risk ING is willing to accept for growth and value creation.
The credit risk appetite is linked to the overall bank-wide RAF and is expressed in quantitative and qualitative
measures.
The credit risk appetite is set at different levels and dimensions within ING. The credit risk appetite framework
specifies the scope and focus of the credit risk which ING takes and the composition of the credit portfolio,
including its concentration and diversification objectives in relation to business lines, locations, sectors and
products. The credit risk appetite framework has also been extended to embed climate risk elements. The
climate risk elements within the credit risk appetite framework allow for more efficient steering of sector
concentrations from a climate risk perspective.
The credit concentration risk framework is composed of:
\u2022 Country risk concentration: Country risk is the risk that arises due to events in a specific country (or
group of countries). To manage the maximum country loss ING is willing to accept, boundaries are
approved by the SB. The estimated level is correlated to the risk rating assigned to a given country. Actual
country limits are set by means of country instruments, which are monitored monthly and updated,
when needed. For countries with elevated levels of geopolitical or severe economic cycle risk, monitoring
is performed on a more frequent basis with strict pipeline and exposure management.
\u2022 Single name and secondary risk concentration: ING has an established credit concentration risk
framework to identify, measure and monitor single name concentration including secondary risk. The
same concept of boundaries and instruments is applicable.
\u2022 Sector and product concentration risk are managed via the credit risk appetite framework.
Credit risk models (*)
Within ING, internal CRR-compliant models are used to determine probability of default (PD), exposure at
default (EAD) and loss given default (LGD) for regulatory and economic capital purposes. These models also
form the basis of ING\u2019s IFRS 9 loan loss provisioning (see \u2018IFRS 9 models\u2019 below).
There are two main types of PD, EAD and LGD models used throughout the bank:
\u2022 Statistical models are created where a large set of default or detailed loss data is available. They are
characterised by sufficient data points to facilitate meaningful statistical estimation of the model
parameters. The model parameters are estimated with statistical techniques based on the data set
available.
\u2022 Hybrid models are statistical models supplemented with knowledge and experience of experts from risk
management and front-office staff, literature from rating agencies, supervisors and academics. These
models are only used for \u2018low default portfolios\u2019, where limited historical defaults exist.
Credit risk rating process (*)
The majority of risk ratings are based on a risk rating (PD) model that complies with the minimum
requirements detailed in CRR/CRD, ECB Supervisory Rules and European Banking Authority (EBA) guidelines.
This concerns all borrower types and segments.
ING\u2019s PD rating models are based on a 1-22 internal risk rating scale (1 = highest rating; 22 = lowest rating)
referred to as the \u2018master scale\u2019, which roughly corresponds to the rating grades that are assigned by
external rating agencies, such as Standard & Poor\u2019s, Moody\u2019s and Fitch. For example, an ING rating of 1
corresponds to an S&P/Fitch rating of AAA and a Moody\u2019s rating of Aaa; an ING rating of 2 corresponds to an
S&P/Fitch rating of AA+ and a Moody\u2019s rating of Aa1, and so on.
The 22 internal risk rating grades are composed of the following categories:
\u2022 Investment grade (risk rating 1-10);
\u2022 Non-investment grade (risk rating 11-17);
\u2022 Performing Restructuring (risk rating 18-19); and
\u2022 Non-performing (risk rating 20-22).
The first three categories (1-19) are risk ratings for performing loans. Ratings are calculated in IT systems
with internally developed models, based on manually or automatically fed data, or for part of the non-
performing loans set by the global or regional credit restructuring department. Under certain conditions, the
outcome of a manually fed model can be challenged through a rating appeal process. For securitisation
portfolios, the external ratings of the tranche in which ING has invested are leading indicators.
Risk ratings assigned to clients are reviewed at least annually, with the performance of the underlying
models monitored regularly. Some of these models are global in nature, such as those for large corporates,
commercial banks, insurance companies, central governments, funds, fund managers, project finance and
leveraged companies. Other models are more regional or country-specific: there are PD models for small and
medium enterprises (SMEs) in the Netherlands, Belgium, and Poland as well as residential mortgage and
consumer loan models in the various retail markets.
Rating models for Retail clients are predominantly statistically driven and automated, such that ratings can
be updated on a monthly basis. Rating models for large corporates, institutions and banks include both
statistical characteristics and expert input, with the ratings being manually updated at least annually. More
frequent reviews (e.g. quarterly) are performed where considered necessary.
In line with evolving regulatory expectations on models and emerging industry practices, ING has embarked
on a multi-year redevelopment process of its credit risk models. This is also in line with ING\u2019s model
governance to ensure continuous improvement of models.
Credit risk portfolio (*)
ING\u2019s credit exposure is mainly related to lending to individuals (also referred to as consumer lending, all
Retail) and businesses (referred to as business lending, both in Retail and Wholesale), followed by
investments in bonds and securitised assets, and money market (Wholesale). Loans to individuals are mainly
mortgage loans secured by residential property. Loans (including guarantees issued) to businesses are often
collateralised, but may be unsecured based on the internal analysis of the borrower\u2019s creditworthiness.
Bonds in the investment portfolio are generally unsecured, but predominantly consist of bonds issued by
central governments and EU and/or OECD-based financial institutions. Secured bonds, such as mortgage-
backed securities and asset-backed securities are secured by the underlying diversified pool of assets
(commercial or residential mortgages, car loans and/or other assets) held by the securities issuer. For money
market, exposure is mainly deposits to central banks. The last major credit risk source involves pre-
settlement exposures which arise from trading activities, including derivatives, repurchase transactions and
securities lending/borrowing transactions. This is also commonly referred to as counterparty credit risk.
Overall portfolio (*)
During 2024, ING\u2019s portfolio size increased by \u20ac30.3 billion (3.2%) to \u20ac961.9 billion outstanding. Foreign
exchange rate changes had a positive impact on the portfolio growth, mainly in WB, increasing total
outstanding by \u20ac8.0 billion, driven by the appreciation of the US dollar against the euro. Retail banking
increased by \u20ac18.9 billion mainly due to underlying growth in residential mortgages.
Rating distribution (*)
Overall, the rating class distribution remained stable in 2024. The share of investment grade rating classes
increased from 76.8% to 78.1%, while the share of non-investment grade decreased from 21.2% to 19.9%.
Performing restructuring outstandings decreased from 0.7% to 0.6% of the total portfolio, whereas non-
performing loans increased from 1.3% to 1.4%.
With respect to the rating distribution within the business lines, in WB, investment grade increased to 83.7%
from 81.2%, while non-investment grade exposures decreased to 14.6% from 17.1% compared to 2023.
Performing restructuring assets decreased from 0.7% to 0.6% of total Wholesale Banking assets where non-
performing loans for WB increased from 1.0% to 1.2%. The non-performing loans (NPL) increase in
Wholesale Banking is mainly caused by Russian exposures as well as a few large NPLs that are unrelated in
terms of asset class, sector or geography.
For Retail Banking, investment grade increased to 73.3% from 73.0%, while non-investment grade exposures
decreased to 24.4% from 24.9% as compared to 2023. Performing restructuring increased to 0.7% from 0.6%
whereas NPL remained constant at 1.5% in 2024.
Industry (*)
The industry breakdown is presented in accordance with the NAICS definition. The increase of \u20ac30.3 billion in
total volume during 2024 was mainly due to the increase in Private Individuals (\u20ac18.4 billion), Non-Bank
Financial Institutions (\u20ac8.8 billion) and Commercial Banks (\u20ac5.2 billion). The share of Private Individuals
increased from 38.8% last year to 39.5%.
Portfolio analysis per business line (*)
Outstandings per line of business (*)1, 2, 3
in EUR million
Wholesale Banking
Retail Banking
Corporate line
Total
Rating class
2024
2023
2024
2023
2024
2023
2024
2023
Investment grade
1 (AAA)
53,363
52,716
29,151
34,683
1,790
2,284
84,304
89,682
2-4 (AA)
72,462
67,034
63,187
59,655
4
6
135,653
126,694
5-7 (A)
101,831
95,320
140,479
132,076
157
147
242,467
227,543
8-10 (BBB)
129,429
123,081
155,375
146,295
3,452
2,357
288,256
271,733
Non-investment grade
11-13 (BB)
53,757
57,348
94,753
94,408
148,510
151,756
14-16 (B)
7,396
12,234
31,165
29,330
38,561
41,565
17 (CCC)
1,037
1,122
3,345
3,113
170
196
4,552
4,431
Performing Restructuring loans
18 (CC)
1,792
2,523
2,001
1,957
3,794
4,481
19 (C)
560
535
1,760
1,313
2,320
1,848
Non-performing loans
20-22 (D)
5,204
4,051
8,100
7,622
13,303
11,673
Total
426,832
415,965
529,317
510,452
5,572
4,989
961,720
931,406
Industry
Private Individuals
2,116
2,330
377,712
359,057
379,827
361,387
Central Banks
61,091
70,139
15,044
21,740
1,785
2,269
77,919
94,147
Natural Resources
39,974
40,511
1,925
1,883
41,899
42,394
Real Estate
24,643
24,904
28,738
26,611
53,381
51,515
Commercial Banks
41,027
37,393
6,662
6,183
3,619
2,515
51,308
46,091
Non-Bank Financial Institutions
64,217
55,313
2,212
2,290
79
89
66,509
57,692
Central Governments
48,389
45,316
8,107
7,304
1
1
56,497
52,621
Transportation & Logistics
27,499
27,106
6,037
5,784
33,536
32,890
Utilities
25,517
23,324
2,196
2,184
27,713
25,509
Food, Beverages & Personal Care
13,827
13,503
10,419
9,883
24,246
23,386
Services
8,844
9,128
13,442
12,872
27
24
22,312
22,023
General Industries
10,512
12,039
8,812
9,086
19,324
21,126
Lower Public Administration
6,959
6,211
19,598
17,493
26,557
23,704
Other
52,218
48,748
28,412
28,082
62
92
80,691
76,922
Total
426,832
415,965
529,317
510,452
5,572
4,989
961,720
931,406
Outstandings per line of business (*) - continued1, 2, 3
in EUR million
Wholesale Banking
Retail Banking
Corporate line
Total
Region
2024
2023
2024
2023
2024
2023
2024
2023
Europe
Netherlands
44,486
54,989
164,590
156,182
1,906
2,366
210,981
213,537
Belgium
26,506
24,171
95,584
91,744
0
7
122,091
115,921
Germany
27,443
26,152
128,598
128,885
30
31
156,071
155,067
Poland
21,190
20,346
30,946
28,971
0
0
52,136
49,317
Spain
11,990
11,047
28,507
27,158
36
35
40,533
38,240
United Kingdom
28,257
28,587
265
275
91
112
28,613
28,974
Luxembourg
26,176
23,805
5,139
5,557
0
0
31,314
29,363
France
24,351
21,528
3,122
3,108
3
14
27,476
24,650
Rest of Europe
72,860
65,157
23,203
20,368
14
32
96,076
85,558
America
86,402
78,851
2,402
2,042
22
25
88,827
80,917
Asia
44,136
49,851
215
159
3,464
2,365
47,815
52,374
Australia
10,887
9,409
46,723
45,977
8
2
57,618
55,389
Africa
2,148
2,071
22
26
0
0
2,170
2,098
Total
426,832
415,965
529,317
510,452
5,572
4,989
961,720
931,406
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.
Portfolio analysis per geographical area (*)
The portfolio analysis per geographical area re-emphasises the international distribution of ING\u2019s credit
portfolio. The Netherlands maintains the largest portfolio share in a single country with 21.9% (2023: 22.9%)
of the total amount, followed by Germany with 16.2% (2023: 16.6%) and Belgium with 12.7% (2023: 12.4%).
In terms of region, the majority of the portfolio balance remained in Europe with 80% (2023: 79%), followed
by Americas with 9.3% (2023: 8.7%) and Australia with 6.0% (2023: 5.9%). The top five countries within Rest
of Europe based on outstandings were Italy (\u20ac20.7 billion), Switzerland (\u20ac16.4 billion), Romania (\u20ac12.4 billion),
T\u00fcrkiye (\u20ac8.6 billion) and Ireland (\u20ac4.8 billion).
The main contributors for the overall increase in outstanding are Americas (+\u20ac7.9 billion), Belgium
(+\u20ac6.2 billion), Poland (+\u20ac2.8 billion) and France (+\u20ac2.8 billion).\u00a0
Private Individuals remained the largest composition of portfolio balances for the Netherlands at 58.3%
(2023: 54.6%), Belgium at 37.4% (2023: 38.5%), Germany at 68.8% (2023: 66.5%) and Australia at 66.1%
(2023: 65.6%). The decrease in Central Banks is mainly attributed to the Netherlands (\u20ac8.5 billion explaining
the decrease in WB Netherlands outstanding), Germany (\u20ac5.0 billion) and Asia (\u20ac4.1 billion).\u00a0
In individual countries, the total share of investment grade/non-investment grade remains substantial for
the Netherlands at 98.5% (2023: 98.6%), Germany at 98.9% (2023: 99.1%) and in Belgium 96.6% (2023:
96.6%).
In Europe, the increase in investment grade was mainly witnessed in Poland (+\u20ac4.3 billion), France
(+\u20ac3.2 billion), Spain (+\u20ac3.2 billion), Belgium (+\u20ac3.2 billion) and Luxembourg (+\u20ac3.2 billion). Non-investment
grade decreased in the Netherlands (-\u20ac2.7 billion), Poland (-\u20ac1.8 billion), Luxembourg (-\u20ac1.2 billion) and Spain
(-\u20ac1.0 billion).
Outstandings by economic sectors and geographical area (*) 1
in EUR million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United
Kingdom
Luxembourg
France
Rest of
Europe
America
Asia
Australia
Africa
2024
Private Individuals
122,914
45,611
107,415
16,525
27,083
122
3,058
2,260
16,391
198
129
38,106
16
379,827
Central Banks
22,529
10,196
13,966
1,729
510
1,935
5,737
0
10,913
0
9,525
879
0
77,919
Natural Resources
2,197
1,531
881
778
152
3,021
2,503
405
11,212
8,475
8,989
1,593
159
41,899
Real Estate
16,749
13,387
1,218
2,085
1,595
552
3,446
2,713
3,707
3,220
1,066
3,642
0
53,381
Commercial Banks
1,353
314
4,129
695
376
4,733
5,268
5,074
7,779
10,700
9,394
1,336
157
51,308
Non-Bank Financial Institutions
2,872
1,766
5,147
2,874
249
8,479
6,031
5,932
5,174
23,157
3,518
1,255
55
66,509
Central Governments
1,416
11,009
51
9,435
5,308
48
82
3,202
9,203
15,377
288
488
589
56,497
Transportation & Logistics
4,290
2,076
1,426
1,623
679
2,262
828
765
7,407
3,983
6,912
504
781
33,536
Utilities
1,805
1,843
3,920
814
1,971
2,826
395
712
3,951
5,886
1,187
2,253
152
27,713
Food, Beverages & Personal Care
7,377
3,690
695
2,215
351
328
1,393
1,102
3,008
2,498
1,168
406
14
24,246
Services
4,919
8,431
1,852
1,538
122
869
540
310
1,271
1,265
516
680
0
22,312
General Industries
4,568
2,690
1,059
2,824
219
301
539
484
3,862
2,039
708
23
8
19,324
Lower Public Administration
782
6,824
7,435
608
557
0
246
3,091
476
1,554
44
4,941
0
26,557
Other
17,208
12,722
6,876
8,394
1,361
3,137
1,248
1,426
11,722
10,475
4,372
1,513
238
80,691
Total
210,981
122,091
156,071
52,136
40,533
28,613
31,314
27,476
96,076
88,827
47,815
57,618
2,170
961,720
Rating class
Investment grade
170,161
74,882
136,096
36,029
32,741
23,844
27,235
21,886
67,110
72,476
41,203
46,959
59
750,680
Non-Investment grade
37,689
43,059
18,238
13,948
7,126
4,388
3,858
5,229
25,679
14,763
5,859
9,889
1,898
191,623
Performing restructuring
1,579
1,078
305
701
234
59
56
54
1,369
443
30
203
4
6,114
Non-performing loans
1,552
3,071
1,432
1,458
432
322
166
307
1,918
1,145
723
568
210
13,303
Total
210,981
122,091
156,071
52,136
40,533
28,613
31,314
27,476
96,076
88,827
47,815
57,618
2,170
961,720
1 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 EUR million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United
Kingdom
Luxembourg
France
Rest of
Europe
America
Asia
Australia
Africa
2023
Private Individuals
116,530
44,637
103,151
14,860
25,452
128
3,347
2,472
14,179
149
121
36,340
20
361,387
Central Banks
31,017
9,756
18,945
2,530
489
4,335
4,853
6,166
13,668
2,379
9
94,147
Natural Resources
2,623
1,346
1,017
685
129
3,789
2,511
429
10,608
8,237
9,785
941
295
42,394
Real Estate
16,907
10,986
1,111
2,184
1,551
420
3,563
2,901
3,492
3,323
1,367
3,709
51,515
Commercial Banks
1,268
404
4,050
601
353
4,488
5,070
4,155
6,757
9,833
8,182
719
210
46,091
Non-Bank Financial Institutions
2,573
1,457
5,710
2,532
652
6,837
4,631
4,274
4,269
19,921
3,884
950
57,692
Central Governments
1,620
9,046
699
8,614
5,491
41
79
2,255
9,384
13,752
520
526
593
52,621
Transportation & Logistics
3,860
2,198
1,277
1,598
658
2,113
596
784
8,177
3,511
7,044
456
618
32,890
Utilities
2,419
1,634
3,516
792
912
2,723
480
619
4,469
4,424
1,306
2,041
173
25,509
Food, Beverages & Personal Care
7,138
3,127
550
2,242
490
540
1,505
1,250
2,455
2,652
1,140
281
18
23,386
Services
5,073
8,463
1,725
1,325
71
745
502
380
1,052
1,576
469
642
22,023
General Industries
5,746
2,604
1,193
2,827
333
199
649
287
3,661
2,848
761
18
21,126
Lower Public Administration
253
6,607
5,349
669
350
0
249
3,488
356
1,550
7
4,826
23,704
Other
16,510
13,657
6,774
7,858
1,309
2,615
1,326
1,356
10,532
9,141
4,120
1,562
163
76,922
Total
213,537
115,921
155,067
49,317
38,240
28,974
29,363
24,650
85,558
80,917
52,374
55,389
2,098
931,406
Rating class
Investment grade
170,118
71,730
136,675
31,772
29,583
24,299
24,083
18,692
56,404
63,652
44,481
44,139
24
715,653
Non-Investment grade
40,399
40,236
16,929
15,785
8,134
4,508
5,013
5,713
25,967
15,806
6,769
10,715
1,776
197,751
Performing restructuring
1,433
799
349
830
230
2
105
122
1,983
245
72
132
26
6,328
Non-performing loans
1,587
3,155
1,114
929
293
165
162
124
1,205
1,213
1,051
403
272
11,673
Total
213,537
115,921
155,067
49,317
38,240
28,974
29,363
24,650
85,558
80,917
52,373
55,389
2,098
931,406
1 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.
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 of ensuring consistent application
within ING. These also require that the value of the cover is monitored on a regular basis. Covers are revalued
periodically and whenever there is reason to believe that the market is subject to significant changes in
conditions. The frequency of monitoring and revaluation depends on the type of cover.
The valuation method also depends on the type of covers. For asset collateral, the valuation sources can be
the customer\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 applies haircuts to the collateral values of real estate, shipping and aviation assets that are
used in the calculation of the loss-given-default in recovery scenarios. The haircut reflects the risks of
adverse price developments between the moment of valuation of an asset and the actual settlement/cash
receipt.
Cover values (*)
This section provides insight into the types of cover and the extent to which exposures benefit from collateral
or guarantees. The disclosure differentiates between risk categories (lending, investment, money market
and pre-settlement). The most relevant types of cover include mortgages, financial collateral (cash and
securities), guarantees and other covers (mainly pledges). ING obtains covers that are eligible for credit risk
mitigation under CRR/CRDIV, as well as covers that are 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.
Cover values including guarantees received (*)
in EUR million
Cover type and value
Collateralisation
2024
Outstandings
Mortgages
Financial Collateral
Guarantees
Other covers
No cover
Partially covered
Fully covered
Consumer lending
378,832
865,466
6,257
25,428
55,115
6.5%
2.0%
91.5%
Business lending
368,424
163,143
24,838
119,410
484,148
34.0%
23.7%
42.3%
Investment and money market
153,495
0
0
1,115
95
99.3%
\u2014%
0.7%
Total lending, investment and money market
900,752
1,028,609
31,095
145,953
539,357
33.6%
10.5%
55.9%
of which NPL
13,295
10,427
194
3,093
11,109
27.6%
27.7%
44.7%
Pre-settlement
60,968
Total Bank
961,720
Cover values including guarantees received (*)
in EUR million
Cover type and value
Collateralisation
2023
Outstandings
Mortgages
Financial Collateral
Guarantees
Other covers
No cover
Partially covered
Fully covered
Consumer lending
360,124
804,994
22,401
25,269
29,070
6.2%
2.0%
91.8%
Business lending
363,680
162,491
26,333
115,944
428,531
35.2%
22.5%
42.3%
Investment and money market
158,506
\u2014
1,040
549
99.0%
0.6%
0.4%
Total lending, investment and money market
882,309
967,485
48,735
142,252
458,149
34.8%
10.2%
55.0%
of which NPL
11,653
8,880
1,609
3,204
9,241
25.7%
26.9%
47.4%
Pre-settlement
49,096
Total Bank
931,406
The above tables gives an overview of the collateralisation of ING\u2019s total portfolio. Excluding the pre-
settlement portfolio, 55.9% (2023: 55.0%) of ING\u2019s outstandings were fully collateralised in 2024. Since
investments traditionally do not require covers, the \u2018no covers\u2019 percentage in this portfolio is over 99%.
Consumer lending portfolio (*)
The consumer lending portfolio accounts for 39.4% (2023: 38.7%) 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 (34.6%), Germany (27.5%), Belgium including Luxembourg (12.8%) and Australia (10.8%).\u00a0
Note that the large increase in Other covers and decrease in Financial Collateral is related to a
reclassification of certain cover types.
Business lending portfolio (*)
Business lending accounts for 38.3% (2023: 39.1%) of ING\u2019s total outstanding. Business lending presented in
this section does not include pre-settlement, investment and money market exposures.
Credit quality (*)
ING uses three distinct statuses to categorise the management of clients with (perceived) deteriorating
credit risk profiles. ING usually classifies a client first with a \u201cwatch list\u201d status 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. Furthermore, ING makes use of Early Warning
Indicators (EWIs) in daily credit risk management processes in non-Retail portfolios which relate to a change
in (internal and/or external) circumstances or outlook of the specific Obligor, the sector or portfolio. Some
clients with a watch list or EWI status may develop into a performing restructuring status (performing loans
that hold a reasonable probability that ING will end up with a loss, if no specific action is taken) or a non-
performing status.
When there is increasing doubt as to the performance and the collectability of the client\u2019s contractual
obligations the loans are managed by Global Credit Restructuring (GCR) or by restructuring units in the
various regions and business units. The statuses and links with rating grades are illustrated in the table
below.
Credit quality outstandings\u00a0 (*)
in EUR million
2024
2023
Performing not past due
823,336
795,796
Business lending performing past due
9,174
8,825
Consumer lending performing past due
802
846
Non-performing
13,295
11,653
Total lending and investment
846,607
817,120
Money market
54,145
65,189
Pre-settlement
60,968
49,096
Total
961,720
931,406
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 customers, ING aims to solve the (potential) financial difficulties by
offering a range of measures (e.g. payment arrangements, restructuring). If the issues cannot be resolved,
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 \u2013 is more than 90 days past due and to risk rating 21 or 22 in
case of an exit scenario.
The table below represents the breakdown of lending and investment credit risk outstandings that are
performing by age and geographic area.
Ageing analysis (past due but performing): Consumer lending portfolio by geographic area, outstandings (*)
in EUR million
2024
2023
Region
Past due
for 1\u201330 days
Past due
for 31\u201360 days
Past due
for 61\u201390 days
Total
Past due
for 1\u201330 days
Past due
for 31\u201360 days
Past due
or 61\u201390 days
Total
Europe
Belgium
185
49
29
263
223
43
29
295
Germany
65
37
24
125
89
40
18
147
Poland
61
9
4
74
76
8
5
89
Netherlands
62
35
4
101
67
24
6
97
Luxembourg
22
6
3
32
21
2
2
25
Spain
12
16
8
36
19
13
6
38
Rest of Europe
93
15
4
112
64
19
11
94
America
0
0
0
1
1
0
0
1
Asia
0
0
0
0
0
0
0
1
Australia
38
19
2
59
43
15
1
59
Africa
0
0
0
0
0
0
0
0
Total
538
186
78
802
602
164
79
846
The past due but performing consumer lending outstanding decreased by \u20ac44 million, due to a decrease in
1-30 days (-\u20ac64 million) which was partially offset by an increase in 31-60 (+\u20ac22 million). The largest
decrease was observed in Belgium (-\u20ac32 million) and Germany (-\u20ac22 million), mainly in the 1-30 days
bucket. The largest increase was seen in Rest of Europe (+\u20ac18 million).
Ageing analysis (past due but performing): Business lending portfolio by geographic area, outstandings (*)
in EUR million
2024
2023
Region
Past due for 1\u201330 days
Past due for 31\u201360 days
Past due for 61\u201390 days
Total
Past due for 1\u201330 days
Past due for 31\u201360 days
Past due for 61\u201390 days
Total
Europe
Belgium
1,187
17
13
1,217
929
98
11
1,037
United Kingdom
830
8
838
623
659
128
1,410
Luxembourg
367
51
5
423
577
8
11
596
Netherlands
929
14
943
509
10
12
531
Poland
173
17
19
209
346
26
10
383
Spain
26
26
France
194
194
58
132
190
Germany
215
3
2
220
131
110
1
242
Rest of Europe
630
4
46
681
972
2
2
977
America
3,504
95
3,599
2,508
101
41
2,650
Asia
310
310
284
22
306
Australia
469
6
475
501
1
502
Africa
39
39
Total
8,873
215
86
9,174
7,437
1,148
240
8,825
Total past due but performing outstanding of business lending increased by \u20ac0.3 billion. Increase was
witnessed in the 1\u201330 days past due bucket (\u20ac1.4 billion) which was offset by the decrease observed in the
31-60 days (-\u20ac0.9 billion) and 61-90 days (-\u20ac0.2 billion) past due buckets. The largest increase was in the
Americas (\u20ac0.9 billion) while the largest decrease was in the United Kingdom (-\u20ac0.6 billion).
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. The aim is to maximise the client\u2019s repayment
ability, thereby avoiding a default situation, or help the client to return to a performing situation.
For ING Retail units, clear criteria have been established to determine whether a client is eligible for the
forbearance process. Specific approval mandates are in place to approve the measures, as well as
procedures to manage, monitor and report the forbearance activities.
ING reviews the performance of forborne exposures at least quarterly, either on a case-by-case (Business) or
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 EUR million
2024
2023
Business line
Outstandings
Of which:
performing
Of which:
non-
performing
% of
total
portfolio
Outstandings
Of which:
performing
Of which:
non-
performing
% of
total
portfolio
Wholesale Banking
5,934
3,191
2,743
1.9%
6,063
3,919
2,144
1.9%
Retail Banking
6,883
3,987
2,897
1.3%
7,026
4,128
2,898
1.4%
Total
12,817
7,178
5,640
1.5%
13,089
8,047
5,042
1.6%
Summary Forborne portfolio by forbearance type (*)
in EUR million
2024
2023
Forbearance
type
Outstandings
Of which:
performing
Of which:
non-
performing
% of total
portfolio
Outstandings
Of which:
performing
Of which:
non-
performing
% of total
portfolio
Loan
modification
11,726
6,734
4,993
1.4%
11,881
7,550
4,331
1.4%
Refinancing
1,091
444
647
0.1%
1,208
497
711
0.1%
Total
12,817
7,178
5,640
1.5%
13,089
8,047
5,042
1.5%
As of 31 December 2024, ING\u2019s total forborne assets decreased by \u20ac272 million compared to 31 December
2023. WB decreased by \u20ac129 million and Retail decreased by \u20ac143 million.
Wholesale Banking (*)
As of December 2024, WB forborne assets amounted to \u20ac5.9 billion (2023: \u20ac6.1 billion), which represented
1.9% (2023: 1.8%) of the total WB portfolio.
Wholesale Banking: Forborne portfolio by geographical area (*)
in EUR million
2024
2023
Region
Outstandings
Of which:
performing
Of which: non-
Outstandings
Of which:
performing
Of which: non-
performing
performing
Europe
Netherlands
217
69
148
361
301
60
Belgium
172
165
7
454
446
8
Germany
372
62
310
288
148
139
United
Kingdom
444
266
178
583
425
158
Italy
389
353
36
54
19
34
Norway
0
0
0
6
0
6
Poland
630
284
346
520
519
0
Rest of Europe
1,339
940
399
1,421
1,142
279
America
1,586
867
719
1,025
532
493
Asia
652
111
541
1,198
277
921
Australia
79
34
44
87
87
\u2014
Africa
54
40
15
68
23
45
Total
5,934
3,191
2,743
6,063
3,919
2,144
Wholesale Banking: Forborne portfolio by economic sector (*)
in \u20ac million
2024
2023
Industry
Outstandings
Of which:
performing
Of which: non-
Outstandings
Of which:
performing
Of which: non-
performing
performing
Natural Resources
781
424
356
788
321
467
Real Estate
1,115
703
412
1,320
1,254
66
Transportation & Logistics
214
83
131
315
175
139
Food, Beverages &
Personal Care
810
415
395
866
465
401
Services
211
176
34
284
254
30
Automotive
332
183
149
138
98
40
Utilities
677
301
376
510
255
255
General Industries
127
70
58
145
74
71
Retail
149
21
128
282
104
178
Chemicals, Health &
Pharmaceuticals
668
136
532
571
559
11
Builders & Contractors
122
118
5
133
72
61
Other
729
561
168
712
287
425
Total
5,934
3,191
2,743
6,063
3,919
2,144
Net decrease in WB is driven by the performing forborne exposures -\u20ac728 million. Non-performing forborne
assets increased by \u20ac599 million, mainly in Chemicals, Health & Pharmaceuticals and in Real Estate in line
with earlier mentioned NPL increases.
WB's forborne assets are mainly concentrated in real estate; food, beverages & personal care; natural
resources; chemicals, health & pharmaceuticals; and utilities. These five sectors accounted for 68.3% of the
total WB forborne outstandings.
Retail Banking (*)
As of 31 December 2024, Retail Banking forborne assets amounted to \u20ac6.9 billion (2023: \u20ac7.0 billion), which
represented 1.3% (2023: 1.4%) of the total RB portfolio. 26.7% f the forborne exposures were in Private
Individuals.\u00a0
Retail Banking: Forborne portfolio by geographical area (*)
in \u20ac million
2024
2023
Region
Outstandings
Of which:
performing
Of which: non-
Outstandings
Of which:
performing
Of which: non-
performing
performing
Europe
Netherlands
1,548
1,134
414
1,483
981
502
Belgium
1,942
800
1,142
2,153
838
1,315
Germany
1,379
1,052
327
1,309
1,064
246
Poland
777
403
374
852
522
330
T\u00fcrkiye
13
9
4
25
15
10
Italy
122
43
79
123
51
71
Romania
173
72
101
135
49
86
Spain
159
127
31
138
118
21
Rest of Europe
102
50
52
88
58
30
America
22
17
6
21
20
Asia
1
1
2
1
1
Australia
646
279
367
697
411
286
Africa
Total
6,883
3,987
2,897
7,026
4,128
2,898
The main concentration of forborne assets in a single country was in Belgium with 28.2% (2023: 30.6%) of
total Retail Banking forborne assets and 39.4% (2023: 45.4%) of the non-performing forborne assets,
followed by the Netherlands with 22.5% (2023: 21.1%) and Germany having 20.0% (2023: 18.6%) of the total
Retail forborne assets.
Non-performing loans (*)
ING has aligned the regulatory concept of non-performing with that of the definition of default. Hence,
borrowers are classified as non-performing when a default trigger occurs:
\u2022 ING believes the borrower is unlikely to pay. The borrower has evidenced significant financial difficulty, to
the extent that it will have a negative impact on the future cash flows of the financial asset. The following
events could be seen as indicators of financial difficulty:
\u2022 The borrower (or third party) has started insolvency proceedings;
\u2022 A group company/co-borrower has NPL status;
\u2022 Indication of fraud (affecting the company\u2019s ability to service its debt);
\u2022 There is doubt as to the borrower\u2019s ability to generate stable and sufficient cash flows to service its
debt; and
\u2022 Restructuring of debt.
\u2022 ING 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.
\u2022 The obligor has failed in the payment of principal, interest or fees; the total past due amount is above the
materiality threshold and this remains the case for more than 90 consecutive days.
Further, WB has an individual name approach, using early warning indicators to signal possible future issues
in debt service.
The table below represents the breakdown of credit risk outstandings that have been classified as non-
performing by sector and business line.
Non-performing Loans: outstandings by economic sector and business lines (*)1
in EUR million
Wholesale Banking
Retail Banking
Total
Industry
2024
2023
2024
2023
2024
2023
Private Individuals
4
4
4,766
4,416
4,769
4,419
Natural Resources
965
669
99
85
1,064
754
Food, Beverages & Personal
Care
452
565
357
520
809
1,085
Transportation & Logistics
347
437
157
134
504
572
Services
102
101
394
481
495
582
Real Estate
831
592
603
462
1,434
1,053
General Industries
236
111
451
385
687
497
Builders & Contractors
51
124
445
453
496
577
Retail
157
207
224
188
381
395
Utilities
582
331
19
18
600
348
Chemicals, Health &
Pharmaceuticals
654
101
185
132
839
233
Telecom
151
378
12
12
163
390
Other
666
412
387
336
1,052
748
Total
5,196
4,034
8,099
7,619
13,295
11,653
1 Based on lending and investment outstandings.
Non-performing Loans: outstandings by economic sectors and geographical area (*)
in EUR million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United Kingdom
France
Luxembourg
Rest of Europe
America
Asia
Australia
Africa
2024
Private Individuals
646
1,461
1,066
210
304
10
8
44
545
2
2
469
4,769
Natural Resources
13
54
33
569
31
343
21
1,064
Food, Beverages & Personal Care
196
154
1
93
23
5
158
51
127
809
Transportation & Logistics
93
40
3
124
47
1
136
1
59
504
Services
57
293
5
87
2
1
3
5
10
34
495
Real Estate
12
374
63
114
59
59
90
6
606
52
1,434
General Industries
153
123
24
147
20
2
1
170
17
30
687
Builders & Contractors
68
175
5
162
7
78
496
Retail
53
97
39
62
3
14
97
15
1
381
Utilities
13
8
25
21
285
12
128
109
600
Chemicals, Health & Pharmaceuticals
37
94
84
340
1
110
113
36
24
839
Telecom
7
1
3
44
14
90
4
163
Other
202
198
117
60
2
72
17
90
54
92
150
1,052
Total
1,549
3,071
1,432
1,457
432
322
307
166
1,916
1,145
723
567
210
13,295
Non-performing Loans: outstandings by economic sectors and geographical area (*)
in EUR million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United Kingdom
France
Luxembourg
Rest of Europe
America
Asia
Australia
Africa
2023
Private Individuals
609
1,535
885
225
235
3
8
45
489
2
2
380
1
4,419
Natural Resources
30
60
1
23
55
164
31
369
20
754
Food, Beverages & Personal Care
281
157
1
131
139
7
158
82
128
1,085
Transportation & Logistics
110
50
2
51
47
20
1
168
49
1
2
72
572
Services
121
342
2
55
2
3
8
13
37
582
Real Estate
40
297
53
55
9
36
16
7
519
21
1,053
General Industries
145
127
49
99
2
7
24
42
496
Builders & Contractors
113
181
2
135
22
91
32
577
Retail
51
82
36
52
2
14
149
7
395
Utilities
14
5
21
18
153
138
348
Chemicals, Health & Pharmaceuticals
31
77
13
25
64
11
12
233
Telecom
12
1
28
3
13
56
277
390
Other
28
239
42
55
2
1
6
23
46
128
179
748
Total
1,586
3,153
1,114
929
293
165
124
162
1,193
1,210
1,050
403
272
11,653
In 2024, the NPL portfolio increased to \u20ac13.3 billion. n increase in Wholesale Banking (+\u20ac1.2 billion) together
with an increase in Retail Banking (+\u20ac0.5 billion). The increase in Wholesale Banking was mainly witnessed in
real estate; chemicals, health & pharmaceuticals; and in natural resources, partially offset by telecom. In
Retail Banking, the increase was concentrated in Private Individuals. The top three countries by NPL
outstanding are Belgium, the Netherlands and Poland.
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,
financial- and non-financial guarantees issued.
ING distinguishes between two types of calculation methods for credit loss allowances:
\u2022 Collective 12-month ECL (Stage 1) and collective lifetime ECL (Stage 2) for portfolios of financial
instruments, as well as collective lifetime ECL for credit-impaired exposures (Stage 3) below \u20ac1 million;
\u2022 Individual 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: (i) to the economic outlook and (ii) for Stage 2 and Stage 3 assets only, to the lifetime horizon.
The IFRS 9 model parameters are estimated based on statistical techniques and supported by expert
judgement.
ING has aligned the definition of default for regulatory purposes with the definition of \u2018credit-impaired\u2019
financial assets under IFRS 9 (Stage 3). ING has also aligned its definition of default between IFRS 9 and the
regulatory technical standards (RTS) and EBA guidelines. More information can be found in section 1.5.6 of
the consolidated financial statements.
Climate and environmental risks in IFRS 9 models (*)
Climate risk drivers (physical and transition risks) can reduce the ability of businesses and households to fulfil
their obligations due on existing lending contracts. These may also lead to the depreciation/erosion of
collateral values, which would translate into higher credit losses and loan-to-value ratios in the lending
portfolio of ING.
Currently, it is not yet possible to fully incorporate climate risk separately into IFRS 9 ECL models given the
lack of sufficient empirical historical data and data limitations in the risk assessments on client level.
However, ING has taken next steps in 2024 to more explicitly cover for climate-risk drivers in loan loss
provisioning. A management adjustment to ECL models for business clients was introduced to specifically
cover for the medium- to long-term transition risk on high greenhouse gas-emitting sectors. For households,
particularly the mortgage book, next step in the development will be to apply differentiation in collateral
valuation based on EPC labels.
Additionally, where climate and environmental factors have impacted the economy in the recent past or
present, these impacts are implicitly embedded in ING\u2019s IFRS 9 ECL models through the projected
macroeconomic indicators (e.g. indirectly via GDP growth and unemployment rates). We note, however, 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 specific climate-related matters, particularly physical risk events that have
already occurred (e.g. floods, stranded assets etc.), the impact of such events is individually assessed in the
calculation of Stage 3 individual provisions, collective SICR or management adjustments to ECL models. For
example, we consider whether affected assets have suffered from a significant increase in credit risk (or are
credit impaired) and whether the ECL is appropriate. Furthermore as at 31 December 2024 we have reported
a management adjustment for the increased expected credit risk in the Mortgage and Consumer Lending
portfolio in Spain due to payment holidays provided for customers with collateral or activities in the Valencia
area impacted by the severe floods in the fourth quarter of 2024. For more, see \u2018Management adjustments
applied this reporting period\u2019.
Going forward, ING aims to continue to improve on climate risk data, which will enable us to further embed
climate risks into the IFRS 9 ECL models. For further details on ESG risk management, see \u2018ESG risk\u2019
Portfolio quality (*)
The table below describes the portfolio composition over the different IFRS 9 stages and rating classes. The
Stage 1 portfolio represents 91.1% (2023: 91.5%) of the total gross carrying amounts, mainly composed of
investment grade, while Stage 2 makes up 7.6% (2023: 7.3%) and Stage 3 makes up 1.3% (2023: 1.2%) of the
total gross carrying amounts, respectively.
Gross carrying amount per IFRS 9 stage and rating class (*)1,2, 3
in EUR million
12-month ECL\u00a0 (Stage 1)
Lifetime ECL not credit impaired (Stage 2)
Lifetime ECL credit impaired (Stage 3)
Total
Rating class
Gross carrying amount
Provisions
Gross carrying amount
Provisions
Gross carrying amount
Provisions
Gross carrying amount
Provisions
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
Investment grade
1 (AAA)
79,076
87,122
1
1
281
439
79,357
87,561
1
1
2-4 (AA)
140,671
132,159
10
8
1,579
2,553
1
2
142,250
134,711
11
9
5-7 (A)
244,306
231,018
22
24
6,908
6,188
8
6
251,214
237,206
29
30
8-10 (BBB)
310,114
302,967
55
85
24,683
17,004
55
24
334,797
319,971
110
108
Non-Investment grade
11-13 (BB)
154,348
157,387
190
226
18,479
19,273
91
93
172,827
176,661
281
319
14-16 (B)
25,377
26,414
124
164
17,433
19,336
366
455
42,811
45,750
490
618
17 (CCC)
905
617
8
10
3,992
3,928
173
233
4,897
4,545
181
242
Performing
Restructuring
18 (CC)
4,059
4,617
233
402
4,060
4,617
233
402
19 (C)
2,474
1,919
203
221
2,474
1,919
203
221
Non-performing loans
20-22 (D)
13,742
11,956
4,509
3,887
13,742
11,956
4,509
3,887
Total
954,798
937,684
409
517
79,888
75,257
1,130
1,435
13,742
11,956
4,509
3,887
1,048,429
1,024,897
6,049
5,839
1 Compared to the credit risk portfolio, the differences are mainly undrawn committed amounts (\u20ac155 billion; 2023: \u20ac151 billion) and other positions (\u20ac6 billion; 2023: \u20ac9 billion) not included in credit outstandings and non-IFRS 9 eligible assets (\u20ac75 billion; 2023: \u20ac67 billion), mainly
pre-settlement exposures) included in credit outstandings but not in the gross carrying amounts.
2 Stage 3 lifetime credit impaired provision includes \u20ac21 million (2023: \u20ac11 million) on purchased or originated credit impaired.
Changes in gross carrying amounts and loan loss provisions (*)
The table below provides a reconciliation by stage of the gross carrying amount and allowances for loans
and advances to banks and customers, including loan commitments and financial guarantees. The transfers
of financial instruments represent the impact of stage transfers upon the gross carrying/nominal amount
and associated allowance for ECL. This includes the net-remeasurement of ECL arising from stage transfers,
for example, moving from a 12-month (Stage 1) to a lifetime (Stage 2) ECL measurement basis.
The net-remeasurement line represents the changes in provisions for facilities that remain in the same
stage.
Please note the following comments with respect to the movements observed in the table below:
\u2022 Stage 3 gross carrying amount increased by \u20ac1.7 billion from \u20ac12.0 billion as at 31 December 2023 to
\u20ac13.7 billion as at 31 December 2024, mainly as a result of \u20ac4.8 billion net inflow into NPL (credit
impaired) in 2024 which is offset by \u20ac1.8 billion derecognitions and repayments and \u20ac1.3 billion write-offs
and disposals. Following the increase in carrying amount, Stage 3 provisions increased by \u20ac0.6 billion.
\u2022 Stage 2 gross carrying amounts increased by \u20ac4.6 billion from \u20ac75.3 billion as at 31 December 2023 to
\u20ac79.9 billion as at 31 December 2024, largely driven by \u20ac23.7 billion net transfers from Stage 1 into Stage
2, including the impact of changes in risk drivers (including updated macro-economic forecasts), model
redevelopments mainly for Wholesale Banking models and new Stage 2 overlays. This was offset by a
decrease of exposure by \u20ac16.2 billion due to derecognised financial assets (including sales), repayments
and \u20ac2.9 billion exposure moving to Stage 3. Stage 2 provisions decreased by \u20ac0.3 billion to \u20ac1.1 billion as
of 31 December 2024.
Changes in gross carrying amounts and loan loss provisions (*)1, 2
in EUR million
12-month ECL\u00a0 (Stage
1)
Lifetime ECL not
credit impaired
(Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
12-month ECL\u00a0
(Stage 1)
Lifetime ECL not
credit impaired
(Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
2024
2023
Opening balance
937,684
517
75,258
1,435
11,956
3,887
1,024,897
5,839
884,886
580
70,725
1,679
11,708
3,841
967,319
6,100
Impact of changes in accounting policies
37,079
9
4,704
13
158
73
41,941
95
Adjusted opening balance
921,965
589
75,429
1,692
11,866
3,914
1,009,260
6,195
Transfer into 12-month ECL (Stage 1)
20,276
22
-20,026
-195
-249
-34
-207
11,832
28
-11,583
-239
-249
-36
0
-247
Transfer into lifetime ECL not credit impaired (Stage 2)
-43,155
-49
43,900
429
-745
-96
285
-29,134
-67
29,849
449
-716
-105
0
276
Transfer into lifetime ECL credit impaired (Stage 3)
-2,980
-18
-2,856
-235
5,836
1,802
1,548
-2,053
-10
-1,775
-114
3,828
978
0
853
Net remeasurement of loan loss provisions
-180
-137
185
-133
0
-149
0
-94
0
59
0
-183
New financial assets originated or purchased
212,529
192
212,529
192
195,826
204
0
0
0
0
195,826
204
Financial assets that have been derecognised
-126,858
-76
-11,840
-153
-1,450
-257
-140,148
-485
-121,991
-72
-14,239
-215
-1,475
-266
-137,705
-552
Net drawdowns and repayments
-41,763
-4,406
-309
-46,478
-38,758
0
-2,386
0
-229
0
-41,372
0
Changes in models/risk parameters
8
-6
-22
-20
0
7
0
11
0
84
0
102
Increase in loan loss provisions
-101
-297
1,578
1,179
-58
-203
714
452
Write-offs3
-1,017
-1,017
-1,017
-1,017
-3
-3
-787
-787
-790
-790
Disposals3
-935
-1
-141
-8
-279
-215
-1,355
-225
-38
-38
-283
-283
-321
-321
Recoveries of amounts previously written off
69
69
0
0
0
0
0
71
0
71
Foreign exchange and other movements
-5
208
203
0
-12
0
-15
0
257
0
231
Closing balance
954,798
409
79,888
1,130
13,742
4,509
1,048,429
6,048
937,684
517
75,258
1,435
11,956
3,887
1,024,897
5,839
1 Stage 3 lifetime credit impaired provision includes \u20ac21 million (2023: \u20ac11 million) on purchased or originated credit impaired.
2 The addition to the loan provision (in the consolidated statement of profit or loss) amounts to \u20ac1,194 million (2023: \u20ac520 million) of which \u20ac1,170 million (2023: \u20ac483 million)related to IFRS 9 eligible financial assets, \u20ac9 million (2023: \u20ac-31 million) related to non-credit
replacement guarantees and \u20ac15 million(2023: \u20ac67 million) to modification gains and losses on restructured financial assets.
3 Table was updated for presentation purposes to disaggregate utilisation of the provision between write-offs and disposals. Comparatives have been updated accordingly.
Modification of financial assets (*)
The table below provides the following information:
\u2022 Financial assets that were modified during the year (i.e. qualified as forborne) while they had a loss
allowance measured at an amount equal to lifetime ECL.
\u2022 Financial assets that were reclassified to Stage 1 during the period.
Financial assets modified (*)
in EUR million
2024
2023
Financial assets modified during the period
Amortised cost before modification
1,888
1,565
Net modification results
-107
-75
Financial assets modified since initial recognition
Gross carrying amount at 31 December of financial assets for which loss allowance has changed
to 12-month measurement during the period
1,506
2,599
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). Input
from a leading third-party service provider is used to complement the consensus with consistent projections
for variables for which there are no consensus estimates available (most notably house prices and \u2013 for
some countries \u2013 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, risk and modelling, while the second panel
consists of relevant senior managers in ING.
Alternative scenarios and probability weights (*)
Two alternative scenarios are taken into account: an upside and a downside scenario. The alternative
scenarios have statistical characteristics as they are based on the forecast deviations of the leading third-
party service provider.
To understand the baseline level of uncertainty around any forecast, the leading third-party service provider
keeps track of all its deviations (so-called forecast errors) of the past 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, the leading third-party service provider runs a survey with respondents from around the
world and across a broad range of industries. In this survey, respondents put forward their views of key risks.
Following the survey results, the distribution of forecast errors (that is being used for determining the
scenarios) may be skewed.
For the downside scenario, ING has chosen the 90th percentile of that distribution because this corresponds
with the way risk management earnings-at-risk is defined within the Group. The upside scenario is
represented by the 10th percentile of the distribution. The applicable percentiles of the distribution imply a
20 percent probability for each alternative scenario. Consequently, the baseline scenario has a 60 percent
probability weighting. Please note that, given their technical nature, the downside and upside scenarios are
not based on an explicit specific narrative.
Macroeconomic scenarios applied (*)
The macroeconomic scenarios applied in the calculation of loan loss provisions are based on the consensus
forecasts.
Baseline assumptions (*)
The general picture that the consensus conveys is that global economic growth is diverging between major
blocs. US growth is expected to continue to outpace European markets, while China is expected to continue
on a declining growth trend, but still at higher rates than seen in advanced markets. Inflation is expected to
remain near target for most advanced economies, although it is set to remain above target for the United
States. With interest rates moderating, although some uncertainty about this path for the US exists at this
point, monetary conditions should turn more favourable for growth. For the housing market, continued price
growth is expected for almost all main markets.
The December 2024 consensus expects global output (as measured by the weighted average GDP growth
rate of ING\u2019s 25 main markets) to slow from 2.5 percent in 2024 to 2.4 percent in 2025. For 2026-2027,
economic growth is expected to come in at 2.4 percent and 2.3 percent respectively.\u00a0
The American economy continues to perform very well despite signs of a slowing labour market around the
summer of 2024. Inflation has come down to more benign levels, which has prompted the Federal Reserve to
lower interest rates. Still, inflation remains above the 2% target and the outlook for inflation has become
more uncertain. The US administration\u2019s economic plans are set to stimulate the economy for 2025, as
reflected in the increased expectations for 2025 GDP of consensus forecasters. The consensus expects the
growth rate of the US economy to slow from 2.7 percent in 2024 to 2.0 percent for both 2025 and 2026.The
eurozone economy has seen some growth return in 2024 after a long period of stagnation that started
during the energy crisis. Still, expectations for 2025 remain modest. The export environment continues to be
plagued by weak global demand and investments are stymied by high interest rates and weak
manufacturing performance. Expectations of a pickup in growth over the course of the year hang on
domestic drivers like a pickup in real wage growth and continued rate cuts from the ECB at the start of the
year. Consensus expects the eurozone to have grown by only 0.8 percent in 2024, before recovering slightly
to 1.0 percent and 1.2 percent in 2025 and 2026 respectively.Elsewhere in Europe, the outlook is more
upbeat. In Poland, domestic demand appears to remain the key growth driver over the near-term forecast.
Foremost, consumers remain willing to spend, encouraged by elevated wage growth and a resilient labour
market. The economy is expected to grow by 2.7 percent in 2024, picking up to 3.5 percent in 2025 and 3.8
percent in 2026. The consensus expectation for T\u00fcrkiye is to see growth slow, which is being confirmed by
weak incoming data. Consensus expects growth to slow from 3.1 percent in 2024 to 2.6 percent in 2025, in
part due to soft demand from export orders. For 2026, a recovery to 3.5 percent is expected. The Russian
economy is expected to slow substantially in 2025 after a strong 2024. Growth is expected to drop from 3.7
percent in 2024 to 1.6 percent in 2025 and 1.3 percent in 2026.
For China, economic underperformance continues as it still struggles with the impact of the real estate
correction and weak domestic demand. Large scale stimulus plans and a possible bottoming out of the real
estate market do help economic forecasts for the short-run, although medium term consensus continues to
be downbeat for the moment. For 2024, consensus expects 4.8 percent growth, down to 4.4 percent in 2025
and 4.1 percent in 2026.
Economic momentum in Australia is expected to be soft. The economy is lacking a clear growth engine, with
the private sector clearly struggling against restrictive policy settings and consumers facing a tough outlook.
Growth is expected to have come in at 1.2 percent in 2024, with just moderate pick-up expected for 2025 to
2.0 percent and 2.4 percent for 2026.
When compared to the June 2024 consensus forecast, the December 2024 forecast is relatively stable.
Global GDP is expected to increase by 2.5 percent in 2024 (compared to 2.4 percent assumed before) and is
expected to grow by 2.4 percent in 2025 (2.3 percent assumed before). With the energy crisis and pandemic
now further behind us, the consensus for economic activity in major markets is showing smaller deviations
over time despite economic and geopolitical uncertainty still being very prevalent.
Alternative scenarios and risks (*)
The baseline scenario assumes continued steady economic growth. However, a longer period of weakness,
due to even more concerning geopolitical tensions, persistent elevated inflation and trade tensions 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 downside scenario \u2013 though technical in nature \u2013 sees a recession in 2025 and 2026 for most countries.
Unemployment increases strongly in this scenario and house prices in most countries show outright falls.
The downside scenario captures the possible impact from escalating geopolitical tensions, increased trade
tensions and persistent elevated inflation.
The upside scenario \u2013 while equally technical in nature \u2013 reflects the possibility of a better economic out-turn
because of a substantial loosening of monetary policy, and policy stimulus in China.
Management adjustments applied this reporting period (*)
In times of volatility and uncertainty where portfolio quality and the economic environment are changing
rapidly, models alone may not be able to accurately predict losses. In these cases, management
adjustments can be applied to appropriately reflect ECL. Management adjustments can also be applied
where the impact of the updated macroeconomic scenarios is over- or under-estimated by the IFRS 9
models, as well as to reflect the impact of model redevelopment or recalibration and periodic model
assessment procedures that have not been incorporated in the IFRS 9 models yet.
ING has internal governance frameworks and controls in place to assess the appropriateness of all
management adjustments.
Management adjustments to ECL models (*)
in EUR million
2024
2023
Commercial Real Estate/ Inflation and interest rate increases
50
351
Economic sector / portfolio based adjustments
38
36
Mortgage portfolio adjustments
112
126
Climate transition risk
29
Other Post Model Adjustments
-27
64
Total management adjustments
203
577
As the ING credit risk models generally assume that inflation and interest rate increase risks materialise via
other risk drivers, such as GDP and unemployment rates with a delay, an overlay approach was determined
in previous financial years to timely estimate the expected credit losses (ECL) related to reduced repayment
capacity and affordability for private individuals and business clients in the Retail Banking segment.
As inflationary stress has decreased since origination of the overlay approach and the limited observed
impact in both the Retail and the Wholesale Banking segment, no management adjustment is reported as at
31 December 2024, with exception of a management adjustment of \u20ac50 million for the Commercial Real
Estate portfolio (31 December 2023: \u20ac351 million in total). The \u20ac50 million management adjustment related
to the Commercial Real Estate portfolio is reported in Wholesale Banking (\u20ac33.5 million) and in Business
Banking in the Netherlands (\u20ac16.5 million) because the prevailing risks from increased levels of interest rates
and inflation still exist for this sector in these portfolios. This management adjustment is reflected in Stage 1
and Stage 2.Furthermore, in specific parts in the Retail Banking segment, that were previously included in the
inflation and interest rate increases overlay and where increased risked not yet captured in the credit risk
models are still observed, specific portfolio-based adjustments have been recognised.
As at 31 December 2024, the economic sector / portfolio based adjustments in Stage 2 of \u20ac38 million in total
included a management adjustment of \u20ac14 million for the increased expected credit risk in the Mortgage
and Consumer Lending portfolio in Spain due to payment holidays provided for customers with collateral or
activities in the areas impacted by the severe floods in the Valencia area in the fourth quarter of 2024.
Furthermore, adjustments have been taken in the Business Banking portfolio in Germany (\u20ac10 million) to
cover for the increased uncertainty in the German economy and to the Mortgage portfolio in Australia (\u20ac15
million) to cover for affordability risk from inflation and interest rate increases.
The economic sector adjustments as at 31 December 2023 of \u20ac36 million, fully related to Business Banking
clients that have benefited from government support programs in the Netherlands during the Covid-19
pandemic. This adjustment was released in full in 2024 as the risk was considered to be no longer present in
the portfolio. The overall mortgage portfolio adjustment as at 31 December 2024 decreased to \u20ac112 million
(31 December 2023: \u20ac126 million). The management adjustment in Stage 2 for the risk segmentation model
that captures affordability, repayment and refinancing risk on performing mortgage customers with a bullet
loan in the Netherlands was decreased to \u20ac112 million (31 December 2023: \u20ac115 million). The mortgage
portfolio adjustment that related to the overvaluation of house prices was released in full in 2024 (31
December 2023: \u20ac11 million).
As of 31 December 2024, an adjustment of \u20ac29 million was introduced to cover for the impact of climate
transition risk in Wholesale Banking (\u20ac17 million) and in Business Banking (\u20ac12 million). Climate transition risk
is expected to lead to a structural change in credit risk, which means specific business activities will become
structurally riskier due to environmental policies, technological progress or changes in market sentiment and
preferences. The current IFRS 9 models do not capture this (novel) risk. The management adjustment to ECL
models for business clients was made to specifically cover for the medium- to long-term transition risk on
high greenhouse gas-emitting sectors and is reported in Stage 2.
Other post-model adjustments mainly relate to the impact of model redevelopment or recalibration and
periodic model assessment procedures that have not been incorporated in the ECL models yet. The impact
on total ECL can be positive or negative. These result from both regular model maintenance and ING\u2019s
multiyear programme to update ECL models. These adjustments will be removed once updates to the
specific models have been implemented. The change in balance compared to previous reporting date is due
to i) released PMAs because of model updates that have been implemented and ii) new PMAs recognised for
new redevelopments and recalibrations.
Analysis on sensitivity (*)
The table below presents the analysis on the sensitivity of key forward-looking macroeconomic inputs used
in the ECL collective-assessment modelling process and the probability weights applied to each of the three
scenarios. The countries included in the analysis are the most significant geographic regions in ING, and for
Wholesale Banking the US is the most significant in terms of both gross contribution to reportable ECL and
sensitivity of ECL to forward-looking macroeconomics. Accordingly, ING considers these portfolios to present
the most significant risk of resulting in a material adjustment to the carrying amount of financial assets
within the next financial year. 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 2024\u00a0 (*)
2025
2026
2027
Un-weighted
ECL (\u20ac mln)
Probability-
weighting
Reportable
ECL (\u20ac mln)1
Netherlands
Upside scenario
Real GDP
2.6
3.0
2.5
193
20%
270
Unemployment
3.5
3.3
3.3
HPI
18.9
11.7
2.5
Baseline scenario
Real GDP
1.5
1.4
1.5
249
60%
Unemployment
4.0
4.1
4.3
HPI
9.1
3.5
2.4
Downside scenario
Real GDP
-0.4
-1.4
-0.2
411
20%
Unemployment
5.7
7.2
8.1
HPI
-3.7
-7.2
2.2
Germany
Upside scenario
Real GDP
2.0
2.8
1.6
510
20%
548
Unemployment
2.9
2.4
2.0
HPI
5.4
8.9
9.9
Baseline scenario
Real GDP
0.5
1.1
1.2
540
60%
Unemployment
3.4
3.3
3.2
HPI
2.6
5.6
6.3
Downside scenario
Real GDP
-1.7
-1.7
0.3
609
20%
Unemployment
4.7
5.6
5.9
HPI
-1.7
1.3
2.2
Belgium
Upside scenario
Real GDP
2.2
2.6
2.1
534
20%
579
Unemployment
5.1
5.0
4.9
HPI
4.8
4.5
4.4
Baseline scenario
Real GDP
1.1
1.5
1.6
569
60%
Unemployment
5.7
5.7
5.6
HPI
3.2
4.1
3.8
Downside scenario
Real GDP
-0.6
-0.2
1.1
654
20%
Unemployment
7.0
8.0
8.0
HPI
1.2
2.9
2.5
United States
Upside scenario
Real GDP
3.1
3.5
3.2
74
20%
113
Unemployment
3.4
2.4
2.3
HPI
4.3
8.4
9.4
Baseline scenario
Real GDP
2.0
2.0
2.0
101
60%
Unemployment
4.2
4.1
4.0
HPI
3.3
3.7
3.9
Downside scenario
Real GDP
-0.1
-1.1
-0.4
187
20%
Unemployment
5.9
7.3
8.0
HPI
-0.7
-3.0
-2.5
1 Excluding management adjustments.
Sensitivity analysis as at December 2023 (*)
2024
2025
2026
Un-weighted
ECL (\u20ac mln)
Probability-
weighting
Reportable
ECL (\u20ac mln)1
Netherlands
Upside scenario
Real GDP
1.3
3.3
2.8
214
20%
310
Unemployment
3.7
3.3
3.3
HPI
10.4
11.2
4.0
Baseline scenario
Real GDP
0.8
1.6
1.5
282
60%
Unemployment
4.1
4.3
4.5
HPI
0.9
3.0
3.9
Downside scenario
Real GDP
-1.7
-1.2
0.1
487
20%
Unemployment
5.9
7.2
8.1
HPI
-10.9
-7.4
3.7
Germany
Upside scenario
Real GDP
1.4
3.1
1.6
472
20%
525
Unemployment
2.6
2.0
1.7
HPI
0.9
6.6
8.0
Baseline scenario
Real GDP
0.5
1.3
1.2
513
60%
Unemployment
3.0
3.0
3.0
HPI
-1.4
3.4
4.5
Downside scenario
Real GDP
-2.4
-1.4
0.3
615
20%
Unemployment
4.5
5.2
5.5
HPI
-6.0
-0.8
0.4
Belgium
Upside scenario
Real GDP
1.5
2.7
2.3
568
20%
619
Unemployment
5.3
5.0
4.9
HPI
1.3
5.6
4.5
Baseline scenario
Real GDP
0.9
1.5
1.8
604
60%
Unemployment
5.6
5.5
5.4
HPI
0.4
5.2
3.9
Downside scenario
Real GDP
-1.3
-0.2
1.2
713
20%
Unemployment
7.3
8.0
7.9
HPI
-2.2
3.9
2.6
United States
Upside scenario
Real GDP
1.8
3.2
3.4
102
20%
165
Unemployment
4.1
3.3
3.1
HPI
0.6
8.7
8.7
Baseline scenario
Real GDP
0.9
1.9
2.1
144
60%
Unemployment
4.5
4.5
4.4
HPI
-0.7
3.5
3.3
Downside scenario
Real GDP
-1.3
-1.4
-0.1
292
20%
Unemployment
6.6
8.2
8.8
HPI
-4.2
-2.7
-3.0
1 Excluding management adjustments.
When compared to the sensitivity analysis of 2023, the macroeconomic inputs are overall more favourable.
This is driven by an improved macroeconomic outlook, mainly because economies prove to be rather
resilient to increased interest rates, particularly in the US, as well as recovery in house prices in, among
others, the Netherlands.
On a total ING level, the unweighted ECL for all collective provisioned clients in the upside scenario was
\u20ac2,721 million, in the baseline scenario \u20ac2,949 million and in the downside scenario \u20ac3,533 million compared
to \u20ac3,020 million reportable collective provisions as at 31 December 2024 (excluding all management
adjustments). To perform the sensitivity analysis, a point in time reportable ECL is used as input, which
slightly deviates from the total Model ECL as reported below:
Reconciliation of reportable collective ECL to total ECL (*)
in EUR million
2024
2023
Total reportable collective provisions
2,975
2,856
ECL from individually assessed impairments
2,871
2,406
ECL from management adjustments
203
577
Total ECL
6,049
5,839
Criteria for identifying a significant increase in credit risk (SICR) (*)
All assets and off-balance-sheet items that are in scope of IFRS 9 impairment and which are subject to
collective ECL assessment are allocated a 12-month ECL if deemed to belong in Stage 1, or a lifetime ECL if
deemed to belong in Stages 2 or 3. An asset belongs in Stage 2 if it is considered to have experienced a
significant increase in credit risk (SICR) since initial origination or purchase.
The main determinant of SICR is a quantitative test, whereby the lifetime 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 either a threshold for absolute change in lifetime PD or a threshold for relative change in lifetime PD is
reached, the item is considered to have experienced a SICR (for more details on absolute and relative
thresholds, see the following sections). Furthermore, any facility which shows an increase of 200 percent
between the PD at the date of initial recognition and the lifetime PD at the reporting date (i.e. threefold
increase in PD) must be classified as Stage 2. This is considered a backstop within the quantitative
assessment of SICR.
In Wholesale Banking, significant increase in lifetime PD is not considered plausible for assets of obligors with
a credit rating at the reporting date in the top range of investment grade. As of 2024, the assets of these
Wholesale Banking obligors are excluded from the assessment of significant increase in credit risk triggers.
For these obligors the qualitative significant increases in credit risk triggers remain applicable (see the
section below on Qualitative SICR triggers). These are for example the Watchlist and/ or forbearance triggers.
Finally, the 30 days past due backstop also remains applicable for the top range of investment grade
exposures to ensure significant increase in credit risk recognition.
Absolute lifetime PD threshold
The absolute threshold is a fixed value calibrated per portfolio/segment and provides a fixed threshold that, if
exceeded by the difference between lifetime PD at reporting date and lifetime PD at origination, triggers
Stage 2 classification. The absolute threshold is calibrated during model development.
Relative lifetime PD threshold
The relative threshold defines a relative increase of the lifetime PD beyond which a given facility is classified
in Stage 2 because of a significant increase in credit risk. The relative threshold is dependent on the individual
PD assigned to each facility at the moment of origination, and a scaling factor calibrated in the model
development phase.
Ultimately, the relative threshold provides a criterion to assess whether the ratio (i.e. increase) between
lifetime PD at reporting date and lifetime PD at origination date is deemed a significant increase in credit risk.
If the threshold is breached, SICR is identified and Stage 2 is assigned to the given facility.
The threshold for the relative change in lifetime PD is inversely correlated with the PD at origination; the
higher the PD at origination, the lower the threshold. The logic behind this is to allow facilities originated in
very favourable ratings to downgrade for longer without the need of a Stage 2 classification. In fact, it is
likely that such facilities will still be in favourable ratings even after a downgrade of a few notches. On the
contrary, facilities originated in already unfavourable ratings grades are riskier and even a single-notch
downgrade might represent a significant increase in credit risk and thus a tighter threshold will be in place.
Still, the relative threshold is relatively sensitive for investment-grade assets while the absolute threshold
primarily affects non-investment grade assets.
Average threshold ratio
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 2023 and year-end 2024.
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 (*)
2024
2023
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
2.9
2.4
2.5
2.3
Consumer lending
2.8
2.1
2.9
2.1
Business lending
2.7
2.1
2.7
2.1
Governments and financial institutions
2.9
1.9
3.0
1.9
Other Wholesale Banking
2.7
1.9
2.8
1.8
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.
Sensitivity of ECL to PD lifetime PD thresholds
The setting of PD threshold bands requires management judgement and is a key source of estimation
uncertainty. On Group level, the total model ECL on performing assets, which is the ECL collective-
assessment without taking management adjustments into account, was \u20ac1,328 million as at 31 December
2024 (31 December 2023: \u20ac1,412 million). To demonstrate the sensitivity of the ECL to these PD threshold
bands, hypothetically solely applying the upside scenario would result in total model ECL on performing
assets of \u20ac1,066 million and a decrease in the Stage 2 ratio by 0.5%-point, while solely applying the
downside scenario would result in total model ECL on performing assets of \u20ac1,911 million and an increase in
the Stage 2 ratio by 1.9%-point.
Qualitative SICR thresholds
It should be noted that the lifetime PD thresholds are not the only drivers of stage allocation as ING Bank
also relies on a number of qualitative indicators to identify and assess SICR. An asset can also change stages
as a result of other triggers, such as having over 30 days arrears (used as a backstop), collective SICR
assessment, being on a watch list, being under intensive care management, having a substandard internal
rating or being forborne.
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. Policies and processes are in place to
monitor the inclusion of positions in either the trading or banking book as well as to monitor the transfer of
risk between the trading and banking books.
The following sections elaborate on the various elements of the risk management framework for:
\u2022 Market risk in banking books;
\u2022 Market risk in trading books; and
\u2022 Market risk capital.
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 they are 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.
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:
\u2022 Investment of own funds.
\u2022 Commercial business.
\u2022 Group Treasury exposures including strategic interest rate positions.
Group Treasury is responsible for managing the investment of own funds (core capital). Capital is invested
for longer periods to contribute to stable earnings within the risk appetite boundaries set by ALCO Bank. 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 due to different re-pricing properties of assets and
liabilities. Also, interest rate risk can arise from customer behaviour and/or convexity risk, depending on the
nature of the underlying product characteristics.
To determine the interest rate risk in particular products (like savings, mortgages) specific assumptions may
need to be made. Customer behaviour risk is defined as the potential future (value) loss due to deviations in
the actual behaviour of clients versus the modelled behaviour with respect to 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 the following main
product types: savings and current accounts (funds entrusted), demand deposits, mortgages and loans.
Savings and demand deposits are generally invested in such a way that both the value is hedged and the
sensitivity of the margin to market interest rates is minimised. This is achieved by creating the investment
profile distributed from short term to long term, which dampens the immediate impact from changes in the
market rates as well as stabilises margin in the longer horizon. Interest rate risk is modelled based on the
stability of deposits and the pass-through rate. This takes account of different elements, such as pricing
strategies, volume developments and the level and shape of the yield curve.
Interest rate risk for mortgages arises due to prepayment or other embedded optionalities. 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 analysis of historical data. However, the substantial change in the interest rate environment in
recent years makes the analysis 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, and are closely monitored on a monthly basis.
Linear risk transfers take place from commercial business books to the treasury book (Group Treasury), if
necessary, by using estimations of customer behaviour. The originating commercial business is ultimately
responsible for estimating this customer behaviour, leaving convexity risk and (unexpected) customer
behaviour risk with the commercial business. Risk measurement and the risk transfer process take place at
least monthly. If deemed necessary, additional risk transfers can take place.
The commercial business manages the convexity risk that is the result of products that contain embedded
options, like mortgages. Here the convexity risk is defined as the optionality effects in the value due to
interest rate changes, excluding the first-order effects. In some cases, convexity risk is transferred from the
commercial books to treasury books using cap/floor contracts and swaptions.
In the following sections, the interest rate risk exposures in the banking books are presented. ING quantifies
risk measures from both earnings and value perspectives. 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 NPV-at-Risk is measured under a direct interest rate shock. Hence no additional,
corrective hedges are included in the measure. The NII-at-Risk measure is measured for interest rate
movements over a period, whereby (assumed) corrective hedges are included in the risk metric.
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 (dynamic plan) are included in this risk metric. NII-at-
Risk provides insight into the sensitivity of ING\u2019s NII under shocked interest rate scenarios against what is
projected in a base case scenario.
In its risk management, ING monitors the NII-at-Risk under a three-year time frame. Interest rates are
shocked during the first year of analysis through the gradual application of shock. The rate changes
considered encompass both upward and downward scenarios, as well as both parallel (equal movements
across the yield curve) and non-parallel scenarios.
The impact of changing interest rates on ING\u2019s NII is predominantly caused by the following factors:
\u2022 Change in returns of (re)investments of client deposits;
\u2022 Change in client deposit rates (mainly savings), (partially) tracking changes in market interest rates;
\u2022 Change in the amortisation profile of mortgages, due to an increase or decrease in expected
prepayments;
\u2022 Higher/lower returns of (re-)investments of capital investment;
\u2022 Open interest rate positions, leading to changes in return because of different market rates; and
\u2022 Assumed volume development of the balance sheet in line with ING\u2019s dynamic plan.
For projecting the change in client deposit rates, ING uses a client rate model that describes the relation
between market interest rates and client deposit rates. The model is calibrated under a range of interest
rate scenarios. Per scenario, the actual change in client deposit rates may deviate from this calibrated
model. The actual NII development of customer deposits may, indeed, differ from the provided scenarios,
depending on, among other things, actual interest rate and savings client rate evolution, as well as changes
to ING\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 table below reflect a parallel, linear interest rate movement during a year
('ramped') under the assumption of balance sheet developments in line with ING\u2019s dynamic plan with a time
horizon of one year. The majority of the risk comes from fixed-rate positions, most notably non-
remunerated current accounts and variable-rate savings accounts .
The NII-at-Risk is mainly influenced by the difference in the sensitivity between client liabilities and client
assets and investments to rate changes. The primary factor of NII-at-Risk are the investments of current
accounts, while the investments of own funds have a marginal effect, as only a relatively small portion
needs to be (re)invested within a one-year period.
NII-at-Risk banking book per currency - year one (*)
in EUR million
2024
2023
Ramped, floored
Ramped, floored
parallel \u25bc
parallel \u25b2
parallel \u25bc
parallel \u25b2
By currency
Euro
-144
158
-165
155
US dollar
-4
5
-12
12
Other
-2
21
-62
69
Total
-151
184
-239
236
EUR ramped (floored at -100bps) is at +/- 120bps in 1 year (2023: +/-110bps)
USD ramped (floored at -100bps) is at +/- 120bps in 1 year (2023: +/-110bps)
The change in NII under declining and upward interest rate scenarios may not be equal. This is due to
different expected reactions in prepayment behaviour of mortgages and different pricing developments of
commercial loans and deposits products (mainly savings). This is caused by embedded options, explicit or
implicit pricing floors and other (assumed) pricing factors.
The metrics mentioned above are internal metrics, which therefore deviate from the regulatory NII SOT
metrics.
Year-on-year variance analysis (*)
In 2024, in response to falling inflation, most central banks (including ECB and FED) began to ease their
monetary policy, executing series of rates cuts. ING applied a dynamic hedging process, by which interest
rate risk was transferred from the business to Group Treasury and subsequently hedged in the markets. The
impact of explicit and implicit floors on both rates of client assets and savings remains limited. Pre-existing
hedges, as executed by Group Treasury, were also adjusted continuously throughout the year to hedge any
interest rate risk coming from lower interest rates. Most of the year-on-year change in NII sensitivity is due
to enhancements in risk management framework in one of non-EUR locations. These enhancements are
aimed at mitigating sensitivity in a volatile rate environment and include increasing the granularity of risk
transferred positions and implementing limits to trigger an intra-month recalibration of the hedges.
Excluding model risk, the total NII-at-Risk remains relatively limited in comparison to ING\u2019s total interest
income.
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. 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. The majority of the risk comes from the investments of own funds and from positions
exhibiting negative convexity due to embedded optionality (most notably variable rate savings and fixed
rate mortgages).
The metrics mentioned above are internal metrics, which therefore deviate from the regulatory EVE SOT
metrics.
NPV-at-Risk banking books per currency (*)
in EUR million
2024
2023
floored
floored
parallel \u25bc
parallel \u25b2
parallel \u25bc
parallel \u25b2
By currency
Euro
7
-1,473
-291
-645
US dollar
274
-266
186
-178
Other
321
-329
131
-146
Total
602
-2,068
27
-969
EUR (floored at -100bps) is at +/- 120bps (2023: +/-110bps)
USD (floored at -100bps) is at +/- 120bps (2023: +/-110bps)
Year-on-year variance analysis (*)
The overall NPV sensitivity increased considerably over last year. The worst-case scenario remains the
parallel up, while the shock used in calculation for main currencies (EUR and USD) increased from 110bps to
120bps on the back of increased volatility observed in the market during 2023. This increase partially
explains the observed higher sensitivity. The other important factor impacting end of 2024 utilisation is
convexity: with lower interest rates, the increase in convexity on mortgages and savings accounts was
observed, especially for EUR positions. Lastly, Group Treasury actively managed the position and executed
investments for capital in the anticipation of possible further rates decreases.
The impact of the benchmark rate reform (*)
In line with the recommendations of the Financial Stability Board, a fundamental review of important
interest rates benchmarks has been undertaken. Some interest rate benchmarks have been reformed, while
others have or will be replaced by risk-free rates and discontinued. USD LIBOR in its current form ceased on
30 June 2023, whereas the cessation of GBP, CHF, JPY, and EUR LIBOR rates occurred on 31 December 2021.
To support these changes, the financial sector has issued several guidance papers and other initiatives to
help phase the transition. In 2024, the benchmark rate reform of only one reference rate, to which the Group
has significant exposures as at 31 December 2024, was continuing (i.e. WIBOR). The WIBOR rate is expected
to be ceased and replaced by a risk-free rate (RFR) by 31 December 2027.
The Steering Committee of the National Working Group (NWG SC) appointed in connection with the WIBOR
benchmark reform the decision (published on 10 December 2024) on the selection of the proposed index
with the technical name 'WIRF \u2013' as the ultimate interest rate benchmark in Poland to replace the WIBOR
benchmark. On 24 January 2025, the Steering Committee of the National Working Group has selected target
name POLSTR (Polish Short Term Rate) for this index.The chosen index is calculated based on unsecured
deposits of Credit and Financial Institutions. Thus, the NWG SC has reviewed and modified its previous
decision to select WIRON as alternative RFR in Poland. The WIBOR rate is still expected to be ceased and
replaced by a new RFR (\"WIRF -\") by 31 December 2027.
Due to the discontinuation of WIBOR, ING, its customers, and in general those market participants with
exposure to such benchmark rates will be faced with a number of risks. These risks include legal, financial,
operational, reputational and conduct risk. The WIBOR rates are used in several of our lending and derivative
products, and hence a project team has been established to manage the transition. WIBOR transition is
especially important for our Polish subsidiary (ING Bank \u015al\u0105ski S.A.) with a significant amount of Polish zloty-
denominated assets and liabilities including derivatives that are continuously rebalanced to hedge the risk
exposures.
The tables below summarise the approximate gross exposures of ING that have yet to transition related to
USD LIBOR and WIBOR, excluding exposures expiring before the transition date 31 December 2027 for
WIBOR.
Non-derivative financial instruments to transition to alternative benchmarks (*)
Financial assets non-
derivative
Financial liabilities\u00a0
non-derivative
Off balance sheet
commitments
in EUR million at 31 December 2024
Carrying value
Carrying value
Nominal value
By benchmark rate
USD LIBOR
WIBOR
19,202
134
1,544
Total
19,202
134
1,544
in EUR million at 31 December 2023
By benchmark rate
USD LIBOR
915
16
9
WIBOR
18,064
1,021
Total
18,979
16
1,030
Derivative financial instruments to transition to alternative benchmarks (*)
31 December 2024
31 December 2023
in EUR million
Nominal value
Nominal value
By benchmark rate
USD LIBOR
151
WIBOR
110,189
77,238
Total
110,189
77,388
sections 1.5.4 and 1.5.7 of Note 1 \u2018Basis of preparation and material accounting policy information\u2019 for
information on the Phase 1 and Phase 2 amendments.
As at 31 December 2024, Phase 1 reliefs are applicable to WIBOR indexed fair value and cash flow hedge
accounting relationships as there is uncertainty arising from the WIBOR reform with respect to the timing
and the amount of the underlying cash flows that the Group is exposed to. Therefore, for WIBOR financial
instruments designated in hedge accounting the applicable Phase 1 reliefs will continue to apply until the
relevant contract is modified. At that point in time, Phase 2 reliefs will become applicable. For these affected
fair value and cash flow hedge relationships, ING assumes that the 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 WIBOR
reform still meet the highly probable requirement, assuming the 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 that are used in the ING\u2019s hedge accounting
relationships for which the Phase 1 amendments to IAS 39 were applied are:
Notional amounts of hedging instruments (*)
31 December 2024
31 December 2023
in EUR million
Nominal value
Nominal value
By benchmark rate
WIBOR
99,663
89,338
As at 31 December 2024, 32% (31\u00a0December 2023: 29%) of the notional amounts for WIBOR have a
maturity date beyond 31 December 2027. The notional amounts of the derivative hedging instruments
provide a close approximation of the extent of the risk exposure ING manages through these hedging
relationships.
Credit spread risk in banking books (CSRBB) (*)
Credit spread risk is defined as risk driven by the changes of the market price for credit risk, for liquidity and
potentially other characteristics of credit-risky instruments, which is not captured by another existing
prudential framework such as IRRBB or by expected credit/(jump-to-) default risk. CSRBB framework is
implemented based on EBA Guidelines. Metrics used are NPV-at-Risk, NII-at-Risk and Market Value Changes-
at Risk and view the positions across different accounting treatments.
Credit spread risk is not part of the internal risk transfer towards Group Treasury and therefore remains in
the business unit it originated in. Group Treasury itself is also an important driver of credit spread risk via its
HQLA investment portfolio and issuance activities.
Risk appetite limits are set on a combination of metrics and accounting scopes and are cascaded to local
ALCOs depending on the type of limit and materiality. Metrics and limits are monitored and reported
monthly to ALCO Bank, local ALCOs and various stakeholders.
Foreign exchange (FX) risk in banking books (*)
FX exposures in banking books result from core banking business activities (business units doing business in
currencies other than their base currency), foreign currency investments in subsidiaries (including realised
net profit and loss), and strategic equity stakes in foreign currencies. The policy regarding these exposures is
briefly explained below.
Core banking business (*)
Every business unit hedges the FX risk resulting from core banking business activities into its base currency
to prevent volatility in profit and loss. Consequently, assets and liabilities are matched in terms of currency,
within certain friction limits.
FX translation (*)
ING\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 (*)
The following table presents the currency exposures in the banking books for the most important currencies
for the FX translation result. Positive figures indicate long positions in the respective currency. As a result of
the strategy to hedge the CET1 ratio an open structural FX exposure exists.
To measure the volatility of the CET1 ratio from FX rate fluctuations, different metrics are used, including the
CET1 Ratio-at-Risk. The impact is controlled via the Solvency and Financial Risk RAS.
EBA Structural FX guidelines
In line with the EBA guidelines on Structural FX, upon permission from the competent authorities, certain
currency positions are being excluded from the calculation of net open currency positions under CRR article
352(2). The resulting impact is presented in the Pillar 3 disclosure.
Foreign currency exposures banking books (*)
in EUR million
Foreign Investments
Hedges
Net exposures
2024
2023
2024
2023
2024
2023
US dollar1
11,251
10,337
-4,823
-3,416
6,429
6,921
Pound Sterling
1,674
1,659
-484
-156
1,190
1,503
Polish Zloty
4,395
3,976
-1,616
-1,254
2,779
2,722
Australian Dollar
3,373
3,620
-2,161
-2,273
1,212
1,346
Turkish Lira
557
517
557
517
Chinese Yuan
2,439
1,815
-830
-348
1,609
1,466
Russian Rouble
396
375
396
375
Romanian Leu
913
895
-176
-134
736
761
Thai Baht
1,266
1,128
-838
-697
428
431
Other currency
3,346
3,704
-2,748
-2,897
599
806
Total
29,612
28,024
-13,675
-11,175
15,936
16,849
*The FX sensitivity is expressed as the FX spot equivalent position.
Equity price risk in banking books (*)
ING maintains a portfolio with substantial equity exposure in its banking books.\u00a0
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 values 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 \u20ac1,679 million (2023: \u20ac1,509 million) and equity securities
held at fair value through other comprehensive income (FVOCI) of \u20ac2,562 million (2023: \u20ac1,885 million). The
value of equity securities held at FVOCI is directly linked to equity security prices with increases/decreases
being recognised in the revaluation reserve. Investments in associates and joint ventures are measured in
accordance with the equity method of accounting, and the balance sheet value is therefore not directly
linked to equity security prices. The equity sensitivity is expressed as the equity position.
Year-on-year variance analysis (*)
In 2024, the revaluation reserve equity securities increased by \u20ac664 million from \u20ac1,152 million to \u20ac1,816
million mainly due to revaluation of the shares in Bank of Beijing with \u20ac 652 million. In 2024, the equity
securities at fair value through OCI increased by \u20ac678 million.
Revaluation reserve equity securities at fair value through other comprehensive income (*)
in EUR million
2024
2023
Positive re-measurement
1,820
1,158
Negative re-measurement
-4
-6
Total
1,816
1,152
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 2024, ING
continued its strategy of undertaking trading activities to develop its client-driven franchise and deliver a
differentiating experience by offering multiple market and trading products.
With respect to the trading portfolios, Trading Risk Management (TRM) focuses on the management of
market risks of Wholesale Banking (mainly Financial Markets) as this is the only business line within ING
where trading activities take place. Trading activities include facilitation of client business and market
making. TRM is responsible for the development and implementation of trading risk policies and risk
measurement methodologies, and for reporting and monitoring risk exposures against approved trading
limits. TRM also reviews trading mandates and global limits, and performs the gatekeeper role in the product
review process (PARP).
Risk measurement (*)
ING uses a comprehensive set of methodologies and techniques to measure market risk in trading books:
Value at Risk (VaR) and Stressed Value at Risk (SVaR), Incremental Risk Charge (IRC), and stress testing.
Systematic validation processes are in place to validate the accuracy and internal consistency of data and
parameters used for the internal models and modelling processes.
Value at Risk (*)
TRM uses the historical simulation VaR methodology (HVaR) as its primary risk measure. The HVaR for
market risk quantifies, with a one-sided confidence level of 99 percent, the maximum overnight loss that
could occur in the trading portfolio of ING due to changes in risk factors (e.g. interest rates, equity prices,
foreign exchange rates, credit spreads, implied volatilities) considering the positions remain unchanged for a
time period of one day.
Next to general market movements in these risk factors, HVaR also takes into account market data
movements for specific moves in, for example, the underlying issuer or securities. A single model which
diversifies general and specific risk is used. In general, a full revaluation approach is applied, while for a
limited number of linear trading positions and risk factors in commodity and equity risk classes a sensitivity-
based approach is applied. The potential impact of historical market movements on today\u2019s portfolio is
estimated, based on equally weighted observed market movements of the previous year (260 business
days). When simulating potential movements in risk factors, depending on the risk factor type, either an
absolute or a relative shift is used.
The data used in the computations is updated daily. ING uses HVaR with a one-day horizon for internal risk
measurement, management control, and backtesting, and HVaR with a 10-day horizon for determining
regulatory capital. To compute HVaR with a 10-day horizon, the one-day risk factor shifts are scaled by the
square root of 10 and then used as an input for the revaluation. The same model is used for all legal entities
within ING with market risk exposure in the trading portfolio.
Limitations (*)
HVaR has some limitations: it uses historical data to forecast future price behaviour, but future price
behaviour could differ substantially from past behaviour. Moreover, the use of a one-day holding period (or
10 days for regulatory capital calculations) assumes that all positions in the portfolio can be liquidated or
hedged in one day. In periods of illiquidity or market events, this assumption may not hold. Also, the use of a
99 percent confidence level means that HVaR does not take into account any losses that occur beyond this
confidence level.
Backtesting (*)
Backtesting is a technique for the ongoing monitoring of the plausibility of the HVaR model in use. Although
HVaR models estimate potential future trading results, estimates are based on historical market data. In a
backtest, the actual daily trading result (excluding fees and commissions) is compared with the one-day
HVaR.
In addition to using actual results for backtesting, ING also uses hypothetical results, which exclude the
effects of intraday trading, fees, and commissions. When an actual or a hypothetical loss exceeds the HVaR,
an \u2018outlier\u2019 occurs. Based on ING\u2019s one-sided confidence level of 99 percent, an outlier is expected once in
every 100 business days.
On an overall level in 2024, there was one outlier for hypothetical P&L and zero outliers for actual P&L. The
hypothetical outlier occurred in the third quarter of 2024, mainly due to higher interest rate and FX market
movements.
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 10-day horizon. The data for the
historical stress period used currently includes the height of the credit crisis around the fall of Lehman
Brothers (2008-2009), and this 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 percent
confidence level. Trading positions (excluding securitisations) of ING, which are subject to specific interest
rate risk included in the internal model approach for market risk regulatory capital, are in scope of the IRC
model. By model choice, equity is excluded from the model. For the calculation of IRC, ING performs a Monte
Carlo simulation based on a multi-factor t-copula. In the multi-factor IRC model the supervisory asset
correlations are no longer applicable and the calibration of the correlations is based on historical market
data. The rating change is simulated for all issuers over the different liquidity horizons (i.e. time required to
liquidate the position or hedge all significant risks) within one year. Movements across different rating
categories and probabilities of default are governed by a credit-rating transition matrix. An internal
transition matrix along with internal LGDs is used, to comply with the consistency requirement. The financial
impact is then determined for the simulated migration to default, or for the simulated migration to a
different rating category, based on LGD or credit spread changes, respectively.
The liquidity horizon has been set to the regulatory minimum of three months for all positions in scope. ING
reviews the liquidity horizons on a yearly basis, based on a structured assessment of the time it takes to
liquidate the positions in the trading portfolio.
Stress testing and event risk (*)
Stress testing is a valuable risk management tool. In addition to the bank-wide stress-test framework as
described in the stress-testing section, Trading Risk Management performs stress tests specific to the trading
book with various frequencies. The trading book stress tests evaluate the impact on the bank\u2019s trading book
under severe but plausible stress scenarios, using a full revaluation approach. The framework is based on
historical as well as hypothetical scenarios. The stress result is an estimate of the profit and loss caused by a
potential event and its worldwide impact for ING. The results of the stress tests are used for decision-making,
aimed at maintaining a financially healthy going-concern institution after a severe event occurs.
In stress scenarios, shocks are applied to prices (credit spreads, interest rates, equity, commodities, and FX
rates) and volatilities. Depending on the type of the stress test, additional scenario assumptions can be
made, for example on correlations, dividends, or recovery rates. The structural scenarios are defined to cover
market moves in various directions and capture different asset class correlations. Scenarios are calculated
using full revaluation approach. The worst scenarios are determined for each product line, business line and
super business line, and compared against limits
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 EUR million
2024
2023
Foreign exchange
Foreign exchange
US Dollar
-93
Japanese Yen
61
Turkish Lira
84
Taiwan Dollar
-58
Korean Won
62
Romanian Leu
58
Japanese Yen
61
Chinese Yuan
49
Chinese Yuan
-37
Hong Kong Dollar
-38
Most important interest rate and credit spread sensitivities at year-end (*)
in EUR thousand
2024
2023
Interest rate (BPV) 1
Interest rate (BPV) 1
Euro
-799
Euro
-309
US Dollar
-198
Czech Koruna
71
British Pound
-189
Korean Won
-41
Korean Won
-54
US Dollar
-40
Philippine Peso
-54
British Pound
-35
Credit spread (CSO1) 2
Credit spread (CSO1) 2
United States
193
Germany
405
Netherlands
-165
Netherlands
120
France
-113
Korea
-111
Poland
69
Japan
106
Germany
49
United Kingdom
101
1 Basis point value (BPV) measures the impact on value of a one basis point increase in interest rates.
2 Credit spread sensitivity (CS01) measures the impact on value of a one basis point increase in credit spreads. Exposures to
supranational institutions are not assigned to a specific country.
Credit spread sensitivities per risk class and sector at year-end (*)
2024
2023
in EUR thousand
Corporate
Financial
institutions
Corporate
Financial
institutions
Credit Spread (CSO1) 1
Risk classes
1 (AAA)
-2
-118
2\u20134 (AA)
-44
-27
12
50
5\u20137 (A)
49
-246
57
50
8\u201310 (BBB)
93
-76
106
13
11\u201313 (BB)
38
-13
25
-25
14\u201316 (B)
23
-12
17
-4
17\u201322 (CCC and NPL)
4
2
-8
-20
Total
162
-489
208
65
1 Credit Spread Sensitivity (CS01) measures the impact on value of a 1 basis point increase in credit spreads.
Funding and liquidity risk (*)
Introduction (*)
Funding and liquidity (F&L) risk is the risk that ING or one of its subsidiaries cannot meet their financial
obligations upon their maturity date at a reasonable cost and in a timely manner. ING incorporates funding
and liquidity risk management in its business strategy and has established a funding and liquidity risk
framework to manage these risks within pre-defined boundaries.
The following sections elaborate on the various elements of funding and liquidity risk:
\u2022 Funding and liquidity risk framework;
\u2022 Funding and liquidity risk management strategy and objectives;
\u2022 Funding and liquidity adequacy and risk appetite;
\u2022 Funding and liquidity risk indicators;
\u2022 Liquidity stress testing; and
\u2022 Contingency funding planning.
Funding and liquidity risk framework (*)
Macroeconomic and market environment are important considerations in ING\u2019s F&L framework. The
macroeconomic environment is comprised of various exogenous factors over which ING has no control, but
which may have a material impact on ING\u2019s F&L position. The main macroeconomic factors analysed on a
regular basis include:
\u2022 performance of global and local macroeconomic indicators, e.g. shifts in GDP, inflation rates,
unemployment rates, and public deficit/surplus;
\u2022 developments and risks arising from geopolitical tensions and trends;
\u2022 monetary policy with a focus on the alternative monetary measures employed by central banks in recent
years as a result of the global energy crisis and the recent period of high inflation; and
\u2022 regulatory 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.
The EB, MBB and staff departments from the CRO and CFO domains, as well as Group Treasury, have
oversight of, and are responsible for, managing funding and liquidity risks.
Funding and liquidity management strategy and objectives (*)
The main objective of ING\u2019s funding and liquidity risk management is to maintain sufficient liquidity to fund
the commercial activities of ING both under normal and stressed market circumstances across various
locations, currencies and tenors.
ING\u2019s funding consists mainly of retail and corporate deposits contributing 53 percent and 22 percent of total
funding, respectively. These funding sources provide a (relatively) stable funding base. The remainder of the
required funding is attracted primarily through a combination of long-term and short-term professional
funding. Group Treasury manages the professional funding in line with the F&L risk appetite with the aim of
ensuring a sufficiently diversified and stable funding base.
Funding and liquidity adequacy and risk appetite (*)
ING identifies key drivers of short-term and future liquidity and funding needs on an ongoing basis through
the periodic risk-identification process. Taking into consideration the identified risk drivers, ING regularly
assesses its current and future liquidity adequacy and, if deemed necessary, takes action to further improve
ING\u2019s liquidity position and maintain sufficient counterbalancing capacity. A Liquidity Adequacy Statement is
formulated on a regular basis to substantiate and reflect the management view on the current funding and
liquidity position as well as the potential future challenges. The Liquidity Adequacy Statement is an
important part of ING\u2019s ILAAP process. Additionally, ING completes ad hoc funding and liquidity assessments
if deemed necessary. In 2024, ING focused on the implementation of activities which steered the LCR higher
and diversified the funding mix in order to ensure funding stability for the bank into the F&L risk appetite.
ING assesses its F&L adequacy through three lenses \u2013 stress, economic and normative:
\u2022 Through the stress lens, ING evaluates its ability to withstand periods of prolonged F&L stress for both
normative and economic requirements or limits under idiosyncratic, market-related, combined
idiosyncratic and market-related, and climate risk scenarios, which lead to customer deposit outflows,
deterioration of access to funding markets, and lower liquidity value of counterbalancing capacity.
\u2022 Through the economic lens, ING assesses the extent to which its customers, professional counterparties
and investors are comfortable to provide deposits and funding in the tenors, currencies and instruments
necessary to sustainably fund the business (intraday, short-term and long-term) in a going-concern
situation.
\u2022 Through the normative lens, ING ascertains that the bank is in the position to meet current and future
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.
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, combined (idiosyncratic and market-
wide) and climate-stress scenarios. The design of the framework is based on empirical evidence
supplemented by expert judgment. The framework can be extended to additional ad-hoc scenarios. For
example, it can be used as input for firm-wide stress testing and reverse stress testing.
Outcomes of the stress tests are considered in the key aspects of ING\u2019s F&L risk framework and F&L risk
management, including:
\u2022 Risk Appetite Framework (through risk appetite statements);
\u2022 Risk identification and assessment;
\u2022 Monitoring of the liquidity and funding position;
\u2022 Business actions (if needed);
\u2022 Contingency funding plan; and
\u2022 Early-warning indicators.
The funding and liquidity stress-testing framework is also subject to regular internal validation by model
validation.
In line with supervisory expectations, ING\u2019s liquidity position is stress tested on (at minimum) a monthly basis
using scenarios that form part of the F&L risk appetite statement. The results of all internal stress scenarios
are monitored and assessed on a monthly basis. In addition, ad hoc scenarios based on current economic
and market developments are run to determine their potential impacts on the funding and liquidity position
of ING. In 2024, this included stress-test scenarios assessing the impact of a shutdown of US short- and long-
term funding markets and FX markets. The internal stress scenarios and their corresponding results serve as
input in the decision on holding additional contingency measures.
Contingency funding planning (*)
ING\u2019s contingent F&L risks are addressed in its Contingency Capital and Funding Plan (CCFP).The objectives of
the CCFP include the following:
\u2022 Establishment of a monitoring framework to detect approaching contingent events as well as their
impact on ING\u2019s F&L position;
\u2022 Provision of a plan for responding to various and increasing levels of a bank\u2019s liquidity and capital shortfall
under adverse and stressed conditions;
\u2022 Designation of management responsibilities, crisis communication methods and channels, and reporting
requirements;
\u2022 Identification of contingent capital and liquidity sources that can be used under various and increasing
adverse as well as stressed circumstances; and
\u2022 Description of steps which should be taken to ensure that the bank\u2019s sources of capital and liquidity are
sufficient to fund scheduled operating requirements and meet the institution\u2019s commitments with
minimal costs and disruption.
The contingency funding measures are developed in conjunction with the ING Recovery Plan and are
reviewed and tested on a regular basis.
1.2.1\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:DisclosureOfFinancialRiskManagementExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-2": { "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 the 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 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. 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 1.5.4 \u2018Derivatives and hedge
accounting\u2019 of this note and to Note 33 '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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-3": { "value": "
Credit risk
Credit & counterparty risk categories (*)
In the following table the different types of credit and counterparty risk categories are described and a
reconciliation with the notes in the financial statements is also included:
Reconciliation between credit & counterparty risk categories and financial position (*)
Credit risk categories
Notes in the financial statements
Lending risk: The risk that the client (counterparty, corporate or individual) does not pay the principal interest or fees on a loan when they are due,
or on demand for letters of credit (LCs) and guarantees provided by ING.
2
Cash and balances with central banks
3
Loans and advances to banks
4
Financial assets at fair value through profit or loss
5
Financial assets at fair value through other comprehensive income
7
Loans and advances to customers
38
Contingent liabilities and commitments
Investment risk: 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.
4
Financial assets at fair value through profit or loss
5
Financial assets at fair value through other comprehensive income
6
Debt securities
Money market risk: This arises when ING places short-term deposits with a counterparty in order to manage excess liquidity. In the event of a
counterparty default, ING may lose the deposit placed.
2
Cash and balances with central banks
3
Loans and advances to banks
7
Loans and advances to customers
Pre-settlement risk: This arises when a client defaults on a transaction before settlement and ING must replace the contract by a trade with another
counterparty at the then prevailing (possibly unfavourable) market price. This credit risk category is associated with derivatives transactions
(exchange-traded derivatives, over-the-counter (OTC) derivatives and securities financing transactions).
4
Financial assets at fair value through profit or loss
14
Financial liabilities at fair value through profit or loss
37
Offsetting financial assets and liabilities
Settlement risk: This arises when there is an exchange of value (funds or instruments) and receipt from its counterparty is not verified or expected
until after ING has given irrevocable instructions to pay or has paid or delivered its side of the trade. The risk is that ING delivers but does not receive
delivery from its counterparty.
4
Financial assets at fair value through profit or loss
11
Other assets
14
Financial liabilities at fair value through profit or loss
16
Other liabilities
Credit risk appetite and concentration risk framework (*)
The credit risk appetite and concentration risk framework is designed to prevent undesired high levels of
credit risk and credit concentrations within various levels of the ING portfolio. It is derived from the concepts
of boundaries and instruments as described in the ING RAF.
Credit risk appetite is the maximum level of credit risk ING is willing to accept for growth and value creation.
The credit risk appetite is linked to the overall bank-wide RAF and is expressed in quantitative and qualitative
measures.
The credit risk appetite is set at different levels and dimensions within ING. The credit risk appetite framework
specifies the scope and focus of the credit risk which ING takes and the composition of the credit portfolio,
including its concentration and diversification objectives in relation to business lines, locations, sectors and
products. The credit risk appetite framework has also been extended to embed climate risk elements. The
climate risk elements within the credit risk appetite framework allow for more efficient steering of sector
concentrations from a climate risk perspective.
The credit concentration risk framework is composed of:
\u2022 Country risk concentration: Country risk is the risk that arises due to events in a specific country (or
group of countries). To manage the maximum country loss ING is willing to accept, boundaries are
approved by the SB. The estimated level is correlated to the risk rating assigned to a given country. Actual
country limits are set by means of country instruments, which are monitored monthly and updated,
when needed. For countries with elevated levels of geopolitical or severe economic cycle risk, monitoring
is performed on a more frequent basis with strict pipeline and exposure management.
\u2022 Single name and secondary risk concentration: ING has an established credit concentration risk
framework to identify, measure and monitor single name concentration including secondary risk. The
same concept of boundaries and instruments is applicable.
\u2022 Sector and product concentration risk are managed via the credit risk appetite framework.
Credit risk models (*)
Within ING, internal CRR-compliant models are used to determine probability of default (PD), exposure at
default (EAD) and loss given default (LGD) for regulatory and economic capital purposes. These models also
form the basis of ING\u2019s IFRS 9 loan loss provisioning (see \u2018IFRS 9 models\u2019 below).
There are two main types of PD, EAD and LGD models used throughout the bank:
\u2022 Statistical models are created where a large set of default or detailed loss data is available. They are
characterised by sufficient data points to facilitate meaningful statistical estimation of the model
parameters. The model parameters are estimated with statistical techniques based on the data set
available.
\u2022 Hybrid models are statistical models supplemented with knowledge and experience of experts from risk
management and front-office staff, literature from rating agencies, supervisors and academics. These
models are only used for \u2018low default portfolios\u2019, where limited historical defaults exist.
Credit risk rating process (*)
The majority of risk ratings are based on a risk rating (PD) model that complies with the minimum
requirements detailed in CRR/CRD, ECB Supervisory Rules and European Banking Authority (EBA) guidelines.
This concerns all borrower types and segments.
ING\u2019s PD rating models are based on a 1-22 internal risk rating scale (1 = highest rating; 22 = lowest rating)
referred to as the \u2018master scale\u2019, which roughly corresponds to the rating grades that are assigned by
external rating agencies, such as Standard & Poor\u2019s, Moody\u2019s and Fitch. For example, an ING rating of 1
corresponds to an S&P/Fitch rating of AAA and a Moody\u2019s rating of Aaa; an ING rating of 2 corresponds to an
S&P/Fitch rating of AA+ and a Moody\u2019s rating of Aa1, and so on.
The 22 internal risk rating grades are composed of the following categories:
\u2022 Investment grade (risk rating 1-10);
\u2022 Non-investment grade (risk rating 11-17);
\u2022 Performing Restructuring (risk rating 18-19); and
\u2022 Non-performing (risk rating 20-22).
The first three categories (1-19) are risk ratings for performing loans. Ratings are calculated in IT systems
with internally developed models, based on manually or automatically fed data, or for part of the non-
performing loans set by the global or regional credit restructuring department. Under certain conditions, the
outcome of a manually fed model can be challenged through a rating appeal process. For securitisation
portfolios, the external ratings of the tranche in which ING has invested are leading indicators.
Risk ratings assigned to clients are reviewed at least annually, with the performance of the underlying
models monitored regularly. Some of these models are global in nature, such as those for large corporates,
commercial banks, insurance companies, central governments, funds, fund managers, project finance and
leveraged companies. Other models are more regional or country-specific: there are PD models for small and
medium enterprises (SMEs) in the Netherlands, Belgium, and Poland as well as residential mortgage and
consumer loan models in the various retail markets.
Rating models for Retail clients are predominantly statistically driven and automated, such that ratings can
be updated on a monthly basis. Rating models for large corporates, institutions and banks include both
statistical characteristics and expert input, with the ratings being manually updated at least annually. More
frequent reviews (e.g. quarterly) are performed where considered necessary.
In line with evolving regulatory expectations on models and emerging industry practices, ING has embarked
on a multi-year redevelopment process of its credit risk models. This is also in line with ING\u2019s model
governance to ensure continuous improvement of models.
Credit risk portfolio (*)
ING\u2019s credit exposure is mainly related to lending to individuals (also referred to as consumer lending, all
Retail) and businesses (referred to as business lending, both in Retail and Wholesale), followed by
investments in bonds and securitised assets, and money market (Wholesale). Loans to individuals are mainly
mortgage loans secured by residential property. Loans (including guarantees issued) to businesses are often
collateralised, but may be unsecured based on the internal analysis of the borrower\u2019s creditworthiness.
Bonds in the investment portfolio are generally unsecured, but predominantly consist of bonds issued by
central governments and EU and/or OECD-based financial institutions. Secured bonds, such as mortgage-
backed securities and asset-backed securities are secured by the underlying diversified pool of assets
(commercial or residential mortgages, car loans and/or other assets) held by the securities issuer. For money
market, exposure is mainly deposits to central banks. The last major credit risk source involves pre-
settlement exposures which arise from trading activities, including derivatives, repurchase transactions and
securities lending/borrowing transactions. This is also commonly referred to as counterparty credit risk.
Overall portfolio (*)
During 2024, ING\u2019s portfolio size increased by \u20ac30.3 billion (3.2%) to \u20ac961.9 billion outstanding. Foreign
exchange rate changes had a positive impact on the portfolio growth, mainly in WB, increasing total
outstanding by \u20ac8.0 billion, driven by the appreciation of the US dollar against the euro. Retail banking
increased by \u20ac18.9 billion mainly due to underlying growth in residential mortgages.
Rating distribution (*)
Overall, the rating class distribution remained stable in 2024. The share of investment grade rating classes
increased from 76.8% to 78.1%, while the share of non-investment grade decreased from 21.2% to 19.9%.
Performing restructuring outstandings decreased from 0.7% to 0.6% of the total portfolio, whereas non-
performing loans increased from 1.3% to 1.4%.
With respect to the rating distribution within the business lines, in WB, investment grade increased to 83.7%
from 81.2%, while non-investment grade exposures decreased to 14.6% from 17.1% compared to 2023.
Performing restructuring assets decreased from 0.7% to 0.6% of total Wholesale Banking assets where non-
performing loans for WB increased from 1.0% to 1.2%. The non-performing loans (NPL) increase in
Wholesale Banking is mainly caused by Russian exposures as well as a few large NPLs that are unrelated in
terms of asset class, sector or geography.
For Retail Banking, investment grade increased to 73.3% from 73.0%, while non-investment grade exposures
decreased to 24.4% from 24.9% as compared to 2023. Performing restructuring increased to 0.7% from 0.6%
whereas NPL remained constant at 1.5% in 2024.
Industry (*)
The industry breakdown is presented in accordance with the NAICS definition. The increase of \u20ac30.3 billion in
total volume during 2024 was mainly due to the increase in Private Individuals (\u20ac18.4 billion), Non-Bank
Financial Institutions (\u20ac8.8 billion) and Commercial Banks (\u20ac5.2 billion). The share of Private Individuals
increased from 38.8% last year to 39.5%.
Portfolio analysis per business line (*)
Outstandings per line of business (*)1, 2, 3
in EUR million
Wholesale Banking
Retail Banking
Corporate line
Total
Rating class
2024
2023
2024
2023
2024
2023
2024
2023
Investment grade
1 (AAA)
53,363
52,716
29,151
34,683
1,790
2,284
84,304
89,682
2-4 (AA)
72,462
67,034
63,187
59,655
4
6
135,653
126,694
5-7 (A)
101,831
95,320
140,479
132,076
157
147
242,467
227,543
8-10 (BBB)
129,429
123,081
155,375
146,295
3,452
2,357
288,256
271,733
Non-investment grade
11-13 (BB)
53,757
57,348
94,753
94,408
148,510
151,756
14-16 (B)
7,396
12,234
31,165
29,330
38,561
41,565
17 (CCC)
1,037
1,122
3,345
3,113
170
196
4,552
4,431
Performing Restructuring loans
18 (CC)
1,792
2,523
2,001
1,957
3,794
4,481
19 (C)
560
535
1,760
1,313
2,320
1,848
Non-performing loans
20-22 (D)
5,204
4,051
8,100
7,622
13,303
11,673
Total
426,832
415,965
529,317
510,452
5,572
4,989
961,720
931,406
Industry
Private Individuals
2,116
2,330
377,712
359,057
379,827
361,387
Central Banks
61,091
70,139
15,044
21,740
1,785
2,269
77,919
94,147
Natural Resources
39,974
40,511
1,925
1,883
41,899
42,394
Real Estate
24,643
24,904
28,738
26,611
53,381
51,515
Commercial Banks
41,027
37,393
6,662
6,183
3,619
2,515
51,308
46,091
Non-Bank Financial Institutions
64,217
55,313
2,212
2,290
79
89
66,509
57,692
Central Governments
48,389
45,316
8,107
7,304
1
1
56,497
52,621
Transportation & Logistics
27,499
27,106
6,037
5,784
33,536
32,890
Utilities
25,517
23,324
2,196
2,184
27,713
25,509
Food, Beverages & Personal Care
13,827
13,503
10,419
9,883
24,246
23,386
Services
8,844
9,128
13,442
12,872
27
24
22,312
22,023
General Industries
10,512
12,039
8,812
9,086
19,324
21,126
Lower Public Administration
6,959
6,211
19,598
17,493
26,557
23,704
Other
52,218
48,748
28,412
28,082
62
92
80,691
76,922
Total
426,832
415,965
529,317
510,452
5,572
4,989
961,720
931,406
Outstandings per line of business (*) - continued1, 2, 3
in EUR million
Wholesale Banking
Retail Banking
Corporate line
Total
Region
2024
2023
2024
2023
2024
2023
2024
2023
Europe
Netherlands
44,486
54,989
164,590
156,182
1,906
2,366
210,981
213,537
Belgium
26,506
24,171
95,584
91,744
0
7
122,091
115,921
Germany
27,443
26,152
128,598
128,885
30
31
156,071
155,067
Poland
21,190
20,346
30,946
28,971
0
0
52,136
49,317
Spain
11,990
11,047
28,507
27,158
36
35
40,533
38,240
United Kingdom
28,257
28,587
265
275
91
112
28,613
28,974
Luxembourg
26,176
23,805
5,139
5,557
0
0
31,314
29,363
France
24,351
21,528
3,122
3,108
3
14
27,476
24,650
Rest of Europe
72,860
65,157
23,203
20,368
14
32
96,076
85,558
America
86,402
78,851
2,402
2,042
22
25
88,827
80,917
Asia
44,136
49,851
215
159
3,464
2,365
47,815
52,374
Australia
10,887
9,409
46,723
45,977
8
2
57,618
55,389
Africa
2,148
2,071
22
26
0
0
2,170
2,098
Total
426,832
415,965
529,317
510,452
5,572
4,989
961,720
931,406
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.
Portfolio analysis per geographical area (*)
The portfolio analysis per geographical area re-emphasises the international distribution of ING\u2019s credit
portfolio. The Netherlands maintains the largest portfolio share in a single country with 21.9% (2023: 22.9%)
of the total amount, followed by Germany with 16.2% (2023: 16.6%) and Belgium with 12.7% (2023: 12.4%).
In terms of region, the majority of the portfolio balance remained in Europe with 80% (2023: 79%), followed
by Americas with 9.3% (2023: 8.7%) and Australia with 6.0% (2023: 5.9%). The top five countries within Rest
of Europe based on outstandings were Italy (\u20ac20.7 billion), Switzerland (\u20ac16.4 billion), Romania (\u20ac12.4 billion),
T\u00fcrkiye (\u20ac8.6 billion) and Ireland (\u20ac4.8 billion).
The main contributors for the overall increase in outstanding are Americas (+\u20ac7.9 billion), Belgium
(+\u20ac6.2 billion), Poland (+\u20ac2.8 billion) and France (+\u20ac2.8 billion).\u00a0
Private Individuals remained the largest composition of portfolio balances for the Netherlands at 58.3%
(2023: 54.6%), Belgium at 37.4% (2023: 38.5%), Germany at 68.8% (2023: 66.5%) and Australia at 66.1%
(2023: 65.6%). The decrease in Central Banks is mainly attributed to the Netherlands (\u20ac8.5 billion explaining
the decrease in WB Netherlands outstanding), Germany (\u20ac5.0 billion) and Asia (\u20ac4.1 billion).\u00a0
In individual countries, the total share of investment grade/non-investment grade remains substantial for
the Netherlands at 98.5% (2023: 98.6%), Germany at 98.9% (2023: 99.1%) and in Belgium 96.6% (2023:
96.6%).
In Europe, the increase in investment grade was mainly witnessed in Poland (+\u20ac4.3 billion), France
(+\u20ac3.2 billion), Spain (+\u20ac3.2 billion), Belgium (+\u20ac3.2 billion) and Luxembourg (+\u20ac3.2 billion). Non-investment
grade decreased in the Netherlands (-\u20ac2.7 billion), Poland (-\u20ac1.8 billion), Luxembourg (-\u20ac1.2 billion) and Spain
(-\u20ac1.0 billion).
Outstandings by economic sectors and geographical area (*) 1
in EUR million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United
Kingdom
Luxembourg
France
Rest of
Europe
America
Asia
Australia
Africa
2024
Private Individuals
122,914
45,611
107,415
16,525
27,083
122
3,058
2,260
16,391
198
129
38,106
16
379,827
Central Banks
22,529
10,196
13,966
1,729
510
1,935
5,737
0
10,913
0
9,525
879
0
77,919
Natural Resources
2,197
1,531
881
778
152
3,021
2,503
405
11,212
8,475
8,989
1,593
159
41,899
Real Estate
16,749
13,387
1,218
2,085
1,595
552
3,446
2,713
3,707
3,220
1,066
3,642
0
53,381
Commercial Banks
1,353
314
4,129
695
376
4,733
5,268
5,074
7,779
10,700
9,394
1,336
157
51,308
Non-Bank Financial Institutions
2,872
1,766
5,147
2,874
249
8,479
6,031
5,932
5,174
23,157
3,518
1,255
55
66,509
Central Governments
1,416
11,009
51
9,435
5,308
48
82
3,202
9,203
15,377
288
488
589
56,497
Transportation & Logistics
4,290
2,076
1,426
1,623
679
2,262
828
765
7,407
3,983
6,912
504
781
33,536
Utilities
1,805
1,843
3,920
814
1,971
2,826
395
712
3,951
5,886
1,187
2,253
152
27,713
Food, Beverages & Personal Care
7,377
3,690
695
2,215
351
328
1,393
1,102
3,008
2,498
1,168
406
14
24,246
Services
4,919
8,431
1,852
1,538
122
869
540
310
1,271
1,265
516
680
0
22,312
General Industries
4,568
2,690
1,059
2,824
219
301
539
484
3,862
2,039
708
23
8
19,324
Lower Public Administration
782
6,824
7,435
608
557
0
246
3,091
476
1,554
44
4,941
0
26,557
Other
17,208
12,722
6,876
8,394
1,361
3,137
1,248
1,426
11,722
10,475
4,372
1,513
238
80,691
Total
210,981
122,091
156,071
52,136
40,533
28,613
31,314
27,476
96,076
88,827
47,815
57,618
2,170
961,720
Rating class
Investment grade
170,161
74,882
136,096
36,029
32,741
23,844
27,235
21,886
67,110
72,476
41,203
46,959
59
750,680
Non-Investment grade
37,689
43,059
18,238
13,948
7,126
4,388
3,858
5,229
25,679
14,763
5,859
9,889
1,898
191,623
Performing restructuring
1,579
1,078
305
701
234
59
56
54
1,369
443
30
203
4
6,114
Non-performing loans
1,552
3,071
1,432
1,458
432
322
166
307
1,918
1,145
723
568
210
13,303
Total
210,981
122,091
156,071
52,136
40,533
28,613
31,314
27,476
96,076
88,827
47,815
57,618
2,170
961,720
1 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 EUR million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United
Kingdom
Luxembourg
France
Rest of
Europe
America
Asia
Australia
Africa
2023
Private Individuals
116,530
44,637
103,151
14,860
25,452
128
3,347
2,472
14,179
149
121
36,340
20
361,387
Central Banks
31,017
9,756
18,945
2,530
489
4,335
4,853
6,166
13,668
2,379
9
94,147
Natural Resources
2,623
1,346
1,017
685
129
3,789
2,511
429
10,608
8,237
9,785
941
295
42,394
Real Estate
16,907
10,986
1,111
2,184
1,551
420
3,563
2,901
3,492
3,323
1,367
3,709
51,515
Commercial Banks
1,268
404
4,050
601
353
4,488
5,070
4,155
6,757
9,833
8,182
719
210
46,091
Non-Bank Financial Institutions
2,573
1,457
5,710
2,532
652
6,837
4,631
4,274
4,269
19,921
3,884
950
57,692
Central Governments
1,620
9,046
699
8,614
5,491
41
79
2,255
9,384
13,752
520
526
593
52,621
Transportation & Logistics
3,860
2,198
1,277
1,598
658
2,113
596
784
8,177
3,511
7,044
456
618
32,890
Utilities
2,419
1,634
3,516
792
912
2,723
480
619
4,469
4,424
1,306
2,041
173
25,509
Food, Beverages & Personal Care
7,138
3,127
550
2,242
490
540
1,505
1,250
2,455
2,652
1,140
281
18
23,386
Services
5,073
8,463
1,725
1,325
71
745
502
380
1,052
1,576
469
642
22,023
General Industries
5,746
2,604
1,193
2,827
333
199
649
287
3,661
2,848
761
18
21,126
Lower Public Administration
253
6,607
5,349
669
350
0
249
3,488
356
1,550
7
4,826
23,704
Other
16,510
13,657
6,774
7,858
1,309
2,615
1,326
1,356
10,532
9,141
4,120
1,562
163
76,922
Total
213,537
115,921
155,067
49,317
38,240
28,974
29,363
24,650
85,558
80,917
52,374
55,389
2,098
931,406
Rating class
Investment grade
170,118
71,730
136,675
31,772
29,583
24,299
24,083
18,692
56,404
63,652
44,481
44,139
24
715,653
Non-Investment grade
40,399
40,236
16,929
15,785
8,134
4,508
5,013
5,713
25,967
15,806
6,769
10,715
1,776
197,751
Performing restructuring
1,433
799
349
830
230
2
105
122
1,983
245
72
132
26
6,328
Non-performing loans
1,587
3,155
1,114
929
293
165
162
124
1,205
1,213
1,051
403
272
11,673
Total
213,537
115,921
155,067
49,317
38,240
28,974
29,363
24,650
85,558
80,917
52,373
55,389
2,098
931,406
1 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.
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 of ensuring consistent application
within ING. These also require that the value of the cover is monitored on a regular basis. Covers are revalued
periodically and whenever there is reason to believe that the market is subject to significant changes in
conditions. The frequency of monitoring and revaluation depends on the type of cover.
The valuation method also depends on the type of covers. For asset collateral, the valuation sources can be
the customer\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 applies haircuts to the collateral values of real estate, shipping and aviation assets that are
used in the calculation of the loss-given-default in recovery scenarios. The haircut reflects the risks of
adverse price developments between the moment of valuation of an asset and the actual settlement/cash
receipt.
Cover values (*)
This section provides insight into the types of cover and the extent to which exposures benefit from collateral
or guarantees. The disclosure differentiates between risk categories (lending, investment, money market
and pre-settlement). The most relevant types of cover include mortgages, financial collateral (cash and
securities), guarantees and other covers (mainly pledges). ING obtains covers that are eligible for credit risk
mitigation under CRR/CRDIV, as well as covers that are 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.
Cover values including guarantees received (*)
in EUR million
Cover type and value
Collateralisation
2024
Outstandings
Mortgages
Financial Collateral
Guarantees
Other covers
No cover
Partially covered
Fully covered
Consumer lending
378,832
865,466
6,257
25,428
55,115
6.5%
2.0%
91.5%
Business lending
368,424
163,143
24,838
119,410
484,148
34.0%
23.7%
42.3%
Investment and money market
153,495
0
0
1,115
95
99.3%
\u2014%
0.7%
Total lending, investment and money market
900,752
1,028,609
31,095
145,953
539,357
33.6%
10.5%
55.9%
of which NPL
13,295
10,427
194
3,093
11,109
27.6%
27.7%
44.7%
Pre-settlement
60,968
Total Bank
961,720
Cover values including guarantees received (*)
in EUR million
Cover type and value
Collateralisation
2023
Outstandings
Mortgages
Financial Collateral
Guarantees
Other covers
No cover
Partially covered
Fully covered
Consumer lending
360,124
804,994
22,401
25,269
29,070
6.2%
2.0%
91.8%
Business lending
363,680
162,491
26,333
115,944
428,531
35.2%
22.5%
42.3%
Investment and money market
158,506
\u2014
1,040
549
99.0%
0.6%
0.4%
Total lending, investment and money market
882,309
967,485
48,735
142,252
458,149
34.8%
10.2%
55.0%
of which NPL
11,653
8,880
1,609
3,204
9,241
25.7%
26.9%
47.4%
Pre-settlement
49,096
Total Bank
931,406
The above tables gives an overview of the collateralisation of ING\u2019s total portfolio. Excluding the pre-
settlement portfolio, 55.9% (2023: 55.0%) of ING\u2019s outstandings were fully collateralised in 2024. Since
investments traditionally do not require covers, the \u2018no covers\u2019 percentage in this portfolio is over 99%.
Consumer lending portfolio (*)
The consumer lending portfolio accounts for 39.4% (2023: 38.7%) 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 (34.6%), Germany (27.5%), Belgium including Luxembourg (12.8%) and Australia (10.8%).\u00a0
Note that the large increase in Other covers and decrease in Financial Collateral is related to a
reclassification of certain cover types.
Business lending portfolio (*)
Business lending accounts for 38.3% (2023: 39.1%) of ING\u2019s total outstanding. Business lending presented in
this section does not include pre-settlement, investment and money market exposures.
Credit quality (*)
ING uses three distinct statuses to categorise the management of clients with (perceived) deteriorating
credit risk profiles. ING usually classifies a client first with a \u201cwatch list\u201d status 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. Furthermore, ING makes use of Early Warning
Indicators (EWIs) in daily credit risk management processes in non-Retail portfolios which relate to a change
in (internal and/or external) circumstances or outlook of the specific Obligor, the sector or portfolio. Some
clients with a watch list or EWI status may develop into a performing restructuring status (performing loans
that hold a reasonable probability that ING will end up with a loss, if no specific action is taken) or a non-
performing status.
When there is increasing doubt as to the performance and the collectability of the client\u2019s contractual
obligations the loans are managed by Global Credit Restructuring (GCR) or by restructuring units in the
various regions and business units. The statuses and links with rating grades are illustrated in the table
below.
Credit quality outstandings\u00a0 (*)
in EUR million
2024
2023
Performing not past due
823,336
795,796
Business lending performing past due
9,174
8,825
Consumer lending performing past due
802
846
Non-performing
13,295
11,653
Total lending and investment
846,607
817,120
Money market
54,145
65,189
Pre-settlement
60,968
49,096
Total
961,720
931,406
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 customers, ING aims to solve the (potential) financial difficulties by
offering a range of measures (e.g. payment arrangements, restructuring). If the issues cannot be resolved,
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 \u2013 is more than 90 days past due and to risk rating 21 or 22 in
case of an exit scenario.
The table below represents the breakdown of lending and investment credit risk outstandings that are
performing by age and geographic area.
Ageing analysis (past due but performing): Consumer lending portfolio by geographic area, outstandings (*)
in EUR million
2024
2023
Region
Past due
for 1\u201330 days
Past due
for 31\u201360 days
Past due
for 61\u201390 days
Total
Past due
for 1\u201330 days
Past due
for 31\u201360 days
Past due
or 61\u201390 days
Total
Europe
Belgium
185
49
29
263
223
43
29
295
Germany
65
37
24
125
89
40
18
147
Poland
61
9
4
74
76
8
5
89
Netherlands
62
35
4
101
67
24
6
97
Luxembourg
22
6
3
32
21
2
2
25
Spain
12
16
8
36
19
13
6
38
Rest of Europe
93
15
4
112
64
19
11
94
America
0
0
0
1
1
0
0
1
Asia
0
0
0
0
0
0
0
1
Australia
38
19
2
59
43
15
1
59
Africa
0
0
0
0
0
0
0
0
Total
538
186
78
802
602
164
79
846
The past due but performing consumer lending outstanding decreased by \u20ac44 million, due to a decrease in
1-30 days (-\u20ac64 million) which was partially offset by an increase in 31-60 (+\u20ac22 million). The largest
decrease was observed in Belgium (-\u20ac32 million) and Germany (-\u20ac22 million), mainly in the 1-30 days
bucket. The largest increase was seen in Rest of Europe (+\u20ac18 million).
Ageing analysis (past due but performing): Business lending portfolio by geographic area, outstandings (*)
in EUR million
2024
2023
Region
Past due for 1\u201330 days
Past due for 31\u201360 days
Past due for 61\u201390 days
Total
Past due for 1\u201330 days
Past due for 31\u201360 days
Past due for 61\u201390 days
Total
Europe
Belgium
1,187
17
13
1,217
929
98
11
1,037
United Kingdom
830
8
838
623
659
128
1,410
Luxembourg
367
51
5
423
577
8
11
596
Netherlands
929
14
943
509
10
12
531
Poland
173
17
19
209
346
26
10
383
Spain
26
26
France
194
194
58
132
190
Germany
215
3
2
220
131
110
1
242
Rest of Europe
630
4
46
681
972
2
2
977
America
3,504
95
3,599
2,508
101
41
2,650
Asia
310
310
284
22
306
Australia
469
6
475
501
1
502
Africa
39
39
Total
8,873
215
86
9,174
7,437
1,148
240
8,825
Total past due but performing outstanding of business lending increased by \u20ac0.3 billion. Increase was
witnessed in the 1\u201330 days past due bucket (\u20ac1.4 billion) which was offset by the decrease observed in the
31-60 days (-\u20ac0.9 billion) and 61-90 days (-\u20ac0.2 billion) past due buckets. The largest increase was in the
Americas (\u20ac0.9 billion) while the largest decrease was in the United Kingdom (-\u20ac0.6 billion).
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. The aim is to maximise the client\u2019s repayment
ability, thereby avoiding a default situation, or help the client to return to a performing situation.
For ING Retail units, clear criteria have been established to determine whether a client is eligible for the
forbearance process. Specific approval mandates are in place to approve the measures, as well as
procedures to manage, monitor and report the forbearance activities.
ING reviews the performance of forborne exposures at least quarterly, either on a case-by-case (Business) or
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 EUR million
2024
2023
Business line
Outstandings
Of which:
performing
Of which:
non-
performing
% of
total
portfolio
Outstandings
Of which:
performing
Of which:
non-
performing
% of
total
portfolio
Wholesale Banking
5,934
3,191
2,743
1.9%
6,063
3,919
2,144
1.9%
Retail Banking
6,883
3,987
2,897
1.3%
7,026
4,128
2,898
1.4%
Total
12,817
7,178
5,640
1.5%
13,089
8,047
5,042
1.6%
Summary Forborne portfolio by forbearance type (*)
in EUR million
2024
2023
Forbearance
type
Outstandings
Of which:
performing
Of which:
non-
performing
% of total
portfolio
Outstandings
Of which:
performing
Of which:
non-
performing
% of total
portfolio
Loan
modification
11,726
6,734
4,993
1.4%
11,881
7,550
4,331
1.4%
Refinancing
1,091
444
647
0.1%
1,208
497
711
0.1%
Total
12,817
7,178
5,640
1.5%
13,089
8,047
5,042
1.5%
As of 31 December 2024, ING\u2019s total forborne assets decreased by \u20ac272 million compared to 31 December
2023. WB decreased by \u20ac129 million and Retail decreased by \u20ac143 million.
Wholesale Banking (*)
As of December 2024, WB forborne assets amounted to \u20ac5.9 billion (2023: \u20ac6.1 billion), which represented
1.9% (2023: 1.8%) of the total WB portfolio.
Wholesale Banking: Forborne portfolio by geographical area (*)
in EUR million
2024
2023
Region
Outstandings
Of which:
performing
Of which: non-
Outstandings
Of which:
performing
Of which: non-
performing
performing
Europe
Netherlands
217
69
148
361
301
60
Belgium
172
165
7
454
446
8
Germany
372
62
310
288
148
139
United
Kingdom
444
266
178
583
425
158
Italy
389
353
36
54
19
34
Norway
0
0
0
6
0
6
Poland
630
284
346
520
519
0
Rest of Europe
1,339
940
399
1,421
1,142
279
America
1,586
867
719
1,025
532
493
Asia
652
111
541
1,198
277
921
Australia
79
34
44
87
87
\u2014
Africa
54
40
15
68
23
45
Total
5,934
3,191
2,743
6,063
3,919
2,144
Wholesale Banking: Forborne portfolio by economic sector (*)
in \u20ac million
2024
2023
Industry
Outstandings
Of which:
performing
Of which: non-
Outstandings
Of which:
performing
Of which: non-
performing
performing
Natural Resources
781
424
356
788
321
467
Real Estate
1,115
703
412
1,320
1,254
66
Transportation & Logistics
214
83
131
315
175
139
Food, Beverages &
Personal Care
810
415
395
866
465
401
Services
211
176
34
284
254
30
Automotive
332
183
149
138
98
40
Utilities
677
301
376
510
255
255
General Industries
127
70
58
145
74
71
Retail
149
21
128
282
104
178
Chemicals, Health &
Pharmaceuticals
668
136
532
571
559
11
Builders & Contractors
122
118
5
133
72
61
Other
729
561
168
712
287
425
Total
5,934
3,191
2,743
6,063
3,919
2,144
Net decrease in WB is driven by the performing forborne exposures -\u20ac728 million. Non-performing forborne
assets increased by \u20ac599 million, mainly in Chemicals, Health & Pharmaceuticals and in Real Estate in line
with earlier mentioned NPL increases.
WB's forborne assets are mainly concentrated in real estate; food, beverages & personal care; natural
resources; chemicals, health & pharmaceuticals; and utilities. These five sectors accounted for 68.3% of the
total WB forborne outstandings.
Retail Banking (*)
As of 31 December 2024, Retail Banking forborne assets amounted to \u20ac6.9 billion (2023: \u20ac7.0 billion), which
represented 1.3% (2023: 1.4%) of the total RB portfolio. 26.7% f the forborne exposures were in Private
Individuals.\u00a0
Retail Banking: Forborne portfolio by geographical area (*)
in \u20ac million
2024
2023
Region
Outstandings
Of which:
performing
Of which: non-
Outstandings
Of which:
performing
Of which: non-
performing
performing
Europe
Netherlands
1,548
1,134
414
1,483
981
502
Belgium
1,942
800
1,142
2,153
838
1,315
Germany
1,379
1,052
327
1,309
1,064
246
Poland
777
403
374
852
522
330
T\u00fcrkiye
13
9
4
25
15
10
Italy
122
43
79
123
51
71
Romania
173
72
101
135
49
86
Spain
159
127
31
138
118
21
Rest of Europe
102
50
52
88
58
30
America
22
17
6
21
20
Asia
1
1
2
1
1
Australia
646
279
367
697
411
286
Africa
Total
6,883
3,987
2,897
7,026
4,128
2,898
The main concentration of forborne assets in a single country was in Belgium with 28.2% (2023: 30.6%) of
total Retail Banking forborne assets and 39.4% (2023: 45.4%) of the non-performing forborne assets,
followed by the Netherlands with 22.5% (2023: 21.1%) and Germany having 20.0% (2023: 18.6%) of the total
Retail forborne assets.
Non-performing loans (*)
ING has aligned the regulatory concept of non-performing with that of the definition of default. Hence,
borrowers are classified as non-performing when a default trigger occurs:
\u2022 ING believes the borrower is unlikely to pay. The borrower has evidenced significant financial difficulty, to
the extent that it will have a negative impact on the future cash flows of the financial asset. The following
events could be seen as indicators of financial difficulty:
\u2022 The borrower (or third party) has started insolvency proceedings;
\u2022 A group company/co-borrower has NPL status;
\u2022 Indication of fraud (affecting the company\u2019s ability to service its debt);
\u2022 There is doubt as to the borrower\u2019s ability to generate stable and sufficient cash flows to service its
debt; and
\u2022 Restructuring of debt.
\u2022 ING 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.
\u2022 The obligor has failed in the payment of principal, interest or fees; the total past due amount is above the
materiality threshold and this remains the case for more than 90 consecutive days.
Further, WB has an individual name approach, using early warning indicators to signal possible future issues
in debt service.
The table below represents the breakdown of credit risk outstandings that have been classified as non-
performing by sector and business line.
Non-performing Loans: outstandings by economic sector and business lines (*)1
in EUR million
Wholesale Banking
Retail Banking
Total
Industry
2024
2023
2024
2023
2024
2023
Private Individuals
4
4
4,766
4,416
4,769
4,419
Natural Resources
965
669
99
85
1,064
754
Food, Beverages & Personal
Care
452
565
357
520
809
1,085
Transportation & Logistics
347
437
157
134
504
572
Services
102
101
394
481
495
582
Real Estate
831
592
603
462
1,434
1,053
General Industries
236
111
451
385
687
497
Builders & Contractors
51
124
445
453
496
577
Retail
157
207
224
188
381
395
Utilities
582
331
19
18
600
348
Chemicals, Health &
Pharmaceuticals
654
101
185
132
839
233
Telecom
151
378
12
12
163
390
Other
666
412
387
336
1,052
748
Total
5,196
4,034
8,099
7,619
13,295
11,653
1 Based on lending and investment outstandings.
Non-performing Loans: outstandings by economic sectors and geographical area (*)
in EUR million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United Kingdom
France
Luxembourg
Rest of Europe
America
Asia
Australia
Africa
2024
Private Individuals
646
1,461
1,066
210
304
10
8
44
545
2
2
469
4,769
Natural Resources
13
54
33
569
31
343
21
1,064
Food, Beverages & Personal Care
196
154
1
93
23
5
158
51
127
809
Transportation & Logistics
93
40
3
124
47
1
136
1
59
504
Services
57
293
5
87
2
1
3
5
10
34
495
Real Estate
12
374
63
114
59
59
90
6
606
52
1,434
General Industries
153
123
24
147
20
2
1
170
17
30
687
Builders & Contractors
68
175
5
162
7
78
496
Retail
53
97
39
62
3
14
97
15
1
381
Utilities
13
8
25
21
285
12
128
109
600
Chemicals, Health & Pharmaceuticals
37
94
84
340
1
110
113
36
24
839
Telecom
7
1
3
44
14
90
4
163
Other
202
198
117
60
2
72
17
90
54
92
150
1,052
Total
1,549
3,071
1,432
1,457
432
322
307
166
1,916
1,145
723
567
210
13,295
Non-performing Loans: outstandings by economic sectors and geographical area (*)
in EUR million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United Kingdom
France
Luxembourg
Rest of Europe
America
Asia
Australia
Africa
2023
Private Individuals
609
1,535
885
225
235
3
8
45
489
2
2
380
1
4,419
Natural Resources
30
60
1
23
55
164
31
369
20
754
Food, Beverages & Personal Care
281
157
1
131
139
7
158
82
128
1,085
Transportation & Logistics
110
50
2
51
47
20
1
168
49
1
2
72
572
Services
121
342
2
55
2
3
8
13
37
582
Real Estate
40
297
53
55
9
36
16
7
519
21
1,053
General Industries
145
127
49
99
2
7
24
42
496
Builders & Contractors
113
181
2
135
22
91
32
577
Retail
51
82
36
52
2
14
149
7
395
Utilities
14
5
21
18
153
138
348
Chemicals, Health & Pharmaceuticals
31
77
13
25
64
11
12
233
Telecom
12
1
28
3
13
56
277
390
Other
28
239
42
55
2
1
6
23
46
128
179
748
Total
1,586
3,153
1,114
929
293
165
124
162
1,193
1,210
1,050
403
272
11,653
In 2024, the NPL portfolio increased to \u20ac13.3 billion. n increase in Wholesale Banking (+\u20ac1.2 billion) together
with an increase in Retail Banking (+\u20ac0.5 billion). The increase in Wholesale Banking was mainly witnessed in
real estate; chemicals, health & pharmaceuticals; and in natural resources, partially offset by telecom. In
Retail Banking, the increase was concentrated in Private Individuals. The top three countries by NPL
outstanding are Belgium, the Netherlands and Poland.
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,
financial- and non-financial guarantees issued.
ING distinguishes between two types of calculation methods for credit loss allowances:
\u2022 Collective 12-month ECL (Stage 1) and collective lifetime ECL (Stage 2) for portfolios of financial
instruments, as well as collective lifetime ECL for credit-impaired exposures (Stage 3) below \u20ac1 million;
\u2022 Individual 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: (i) to the economic outlook and (ii) for Stage 2 and Stage 3 assets only, to the lifetime horizon.
The IFRS 9 model parameters are estimated based on statistical techniques and supported by expert
judgement.
ING has aligned the definition of default for regulatory purposes with the definition of \u2018credit-impaired\u2019
financial assets under IFRS 9 (Stage 3). ING has also aligned its definition of default between IFRS 9 and the
regulatory technical standards (RTS) and EBA guidelines. More information can be found in section 1.5.6 of
the consolidated financial statements.
Climate and environmental risks in IFRS 9 models (*)
Climate risk drivers (physical and transition risks) can reduce the ability of businesses and households to fulfil
their obligations due on existing lending contracts. These may also lead to the depreciation/erosion of
collateral values, which would translate into higher credit losses and loan-to-value ratios in the lending
portfolio of ING.
Currently, it is not yet possible to fully incorporate climate risk separately into IFRS 9 ECL models given the
lack of sufficient empirical historical data and data limitations in the risk assessments on client level.
However, ING has taken next steps in 2024 to more explicitly cover for climate-risk drivers in loan loss
provisioning. A management adjustment to ECL models for business clients was introduced to specifically
cover for the medium- to long-term transition risk on high greenhouse gas-emitting sectors. For households,
particularly the mortgage book, next step in the development will be to apply differentiation in collateral
valuation based on EPC labels.
Additionally, where climate and environmental factors have impacted the economy in the recent past or
present, these impacts are implicitly embedded in ING\u2019s IFRS 9 ECL models through the projected
macroeconomic indicators (e.g. indirectly via GDP growth and unemployment rates). We note, however, 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 specific climate-related matters, particularly physical risk events that have
already occurred (e.g. floods, stranded assets etc.), the impact of such events is individually assessed in the
calculation of Stage 3 individual provisions, collective SICR or management adjustments to ECL models. For
example, we consider whether affected assets have suffered from a significant increase in credit risk (or are
credit impaired) and whether the ECL is appropriate. Furthermore as at 31 December 2024 we have reported
a management adjustment for the increased expected credit risk in the Mortgage and Consumer Lending
portfolio in Spain due to payment holidays provided for customers with collateral or activities in the Valencia
area impacted by the severe floods in the fourth quarter of 2024. For more, see \u2018Management adjustments
applied this reporting period\u2019.
Going forward, ING aims to continue to improve on climate risk data, which will enable us to further embed
climate risks into the IFRS 9 ECL models. For further details on ESG risk management, see \u2018ESG risk\u2019
Portfolio quality (*)
The table below describes the portfolio composition over the different IFRS 9 stages and rating classes. The
Stage 1 portfolio represents 91.1% (2023: 91.5%) of the total gross carrying amounts, mainly composed of
investment grade, while Stage 2 makes up 7.6% (2023: 7.3%) and Stage 3 makes up 1.3% (2023: 1.2%) of the
total gross carrying amounts, respectively.
Gross carrying amount per IFRS 9 stage and rating class (*)1,2, 3
in EUR million
12-month ECL\u00a0 (Stage 1)
Lifetime ECL not credit impaired (Stage 2)
Lifetime ECL credit impaired (Stage 3)
Total
Rating class
Gross carrying amount
Provisions
Gross carrying amount
Provisions
Gross carrying amount
Provisions
Gross carrying amount
Provisions
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
Investment grade
1 (AAA)
79,076
87,122
1
1
281
439
79,357
87,561
1
1
2-4 (AA)
140,671
132,159
10
8
1,579
2,553
1
2
142,250
134,711
11
9
5-7 (A)
244,306
231,018
22
24
6,908
6,188
8
6
251,214
237,206
29
30
8-10 (BBB)
310,114
302,967
55
85
24,683
17,004
55
24
334,797
319,971
110
108
Non-Investment grade
11-13 (BB)
154,348
157,387
190
226
18,479
19,273
91
93
172,827
176,661
281
319
14-16 (B)
25,377
26,414
124
164
17,433
19,336
366
455
42,811
45,750
490
618
17 (CCC)
905
617
8
10
3,992
3,928
173
233
4,897
4,545
181
242
Performing
Restructuring
18 (CC)
4,059
4,617
233
402
4,060
4,617
233
402
19 (C)
2,474
1,919
203
221
2,474
1,919
203
221
Non-performing loans
20-22 (D)
13,742
11,956
4,509
3,887
13,742
11,956
4,509
3,887
Total
954,798
937,684
409
517
79,888
75,257
1,130
1,435
13,742
11,956
4,509
3,887
1,048,429
1,024,897
6,049
5,839
1 Compared to the credit risk portfolio, the differences are mainly undrawn committed amounts (\u20ac155 billion; 2023: \u20ac151 billion) and other positions (\u20ac6 billion; 2023: \u20ac9 billion) not included in credit outstandings and non-IFRS 9 eligible assets (\u20ac75 billion; 2023: \u20ac67 billion), mainly
pre-settlement exposures) included in credit outstandings but not in the gross carrying amounts.
2 Stage 3 lifetime credit impaired provision includes \u20ac21 million (2023: \u20ac11 million) on purchased or originated credit impaired.
Changes in gross carrying amounts and loan loss provisions (*)
The table below provides a reconciliation by stage of the gross carrying amount and allowances for loans
and advances to banks and customers, including loan commitments and financial guarantees. The transfers
of financial instruments represent the impact of stage transfers upon the gross carrying/nominal amount
and associated allowance for ECL. This includes the net-remeasurement of ECL arising from stage transfers,
for example, moving from a 12-month (Stage 1) to a lifetime (Stage 2) ECL measurement basis.
The net-remeasurement line represents the changes in provisions for facilities that remain in the same
stage.
Please note the following comments with respect to the movements observed in the table below:
\u2022 Stage 3 gross carrying amount increased by \u20ac1.7 billion from \u20ac12.0 billion as at 31 December 2023 to
\u20ac13.7 billion as at 31 December 2024, mainly as a result of \u20ac4.8 billion net inflow into NPL (credit
impaired) in 2024 which is offset by \u20ac1.8 billion derecognitions and repayments and \u20ac1.3 billion write-offs
and disposals. Following the increase in carrying amount, Stage 3 provisions increased by \u20ac0.6 billion.
\u2022 Stage 2 gross carrying amounts increased by \u20ac4.6 billion from \u20ac75.3 billion as at 31 December 2023 to
\u20ac79.9 billion as at 31 December 2024, largely driven by \u20ac23.7 billion net transfers from Stage 1 into Stage
2, including the impact of changes in risk drivers (including updated macro-economic forecasts), model
redevelopments mainly for Wholesale Banking models and new Stage 2 overlays. This was offset by a
decrease of exposure by \u20ac16.2 billion due to derecognised financial assets (including sales), repayments
and \u20ac2.9 billion exposure moving to Stage 3. Stage 2 provisions decreased by \u20ac0.3 billion to \u20ac1.1 billion as
of 31 December 2024.
Changes in gross carrying amounts and loan loss provisions (*)1, 2
in EUR million
12-month ECL\u00a0 (Stage
1)
Lifetime ECL not
credit impaired
(Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
12-month ECL\u00a0
(Stage 1)
Lifetime ECL not
credit impaired
(Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
2024
2023
Opening balance
937,684
517
75,258
1,435
11,956
3,887
1,024,897
5,839
884,886
580
70,725
1,679
11,708
3,841
967,319
6,100
Impact of changes in accounting policies
37,079
9
4,704
13
158
73
41,941
95
Adjusted opening balance
921,965
589
75,429
1,692
11,866
3,914
1,009,260
6,195
Transfer into 12-month ECL (Stage 1)
20,276
22
-20,026
-195
-249
-34
-207
11,832
28
-11,583
-239
-249
-36
0
-247
Transfer into lifetime ECL not credit impaired (Stage 2)
-43,155
-49
43,900
429
-745
-96
285
-29,134
-67
29,849
449
-716
-105
0
276
Transfer into lifetime ECL credit impaired (Stage 3)
-2,980
-18
-2,856
-235
5,836
1,802
1,548
-2,053
-10
-1,775
-114
3,828
978
0
853
Net remeasurement of loan loss provisions
-180
-137
185
-133
0
-149
0
-94
0
59
0
-183
New financial assets originated or purchased
212,529
192
212,529
192
195,826
204
0
0
0
0
195,826
204
Financial assets that have been derecognised
-126,858
-76
-11,840
-153
-1,450
-257
-140,148
-485
-121,991
-72
-14,239
-215
-1,475
-266
-137,705
-552
Net drawdowns and repayments
-41,763
-4,406
-309
-46,478
-38,758
0
-2,386
0
-229
0
-41,372
0
Changes in models/risk parameters
8
-6
-22
-20
0
7
0
11
0
84
0
102
Increase in loan loss provisions
-101
-297
1,578
1,179
-58
-203
714
452
Write-offs3
-1,017
-1,017
-1,017
-1,017
-3
-3
-787
-787
-790
-790
Disposals3
-935
-1
-141
-8
-279
-215
-1,355
-225
-38
-38
-283
-283
-321
-321
Recoveries of amounts previously written off
69
69
0
0
0
0
0
71
0
71
Foreign exchange and other movements
-5
208
203
0
-12
0
-15
0
257
0
231
Closing balance
954,798
409
79,888
1,130
13,742
4,509
1,048,429
6,048
937,684
517
75,258
1,435
11,956
3,887
1,024,897
5,839
1 Stage 3 lifetime credit impaired provision includes \u20ac21 million (2023: \u20ac11 million) on purchased or originated credit impaired.
2 The addition to the loan provision (in the consolidated statement of profit or loss) amounts to \u20ac1,194 million (2023: \u20ac520 million) of which \u20ac1,170 million (2023: \u20ac483 million)related to IFRS 9 eligible financial assets, \u20ac9 million (2023: \u20ac-31 million) related to non-credit
replacement guarantees and \u20ac15 million(2023: \u20ac67 million) to modification gains and losses on restructured financial assets.
3 Table was updated for presentation purposes to disaggregate utilisation of the provision between write-offs and disposals. Comparatives have been updated accordingly.
Modification of financial assets (*)
The table below provides the following information:
\u2022 Financial assets that were modified during the year (i.e. qualified as forborne) while they had a loss
allowance measured at an amount equal to lifetime ECL.
\u2022 Financial assets that were reclassified to Stage 1 during the period.
Financial assets modified (*)
in EUR million
2024
2023
Financial assets modified during the period
Amortised cost before modification
1,888
1,565
Net modification results
-107
-75
Financial assets modified since initial recognition
Gross carrying amount at 31 December of financial assets for which loss allowance has changed
to 12-month measurement during the period
1,506
2,599
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). Input
from a leading third-party service provider is used to complement the consensus with consistent projections
for variables for which there are no consensus estimates available (most notably house prices and \u2013 for
some countries \u2013 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, risk and modelling, while the second panel
consists of relevant senior managers in ING.
Alternative scenarios and probability weights (*)
Two alternative scenarios are taken into account: an upside and a downside scenario. The alternative
scenarios have statistical characteristics as they are based on the forecast deviations of the leading third-
party service provider.
To understand the baseline level of uncertainty around any forecast, the leading third-party service provider
keeps track of all its deviations (so-called forecast errors) of the past 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, the leading third-party service provider runs a survey with respondents from around the
world and across a broad range of industries. In this survey, respondents put forward their views of key risks.
Following the survey results, the distribution of forecast errors (that is being used for determining the
scenarios) may be skewed.
For the downside scenario, ING has chosen the 90th percentile of that distribution because this corresponds
with the way risk management earnings-at-risk is defined within the Group. The upside scenario is
represented by the 10th percentile of the distribution. The applicable percentiles of the distribution imply a
20 percent probability for each alternative scenario. Consequently, the baseline scenario has a 60 percent
probability weighting. Please note that, given their technical nature, the downside and upside scenarios are
not based on an explicit specific narrative.
Macroeconomic scenarios applied (*)
The macroeconomic scenarios applied in the calculation of loan loss provisions are based on the consensus
forecasts.
Baseline assumptions (*)
The general picture that the consensus conveys is that global economic growth is diverging between major
blocs. US growth is expected to continue to outpace European markets, while China is expected to continue
on a declining growth trend, but still at higher rates than seen in advanced markets. Inflation is expected to
remain near target for most advanced economies, although it is set to remain above target for the United
States. With interest rates moderating, although some uncertainty about this path for the US exists at this
point, monetary conditions should turn more favourable for growth. For the housing market, continued price
growth is expected for almost all main markets.
The December 2024 consensus expects global output (as measured by the weighted average GDP growth
rate of ING\u2019s 25 main markets) to slow from 2.5 percent in 2024 to 2.4 percent in 2025. For 2026-2027,
economic growth is expected to come in at 2.4 percent and 2.3 percent respectively.\u00a0
The American economy continues to perform very well despite signs of a slowing labour market around the
summer of 2024. Inflation has come down to more benign levels, which has prompted the Federal Reserve to
lower interest rates. Still, inflation remains above the 2% target and the outlook for inflation has become
more uncertain. The US administration\u2019s economic plans are set to stimulate the economy for 2025, as
reflected in the increased expectations for 2025 GDP of consensus forecasters. The consensus expects the
growth rate of the US economy to slow from 2.7 percent in 2024 to 2.0 percent for both 2025 and 2026.The
eurozone economy has seen some growth return in 2024 after a long period of stagnation that started
during the energy crisis. Still, expectations for 2025 remain modest. The export environment continues to be
plagued by weak global demand and investments are stymied by high interest rates and weak
manufacturing performance. Expectations of a pickup in growth over the course of the year hang on
domestic drivers like a pickup in real wage growth and continued rate cuts from the ECB at the start of the
year. Consensus expects the eurozone to have grown by only 0.8 percent in 2024, before recovering slightly
to 1.0 percent and 1.2 percent in 2025 and 2026 respectively.Elsewhere in Europe, the outlook is more
upbeat. In Poland, domestic demand appears to remain the key growth driver over the near-term forecast.
Foremost, consumers remain willing to spend, encouraged by elevated wage growth and a resilient labour
market. The economy is expected to grow by 2.7 percent in 2024, picking up to 3.5 percent in 2025 and 3.8
percent in 2026. The consensus expectation for T\u00fcrkiye is to see growth slow, which is being confirmed by
weak incoming data. Consensus expects growth to slow from 3.1 percent in 2024 to 2.6 percent in 2025, in
part due to soft demand from export orders. For 2026, a recovery to 3.5 percent is expected. The Russian
economy is expected to slow substantially in 2025 after a strong 2024. Growth is expected to drop from 3.7
percent in 2024 to 1.6 percent in 2025 and 1.3 percent in 2026.
For China, economic underperformance continues as it still struggles with the impact of the real estate
correction and weak domestic demand. Large scale stimulus plans and a possible bottoming out of the real
estate market do help economic forecasts for the short-run, although medium term consensus continues to
be downbeat for the moment. For 2024, consensus expects 4.8 percent growth, down to 4.4 percent in 2025
and 4.1 percent in 2026.
Economic momentum in Australia is expected to be soft. The economy is lacking a clear growth engine, with
the private sector clearly struggling against restrictive policy settings and consumers facing a tough outlook.
Growth is expected to have come in at 1.2 percent in 2024, with just moderate pick-up expected for 2025 to
2.0 percent and 2.4 percent for 2026.
When compared to the June 2024 consensus forecast, the December 2024 forecast is relatively stable.
Global GDP is expected to increase by 2.5 percent in 2024 (compared to 2.4 percent assumed before) and is
expected to grow by 2.4 percent in 2025 (2.3 percent assumed before). With the energy crisis and pandemic
now further behind us, the consensus for economic activity in major markets is showing smaller deviations
over time despite economic and geopolitical uncertainty still being very prevalent.
Alternative scenarios and risks (*)
The baseline scenario assumes continued steady economic growth. However, a longer period of weakness,
due to even more concerning geopolitical tensions, persistent elevated inflation and trade tensions 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 downside scenario \u2013 though technical in nature \u2013 sees a recession in 2025 and 2026 for most countries.
Unemployment increases strongly in this scenario and house prices in most countries show outright falls.
The downside scenario captures the possible impact from escalating geopolitical tensions, increased trade
tensions and persistent elevated inflation.
The upside scenario \u2013 while equally technical in nature \u2013 reflects the possibility of a better economic out-turn
because of a substantial loosening of monetary policy, and policy stimulus in China.
Management adjustments applied this reporting period (*)
In times of volatility and uncertainty where portfolio quality and the economic environment are changing
rapidly, models alone may not be able to accurately predict losses. In these cases, management
adjustments can be applied to appropriately reflect ECL. Management adjustments can also be applied
where the impact of the updated macroeconomic scenarios is over- or under-estimated by the IFRS 9
models, as well as to reflect the impact of model redevelopment or recalibration and periodic model
assessment procedures that have not been incorporated in the IFRS 9 models yet.
ING has internal governance frameworks and controls in place to assess the appropriateness of all
management adjustments.
Management adjustments to ECL models (*)
in EUR million
2024
2023
Commercial Real Estate/ Inflation and interest rate increases
50
351
Economic sector / portfolio based adjustments
38
36
Mortgage portfolio adjustments
112
126
Climate transition risk
29
Other Post Model Adjustments
-27
64
Total management adjustments
203
577
As the ING credit risk models generally assume that inflation and interest rate increase risks materialise via
other risk drivers, such as GDP and unemployment rates with a delay, an overlay approach was determined
in previous financial years to timely estimate the expected credit losses (ECL) related to reduced repayment
capacity and affordability for private individuals and business clients in the Retail Banking segment.
As inflationary stress has decreased since origination of the overlay approach and the limited observed
impact in both the Retail and the Wholesale Banking segment, no management adjustment is reported as at
31 December 2024, with exception of a management adjustment of \u20ac50 million for the Commercial Real
Estate portfolio (31 December 2023: \u20ac351 million in total). The \u20ac50 million management adjustment related
to the Commercial Real Estate portfolio is reported in Wholesale Banking (\u20ac33.5 million) and in Business
Banking in the Netherlands (\u20ac16.5 million) because the prevailing risks from increased levels of interest rates
and inflation still exist for this sector in these portfolios. This management adjustment is reflected in Stage 1
and Stage 2.Furthermore, in specific parts in the Retail Banking segment, that were previously included in the
inflation and interest rate increases overlay and where increased risked not yet captured in the credit risk
models are still observed, specific portfolio-based adjustments have been recognised.
As at 31 December 2024, the economic sector / portfolio based adjustments in Stage 2 of \u20ac38 million in total
included a management adjustment of \u20ac14 million for the increased expected credit risk in the Mortgage
and Consumer Lending portfolio in Spain due to payment holidays provided for customers with collateral or
activities in the areas impacted by the severe floods in the Valencia area in the fourth quarter of 2024.
Furthermore, adjustments have been taken in the Business Banking portfolio in Germany (\u20ac10 million) to
cover for the increased uncertainty in the German economy and to the Mortgage portfolio in Australia (\u20ac15
million) to cover for affordability risk from inflation and interest rate increases.
The economic sector adjustments as at 31 December 2023 of \u20ac36 million, fully related to Business Banking
clients that have benefited from government support programs in the Netherlands during the Covid-19
pandemic. This adjustment was released in full in 2024 as the risk was considered to be no longer present in
the portfolio. The overall mortgage portfolio adjustment as at 31 December 2024 decreased to \u20ac112 million
(31 December 2023: \u20ac126 million). The management adjustment in Stage 2 for the risk segmentation model
that captures affordability, repayment and refinancing risk on performing mortgage customers with a bullet
loan in the Netherlands was decreased to \u20ac112 million (31 December 2023: \u20ac115 million). The mortgage
portfolio adjustment that related to the overvaluation of house prices was released in full in 2024 (31
December 2023: \u20ac11 million).
As of 31 December 2024, an adjustment of \u20ac29 million was introduced to cover for the impact of climate
transition risk in Wholesale Banking (\u20ac17 million) and in Business Banking (\u20ac12 million). Climate transition risk
is expected to lead to a structural change in credit risk, which means specific business activities will become
structurally riskier due to environmental policies, technological progress or changes in market sentiment and
preferences. The current IFRS 9 models do not capture this (novel) risk. The management adjustment to ECL
models for business clients was made to specifically cover for the medium- to long-term transition risk on
high greenhouse gas-emitting sectors and is reported in Stage 2.
Other post-model adjustments mainly relate to the impact of model redevelopment or recalibration and
periodic model assessment procedures that have not been incorporated in the ECL models yet. The impact
on total ECL can be positive or negative. These result from both regular model maintenance and ING\u2019s
multiyear programme to update ECL models. These adjustments will be removed once updates to the
specific models have been implemented. The change in balance compared to previous reporting date is due
to i) released PMAs because of model updates that have been implemented and ii) new PMAs recognised for
new redevelopments and recalibrations.
Analysis on sensitivity (*)
The table below presents the analysis on the sensitivity of key forward-looking macroeconomic inputs used
in the ECL collective-assessment modelling process and the probability weights applied to each of the three
scenarios. The countries included in the analysis are the most significant geographic regions in ING, and for
Wholesale Banking the US is the most significant in terms of both gross contribution to reportable ECL and
sensitivity of ECL to forward-looking macroeconomics. Accordingly, ING considers these portfolios to present
the most significant risk of resulting in a material adjustment to the carrying amount of financial assets
within the next financial year. 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 2024\u00a0 (*)
2025
2026
2027
Un-weighted
ECL (\u20ac mln)
Probability-
weighting
Reportable
ECL (\u20ac mln)1
Netherlands
Upside scenario
Real GDP
2.6
3.0
2.5
193
20%
270
Unemployment
3.5
3.3
3.3
HPI
18.9
11.7
2.5
Baseline scenario
Real GDP
1.5
1.4
1.5
249
60%
Unemployment
4.0
4.1
4.3
HPI
9.1
3.5
2.4
Downside scenario
Real GDP
-0.4
-1.4
-0.2
411
20%
Unemployment
5.7
7.2
8.1
HPI
-3.7
-7.2
2.2
Germany
Upside scenario
Real GDP
2.0
2.8
1.6
510
20%
548
Unemployment
2.9
2.4
2.0
HPI
5.4
8.9
9.9
Baseline scenario
Real GDP
0.5
1.1
1.2
540
60%
Unemployment
3.4
3.3
3.2
HPI
2.6
5.6
6.3
Downside scenario
Real GDP
-1.7
-1.7
0.3
609
20%
Unemployment
4.7
5.6
5.9
HPI
-1.7
1.3
2.2
Belgium
Upside scenario
Real GDP
2.2
2.6
2.1
534
20%
579
Unemployment
5.1
5.0
4.9
HPI
4.8
4.5
4.4
Baseline scenario
Real GDP
1.1
1.5
1.6
569
60%
Unemployment
5.7
5.7
5.6
HPI
3.2
4.1
3.8
Downside scenario
Real GDP
-0.6
-0.2
1.1
654
20%
Unemployment
7.0
8.0
8.0
HPI
1.2
2.9
2.5
United States
Upside scenario
Real GDP
3.1
3.5
3.2
74
20%
113
Unemployment
3.4
2.4
2.3
HPI
4.3
8.4
9.4
Baseline scenario
Real GDP
2.0
2.0
2.0
101
60%
Unemployment
4.2
4.1
4.0
HPI
3.3
3.7
3.9
Downside scenario
Real GDP
-0.1
-1.1
-0.4
187
20%
Unemployment
5.9
7.3
8.0
HPI
-0.7
-3.0
-2.5
1 Excluding management adjustments.
Sensitivity analysis as at December 2023 (*)
2024
2025
2026
Un-weighted
ECL (\u20ac mln)
Probability-
weighting
Reportable
ECL (\u20ac mln)1
Netherlands
Upside scenario
Real GDP
1.3
3.3
2.8
214
20%
310
Unemployment
3.7
3.3
3.3
HPI
10.4
11.2
4.0
Baseline scenario
Real GDP
0.8
1.6
1.5
282
60%
Unemployment
4.1
4.3
4.5
HPI
0.9
3.0
3.9
Downside scenario
Real GDP
-1.7
-1.2
0.1
487
20%
Unemployment
5.9
7.2
8.1
HPI
-10.9
-7.4
3.7
Germany
Upside scenario
Real GDP
1.4
3.1
1.6
472
20%
525
Unemployment
2.6
2.0
1.7
HPI
0.9
6.6
8.0
Baseline scenario
Real GDP
0.5
1.3
1.2
513
60%
Unemployment
3.0
3.0
3.0
HPI
-1.4
3.4
4.5
Downside scenario
Real GDP
-2.4
-1.4
0.3
615
20%
Unemployment
4.5
5.2
5.5
HPI
-6.0
-0.8
0.4
Belgium
Upside scenario
Real GDP
1.5
2.7
2.3
568
20%
619
Unemployment
5.3
5.0
4.9
HPI
1.3
5.6
4.5
Baseline scenario
Real GDP
0.9
1.5
1.8
604
60%
Unemployment
5.6
5.5
5.4
HPI
0.4
5.2
3.9
Downside scenario
Real GDP
-1.3
-0.2
1.2
713
20%
Unemployment
7.3
8.0
7.9
HPI
-2.2
3.9
2.6
United States
Upside scenario
Real GDP
1.8
3.2
3.4
102
20%
165
Unemployment
4.1
3.3
3.1
HPI
0.6
8.7
8.7
Baseline scenario
Real GDP
0.9
1.9
2.1
144
60%
Unemployment
4.5
4.5
4.4
HPI
-0.7
3.5
3.3
Downside scenario
Real GDP
-1.3
-1.4
-0.1
292
20%
Unemployment
6.6
8.2
8.8
HPI
-4.2
-2.7
-3.0
1 Excluding management adjustments.
When compared to the sensitivity analysis of 2023, the macroeconomic inputs are overall more favourable.
This is driven by an improved macroeconomic outlook, mainly because economies prove to be rather
resilient to increased interest rates, particularly in the US, as well as recovery in house prices in, among
others, the Netherlands.
On a total ING level, the unweighted ECL for all collective provisioned clients in the upside scenario was
\u20ac2,721 million, in the baseline scenario \u20ac2,949 million and in the downside scenario \u20ac3,533 million compared
to \u20ac3,020 million reportable collective provisions as at 31 December 2024 (excluding all management
adjustments). To perform the sensitivity analysis, a point in time reportable ECL is used as input, which
slightly deviates from the total Model ECL as reported below:
Reconciliation of reportable collective ECL to total ECL (*)
in EUR million
2024
2023
Total reportable collective provisions
2,975
2,856
ECL from individually assessed impairments
2,871
2,406
ECL from management adjustments
203
577
Total ECL
6,049
5,839
Criteria for identifying a significant increase in credit risk (SICR) (*)
All assets and off-balance-sheet items that are in scope of IFRS 9 impairment and which are subject to
collective ECL assessment are allocated a 12-month ECL if deemed to belong in Stage 1, or a lifetime ECL if
deemed to belong in Stages 2 or 3. An asset belongs in Stage 2 if it is considered to have experienced a
significant increase in credit risk (SICR) since initial origination or purchase.
The main determinant of SICR is a quantitative test, whereby the lifetime 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 either a threshold for absolute change in lifetime PD or a threshold for relative change in lifetime PD is
reached, the item is considered to have experienced a SICR (for more details on absolute and relative
thresholds, see the following sections). Furthermore, any facility which shows an increase of 200 percent
between the PD at the date of initial recognition and the lifetime PD at the reporting date (i.e. threefold
increase in PD) must be classified as Stage 2. This is considered a backstop within the quantitative
assessment of SICR.
In Wholesale Banking, significant increase in lifetime PD is not considered plausible for assets of obligors with
a credit rating at the reporting date in the top range of investment grade. As of 2024, the assets of these
Wholesale Banking obligors are excluded from the assessment of significant increase in credit risk triggers.
For these obligors the qualitative significant increases in credit risk triggers remain applicable (see the
section below on Qualitative SICR triggers). These are for example the Watchlist and/ or forbearance triggers.
Finally, the 30 days past due backstop also remains applicable for the top range of investment grade
exposures to ensure significant increase in credit risk recognition.
Absolute lifetime PD threshold
The absolute threshold is a fixed value calibrated per portfolio/segment and provides a fixed threshold that, if
exceeded by the difference between lifetime PD at reporting date and lifetime PD at origination, triggers
Stage 2 classification. The absolute threshold is calibrated during model development.
Relative lifetime PD threshold
The relative threshold defines a relative increase of the lifetime PD beyond which a given facility is classified
in Stage 2 because of a significant increase in credit risk. The relative threshold is dependent on the individual
PD assigned to each facility at the moment of origination, and a scaling factor calibrated in the model
development phase.
Ultimately, the relative threshold provides a criterion to assess whether the ratio (i.e. increase) between
lifetime PD at reporting date and lifetime PD at origination date is deemed a significant increase in credit risk.
If the threshold is breached, SICR is identified and Stage 2 is assigned to the given facility.
The threshold for the relative change in lifetime PD is inversely correlated with the PD at origination; the
higher the PD at origination, the lower the threshold. The logic behind this is to allow facilities originated in
very favourable ratings to downgrade for longer without the need of a Stage 2 classification. In fact, it is
likely that such facilities will still be in favourable ratings even after a downgrade of a few notches. On the
contrary, facilities originated in already unfavourable ratings grades are riskier and even a single-notch
downgrade might represent a significant increase in credit risk and thus a tighter threshold will be in place.
Still, the relative threshold is relatively sensitive for investment-grade assets while the absolute threshold
primarily affects non-investment grade assets.
Average threshold ratio
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 2023 and year-end 2024.
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 (*)
2024
2023
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
2.9
2.4
2.5
2.3
Consumer lending
2.8
2.1
2.9
2.1
Business lending
2.7
2.1
2.7
2.1
Governments and financial institutions
2.9
1.9
3.0
1.9
Other Wholesale Banking
2.7
1.9
2.8
1.8
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.
Sensitivity of ECL to PD lifetime PD thresholds
The setting of PD threshold bands requires management judgement and is a key source of estimation
uncertainty. On Group level, the total model ECL on performing assets, which is the ECL collective-
assessment without taking management adjustments into account, was \u20ac1,328 million as at 31 December
2024 (31 December 2023: \u20ac1,412 million). To demonstrate the sensitivity of the ECL to these PD threshold
bands, hypothetically solely applying the upside scenario would result in total model ECL on performing
assets of \u20ac1,066 million and a decrease in the Stage 2 ratio by 0.5%-point, while solely applying the
downside scenario would result in total model ECL on performing assets of \u20ac1,911 million and an increase in
the Stage 2 ratio by 1.9%-point.
Qualitative SICR thresholds
It should be noted that the lifetime PD thresholds are not the only drivers of stage allocation as ING Bank
also relies on a number of qualitative indicators to identify and assess SICR. An asset can also change stages
as a result of other triggers, such as having over 30 days arrears (used as a backstop), collective SICR
assessment, being on a watch list, being under intensive care management, having a substandard internal
rating or being forborne.", "dimensions": { "concept": "ifrs-full:DisclosureOfCreditRiskExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-4": { "value": "
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,
financial- and non-financial guarantees issued.
ING distinguishes between two types of calculation methods for credit loss allowances:
\u2022 Collective 12-month ECL (Stage 1) and collective lifetime ECL (Stage 2) for portfolios of financial
instruments, as well as collective lifetime ECL for credit-impaired exposures (Stage 3) below \u20ac1 million;
\u2022 Individual 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: (i) to the economic outlook and (ii) for Stage 2 and Stage 3 assets only, to the lifetime horizon.
The IFRS 9 model parameters are estimated based on statistical techniques and supported by expert
judgement.
ING has aligned the definition of default for regulatory purposes with the definition of \u2018credit-impaired\u2019
financial assets under IFRS 9 (Stage 3). ING has also aligned its definition of default between IFRS 9 and the
regulatory technical standards (RTS) and EBA guidelines. More information can be found in section 1.5.6 of
the consolidated financial statements.
Climate and environmental risks in IFRS 9 models (*)
Climate risk drivers (physical and transition risks) can reduce the ability of businesses and households to fulfil
their obligations due on existing lending contracts. These may also lead to the depreciation/erosion of
collateral values, which would translate into higher credit losses and loan-to-value ratios in the lending
portfolio of ING.
Currently, it is not yet possible to fully incorporate climate risk separately into IFRS 9 ECL models given the
lack of sufficient empirical historical data and data limitations in the risk assessments on client level.
However, ING has taken next steps in 2024 to more explicitly cover for climate-risk drivers in loan loss
provisioning. A management adjustment to ECL models for business clients was introduced to specifically
cover for the medium- to long-term transition risk on high greenhouse gas-emitting sectors. For households,
particularly the mortgage book, next step in the development will be to apply differentiation in collateral
valuation based on EPC labels.
Additionally, where climate and environmental factors have impacted the economy in the recent past or
present, these impacts are implicitly embedded in ING\u2019s IFRS 9 ECL models through the projected
macroeconomic indicators (e.g. indirectly via GDP growth and unemployment rates). We note, however, 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 specific climate-related matters, particularly physical risk events that have
already occurred (e.g. floods, stranded assets etc.), the impact of such events is individually assessed in the
calculation of Stage 3 individual provisions, collective SICR or management adjustments to ECL models. For
example, we consider whether affected assets have suffered from a significant increase in credit risk (or are
credit impaired) and whether the ECL is appropriate. Furthermore as at 31 December 2024 we have reported
a management adjustment for the increased expected credit risk in the Mortgage and Consumer Lending
portfolio in Spain due to payment holidays provided for customers with collateral or activities in the Valencia
area impacted by the severe floods in the fourth quarter of 2024. For more, see \u2018Management adjustments
applied this reporting period\u2019.
Going forward, ING aims to continue to improve on climate risk data, which will enable us to further embed
climate risks into the IFRS 9 ECL models. For further details on ESG risk management, see \u2018ESG risk\u2019
Portfolio quality (*)
The table below describes the portfolio composition over the different IFRS 9 stages and rating classes. The
Stage 1 portfolio represents 91.1% (2023: 91.5%) of the total gross carrying amounts, mainly composed of
investment grade, while Stage 2 makes up 7.6% (2023: 7.3%) and Stage 3 makes up 1.3% (2023: 1.2%) of the
total gross carrying amounts, respectively.
Gross carrying amount per IFRS 9 stage and rating class (*)1,2, 3
in EUR million
12-month ECL\u00a0 (Stage 1)
Lifetime ECL not credit impaired (Stage 2)
Lifetime ECL credit impaired (Stage 3)
Total
Rating class
Gross carrying amount
Provisions
Gross carrying amount
Provisions
Gross carrying amount
Provisions
Gross carrying amount
Provisions
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
Investment grade
1 (AAA)
79,076
87,122
1
1
281
439
79,357
87,561
1
1
2-4 (AA)
140,671
132,159
10
8
1,579
2,553
1
2
142,250
134,711
11
9
5-7 (A)
244,306
231,018
22
24
6,908
6,188
8
6
251,214
237,206
29
30
8-10 (BBB)
310,114
302,967
55
85
24,683
17,004
55
24
334,797
319,971
110
108
Non-Investment grade
11-13 (BB)
154,348
157,387
190
226
18,479
19,273
91
93
172,827
176,661
281
319
14-16 (B)
25,377
26,414
124
164
17,433
19,336
366
455
42,811
45,750
490
618
17 (CCC)
905
617
8
10
3,992
3,928
173
233
4,897
4,545
181
242
Performing
Restructuring
18 (CC)
4,059
4,617
233
402
4,060
4,617
233
402
19 (C)
2,474
1,919
203
221
2,474
1,919
203
221
Non-performing loans
20-22 (D)
13,742
11,956
4,509
3,887
13,742
11,956
4,509
3,887
Total
954,798
937,684
409
517
79,888
75,257
1,130
1,435
13,742
11,956
4,509
3,887
1,048,429
1,024,897
6,049
5,839
1 Compared to the credit risk portfolio, the differences are mainly undrawn committed amounts (\u20ac155 billion; 2023: \u20ac151 billion) and other positions (\u20ac6 billion; 2023: \u20ac9 billion) not included in credit outstandings and non-IFRS 9 eligible assets (\u20ac75 billion; 2023: \u20ac67 billion), mainly
pre-settlement exposures) included in credit outstandings but not in the gross carrying amounts.
2 Stage 3 lifetime credit impaired provision includes \u20ac21 million (2023: \u20ac11 million) on purchased or originated credit impaired.
Changes in gross carrying amounts and loan loss provisions (*)
The table below provides a reconciliation by stage of the gross carrying amount and allowances for loans
and advances to banks and customers, including loan commitments and financial guarantees. The transfers
of financial instruments represent the impact of stage transfers upon the gross carrying/nominal amount
and associated allowance for ECL. This includes the net-remeasurement of ECL arising from stage transfers,
for example, moving from a 12-month (Stage 1) to a lifetime (Stage 2) ECL measurement basis.
The net-remeasurement line represents the changes in provisions for facilities that remain in the same
stage.
Please note the following comments with respect to the movements observed in the table below:
\u2022 Stage 3 gross carrying amount increased by \u20ac1.7 billion from \u20ac12.0 billion as at 31 December 2023 to
\u20ac13.7 billion as at 31 December 2024, mainly as a result of \u20ac4.8 billion net inflow into NPL (credit
impaired) in 2024 which is offset by \u20ac1.8 billion derecognitions and repayments and \u20ac1.3 billion write-offs
and disposals. Following the increase in carrying amount, Stage 3 provisions increased by \u20ac0.6 billion.
\u2022 Stage 2 gross carrying amounts increased by \u20ac4.6 billion from \u20ac75.3 billion as at 31 December 2023 to
\u20ac79.9 billion as at 31 December 2024, largely driven by \u20ac23.7 billion net transfers from Stage 1 into Stage
2, including the impact of changes in risk drivers (including updated macro-economic forecasts), model
redevelopments mainly for Wholesale Banking models and new Stage 2 overlays. This was offset by a
decrease of exposure by \u20ac16.2 billion due to derecognised financial assets (including sales), repayments
and \u20ac2.9 billion exposure moving to Stage 3. Stage 2 provisions decreased by \u20ac0.3 billion to \u20ac1.1 billion as
of 31 December 2024.
Changes in gross carrying amounts and loan loss provisions (*)1, 2
in EUR million
12-month ECL\u00a0 (Stage
1)
Lifetime ECL not
credit impaired
(Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
12-month ECL\u00a0
(Stage 1)
Lifetime ECL not
credit impaired
(Stage 2)
Lifetime ECL credit
impaired (Stage 3)
Total
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
Gross
carrying
amount
Provisions
2024
2023
Opening balance
937,684
517
75,258
1,435
11,956
3,887
1,024,897
5,839
884,886
580
70,725
1,679
11,708
3,841
967,319
6,100
Impact of changes in accounting policies
37,079
9
4,704
13
158
73
41,941
95
Adjusted opening balance
921,965
589
75,429
1,692
11,866
3,914
1,009,260
6,195
Transfer into 12-month ECL (Stage 1)
20,276
22
-20,026
-195
-249
-34
-207
11,832
28
-11,583
-239
-249
-36
0
-247
Transfer into lifetime ECL not credit impaired (Stage 2)
-43,155
-49
43,900
429
-745
-96
285
-29,134
-67
29,849
449
-716
-105
0
276
Transfer into lifetime ECL credit impaired (Stage 3)
-2,980
-18
-2,856
-235
5,836
1,802
1,548
-2,053
-10
-1,775
-114
3,828
978
0
853
Net remeasurement of loan loss provisions
-180
-137
185
-133
0
-149
0
-94
0
59
0
-183
New financial assets originated or purchased
212,529
192
212,529
192
195,826
204
0
0
0
0
195,826
204
Financial assets that have been derecognised
-126,858
-76
-11,840
-153
-1,450
-257
-140,148
-485
-121,991
-72
-14,239
-215
-1,475
-266
-137,705
-552
Net drawdowns and repayments
-41,763
-4,406
-309
-46,478
-38,758
0
-2,386
0
-229
0
-41,372
0
Changes in models/risk parameters
8
-6
-22
-20
0
7
0
11
0
84
0
102
Increase in loan loss provisions
-101
-297
1,578
1,179
-58
-203
714
452
Write-offs3
-1,017
-1,017
-1,017
-1,017
-3
-3
-787
-787
-790
-790
Disposals3
-935
-1
-141
-8
-279
-215
-1,355
-225
-38
-38
-283
-283
-321
-321
Recoveries of amounts previously written off
69
69
0
0
0
0
0
71
0
71
Foreign exchange and other movements
-5
208
203
0
-12
0
-15
0
257
0
231
Closing balance
954,798
409
79,888
1,130
13,742
4,509
1,048,429
6,048
937,684
517
75,258
1,435
11,956
3,887
1,024,897
5,839
1 Stage 3 lifetime credit impaired provision includes \u20ac21 million (2023: \u20ac11 million) on purchased or originated credit impaired.
2 The addition to the loan provision (in the consolidated statement of profit or loss) amounts to \u20ac1,194 million (2023: \u20ac520 million) of which \u20ac1,170 million (2023: \u20ac483 million)related to IFRS 9 eligible financial assets, \u20ac9 million (2023: \u20ac-31 million) related to non-credit
replacement guarantees and \u20ac15 million(2023: \u20ac67 million) to modification gains and losses on restructured financial assets.
3 Table was updated for presentation purposes to disaggregate utilisation of the provision between write-offs and disposals. Comparatives have been updated accordingly.
Modification of financial assets (*)
The table below provides the following information:
\u2022 Financial assets that were modified during the year (i.e. qualified as forborne) while they had a loss
allowance measured at an amount equal to lifetime ECL.
\u2022 Financial assets that were reclassified to Stage 1 during the period.
Financial assets modified (*)
in EUR million
2024
2023
Financial assets modified during the period
Amortised cost before modification
1,888
1,565
Net modification results
-107
-75
Financial assets modified since initial recognition
Gross carrying amount at 31 December of financial assets for which loss allowance has changed
to 12-month measurement during the period
1,506
2,599
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). Input
from a leading third-party service provider is used to complement the consensus with consistent projections
for variables for which there are no consensus estimates available (most notably house prices and \u2013 for
some countries \u2013 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, risk and modelling, while the second panel
consists of relevant senior managers in ING.
Alternative scenarios and probability weights (*)
Two alternative scenarios are taken into account: an upside and a downside scenario. The alternative
scenarios have statistical characteristics as they are based on the forecast deviations of the leading third-
party service provider.
To understand the baseline level of uncertainty around any forecast, the leading third-party service provider
keeps track of all its deviations (so-called forecast errors) of the past 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, the leading third-party service provider runs a survey with respondents from around the
world and across a broad range of industries. In this survey, respondents put forward their views of key risks.
Following the survey results, the distribution of forecast errors (that is being used for determining the
scenarios) may be skewed.
For the downside scenario, ING has chosen the 90th percentile of that distribution because this corresponds
with the way risk management earnings-at-risk is defined within the Group. The upside scenario is
represented by the 10th percentile of the distribution. The applicable percentiles of the distribution imply a
20 percent probability for each alternative scenario. Consequently, the baseline scenario has a 60 percent
probability weighting. Please note that, given their technical nature, the downside and upside scenarios are
not based on an explicit specific narrative.
Macroeconomic scenarios applied (*)
The macroeconomic scenarios applied in the calculation of loan loss provisions are based on the consensus
forecasts.
Baseline assumptions (*)
The general picture that the consensus conveys is that global economic growth is diverging between major
blocs. US growth is expected to continue to outpace European markets, while China is expected to continue
on a declining growth trend, but still at higher rates than seen in advanced markets. Inflation is expected to
remain near target for most advanced economies, although it is set to remain above target for the United
States. With interest rates moderating, although some uncertainty about this path for the US exists at this
point, monetary conditions should turn more favourable for growth. For the housing market, continued price
growth is expected for almost all main markets.
The December 2024 consensus expects global output (as measured by the weighted average GDP growth
rate of ING\u2019s 25 main markets) to slow from 2.5 percent in 2024 to 2.4 percent in 2025. For 2026-2027,
economic growth is expected to come in at 2.4 percent and 2.3 percent respectively.\u00a0
The American economy continues to perform very well despite signs of a slowing labour market around the
summer of 2024. Inflation has come down to more benign levels, which has prompted the Federal Reserve to
lower interest rates. Still, inflation remains above the 2% target and the outlook for inflation has become
more uncertain. The US administration\u2019s economic plans are set to stimulate the economy for 2025, as
reflected in the increased expectations for 2025 GDP of consensus forecasters. The consensus expects the
growth rate of the US economy to slow from 2.7 percent in 2024 to 2.0 percent for both 2025 and 2026.The
eurozone economy has seen some growth return in 2024 after a long period of stagnation that started
during the energy crisis. Still, expectations for 2025 remain modest. The export environment continues to be
plagued by weak global demand and investments are stymied by high interest rates and weak
manufacturing performance. Expectations of a pickup in growth over the course of the year hang on
domestic drivers like a pickup in real wage growth and continued rate cuts from the ECB at the start of the
year. Consensus expects the eurozone to have grown by only 0.8 percent in 2024, before recovering slightly
to 1.0 percent and 1.2 percent in 2025 and 2026 respectively.Elsewhere in Europe, the outlook is more
upbeat. In Poland, domestic demand appears to remain the key growth driver over the near-term forecast.
Foremost, consumers remain willing to spend, encouraged by elevated wage growth and a resilient labour
market. The economy is expected to grow by 2.7 percent in 2024, picking up to 3.5 percent in 2025 and 3.8
percent in 2026. The consensus expectation for T\u00fcrkiye is to see growth slow, which is being confirmed by
weak incoming data. Consensus expects growth to slow from 3.1 percent in 2024 to 2.6 percent in 2025, in
part due to soft demand from export orders. For 2026, a recovery to 3.5 percent is expected. The Russian
economy is expected to slow substantially in 2025 after a strong 2024. Growth is expected to drop from 3.7
percent in 2024 to 1.6 percent in 2025 and 1.3 percent in 2026.
For China, economic underperformance continues as it still struggles with the impact of the real estate
correction and weak domestic demand. Large scale stimulus plans and a possible bottoming out of the real
estate market do help economic forecasts for the short-run, although medium term consensus continues to
be downbeat for the moment. For 2024, consensus expects 4.8 percent growth, down to 4.4 percent in 2025
and 4.1 percent in 2026.
Economic momentum in Australia is expected to be soft. The economy is lacking a clear growth engine, with
the private sector clearly struggling against restrictive policy settings and consumers facing a tough outlook.
Growth is expected to have come in at 1.2 percent in 2024, with just moderate pick-up expected for 2025 to
2.0 percent and 2.4 percent for 2026.
When compared to the June 2024 consensus forecast, the December 2024 forecast is relatively stable.
Global GDP is expected to increase by 2.5 percent in 2024 (compared to 2.4 percent assumed before) and is
expected to grow by 2.4 percent in 2025 (2.3 percent assumed before). With the energy crisis and pandemic
now further behind us, the consensus for economic activity in major markets is showing smaller deviations
over time despite economic and geopolitical uncertainty still being very prevalent.
Alternative scenarios and risks (*)
The baseline scenario assumes continued steady economic growth. However, a longer period of weakness,
due to even more concerning geopolitical tensions, persistent elevated inflation and trade tensions 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 downside scenario \u2013 though technical in nature \u2013 sees a recession in 2025 and 2026 for most countries.
Unemployment increases strongly in this scenario and house prices in most countries show outright falls.
The downside scenario captures the possible impact from escalating geopolitical tensions, increased trade
tensions and persistent elevated inflation.
The upside scenario \u2013 while equally technical in nature \u2013 reflects the possibility of a better economic out-turn
because of a substantial loosening of monetary policy, and policy stimulus in China.
Management adjustments applied this reporting period (*)
In times of volatility and uncertainty where portfolio quality and the economic environment are changing
rapidly, models alone may not be able to accurately predict losses. In these cases, management
adjustments can be applied to appropriately reflect ECL. Management adjustments can also be applied
where the impact of the updated macroeconomic scenarios is over- or under-estimated by the IFRS 9
models, as well as to reflect the impact of model redevelopment or recalibration and periodic model
assessment procedures that have not been incorporated in the IFRS 9 models yet.
ING has internal governance frameworks and controls in place to assess the appropriateness of all
management adjustments.
Management adjustments to ECL models (*)
in EUR million
2024
2023
Commercial Real Estate/ Inflation and interest rate increases
50
351
Economic sector / portfolio based adjustments
38
36
Mortgage portfolio adjustments
112
126
Climate transition risk
29
Other Post Model Adjustments
-27
64
Total management adjustments
203
577
As the ING credit risk models generally assume that inflation and interest rate increase risks materialise via
other risk drivers, such as GDP and unemployment rates with a delay, an overlay approach was determined
in previous financial years to timely estimate the expected credit losses (ECL) related to reduced repayment
capacity and affordability for private individuals and business clients in the Retail Banking segment.
As inflationary stress has decreased since origination of the overlay approach and the limited observed
impact in both the Retail and the Wholesale Banking segment, no management adjustment is reported as at
31 December 2024, with exception of a management adjustment of \u20ac50 million for the Commercial Real
Estate portfolio (31 December 2023: \u20ac351 million in total). The \u20ac50 million management adjustment related
to the Commercial Real Estate portfolio is reported in Wholesale Banking (\u20ac33.5 million) and in Business
Banking in the Netherlands (\u20ac16.5 million) because the prevailing risks from increased levels of interest rates
and inflation still exist for this sector in these portfolios. This management adjustment is reflected in Stage 1
and Stage 2.Furthermore, in specific parts in the Retail Banking segment, that were previously included in the
inflation and interest rate increases overlay and where increased risked not yet captured in the credit risk
models are still observed, specific portfolio-based adjustments have been recognised.
As at 31 December 2024, the economic sector / portfolio based adjustments in Stage 2 of \u20ac38 million in total
included a management adjustment of \u20ac14 million for the increased expected credit risk in the Mortgage
and Consumer Lending portfolio in Spain due to payment holidays provided for customers with collateral or
activities in the areas impacted by the severe floods in the Valencia area in the fourth quarter of 2024.
Furthermore, adjustments have been taken in the Business Banking portfolio in Germany (\u20ac10 million) to
cover for the increased uncertainty in the German economy and to the Mortgage portfolio in Australia (\u20ac15
million) to cover for affordability risk from inflation and interest rate increases.
The economic sector adjustments as at 31 December 2023 of \u20ac36 million, fully related to Business Banking
clients that have benefited from government support programs in the Netherlands during the Covid-19
pandemic. This adjustment was released in full in 2024 as the risk was considered to be no longer present in
the portfolio. The overall mortgage portfolio adjustment as at 31 December 2024 decreased to \u20ac112 million
(31 December 2023: \u20ac126 million). The management adjustment in Stage 2 for the risk segmentation model
that captures affordability, repayment and refinancing risk on performing mortgage customers with a bullet
loan in the Netherlands was decreased to \u20ac112 million (31 December 2023: \u20ac115 million). The mortgage
portfolio adjustment that related to the overvaluation of house prices was released in full in 2024 (31
December 2023: \u20ac11 million).
As of 31 December 2024, an adjustment of \u20ac29 million was introduced to cover for the impact of climate
transition risk in Wholesale Banking (\u20ac17 million) and in Business Banking (\u20ac12 million). Climate transition risk
is expected to lead to a structural change in credit risk, which means specific business activities will become
structurally riskier due to environmental policies, technological progress or changes in market sentiment and
preferences. The current IFRS 9 models do not capture this (novel) risk. The management adjustment to ECL
models for business clients was made to specifically cover for the medium- to long-term transition risk on
high greenhouse gas-emitting sectors and is reported in Stage 2.
Other post-model adjustments mainly relate to the impact of model redevelopment or recalibration and
periodic model assessment procedures that have not been incorporated in the ECL models yet. The impact
on total ECL can be positive or negative. These result from both regular model maintenance and ING\u2019s
multiyear programme to update ECL models. These adjustments will be removed once updates to the
specific models have been implemented. The change in balance compared to previous reporting date is due
to i) released PMAs because of model updates that have been implemented and ii) new PMAs recognised for
new redevelopments and recalibrations.
Analysis on sensitivity (*)
The table below presents the analysis on the sensitivity of key forward-looking macroeconomic inputs used
in the ECL collective-assessment modelling process and the probability weights applied to each of the three
scenarios. The countries included in the analysis are the most significant geographic regions in ING, and for
Wholesale Banking the US is the most significant in terms of both gross contribution to reportable ECL and
sensitivity of ECL to forward-looking macroeconomics. Accordingly, ING considers these portfolios to present
the most significant risk of resulting in a material adjustment to the carrying amount of financial assets
within the next financial year. 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 2024\u00a0 (*)
2025
2026
2027
Un-weighted
ECL (\u20ac mln)
Probability-
weighting
Reportable
ECL (\u20ac mln)1
Netherlands
Upside scenario
Real GDP
2.6
3.0
2.5
193
20%
270
Unemployment
3.5
3.3
3.3
HPI
18.9
11.7
2.5
Baseline scenario
Real GDP
1.5
1.4
1.5
249
60%
Unemployment
4.0
4.1
4.3
HPI
9.1
3.5
2.4
Downside scenario
Real GDP
-0.4
-1.4
-0.2
411
20%
Unemployment
5.7
7.2
8.1
HPI
-3.7
-7.2
2.2
Germany
Upside scenario
Real GDP
2.0
2.8
1.6
510
20%
548
Unemployment
2.9
2.4
2.0
HPI
5.4
8.9
9.9
Baseline scenario
Real GDP
0.5
1.1
1.2
540
60%
Unemployment
3.4
3.3
3.2
HPI
2.6
5.6
6.3
Downside scenario
Real GDP
-1.7
-1.7
0.3
609
20%
Unemployment
4.7
5.6
5.9
HPI
-1.7
1.3
2.2
Belgium
Upside scenario
Real GDP
2.2
2.6
2.1
534
20%
579
Unemployment
5.1
5.0
4.9
HPI
4.8
4.5
4.4
Baseline scenario
Real GDP
1.1
1.5
1.6
569
60%
Unemployment
5.7
5.7
5.6
HPI
3.2
4.1
3.8
Downside scenario
Real GDP
-0.6
-0.2
1.1
654
20%
Unemployment
7.0
8.0
8.0
HPI
1.2
2.9
2.5
United States
Upside scenario
Real GDP
3.1
3.5
3.2
74
20%
113
Unemployment
3.4
2.4
2.3
HPI
4.3
8.4
9.4
Baseline scenario
Real GDP
2.0
2.0
2.0
101
60%
Unemployment
4.2
4.1
4.0
HPI
3.3
3.7
3.9
Downside scenario
Real GDP
-0.1
-1.1
-0.4
187
20%
Unemployment
5.9
7.3
8.0
HPI
-0.7
-3.0
-2.5
1 Excluding management adjustments.
Sensitivity analysis as at December 2023 (*)
2024
2025
2026
Un-weighted
ECL (\u20ac mln)
Probability-
weighting
Reportable
ECL (\u20ac mln)1
Netherlands
Upside scenario
Real GDP
1.3
3.3
2.8
214
20%
310
Unemployment
3.7
3.3
3.3
HPI
10.4
11.2
4.0
Baseline scenario
Real GDP
0.8
1.6
1.5
282
60%
Unemployment
4.1
4.3
4.5
HPI
0.9
3.0
3.9
Downside scenario
Real GDP
-1.7
-1.2
0.1
487
20%
Unemployment
5.9
7.2
8.1
HPI
-10.9
-7.4
3.7
Germany
Upside scenario
Real GDP
1.4
3.1
1.6
472
20%
525
Unemployment
2.6
2.0
1.7
HPI
0.9
6.6
8.0
Baseline scenario
Real GDP
0.5
1.3
1.2
513
60%
Unemployment
3.0
3.0
3.0
HPI
-1.4
3.4
4.5
Downside scenario
Real GDP
-2.4
-1.4
0.3
615
20%
Unemployment
4.5
5.2
5.5
HPI
-6.0
-0.8
0.4
Belgium
Upside scenario
Real GDP
1.5
2.7
2.3
568
20%
619
Unemployment
5.3
5.0
4.9
HPI
1.3
5.6
4.5
Baseline scenario
Real GDP
0.9
1.5
1.8
604
60%
Unemployment
5.6
5.5
5.4
HPI
0.4
5.2
3.9
Downside scenario
Real GDP
-1.3
-0.2
1.2
713
20%
Unemployment
7.3
8.0
7.9
HPI
-2.2
3.9
2.6
United States
Upside scenario
Real GDP
1.8
3.2
3.4
102
20%
165
Unemployment
4.1
3.3
3.1
HPI
0.6
8.7
8.7
Baseline scenario
Real GDP
0.9
1.9
2.1
144
60%
Unemployment
4.5
4.5
4.4
HPI
-0.7
3.5
3.3
Downside scenario
Real GDP
-1.3
-1.4
-0.1
292
20%
Unemployment
6.6
8.2
8.8
HPI
-4.2
-2.7
-3.0
1 Excluding management adjustments.
When compared to the sensitivity analysis of 2023, the macroeconomic inputs are overall more favourable.
This is driven by an improved macroeconomic outlook, mainly because economies prove to be rather
resilient to increased interest rates, particularly in the US, as well as recovery in house prices in, among
others, the Netherlands.
On a total ING level, the unweighted ECL for all collective provisioned clients in the upside scenario was
\u20ac2,721 million, in the baseline scenario \u20ac2,949 million and in the downside scenario \u20ac3,533 million compared
to \u20ac3,020 million reportable collective provisions as at 31 December 2024 (excluding all management
adjustments). To perform the sensitivity analysis, a point in time reportable ECL is used as input, which
slightly deviates from the total Model ECL as reported below:
Reconciliation of reportable collective ECL to total ECL (*)
in EUR million
2024
2023
Total reportable collective provisions
2,975
2,856
ECL from individually assessed impairments
2,871
2,406
ECL from management adjustments
203
577
Total ECL
6,049
5,839
Criteria for identifying a significant increase in credit risk (SICR) (*)
All assets and off-balance-sheet items that are in scope of IFRS 9 impairment and which are subject to
collective ECL assessment are allocated a 12-month ECL if deemed to belong in Stage 1, or a lifetime ECL if
deemed to belong in Stages 2 or 3. An asset belongs in Stage 2 if it is considered to have experienced a
significant increase in credit risk (SICR) since initial origination or purchase.
The main determinant of SICR is a quantitative test, whereby the lifetime 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 either a threshold for absolute change in lifetime PD or a threshold for relative change in lifetime PD is
reached, the item is considered to have experienced a SICR (for more details on absolute and relative
thresholds, see the following sections). Furthermore, any facility which shows an increase of 200 percent
between the PD at the date of initial recognition and the lifetime PD at the reporting date (i.e. threefold
increase in PD) must be classified as Stage 2. This is considered a backstop within the quantitative
assessment of SICR.
In Wholesale Banking, significant increase in lifetime PD is not considered plausible for assets of obligors with
a credit rating at the reporting date in the top range of investment grade. As of 2024, the assets of these
Wholesale Banking obligors are excluded from the assessment of significant increase in credit risk triggers.
For these obligors the qualitative significant increases in credit risk triggers remain applicable (see the
section below on Qualitative SICR triggers). These are for example the Watchlist and/ or forbearance triggers.
Finally, the 30 days past due backstop also remains applicable for the top range of investment grade
exposures to ensure significant increase in credit risk recognition.
Absolute lifetime PD threshold
The absolute threshold is a fixed value calibrated per portfolio/segment and provides a fixed threshold that, if
exceeded by the difference between lifetime PD at reporting date and lifetime PD at origination, triggers
Stage 2 classification. The absolute threshold is calibrated during model development.
Relative lifetime PD threshold
The relative threshold defines a relative increase of the lifetime PD beyond which a given facility is classified
in Stage 2 because of a significant increase in credit risk. The relative threshold is dependent on the individual
PD assigned to each facility at the moment of origination, and a scaling factor calibrated in the model
development phase.
Ultimately, the relative threshold provides a criterion to assess whether the ratio (i.e. increase) between
lifetime PD at reporting date and lifetime PD at origination date is deemed a significant increase in credit risk.
If the threshold is breached, SICR is identified and Stage 2 is assigned to the given facility.
The threshold for the relative change in lifetime PD is inversely correlated with the PD at origination; the
higher the PD at origination, the lower the threshold. The logic behind this is to allow facilities originated in
very favourable ratings to downgrade for longer without the need of a Stage 2 classification. In fact, it is
likely that such facilities will still be in favourable ratings even after a downgrade of a few notches. On the
contrary, facilities originated in already unfavourable ratings grades are riskier and even a single-notch
downgrade might represent a significant increase in credit risk and thus a tighter threshold will be in place.
Still, the relative threshold is relatively sensitive for investment-grade assets while the absolute threshold
primarily affects non-investment grade assets.
Average threshold ratio
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 2023 and year-end 2024.
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 (*)
2024
2023
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
2.9
2.4
2.5
2.3
Consumer lending
2.8
2.1
2.9
2.1
Business lending
2.7
2.1
2.7
2.1
Governments and financial institutions
2.9
1.9
3.0
1.9
Other Wholesale Banking
2.7
1.9
2.8
1.8
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.
Sensitivity of ECL to PD lifetime PD thresholds
The setting of PD threshold bands requires management judgement and is a key source of estimation
uncertainty. On Group level, the total model ECL on performing assets, which is the ECL collective-
assessment without taking management adjustments into account, was \u20ac1,328 million as at 31 December
2024 (31 December 2023: \u20ac1,412 million). To demonstrate the sensitivity of the ECL to these PD threshold
bands, hypothetically solely applying the upside scenario would result in total model ECL on performing
assets of \u20ac1,066 million and a decrease in the Stage 2 ratio by 0.5%-point, while solely applying the
downside scenario would result in total model ECL on performing assets of \u20ac1,911 million and an increase in
the Stage 2 ratio by 1.9%-point.
Qualitative SICR thresholds
It should be noted that the lifetime PD thresholds are not the only drivers of stage allocation as ING Bank
also relies on a number of qualitative indicators to identify and assess SICR. An asset can also change stages
as a result of other triggers, such as having over 30 days arrears (used as a backstop), collective SICR
assessment, being on a watch list, being under intensive care management, having a substandard internal
rating or being forborne.", "dimensions": { "concept": "ifrs-full:DisclosureOfAllowanceForCreditLossesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-5": { "value": "
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. Policies and processes are in place to
monitor the inclusion of positions in either the trading or banking book as well as to monitor the transfer of
risk between the trading and banking books.
The following sections elaborate on the various elements of the risk management framework for:
\u2022 Market risk in banking books;
\u2022 Market risk in trading books; and
\u2022 Market risk capital.
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 they are 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.
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:
\u2022 Investment of own funds.
\u2022 Commercial business.
\u2022 Group Treasury exposures including strategic interest rate positions.
Group Treasury is responsible for managing the investment of own funds (core capital). Capital is invested
for longer periods to contribute to stable earnings within the risk appetite boundaries set by ALCO Bank. 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 due to different re-pricing properties of assets and
liabilities. Also, interest rate risk can arise from customer behaviour and/or convexity risk, depending on the
nature of the underlying product characteristics.
To determine the interest rate risk in particular products (like savings, mortgages) specific assumptions may
need to be made. Customer behaviour risk is defined as the potential future (value) loss due to deviations in
the actual behaviour of clients versus the modelled behaviour with respect to 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 the following main
product types: savings and current accounts (funds entrusted), demand deposits, mortgages and loans.
Savings and demand deposits are generally invested in such a way that both the value is hedged and the
sensitivity of the margin to market interest rates is minimised. This is achieved by creating the investment
profile distributed from short term to long term, which dampens the immediate impact from changes in the
market rates as well as stabilises margin in the longer horizon. Interest rate risk is modelled based on the
stability of deposits and the pass-through rate. This takes account of different elements, such as pricing
strategies, volume developments and the level and shape of the yield curve.
Interest rate risk for mortgages arises due to prepayment or other embedded optionalities. 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 analysis of historical data. However, the substantial change in the interest rate environment in
recent years makes the analysis 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, and are closely monitored on a monthly basis.
Linear risk transfers take place from commercial business books to the treasury book (Group Treasury), if
necessary, by using estimations of customer behaviour. The originating commercial business is ultimately
responsible for estimating this customer behaviour, leaving convexity risk and (unexpected) customer
behaviour risk with the commercial business. Risk measurement and the risk transfer process take place at
least monthly. If deemed necessary, additional risk transfers can take place.
The commercial business manages the convexity risk that is the result of products that contain embedded
options, like mortgages. Here the convexity risk is defined as the optionality effects in the value due to
interest rate changes, excluding the first-order effects. In some cases, convexity risk is transferred from the
commercial books to treasury books using cap/floor contracts and swaptions.
In the following sections, the interest rate risk exposures in the banking books are presented. ING quantifies
risk measures from both earnings and value perspectives. 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 NPV-at-Risk is measured under a direct interest rate shock. Hence no additional,
corrective hedges are included in the measure. The NII-at-Risk measure is measured for interest rate
movements over a period, whereby (assumed) corrective hedges are included in the risk metric.
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 (dynamic plan) are included in this risk metric. NII-at-
Risk provides insight into the sensitivity of ING\u2019s NII under shocked interest rate scenarios against what is
projected in a base case scenario.
In its risk management, ING monitors the NII-at-Risk under a three-year time frame. Interest rates are
shocked during the first year of analysis through the gradual application of shock. The rate changes
considered encompass both upward and downward scenarios, as well as both parallel (equal movements
across the yield curve) and non-parallel scenarios.
The impact of changing interest rates on ING\u2019s NII is predominantly caused by the following factors:
\u2022 Change in returns of (re)investments of client deposits;
\u2022 Change in client deposit rates (mainly savings), (partially) tracking changes in market interest rates;
\u2022 Change in the amortisation profile of mortgages, due to an increase or decrease in expected
prepayments;
\u2022 Higher/lower returns of (re-)investments of capital investment;
\u2022 Open interest rate positions, leading to changes in return because of different market rates; and
\u2022 Assumed volume development of the balance sheet in line with ING\u2019s dynamic plan.
For projecting the change in client deposit rates, ING uses a client rate model that describes the relation
between market interest rates and client deposit rates. The model is calibrated under a range of interest
rate scenarios. Per scenario, the actual change in client deposit rates may deviate from this calibrated
model. The actual NII development of customer deposits may, indeed, differ from the provided scenarios,
depending on, among other things, actual interest rate and savings client rate evolution, as well as changes
to ING\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 table below reflect a parallel, linear interest rate movement during a year
('ramped') under the assumption of balance sheet developments in line with ING\u2019s dynamic plan with a time
horizon of one year. The majority of the risk comes from fixed-rate positions, most notably non-
remunerated current accounts and variable-rate savings accounts .
The NII-at-Risk is mainly influenced by the difference in the sensitivity between client liabilities and client
assets and investments to rate changes. The primary factor of NII-at-Risk are the investments of current
accounts, while the investments of own funds have a marginal effect, as only a relatively small portion
needs to be (re)invested within a one-year period.
NII-at-Risk banking book per currency - year one (*)
in EUR million
2024
2023
Ramped, floored
Ramped, floored
parallel \u25bc
parallel \u25b2
parallel \u25bc
parallel \u25b2
By currency
Euro
-144
158
-165
155
US dollar
-4
5
-12
12
Other
-2
21
-62
69
Total
-151
184
-239
236
EUR ramped (floored at -100bps) is at +/- 120bps in 1 year (2023: +/-110bps)
USD ramped (floored at -100bps) is at +/- 120bps in 1 year (2023: +/-110bps)
The change in NII under declining and upward interest rate scenarios may not be equal. This is due to
different expected reactions in prepayment behaviour of mortgages and different pricing developments of
commercial loans and deposits products (mainly savings). This is caused by embedded options, explicit or
implicit pricing floors and other (assumed) pricing factors.
The metrics mentioned above are internal metrics, which therefore deviate from the regulatory NII SOT
metrics.
Year-on-year variance analysis (*)
In 2024, in response to falling inflation, most central banks (including ECB and FED) began to ease their
monetary policy, executing series of rates cuts. ING applied a dynamic hedging process, by which interest
rate risk was transferred from the business to Group Treasury and subsequently hedged in the markets. The
impact of explicit and implicit floors on both rates of client assets and savings remains limited. Pre-existing
hedges, as executed by Group Treasury, were also adjusted continuously throughout the year to hedge any
interest rate risk coming from lower interest rates. Most of the year-on-year change in NII sensitivity is due
to enhancements in risk management framework in one of non-EUR locations. These enhancements are
aimed at mitigating sensitivity in a volatile rate environment and include increasing the granularity of risk
transferred positions and implementing limits to trigger an intra-month recalibration of the hedges.
Excluding model risk, the total NII-at-Risk remains relatively limited in comparison to ING\u2019s total interest
income.
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. 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. The majority of the risk comes from the investments of own funds and from positions
exhibiting negative convexity due to embedded optionality (most notably variable rate savings and fixed
rate mortgages).
The metrics mentioned above are internal metrics, which therefore deviate from the regulatory EVE SOT
metrics.
NPV-at-Risk banking books per currency (*)
in EUR million
2024
2023
floored
floored
parallel \u25bc
parallel \u25b2
parallel \u25bc
parallel \u25b2
By currency
Euro
7
-1,473
-291
-645
US dollar
274
-266
186
-178
Other
321
-329
131
-146
Total
602
-2,068
27
-969
EUR (floored at -100bps) is at +/- 120bps (2023: +/-110bps)
USD (floored at -100bps) is at +/- 120bps (2023: +/-110bps)
Year-on-year variance analysis (*)
The overall NPV sensitivity increased considerably over last year. The worst-case scenario remains the
parallel up, while the shock used in calculation for main currencies (EUR and USD) increased from 110bps to
120bps on the back of increased volatility observed in the market during 2023. This increase partially
explains the observed higher sensitivity. The other important factor impacting end of 2024 utilisation is
convexity: with lower interest rates, the increase in convexity on mortgages and savings accounts was
observed, especially for EUR positions. Lastly, Group Treasury actively managed the position and executed
investments for capital in the anticipation of possible further rates decreases.
The impact of the benchmark rate reform (*)
In line with the recommendations of the Financial Stability Board, a fundamental review of important
interest rates benchmarks has been undertaken. Some interest rate benchmarks have been reformed, while
others have or will be replaced by risk-free rates and discontinued. USD LIBOR in its current form ceased on
30 June 2023, whereas the cessation of GBP, CHF, JPY, and EUR LIBOR rates occurred on 31 December 2021.
To support these changes, the financial sector has issued several guidance papers and other initiatives to
help phase the transition. In 2024, the benchmark rate reform of only one reference rate, to which the Group
has significant exposures as at 31 December 2024, was continuing (i.e. WIBOR). The WIBOR rate is expected
to be ceased and replaced by a risk-free rate (RFR) by 31 December 2027.
The Steering Committee of the National Working Group (NWG SC) appointed in connection with the WIBOR
benchmark reform the decision (published on 10 December 2024) on the selection of the proposed index
with the technical name 'WIRF \u2013' as the ultimate interest rate benchmark in Poland to replace the WIBOR
benchmark. On 24 January 2025, the Steering Committee of the National Working Group has selected target
name POLSTR (Polish Short Term Rate) for this index.The chosen index is calculated based on unsecured
deposits of Credit and Financial Institutions. Thus, the NWG SC has reviewed and modified its previous
decision to select WIRON as alternative RFR in Poland. The WIBOR rate is still expected to be ceased and
replaced by a new RFR (\"WIRF -\") by 31 December 2027.
Due to the discontinuation of WIBOR, ING, its customers, and in general those market participants with
exposure to such benchmark rates will be faced with a number of risks. These risks include legal, financial,
operational, reputational and conduct risk. The WIBOR rates are used in several of our lending and derivative
products, and hence a project team has been established to manage the transition. WIBOR transition is
especially important for our Polish subsidiary (ING Bank \u015al\u0105ski S.A.) with a significant amount of Polish zloty-
denominated assets and liabilities including derivatives that are continuously rebalanced to hedge the risk
exposures.
The tables below summarise the approximate gross exposures of ING that have yet to transition related to
USD LIBOR and WIBOR, excluding exposures expiring before the transition date 31 December 2027 for
WIBOR.
Non-derivative financial instruments to transition to alternative benchmarks (*)
Financial assets non-
derivative
Financial liabilities\u00a0
non-derivative
Off balance sheet
commitments
in EUR million at 31 December 2024
Carrying value
Carrying value
Nominal value
By benchmark rate
USD LIBOR
WIBOR
19,202
134
1,544
Total
19,202
134
1,544
in EUR million at 31 December 2023
By benchmark rate
USD LIBOR
915
16
9
WIBOR
18,064
1,021
Total
18,979
16
1,030
Derivative financial instruments to transition to alternative benchmarks (*)
31 December 2024
31 December 2023
in EUR million
Nominal value
Nominal value
By benchmark rate
USD LIBOR
151
WIBOR
110,189
77,238
Total
110,189
77,388
sections 1.5.4 and 1.5.7 of Note 1 \u2018Basis of preparation and material accounting policy information\u2019 for
information on the Phase 1 and Phase 2 amendments.
As at 31 December 2024, Phase 1 reliefs are applicable to WIBOR indexed fair value and cash flow hedge
accounting relationships as there is uncertainty arising from the WIBOR reform with respect to the timing
and the amount of the underlying cash flows that the Group is exposed to. Therefore, for WIBOR financial
instruments designated in hedge accounting the applicable Phase 1 reliefs will continue to apply until the
relevant contract is modified. At that point in time, Phase 2 reliefs will become applicable. For these affected
fair value and cash flow hedge relationships, ING assumes that the 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 WIBOR
reform still meet the highly probable requirement, assuming the 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 that are used in the ING\u2019s hedge accounting
relationships for which the Phase 1 amendments to IAS 39 were applied are:
Notional amounts of hedging instruments (*)
31 December 2024
31 December 2023
in EUR million
Nominal value
Nominal value
By benchmark rate
WIBOR
99,663
89,338
As at 31 December 2024, 32% (31\u00a0December 2023: 29%) of the notional amounts for WIBOR have a
maturity date beyond 31 December 2027. The notional amounts of the derivative hedging instruments
provide a close approximation of the extent of the risk exposure ING manages through these hedging
relationships.
Credit spread risk in banking books (CSRBB) (*)
Credit spread risk is defined as risk driven by the changes of the market price for credit risk, for liquidity and
potentially other characteristics of credit-risky instruments, which is not captured by another existing
prudential framework such as IRRBB or by expected credit/(jump-to-) default risk. CSRBB framework is
implemented based on EBA Guidelines. Metrics used are NPV-at-Risk, NII-at-Risk and Market Value Changes-
at Risk and view the positions across different accounting treatments.
Credit spread risk is not part of the internal risk transfer towards Group Treasury and therefore remains in
the business unit it originated in. Group Treasury itself is also an important driver of credit spread risk via its
HQLA investment portfolio and issuance activities.
Risk appetite limits are set on a combination of metrics and accounting scopes and are cascaded to local
ALCOs depending on the type of limit and materiality. Metrics and limits are monitored and reported
monthly to ALCO Bank, local ALCOs and various stakeholders.
Foreign exchange (FX) risk in banking books (*)
FX exposures in banking books result from core banking business activities (business units doing business in
currencies other than their base currency), foreign currency investments in subsidiaries (including realised
net profit and loss), and strategic equity stakes in foreign currencies. The policy regarding these exposures is
briefly explained below.
Core banking business (*)
Every business unit hedges the FX risk resulting from core banking business activities into its base currency
to prevent volatility in profit and loss. Consequently, assets and liabilities are matched in terms of currency,
within certain friction limits.
FX translation (*)
ING\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 (*)
The following table presents the currency exposures in the banking books for the most important currencies
for the FX translation result. Positive figures indicate long positions in the respective currency. As a result of
the strategy to hedge the CET1 ratio an open structural FX exposure exists.
To measure the volatility of the CET1 ratio from FX rate fluctuations, different metrics are used, including the
CET1 Ratio-at-Risk. The impact is controlled via the Solvency and Financial Risk RAS.
EBA Structural FX guidelines
In line with the EBA guidelines on Structural FX, upon permission from the competent authorities, certain
currency positions are being excluded from the calculation of net open currency positions under CRR article
352(2). The resulting impact is presented in the Pillar 3 disclosure.
Foreign currency exposures banking books (*)
in EUR million
Foreign Investments
Hedges
Net exposures
2024
2023
2024
2023
2024
2023
US dollar1
11,251
10,337
-4,823
-3,416
6,429
6,921
Pound Sterling
1,674
1,659
-484
-156
1,190
1,503
Polish Zloty
4,395
3,976
-1,616
-1,254
2,779
2,722
Australian Dollar
3,373
3,620
-2,161
-2,273
1,212
1,346
Turkish Lira
557
517
557
517
Chinese Yuan
2,439
1,815
-830
-348
1,609
1,466
Russian Rouble
396
375
396
375
Romanian Leu
913
895
-176
-134
736
761
Thai Baht
1,266
1,128
-838
-697
428
431
Other currency
3,346
3,704
-2,748
-2,897
599
806
Total
29,612
28,024
-13,675
-11,175
15,936
16,849
*The FX sensitivity is expressed as the FX spot equivalent position.
Equity price risk in banking books (*)
ING maintains a portfolio with substantial equity exposure in its banking books.\u00a0
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 values 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 \u20ac1,679 million (2023: \u20ac1,509 million) and equity securities
held at fair value through other comprehensive income (FVOCI) of \u20ac2,562 million (2023: \u20ac1,885 million). The
value of equity securities held at FVOCI is directly linked to equity security prices with increases/decreases
being recognised in the revaluation reserve. Investments in associates and joint ventures are measured in
accordance with the equity method of accounting, and the balance sheet value is therefore not directly
linked to equity security prices. The equity sensitivity is expressed as the equity position.
Year-on-year variance analysis (*)
In 2024, the revaluation reserve equity securities increased by \u20ac664 million from \u20ac1,152 million to \u20ac1,816
million mainly due to revaluation of the shares in Bank of Beijing with \u20ac 652 million. In 2024, the equity
securities at fair value through OCI increased by \u20ac678 million.
Revaluation reserve equity securities at fair value through other comprehensive income (*)
in EUR million
2024
2023
Positive re-measurement
1,820
1,158
Negative re-measurement
-4
-6
Total
1,816
1,152
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 2024, ING
continued its strategy of undertaking trading activities to develop its client-driven franchise and deliver a
differentiating experience by offering multiple market and trading products.
With respect to the trading portfolios, Trading Risk Management (TRM) focuses on the management of
market risks of Wholesale Banking (mainly Financial Markets) as this is the only business line within ING
where trading activities take place. Trading activities include facilitation of client business and market
making. TRM is responsible for the development and implementation of trading risk policies and risk
measurement methodologies, and for reporting and monitoring risk exposures against approved trading
limits. TRM also reviews trading mandates and global limits, and performs the gatekeeper role in the product
review process (PARP).
Risk measurement (*)
ING uses a comprehensive set of methodologies and techniques to measure market risk in trading books:
Value at Risk (VaR) and Stressed Value at Risk (SVaR), Incremental Risk Charge (IRC), and stress testing.
Systematic validation processes are in place to validate the accuracy and internal consistency of data and
parameters used for the internal models and modelling processes.
Value at Risk (*)
TRM uses the historical simulation VaR methodology (HVaR) as its primary risk measure. The HVaR for
market risk quantifies, with a one-sided confidence level of 99 percent, the maximum overnight loss that
could occur in the trading portfolio of ING due to changes in risk factors (e.g. interest rates, equity prices,
foreign exchange rates, credit spreads, implied volatilities) considering the positions remain unchanged for a
time period of one day.
Next to general market movements in these risk factors, HVaR also takes into account market data
movements for specific moves in, for example, the underlying issuer or securities. A single model which
diversifies general and specific risk is used. In general, a full revaluation approach is applied, while for a
limited number of linear trading positions and risk factors in commodity and equity risk classes a sensitivity-
based approach is applied. The potential impact of historical market movements on today\u2019s portfolio is
estimated, based on equally weighted observed market movements of the previous year (260 business
days). When simulating potential movements in risk factors, depending on the risk factor type, either an
absolute or a relative shift is used.
The data used in the computations is updated daily. ING uses HVaR with a one-day horizon for internal risk
measurement, management control, and backtesting, and HVaR with a 10-day horizon for determining
regulatory capital. To compute HVaR with a 10-day horizon, the one-day risk factor shifts are scaled by the
square root of 10 and then used as an input for the revaluation. The same model is used for all legal entities
within ING with market risk exposure in the trading portfolio.
Limitations (*)
HVaR has some limitations: it uses historical data to forecast future price behaviour, but future price
behaviour could differ substantially from past behaviour. Moreover, the use of a one-day holding period (or
10 days for regulatory capital calculations) assumes that all positions in the portfolio can be liquidated or
hedged in one day. In periods of illiquidity or market events, this assumption may not hold. Also, the use of a
99 percent confidence level means that HVaR does not take into account any losses that occur beyond this
confidence level.
Backtesting (*)
Backtesting is a technique for the ongoing monitoring of the plausibility of the HVaR model in use. Although
HVaR models estimate potential future trading results, estimates are based on historical market data. In a
backtest, the actual daily trading result (excluding fees and commissions) is compared with the one-day
HVaR.
In addition to using actual results for backtesting, ING also uses hypothetical results, which exclude the
effects of intraday trading, fees, and commissions. When an actual or a hypothetical loss exceeds the HVaR,
an \u2018outlier\u2019 occurs. Based on ING\u2019s one-sided confidence level of 99 percent, an outlier is expected once in
every 100 business days.
On an overall level in 2024, there was one outlier for hypothetical P&L and zero outliers for actual P&L. The
hypothetical outlier occurred in the third quarter of 2024, mainly due to higher interest rate and FX market
movements.
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 10-day horizon. The data for the
historical stress period used currently includes the height of the credit crisis around the fall of Lehman
Brothers (2008-2009), and this 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 percent
confidence level. Trading positions (excluding securitisations) of ING, which are subject to specific interest
rate risk included in the internal model approach for market risk regulatory capital, are in scope of the IRC
model. By model choice, equity is excluded from the model. For the calculation of IRC, ING performs a Monte
Carlo simulation based on a multi-factor t-copula. In the multi-factor IRC model the supervisory asset
correlations are no longer applicable and the calibration of the correlations is based on historical market
data. The rating change is simulated for all issuers over the different liquidity horizons (i.e. time required to
liquidate the position or hedge all significant risks) within one year. Movements across different rating
categories and probabilities of default are governed by a credit-rating transition matrix. An internal
transition matrix along with internal LGDs is used, to comply with the consistency requirement. The financial
impact is then determined for the simulated migration to default, or for the simulated migration to a
different rating category, based on LGD or credit spread changes, respectively.
The liquidity horizon has been set to the regulatory minimum of three months for all positions in scope. ING
reviews the liquidity horizons on a yearly basis, based on a structured assessment of the time it takes to
liquidate the positions in the trading portfolio.
Stress testing and event risk (*)
Stress testing is a valuable risk management tool. In addition to the bank-wide stress-test framework as
described in the stress-testing section, Trading Risk Management performs stress tests specific to the trading
book with various frequencies. The trading book stress tests evaluate the impact on the bank\u2019s trading book
under severe but plausible stress scenarios, using a full revaluation approach. The framework is based on
historical as well as hypothetical scenarios. The stress result is an estimate of the profit and loss caused by a
potential event and its worldwide impact for ING. The results of the stress tests are used for decision-making,
aimed at maintaining a financially healthy going-concern institution after a severe event occurs.
In stress scenarios, shocks are applied to prices (credit spreads, interest rates, equity, commodities, and FX
rates) and volatilities. Depending on the type of the stress test, additional scenario assumptions can be
made, for example on correlations, dividends, or recovery rates. The structural scenarios are defined to cover
market moves in various directions and capture different asset class correlations. Scenarios are calculated
using full revaluation approach. The worst scenarios are determined for each product line, business line and
super business line, and compared against limits
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 EUR million
2024
2023
Foreign exchange
Foreign exchange
US Dollar
-93
Japanese Yen
61
Turkish Lira
84
Taiwan Dollar
-58
Korean Won
62
Romanian Leu
58
Japanese Yen
61
Chinese Yuan
49
Chinese Yuan
-37
Hong Kong Dollar
-38
Most important interest rate and credit spread sensitivities at year-end (*)
in EUR thousand
2024
2023
Interest rate (BPV) 1
Interest rate (BPV) 1
Euro
-799
Euro
-309
US Dollar
-198
Czech Koruna
71
British Pound
-189
Korean Won
-41
Korean Won
-54
US Dollar
-40
Philippine Peso
-54
British Pound
-35
Credit spread (CSO1) 2
Credit spread (CSO1) 2
United States
193
Germany
405
Netherlands
-165
Netherlands
120
France
-113
Korea
-111
Poland
69
Japan
106
Germany
49
United Kingdom
101
1 Basis point value (BPV) measures the impact on value of a one basis point increase in interest rates.
2 Credit spread sensitivity (CS01) measures the impact on value of a one basis point increase in credit spreads. Exposures to
supranational institutions are not assigned to a specific country.
Credit spread sensitivities per risk class and sector at year-end (*)
2024
2023
in EUR thousand
Corporate
Financial
institutions
Corporate
Financial
institutions
Credit Spread (CSO1) 1
Risk classes
1 (AAA)
-2
-118
2\u20134 (AA)
-44
-27
12
50
5\u20137 (A)
49
-246
57
50
8\u201310 (BBB)
93
-76
106
13
11\u201313 (BB)
38
-13
25
-25
14\u201316 (B)
23
-12
17
-4
17\u201322 (CCC and NPL)
4
2
-8
-20
Total
162
-489
208
65
1 Credit Spread Sensitivity (CS01) measures the impact on value of a 1 basis point increase in credit spreads.
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Funding and liquidity risk (*)
Introduction (*)
Funding and liquidity (F&L) risk is the risk that ING or one of its subsidiaries cannot meet their financial
obligations upon their maturity date at a reasonable cost and in a timely manner. ING incorporates funding
and liquidity risk management in its business strategy and has established a funding and liquidity risk
framework to manage these risks within pre-defined boundaries.
The following sections elaborate on the various elements of funding and liquidity risk:
\u2022 Funding and liquidity risk framework;
\u2022 Funding and liquidity risk management strategy and objectives;
\u2022 Funding and liquidity adequacy and risk appetite;
\u2022 Funding and liquidity risk indicators;
\u2022 Liquidity stress testing; and
\u2022 Contingency funding planning.
Funding and liquidity risk framework (*)
Macroeconomic and market environment are important considerations in ING\u2019s F&L framework. The
macroeconomic environment is comprised of various exogenous factors over which ING has no control, but
which may have a material impact on ING\u2019s F&L position. The main macroeconomic factors analysed on a
regular basis include:
\u2022 performance of global and local macroeconomic indicators, e.g. shifts in GDP, inflation rates,
unemployment rates, and public deficit/surplus;
\u2022 developments and risks arising from geopolitical tensions and trends;
\u2022 monetary policy with a focus on the alternative monetary measures employed by central banks in recent
years as a result of the global energy crisis and the recent period of high inflation; and
\u2022 regulatory 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.
The EB, MBB and staff departments from the CRO and CFO domains, as well as Group Treasury, have
oversight of, and are responsible for, managing funding and liquidity risks.
Funding and liquidity management strategy and objectives (*)
The main objective of ING\u2019s funding and liquidity risk management is to maintain sufficient liquidity to fund
the commercial activities of ING both under normal and stressed market circumstances across various
locations, currencies and tenors.
ING\u2019s funding consists mainly of retail and corporate deposits contributing 53 percent and 22 percent of total
funding, respectively. These funding sources provide a (relatively) stable funding base. The remainder of the
required funding is attracted primarily through a combination of long-term and short-term professional
funding. Group Treasury manages the professional funding in line with the F&L risk appetite with the aim of
ensuring a sufficiently diversified and stable funding base.
Funding and liquidity adequacy and risk appetite (*)
ING identifies key drivers of short-term and future liquidity and funding needs on an ongoing basis through
the periodic risk-identification process. Taking into consideration the identified risk drivers, ING regularly
assesses its current and future liquidity adequacy and, if deemed necessary, takes action to further improve
ING\u2019s liquidity position and maintain sufficient counterbalancing capacity. A Liquidity Adequacy Statement is
formulated on a regular basis to substantiate and reflect the management view on the current funding and
liquidity position as well as the potential future challenges. The Liquidity Adequacy Statement is an
important part of ING\u2019s ILAAP process. Additionally, ING completes ad hoc funding and liquidity assessments
if deemed necessary. In 2024, ING focused on the implementation of activities which steered the LCR higher
and diversified the funding mix in order to ensure funding stability for the bank into the F&L risk appetite.
ING assesses its F&L adequacy through three lenses \u2013 stress, economic and normative:
\u2022 Through the stress lens, ING evaluates its ability to withstand periods of prolonged F&L stress for both
normative and economic requirements or limits under idiosyncratic, market-related, combined
idiosyncratic and market-related, and climate risk scenarios, which lead to customer deposit outflows,
deterioration of access to funding markets, and lower liquidity value of counterbalancing capacity.
\u2022 Through the economic lens, ING assesses the extent to which its customers, professional counterparties
and investors are comfortable to provide deposits and funding in the tenors, currencies and instruments
necessary to sustainably fund the business (intraday, short-term and long-term) in a going-concern
situation.
\u2022 Through the normative lens, ING ascertains that the bank is in the position to meet current and future
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.
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, combined (idiosyncratic and market-
wide) and climate-stress scenarios. The design of the framework is based on empirical evidence
supplemented by expert judgment. The framework can be extended to additional ad-hoc scenarios. For
example, it can be used as input for firm-wide stress testing and reverse stress testing.
Outcomes of the stress tests are considered in the key aspects of ING\u2019s F&L risk framework and F&L risk
management, including:
\u2022 Risk Appetite Framework (through risk appetite statements);
\u2022 Risk identification and assessment;
\u2022 Monitoring of the liquidity and funding position;
\u2022 Business actions (if needed);
\u2022 Contingency funding plan; and
\u2022 Early-warning indicators.
The funding and liquidity stress-testing framework is also subject to regular internal validation by model
validation.
In line with supervisory expectations, ING\u2019s liquidity position is stress tested on (at minimum) a monthly basis
using scenarios that form part of the F&L risk appetite statement. The results of all internal stress scenarios
are monitored and assessed on a monthly basis. In addition, ad hoc scenarios based on current economic
and market developments are run to determine their potential impacts on the funding and liquidity position
of ING. In 2024, this included stress-test scenarios assessing the impact of a shutdown of US short- and long-
term funding markets and FX markets. The internal stress scenarios and their corresponding results serve as
input in the decision on holding additional contingency measures.
Contingency funding planning (*)
ING\u2019s contingent F&L risks are addressed in its Contingency Capital and Funding Plan (CCFP).The objectives of
the CCFP include the following:
\u2022 Establishment of a monitoring framework to detect approaching contingent events as well as their
impact on ING\u2019s F&L position;
\u2022 Provision of a plan for responding to various and increasing levels of a bank\u2019s liquidity and capital shortfall
under adverse and stressed conditions;
\u2022 Designation of management responsibilities, crisis communication methods and channels, and reporting
requirements;
\u2022 Identification of contingent capital and liquidity sources that can be used under various and increasing
adverse as well as stressed circumstances; and
\u2022 Description of steps which should be taken to ensure that the bank\u2019s sources of capital and liquidity are
sufficient to fund scheduled operating requirements and meet the institution\u2019s commitments with
minimal costs and disruption.
The contingency funding measures are developed in conjunction with the ING Recovery Plan and are
reviewed and tested on a regular basis.
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"scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-476": { "value": "14746000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashFlowsFromUsedInFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00/2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-477": { "value": "2755000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashFlowsFromUsedInFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-478": { "value": "-23203000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:IncreaseDecreaseInCashAndCashEquivalentsBeforeEffectOfExchangeRateChanges", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-479": { "value": "-1481000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:IncreaseDecreaseInCashAndCashEquivalentsBeforeEffectOfExchangeRateChanges", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00/2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-480": { "value": "-11770000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:IncreaseDecreaseInCashAndCashEquivalentsBeforeEffectOfExchangeRateChanges", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-481": { "value": "93011000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-482": { "value": "95390000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-483": { "value": "107664000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-484": { "value": "-740000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:EffectOfExchangeRateChangesOnCashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-485": { "value": "-898000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:EffectOfExchangeRateChangesOnCashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00/2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-486": { "value": "-505000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:EffectOfExchangeRateChangesOnCashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-487": { "value": "69068000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-488": { "value": "93011000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-489": { "value": "95390000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-491": { "value": "
Cash and cash equivalents
in EUR million
2024
2023
2022
Treasury bills and other eligible bills included in securities at AC
37
0
1
Deposits from banks
-6,303
-5,132
-6,172
Loans and advances to banks
4,981
7,930
13,947
Cash and balances with central banks
70,353
90,214
87,614
Cash and cash equivalents at end of year
69,068
93,011
95,390
Cash and cash equivalents include deposits from banks and loans and advances to banks that are payable
on demand.
Included in Cash and cash equivalents are minimum mandatory reserve deposits held at various central
banks. Reference is made to Note 36 'Transfer of financial assets, assets pledged and received as collateral'
for restrictions on Cash and balances with central banks.
References relate to the accompanying notes. These are an integral part of the Consolidated financial
statements.
Changes in liabilities arising from financing activities
Debt securities in issue
Subordinated Loans
Lease liabilities
Senior non-preferred
debt
in EUR million
2024
2023
2022
2024
2023
2022
2024
2023
2022
2024
2023
2022
Opening
balance
84,423
58,075
57,443
15,404
15,789
16,719
1,162
1,174
1,220
40,213
37,806
34,303
Cash flows:
Additions
115,308
110,477
81,636
4,603
2,225
983
9,533
7,013
10,347
Redemptions /
Disposals
-109,358
-86,061
-78,609
-2,931
-2,894
-1,090
-290
-291
-296
-3,692
-5,451
-3,897
Non cash
changes:
Amortisation
1,062
730
281
28
34
31
27
28
15
-3
1
-7
Other
111
403
-66
24
12
8
212
256
239
1,669
102
106
Changes in
unrealised
revaluations
594
1,279
-3,746
188
473
-1,470
544
1,436
-3,866
Foreign
exchange
movement
2,318
-479
1,135
564
-236
608
5
-4
-4
1,129
-694
820
Closing balance
94,459
84,423
58,075
17,879
15,404
15,789
1,116
1,162
1,174
49,393
40,213
37,806
Part of Debt securities in issue and subordinated loans are subject to fair value hedge accounting. Hence,
changes in unrealised revaluations represent fair value adjustments to the hedged item attributable to the
hedged interest rate risk. Reference is made to the paragraph 'fair value hedge accounting' in Note 33
'Derivatives and hedge accounting'.
The table below presents the Interest and dividend received and paid.
in EUR million
2024
2023
2022
Interest received
57,201
51,030
28,110
Interest paid
-41,459
-33,859
-14,201
15,742
17,171
13,909
Dividend received
235
205
229
Dividend paid
-5,239
-10,272
-6,319
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.
", "dimensions": { "concept": "ifrs-full:DisclosureOfCashFlowStatementExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-490": { "value": "
Cash and cash equivalents
in EUR million
2024
2023
2022
Treasury bills and other eligible bills included in securities at AC
37
0
1
Deposits from banks
-6,303
-5,132
-6,172
Loans and advances to banks
4,981
7,930
13,947
Cash and balances with central banks
70,353
90,214
87,614
Cash and cash equivalents at end of year
69,068
93,011
95,390
Cash and cash equivalents include deposits from banks and loans and advances to banks that are payable
on demand.
Included in Cash and cash equivalents are minimum mandatory reserve deposits held at various central
banks. Reference is made to Note 36 'Transfer of financial assets, assets pledged and received as collateral'
for restrictions on Cash and balances with central banks.
References relate to the accompanying notes. These are an integral part of the Consolidated financial
statements.
", "dimensions": { "concept": "ifrs-full:DisclosureOfCashAndCashEquivalentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-492": { "value": "37000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:TreasuryBillsAndOtherEligibleBills", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-493": { "value": "0.0", "decimals": -6, "dimensions": { "concept": "ingbank:TreasuryBillsAndOtherEligibleBills", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-494": { "value": "1000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:TreasuryBillsAndOtherEligibleBills", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-495": { "value": "6303000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:CashAndCashEquivalentsDepositsFromBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-496": { "value": "5132000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:CashAndCashEquivalentsDepositsFromBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-497": { "value": "6172000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:CashAndCashEquivalentsDepositsFromBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-498": { "value": "4981000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:CashAndCashEquivalentsLoansAndAdvancesToBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-499": { "value": "7930000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:CashAndCashEquivalentsLoansAndAdvancesToBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-500": { "value": "13947000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:CashAndCashEquivalentsLoansAndAdvancesToBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-501": { "value": "70353000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndBankBalancesAtCentralBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-502": { "value": "90214000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndBankBalancesAtCentralBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-503": { "value": "87614000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndBankBalancesAtCentralBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-504": { "value": "69068000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-505": { "value": "93011000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-506": { "value": "95390000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-508": { "value": "
Cash and cash equivalents include deposits from banks and loans and advances to banks that are payable
on demand.
Included in Cash and cash equivalents are minimum mandatory reserve deposits held at various central
banks. Reference is made to Note 36 'Transfer of financial assets, assets pledged and received as collateral'
for restrictions on Cash and balances with central banks.
1\u00a0 Basis of preparation and material accounting policy information
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\u00a0December 2024, 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.\u00a0
The ING Bank Consolidated financial statements, as at and for the year ended 31 December 2024, were
authorised for issue in accordance with a resolution of the Management Board Banking on 3\u00a0March 2025. 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 1.5.4 \u2018Derivatives and hedge
accounting\u2019 of this note and to Note 33 '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 Changes to accounting policies and presentation
ING Bank has consistently applied its accounting policies to all periods presented in these Consolidated
financial statements.
In 2024, ING Bank updated the presentation of the Consolidated statement of changes in equity to simplify
its structure and reduce duplication. Comparative figures have been updated accordingly. Furthermore, ING
has changed the presentation and classification of Senior non-preferred instruments respectively in the
consolidated statement of financial position and consolidated statement of cash flows. ING believes this
change further improves presentation about these instruments and related cash flows. Comparative figures
have been updated accordingly. In addition, presentation in Note 28 'Segments' was updated to reflect the
clarified requirements for segment disclosures as issued by the IFRIC in an agenda decision issued in July
2024.
1.3.1\u00a0 Changes in IFRS effective in 2024
The following amendments to IFRS became effective in the current reporting period (and have been EU
endorsed) with no significant impact for ING Bank:
\u2022 Amendments to IFRS 16 'Leases': Lease Liability in a Sale and Leaseback (issued in September 2022).
\u2022 Amendments to IAS 1 \u2018Presentation of Financial Statements\u2019: Classification of Liabilities as Current or Non-
current (issued in January 2020) and Non-current liabilities with Covenants (issued in October 2022).
\u2022 Amendments to IAS 7 'Statement of Cash flows' and IFRS 7 'Financial Instruments: Disclosures': Supplier
Finance Arrangements (issued in May 2023).
1.3.2\u00a0 Upcoming changes in IFRS after 2024
ING Bank has not early adopted any of the following Standards, interpretations or amendments that have
been issued, but are not yet effective and is assessing their potential impact on for ING Bank.
Effective in 2025 (endorsed by the EU):
\u2022 Amendments to IAS 21 'The Effects of Changes in Foreign Exchange Rates': Lack of Exchangeability
(issued in August 2023).
The implementation of the above amendments is expected to have no significant impact on ING Bank's
Consolidated financial statements when they become effective.
Effective in 2026 (not yet endorsed by the EU):
\u2022 Amendments to IFRS 9 'Financial Instruments' and IFRS 7 'Financial Instruments: Disclosure': Classification
and Measurement of Financial Instruments (issued in May 2024).
\u2022 Amendments to IFRS 9 'Financial Instruments' and IFRS 7 'Financial Instruments: Disclosure': Contracts
Referencing Nature-dependent Electricity (issued in December 2024).
\u2022 Annual Improvements to IFRS Accounting Standards: Volume 11 (issued in July 2024).
Effective in 2027 (not yet endorsed by the EU):
\u2022 New Standard IFRS 18 'Presentation and Disclosure in Financial Statements' (issued in April 2024).
In addition, in May 2024, the IASB also issued a new accounting Standard IFRS 19 'Subsidiaries without Public
Accountability: Disclosures'. However, it is not applicable for the consolidated financial statements of ING
Bank.
1.4\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:
\u2022 Loan loss provisions (financial assets) (refer to Note 1.5.6 \u2018Impairment of financial assets');
\u2022 The determination of the fair values of financial assets and liabilities (refer to Note 1.5.3 for \u2018Fair values of
financial assets and liabilities\u2019);\u00a0
\u2022 Investment in associate - assessment of additional impairment losses or reversal of previous impairment
losses (refer to Note 1.10 \u2018Investments in associates and joint ventures); and
\u2022 Provisions (refer to Note 1.15 \u2018Provisions, contingent liabilities and contingent assets\u2019).
In March 2024 ING repaid the final EUR 6 billion of its Targeted Longer-Term Refinancing Operations (TLTRO) III
participation. As a result, accounting for TLTRO is no longer an area of significant judgement in 2024, while it was
as such in 2023 and 2022.
1.5\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.
1.5.1\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.
1.5.2\u00a0 Classification and measurement of financial instruments
Financial assets
ING Bank classifies its financial assets in the following measurement categories:
\u2022 those to be measured subsequently at fair value (either through OCI, or through profit or loss); and
\u2022 those 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 \u2013 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:
\u2022 Amortised Cost (AC):
Debt instruments that are held for collection of contractual cash flows under a HtC business model where
those cash flows represent SPPI are measured at AC. Interest income from these financial assets is
included in Interest income using the Effective Interest Rate (EIR) method. Any gain or loss arising on
derecognition is recognised directly in profit or loss. Impairment losses are presented as a separate line
item in the statement of profit or loss.
\u2022 FVOCI:
Debt instruments that are held for collection of contractual cash flows and for selling the financial assets
under a HtC&S business model, where the assets\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.
\u2022 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 Other interest income or Other
interest expense in the period in which it arises. The interest arising on a debt instrument that is part of a
hedge relationship, but not subject to hedge accounting, is recognised in profit or loss and presented
within Other interest income or Other interest expense in the period in which it arises.
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 \u2013 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:
\u2022 the amount of change in the fair value that is attributable to changes in own credit risk of the liability
designated at FVPL is presented in OCI. Upon derecognition this Debit Valuation Adjustment (DVA) impact
does not recycle from OCI to profit or loss; and
\u2022 the 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 \u2018Other interest
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 'Impairment of financial assets') and (b) the amount
initially recognised less, when appropriate, cumulative amortisation recognised in accordance with the
revenue recognition principle of IFRS 15 \u2018Revenue from contracts with customers\u2019.
Repurchase transactions and reverse repurchase transactions
Securities sold subject to repurchase agreements (repo's), 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.
1.5.3\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.
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 such as Bid-Offer adjustments, Model Risk
Adjustments and Collateral Valuation Adjustments (CollVA).
Significant judgements and critical accounting estimates and assumptions:
\u2022 Even if market prices are available, when markets are less liquid there may be a range of prices for the
same security from different price sources. Selecting the most appropriate price requires judgement
and could result in different estimates of fair value.\u00a0
\u2022 Valuation techniques are subjective in nature and significant judgement is involved in establishing fair
values for certain financial assets and liabilities. Valuation techniques involve various assumptions
regarding pricing factors. The use of different valuation techniques and assumptions could produce
significantly different estimates of fair value.\u00a0
\u2022 Price testing is performed to assess whether the process of valuation has led to an appropriate fair
value of the position and to minimise the potential risks of economic losses due to incorrect or misused
models.
\u2022 Assessing 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.
\u2022 Reference is made to Note 32 '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.
1.5.4\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 or so-called economic hedges that are not in a formal hedge accounting relationship where a
component is presented separately in interest result in line with ING 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.
Benchmark rate reform \u2013 specific policies for hedges directly affected by the benchmark rate
reform
As explained in the \u2018Impact of the benchmark rate reform\u2019 paragraph of the \u2018Risk management\u2019 section, a
fundamental review of important interest rate benchmarks has been carried out, and is still ongoing for
some of them (for instance, WIBOR).
Given that the benchmark rate reform may have various accounting implications, the IASB has undertaken a
two-phase project. Phase 1 (issued in 2019) addresses those issues that affect financial reporting before the
replacement of an existing benchmark. Phase 2 (issued in 2020) focuses on issues that may affect financial
reporting when the existing benchmark rate is reformed or replaced.\u00a0
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:
\u2022 Highly 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.
\u2022 Prospective 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.
\u2022 Retrospective 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 benchmark rate
reform.
\u2022 Designation 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 the benchmark
interest rate exposure part of the benchmark rate 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 2024 (mainly for WIBOR hedges).
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 \u2018Risk management/ Impact of the benchmark
rate reform\u2019 for the disclosures relating to the application of the amendments as part of Phase 1.
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 benchmark rate
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. By applying these
mandatory amendments, ING Bank avoids hedge accounting discontinuations when modifying both hedged
items and hedging instruments (and related hedge documentation) as a consequence of the benchmark
rate reform that would otherwise be required in the absence of Phase 2 amendments. During 2024, 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.
More specifically, the following temporary reliefs are part of the Phase 2 amendments:
Relief from discontinuing hedging relationships
\u2022 Amendments in the hedge documentation as a consequence of changes required by the benchmark rate
reform do not result in the discontinuation of the hedge relationship nor the designation of a new hedge
relationship. The changes can be in the 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.
\u2022 When the hedged item is amended as a consequence of the benchmark rate 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.
\u2022 When the items within a designated group of hedged items are amended as a consequence of the
benchmark rate reform, the hedging strategy remains and is not discontinued. As items within the
hedged group transition at different times from the benchmark rates to RFRs, they are transferred to sub-
groups of instruments that reference RFRs as the hedged risk. The existing benchmark rates 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.
\u2022 For 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 decision is
made separately for each hedging relationship (i.e., on a hedge-by-hedge basis).
\u2022 Temporary 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.
As explained above, Phase 1 and Phase 2 benchmark rate amendments to IFRS provide specific hedge
accounting reliefs that allow hedge accounting relationships to continue when the benchmark rate reform is
ongoing. Phase 1 reliefs cease to apply when uncertainty arising from the benchmark rate reform is no
longer present with respect to the timing and amount of the benchmark rate-based cash flows of the
relevant instruments, or when the hedging instrument is discontinued. It is ING Bank\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. Refer to note \u2018Risk management/Impact of the benchmark rate reform\u2019 for
the disclosures relating to the application of the amendments as part of Phase 2.
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.
1.5.5\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 derivatives, repurchase and reverse repurchase agreements and cash pooling
agreements. A significant portion of offsetting is applied to derivatives and related cash margin balances,
which are either directly cleared through central clearing parties or cleared through clearing members of
central clearing parties. For more information, reference is made to Note 39 \u2018Offsetting financial assets and
liabilities\u2019.
1.5.6Impairment 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 ECL by considering on a discounted basis the cash shortfall it would
incur in case of a default and multiplying the shortfall by the probability of a default occurring. The ECL is the
sum of the probability-weighted outcomes. The ECL estimates are unbiased and include reasonable and
supportable information about past events, current conditions, and forecasts of future economic conditions.
ECL is recognised on the balance sheet as loan loss provisions (LLP).
Three stage approach
Financial assets are classified in one of the below three stages at each reporting date. A financial asset can
move between Stages during its lifetime. The Stages are based on changes in credit quality since initial
recognition and defined as follows:
\u2022 Stage 1
Financial assets that have not had a significant increase in credit risk since initial recognition (i.e. no
Stage 2 or 3 triggers apply). Assets are classified as Stage 1 upon initial recognition (with the exception
of purchased or originated credit impaired (POCI) assets) and ECL is determined by the probability that
a default occurs in the next 12 months (12 months ECL);
\u2022 Stage 2
Financial assets showing a significant increase in credit risk since initial recognition. For assets in Stage
2 ECL reflects an estimate on the credit losses over the remaining maturity of the asset (lifetime ECL);
or
\u2022 Stage 3
Financial assets that are credit-impaired. Also for these assets ECL is determined over the remaining
maturity of the asset.
Significant increase in credit risk
ING 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. Reference is made to the \u2018Criteria for identifying a significant increase in credit risk (SICR)\u2019 in
the \u2018Risk management\u2019 section of the Annual Report.
An asset that is in Stage 2 will move back to Stage 1 when none of the above criteria are in place anymore.
However, if the asset was moved to Stage 2 based on the forbearance status, then the asset stays in Stage 2
for at least 24 months. If the asset was classified as Stage 2 due to the '30 days past due' trigger, then the
asset is moved back to Stage 1 only after three months from when the trigger no longer applies.
Credit-impaired financial assets (Stage 3)
Financial assets are assessed for credit-impairment at each reporting date and more frequently when
circumstances warrant further assessment. Evidence of credit-impairment includes arrears of over 90 days
on any material credit obligation, indications that the borrower is experiencing significant financial difficulty,
a breach of contract, bankruptcy or distressed restructuring. The definition of 'credit-impaired' under IFRS 9
(Stage 3) is aligned with the definition of 'default' used by ING 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 enriched with the internal ING Bank view. A baseline, up-scenario and\u00a0 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.
The probability weights applied to each of the three scenarios
ING Bank uses three macroeconomic scenarios when determining IFRS 9 ECL (baseline, upside and
downside). The management approach used to determine the weights of each scenario and in selecting the
parts of the distribution of forecast errors from which the weights are derived is disclosed in the 'Alternative
Scenarios and Probability Weights' section. Additionally, this approach is detailed in the sensitivity analysis
within the 'Risk Management' section of the Annual Report.
Measurement of ECL
ING 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 the loan type, industry, geographic location,
collateral type, past due status and other relevant factors. These characteristics are relevant to the
estimation of future cash flows for groups of such assets by being indicative of the debtors\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 measurement 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 other things, repayment of the loan, collateral
recovery and the sale of the asset. Cash flows from collateral and other credit enhancements are included in
the measurement of ECL of the related financial asset when it is part of or integral to the contractual terms
of the financial asset and the credit enhancement is not recognised separately. For the individual
assessment, with granular (company or asset-specific) scenarios, specific factors can have a larger impact
on the future cash flows than macroeconomic factors.
When a financial asset is credit-impaired, interest income is no longer recognised based on the gross
carrying amount of the asset. Instead, interest income is calculated by applying the original effective
interest rate to the amortised cost of the asset, which is the gross carrying amount less the related loan loss
provision.
Purchased or Originated Credit Impaired (POCI) assets
POCI assets are financial assets that are credit-impaired on initial recognition. Impairment on a POCI asset is
determined based on lifetime ECL from initial recognition. POCI assets are recognised initially at an amount
net of ECL and are measured at AC using a credit-adjusted effective interest rate. In subsequent periods any
changes to the estimated lifetime ECL are recognised in profit or loss. Favourable changes are recognised as
an impairment gain if the lifetime ECL at the reporting date is lower than the estimated lifetime ECL at
origination.
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:
\u2022 After a restructuring has been completed and there is a high improbability of recovery of part of the
remaining loan exposure (including partial debt forgiveness);
\u2022 In a bankruptcy liquidation scenario;
\u2022 After divestment or sale of a credit facility at a discount;
\u2022 Specific fraud cases with no recourse options.
When a loan is uncollectable, it is written off against the related loan loss provision. Subsequent recoveries of
amounts previously written off are recognised in \u2018Addition to loan loss provisions\u2019 in the Consolidated
statement of profit or loss.
Debt forgiveness (or debt settlement) involves write-off, but also involves the forgiveness of a legal
obligation, in whole or in part. This means that ING Bank forfeits the legal right to recover the debt. As a
result, the financial asset needs to be derecognised.
Presentation of ECL
ECL for financial assets measured at AC is deducted from the gross carrying amount of the assets. For debt
instruments at FVOCI, the ECL is recognised in OCI, instead of deducting it from the carrying amount of the
asset. ECL also reflects any credit losses related to the portion of the loan commitment that is expected to
be drawn down over the remaining life of the instrument. The ECL on issued financial guarantee contracts, in
scope of IFRS 9 and not measured at FVPL, is recognised as liabilities and presented in Other provisions. ECL
are presented in profit or loss in Addition to loan loss provision.
Significant judgements and critical accounting estimates and assumptions:
The calculation of ECL requires a number of judgements and estimates. In particular:
\u2022 ING Bank makes various assumptions about the risk of default, the credit loss rates in case of a
default and expected future cash flows. For collective provisions, ING Bank applies significant
judgement when estimating modelled parameters such as PD, LGD and EAD, including the selection
and calibration of relevant models. For stage 3 individual provisioning, the determination and
probabilities of restructuring and recovery scenarios as well as the amount and timing of expected
future cash flows may be particularly subjective.
\u2022 Forward-looking macroeconomic scenarios used in impairment assessments are uncertain in nature.
The use of alternate forward-looking macroeconomic scenarios can produce significantly different
estimates of ECL. This is demonstrated in the sensitivity analysis in the \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.
\u2022 When determining whether the credit risk on a financial asset has increased significantly (criteria for
identifying a significant increase in credit risk), ING Bank 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.
\u2022 Judgement is exercised in management\u2019s evaluation of whether there is objective evidence that
exposures are credit-impaired.
\u2022 To reflect the risks that are not properly captured by the ECL models (including climate risk), a number
of management adjustments to the model-based ECL were necessary as at 31 December 2024, which
required significant judgement. Reference is made to the \u2018Management adjustments applied this
reporting period\u2019 paragraph in the \u2018Risk management\u2019 section of the Annual Report.
1.5.7\u00a0 Modification of financial instruments
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 are executed based on credit concerns they are also referred to as forbearance (refer to the \u2018Risk
Management\u2019 section of the Annual Report for more details) and require analysis on whether the contractual
terms have been substantially modified or not. A similar assessment is needed when contractual terms are
modified for reasons other than forbearance.
ING Bank determines whether there has been a substantial modification using both quantitative and
qualitative factors. If the modification results in a substantial modification of the terms of the loan, the
original loan is derecognised and a new loan is recognised at fair value at the modification date. In case of a
non-substantial modification, a modification gain or loss is recognised in profit or loss.
Benchmark rate reform\u2013 specific policies for modifications necessary to implement the benchmark rate
reform
As explained in the \u2018Benchmark rate reform \u2013 specific policies for hedges directly affected by the benchmark
rate reform\u2019 paragraph of section \u20181.5.4 Derivatives and hedge accounting\u2019, given that the benchmark rate
reform may have various accounting implications, the IASB undertook a two-phase project. Apart from
hedge accounting, Phase 2 amendments to IFRS relate to accounting for changes in the basis for
determining the contractual cash flows of financial assets and liabilities due to the benchmark rate reform.
Specifically, Phase 2 amendments require that the effective interest rate on debt financial instruments is
adjusted, but only to the extent that the modifications made to financial instruments are those necessary to
implement the benchmark rate reform and that the new basis for calculating cash flows is \u2018economically
equivalent\u2019 to the previous basis. By applying these mandatory amendments, ING Bank 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 the benchmark rate reform are treated as a
reset to the instrument\u2019s variable interest rate). Refer to note \u2018Risk management/Impact of the benchmark
rate reform\u2019 for the disclosures relating to the application of the amendments as part of Phase 2.
1.5.8\u00a0 Accounting for Targeted Longer-Term Refinancing Operations (TLTRO)
ING Bank participated in the Targeted Longer-Term Refinancing Operations (TLTRO III), which mainly affected
comparative periods as, in March 2024, ING repaid the final EUR 6 billion of its TLTRO III participation. ING
Bank considered TLTRO funding provided by the ECB to banks to be on market terms on the basis that the
ECB has established a separate market with TLTRO programmes. They have specific terms which are
different from other sources of funding available to banks, including those provided by the ECB.
Consequently, the rate under TLTRO was considered to be a market conforming rate and TLTRO funding was
recognised fully as a financial liability.
ING Bank interpreted the whole rate set by the ECB under TLTRO as a floating rate on the financial liability,
being the market rate for each specific period in time. This resulted in discrete rates for discrete interest
periods over the life of TLTRO. The change in the applicable rate between interest periods was seen as a
change in the floating rate and was accounted for prospectively. Similarly, if the ECB announced changes in
the rate for the amounts already drawn under the existing TLTRO, then such changes also represented a
change in a floating rate. Following this, such changes led to the recognition of an increased/decreased
interest in the relevant period of life of the exposure, rather than by the recognition of an immediate
modification gain or loss at the moment of the change of terms by the ECB. If the change related to the
periods already passed, the impact for those past periods was recognised in profit or loss immediately.
Reference is made to Note 12 \u2018Deposits from banks\u2019 and to Note 21 \u2018Net interest income\u2019 for the presentation
of ING Bank\u2019s participation in TLTRO programmes.
1.6\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.
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 41 \u2018Principal subsidiaries\u2019 and a description of ING's activities
involving structured entities is included in Note 42 '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.
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 regarding the minimum capital requirements that are imposed
by industry regulators in the countries in which the subsidiaries operate, other limitations exist in certain
countries.
1.7\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)) who decide which resources to allocate 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 reviews and assesses ING Bank's performance primarily by line of business. As a result, ING
identified five operating segments which are are also disclosed as reportable segments. Additionally, the
CODM receives information by geographical area based on the location of the office where trasnsactions
originate.
1.8\u00a0 Hyperinflation accounting
Since the second quarter of 2022, T\u00fcrkiye has been considered a hyperinflationary economy for accounting
purposes. As ING Bank has a subsidiary in T\u00fcrkiye, ING Bank has applied IAS 29 \u2018Financial Reporting in
Hyperinflationary Economies\u2019 to its operations since 2022 as if the economy in T\u00fcrkiye had always been
hyperinflationary. Given that ING Bank presents its results in EUR, comparatives do not get restated. As a
result, the impact of the first-time application of IAS 29, as well as the effect for that year were both
recognised in 2022. IAS 29 continued to be relevant for ING\u2019s operations in T\u00fcrkiye in 2023 and 2024. Under
IAS 29, the results of the operations in T\u00fcrkiye should be stated in terms of the current purchasing power at
the reporting date. For that, the consumer price index (CPI) as determined by the Turkish Statistical Institute
was used. The CPI for T\u00fcrkiye (2003=100) at 31 December 2024 was 2,684.55, at 31 December 2023 was
1,859.38 and for 2022 was 1,128.45 (movement 2024: 44.38%; movement 2023: 64.77%, movement 2022:
64.27%). The effect of such restatement for inflation in the current period of the statement of
comprehensive income and the balance sheet has been recognised in the statement of profit or loss within
\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
T\u00fcrkiye.
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 T\u00fcrkiye were translated and presented in EUR at the exchange rate on
31 December 2024. 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 chose to present both the restatement effect resulting from restating
ING Bank\u2019s interest in the equity of ING T\u00fcrkiye 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.
1.9\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 23 \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 20 'Equity', which discloses
the amounts included in the statement of profit or loss.
Group companies
The results and financial positions of all group companies that have a functional currency different from the
presentation currency are translated into the presentation currency as follows:
\u2022 Assets and liabilities are translated at the closing rate at the date of the statement of financial position;\u00a0
\u2022 Income and expenses are translated at average exchange rates (unless this average is not a reasonable
approximation of the cumulative effect of the rates prevailing on the transaction dates, in which case
income and expenses are translated at the dates of the transactions). However, under hyperinflation
accounting, income and expenses of ING T\u00fcrkiye are translated at the closing rate; and\u00a0
\u2022 All 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.
1.10\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:
\u2022 Representation on the board of directors;\u00a0
\u2022 Participation in the policymaking process; and\u00a0
\u2022 Interchange of managerial personnel.\u00a0
Joint ventures are entities over which ING Bank has joint control.
Investments in associates and joint ventures are initially recognised at cost and subsequently accounted for
using the equity method of accounting.
ING 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:
Identification of impairment indicators as well as indicators of potential reversal of previous impairments
of ING Bank\u2019s investment in TMBThanachart Bank Public Company Limited (hereafter: TTB), an associate,
requires significant judgement. When there is objective evidence of impairment or indicators that prior
period impairment losses no longer exist or may have decreased, value in use (VIU) needs to be
determined. Estimation of VIU involves significant estimates and management assumptions. See Note 8
\u2018Investments in associates and joint ventures\u2019.
1.11\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. Depreciation is
recognised on a straight-line basis over the estimated useful life (in general 20\u201350 years). On disposal, the
related revaluation reserve is transferred to retained earnings.
Equipment
Equipment is stated at cost less accumulated depreciation and any impairment losses. The cost of the assets
is depreciated on a straight line basis over their estimated useful lives, which are generally as follows: two to
five years for data processing equipment, and four to ten years for fixtures and fittings.\u00a0
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:
\u2022 Fixed payments (including in-substance fixed payments), less any lease incentives receivable;
\u2022 Variable lease payments that are based on an index or a rate;
\u2022 Amounts expected to be payable by the lessee under residual value guarantees;
\u2022 The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and
\u2022 Payments of penalties for terminating the lease, if the lease term reflects the lessee exercising that
option.
The lease payments are discounted using the interest rate implicit in the lease. If that rate cannot be readily
determined, the lessee\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.
Right-of-use assets are measured at cost comprising the amount of the initial measurement of the lease
liability, any lease payments made at or before the commencement date less any lease incentives received
and any initial direct costs and restoration costs.
The right-of-use asset is included in the statement of financial position line-item \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
decreases when payments are made. Any remeasurement of the lease liability due to a lease modification
or other reassessment results in a corresponding adjustment to the carrying amount of the right-of-use
asset.
1.12\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.
1.13\u00a0 Goodwill and other intangible assets
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. Impairment of goodwill, if
applicable, is included in the statement of profit or loss in Other operating expenses and is not subsequently
reversed.
Computer software
Computer software that has been purchased or generated internally for own use is stated at cost less
amortisation and any impairment losses. Amortisation is calculated on a straight-line basis over its useful
life, which generally does not exceed five years. Amortisation is included in Other operating expenses.
1.14\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.
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.
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.
1.15\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 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 39
'Legal proceedings'.
Critical accounting estimates and assumptions for the reorganisation provision are in estimating the
amounts and timing of cash flows as the announced transformation initiatives are implemented over a
period of several years. Reference is made to Note 15 'Provisions'.
1.16\u00a0 Irrevocable Payment Commitments on contributions to SRF and DGS
ING makes contributions to the Single Resolution Fund (SRF) and Deposit Guarantee Schemes (DGS). The
annual contributions are paid in cash or, in some cases, partly using Irrevocable Payment Commitments
(IPCs) that become payable if and when called. Cash contributions are accounted for as levies as described in
section 1.15 above while IPCs are disclosed as contingent liabilities in Note 38 Contingent liabilities and
commitments. Cash collateral posted on IPCs to the SRF is accounted for as an interest bearing financial
asset at amortised cost. Government bonds posted as collateral on IPCs to DGS continue to be recognised as
assets of ING as securities at amortised cost.
1.17\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.
Changes in plan assets include mainly:
\u2022 Return on plan assets are recognised as staff costs in the statement of profit or loss. It is determined
using a high quality corporate bond rate (identical to the discount rate used in determining the defined
benefit obligation) at the start of the reporting period; and\u00a0
\u2022 Remeasurements 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.\u00a0
Changes in the defined benefit obligation include mainly:
\u2022 Service cost which is recognised as staff costs in the statement of profit or loss;\u00a0
\u2022 Interest expenses are recognised as staff costs in the Statement of profit or loss. It is determined using a
high quality corporate bond rate at the start of the period;
\u2022 Remeasurements which are recognised in Other comprehensive income (equity) and not recycled to the
Statement of profit or loss;
\u2022 Any past service cost relating to a plan amendment is recognised in profit or loss in the period of the plan
amendment; and
\u2022 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.
1.18\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.
1.19\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 generally result from contracts with ING service providers, who
perform their 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.
1.20\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 include deposits from banks and
loans and advances to banks that are on demand. Furthermore, it includes treasury bills and other eligible
bills shorter than three months. Investments qualify as a cash equivalent if they are readily convertible to a
known amount of cash and are subject to an insignificant risk of changes in value.
Cash flows arising from foreign currency transactions are translated into the functional currency using the
exchange rates at the date of the cash flows.
The net cash flow shown in respect of Loans and advances to customers relates only to transactions
involving actual payments or receipts. The Addition to loan loss provision, which is deducted from the item
Loans and advances to customers in the statement of financial position, has been adjusted accordingly from
the result before tax and is shown separately in the statement of cash flows.
The difference between the Net cash flow in accordance with the statement of cash flows and the change
between the opening and closing balance of Cash and cash equivalents in the statement of financial position
is due to exchange rate differences and is presented separately in the cash flow statement.
Liabilities arising from financing activities are debt securities, lease liabilities and subordinated loans.
No change occurred in the issued share capital and share premium in 2024, 2023 and 2022.
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
December 2024, 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
December 2024, 7 preference shares were issued and fully paid (2023: 7 preference shares; 2022: 7
preference shares) amounting to EUR 8 (2023: EUR 8 and 2022: EUR 8).
43\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 30 '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.", "dimensions": { "concept": "ifrs-full:DisclosureOfMaterialAccountingPolicyInformationExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-507": { "value": "
Cash and cash equivalents include deposits from banks and loans and advances to banks that are payable
on demand.
Included in Cash and cash equivalents are minimum mandatory reserve deposits held at various central
banks. Reference is made to Note 36 '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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-509": { "value": "
Included in Cash and cash equivalents are minimum mandatory reserve deposits held at various central
banks. Reference is made to Note 36 'Transfer of financial assets, assets pledged and received as collateral'
for restrictions on Cash and balances with central banks.
Furthermore, in addition to the restrictions regarding the minimum capital requirements that are imposed
by industry regulators in the countries in which the subsidiaries operate, other limitations exist in certain
countries.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForRestrictedCashAndCashEquivalentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-510": { "value": "
Changes in liabilities arising from financing activities
Debt securities in issue
Subordinated Loans
Lease liabilities
Senior non-preferred
debt
in EUR million
2024
2023
2022
2024
2023
2022
2024
2023
2022
2024
2023
2022
Opening
balance
84,423
58,075
57,443
15,404
15,789
16,719
1,162
1,174
1,220
40,213
37,806
34,303
Cash flows:
Additions
115,308
110,477
81,636
4,603
2,225
983
9,533
7,013
10,347
Redemptions /
Disposals
-109,358
-86,061
-78,609
-2,931
-2,894
-1,090
-290
-291
-296
-3,692
-5,451
-3,897
Non cash
changes:
Amortisation
1,062
730
281
28
34
31
27
28
15
-3
1
-7
Other
111
403
-66
24
12
8
212
256
239
1,669
102
106
Changes in
unrealised
revaluations
594
1,279
-3,746
188
473
-1,470
544
1,436
-3,866
Foreign
exchange
movement
2,318
-479
1,135
564
-236
608
5
-4
-4
1,129
-694
820
Closing balance
94,459
84,423
58,075
17,879
15,404
15,789
1,116
1,162
1,174
49,393
40,213
37,806
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 2024 was EUR 290\u00a0million (2023: EUR
291\u00a0million).
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
2024
2023
Fixed rate debt securities
Within 1 year
26,358
29,790
More than 1 year but less than 2 years
5,718
4,660
More than 2 years but less than 3 years
4,429
6,279
More than 3 years but less than 4 years
5,907
4,068
More than 4 years but less than 5 years
6,105
4,722
More than 5 years
12,335
13,139
Total fixed rate debt securities
60,851
62,658
Floating rate debt securities
Within 1 year
26,262
17,871
More than 1 year but less than 2 years
2,343
226
More than 2 years but less than 3 years
1,080
2,176
More than 3 years but less than 4 years
117
75
More than 4 years but less than 5 years
902
0
More than 5 years
2,903
1,417
Total floating rate debt securities
33,607
21,765
Total debt securities
94,459
84,423
Reference is made to the consolidated statement of cash flows for further information on issuances,
redemptions and non-cash movements.
18\u00a0 Senior non-preferred debt
Senior non-preferred debt
In EUR million
2024
2023
Senior non-preferred debt
49,393
40,213
49,393
40,213
Senior non-preferred debt is lent on by ING Groep N.V. to ING Bank N.V. In the event of bankruptcy, such
senior non-preferred debt ranks senior to subordinated liabilities but junior to any other liabilities of ING Bank
N.V.
19\u00a0 Subordinated loans
Subordinated loans
In EUR million
2024
2023
Subordinated loans
17,879
15,404
17,879
15,404
Subordinated loans are bonds issued by ING Groep N.V. and its subsidiaries to raise Tier 1 and Tier 2 (CRR-\u00a0
eligible) capital. Under IFRS these securities are classified as liabilities and for regulatory purposes, they are
considered as capital. Subordinated loans of EUR 18,403 million (2023: EUR 16,240 million) have been placed
with ING Bank N.V. by ING Groep N.V.
In 2024 ING Groep N.V. issued USD 1.25 billion 8.00% Perpetual AT1 Contingent Convertible Capital Securities
in February, EUR 1.25 billion 4.38% Fixed Rate Subordinated Tier 2 Notes in May, EUR 1.25 billion\u00a0 4.25% Fixed
Rate Subordinated Tier 2 Notes in August and USD 1 billion 7.25% Perpetual AT1 Contingent Convertible
Capital Securities in September.
In 2024 ING T\u00fcrkiye issued USD 150\u00a0million 8.50% Fixed Rate Subordinated Tier 2 Notes in September.
In 2024 ING Groep N.V. redeemed USD 1.25 billion 6.75% Perpetual AT1 Contingent Convertible Capital
Securities in April, EUR 750 million 2.50% Fixed Subordinated Tier 2 notes in February and EUR 1 billion 1.63%
Fixed Subordinated Tier 2 notes in September on their first call dates.
Reference is made to the consolidated statement of cash flows for further information on issuances and
redemptions.
The average interest rate on subordinated loans is 4.59% (2023: 4.44%).", "dimensions": { "concept": "ifrs-full:DisclosureOfBorrowingsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-511": { "value": "84423000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:DebtSecuritiesInIssueMember", "unit": "iso4217:EUR" } }, "f-512": { "value": "58075000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:DebtSecuritiesInIssueMember", "unit": "iso4217:EUR" } }, "f-513": { "value": "57443000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:DebtSecuritiesInIssueMember", "unit": "iso4217:EUR" } }, "f-514": { "value": "15404000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SubordinatedLoansMember", "unit": "iso4217:EUR" } }, "f-515": { "value": "15789000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SubordinatedLoansMember", "unit": "iso4217:EUR" } }, "f-516": { "value": "16719000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SubordinatedLoansMember", "unit": "iso4217:EUR" } }, "f-517": { "value": "1162000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ifrs-full:LeaseLiabilitiesMember", "unit": "iso4217:EUR" } }, "f-518": { "value": "1174000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ifrs-full:LeaseLiabilitiesMember", "unit": "iso4217:EUR" } }, "f-519": { "value": "1220000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ifrs-full:LeaseLiabilitiesMember", "unit": "iso4217:EUR" } }, "f-520": { "value": "40213000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SeniorNonPreferredDebt1", "unit": "iso4217:EUR" } }, "f-521": { "value": "37806000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SeniorNonPreferredDebt1", "unit": "iso4217:EUR" } }, "f-522": { "value": "34303000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SeniorNonPreferredDebt1", "unit": "iso4217:EUR" } }, "f-523": { "value": "115308000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:IncreaseDecreaseThroughAdditionsLiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:DebtSecuritiesInIssueMember", "unit": "iso4217:EUR" } }, "f-524": { "value": "110477000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:IncreaseDecreaseThroughAdditionsLiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00/2024-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:DebtSecuritiesInIssueMember", "unit": "iso4217:EUR" } }, "f-525": { "value": "81636000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:IncreaseDecreaseThroughAdditionsLiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:DebtSecuritiesInIssueMember", "unit": "iso4217:EUR" } }, "f-526": { "value": "4603000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:IncreaseDecreaseThroughAdditionsLiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SubordinatedLoansMember", "unit": "iso4217:EUR" } }, "f-527": { "value": "2225000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:IncreaseDecreaseThroughAdditionsLiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00/2024-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SubordinatedLoansMember", "unit": "iso4217:EUR" } }, "f-528": { "value": "983000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:IncreaseDecreaseThroughAdditionsLiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SubordinatedLoansMember", "unit": "iso4217:EUR" } }, "f-529": { "value": "9533000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:IncreaseDecreaseThroughAdditionsLiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SeniorNonPreferredDebt1", "unit": "iso4217:EUR" } }, "f-530": { "value": "7013000000.0", "decimals": -6, "dimensions": { "concept": 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"scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SubordinatedLoansMember", "unit": "iso4217:EUR" } }, "f-583": { "value": "5000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:IncreaseDecreaseThroughEffectOfChangesInForeignExchangeRatesLiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ifrs-full:LeaseLiabilitiesMember", "unit": "iso4217:EUR" } }, "f-584": { "value": "-4000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:IncreaseDecreaseThroughEffectOfChangesInForeignExchangeRatesLiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00/2024-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ifrs-full:LeaseLiabilitiesMember", "unit": "iso4217:EUR" } }, "f-585": { "value": "-4000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:IncreaseDecreaseThroughEffectOfChangesInForeignExchangeRatesLiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ifrs-full:LeaseLiabilitiesMember", "unit": "iso4217:EUR" } }, "f-586": { "value": "1129000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:IncreaseDecreaseThroughEffectOfChangesInForeignExchangeRatesLiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SeniorNonPreferredDebt1", "unit": "iso4217:EUR" } }, "f-587": { "value": "-694000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:IncreaseDecreaseThroughEffectOfChangesInForeignExchangeRatesLiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00/2024-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SeniorNonPreferredDebt1", "unit": "iso4217:EUR" } }, "f-588": { "value": "820000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:IncreaseDecreaseThroughEffectOfChangesInForeignExchangeRatesLiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SeniorNonPreferredDebt1", "unit": "iso4217:EUR" } }, "f-589": { "value": "94459000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:DebtSecuritiesInIssueMember", "unit": "iso4217:EUR" } }, "f-590": { "value": "84423000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:DebtSecuritiesInIssueMember", "unit": "iso4217:EUR" } }, "f-591": { "value": "58075000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:DebtSecuritiesInIssueMember", "unit": "iso4217:EUR" } }, "f-592": { "value": "17879000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SubordinatedLoansMember", "unit": "iso4217:EUR" } }, "f-593": { "value": "15404000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SubordinatedLoansMember", "unit": "iso4217:EUR" } }, "f-594": { "value": "15789000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SubordinatedLoansMember", "unit": "iso4217:EUR" } }, "f-595": { "value": "1116000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ifrs-full:LeaseLiabilitiesMember", "unit": "iso4217:EUR" } }, "f-596": { "value": "1162000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ifrs-full:LeaseLiabilitiesMember", "unit": "iso4217:EUR" } }, "f-597": { "value": "1174000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ifrs-full:LeaseLiabilitiesMember", "unit": "iso4217:EUR" } }, "f-598": { "value": "49393000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SeniorNonPreferredDebt1", "unit": "iso4217:EUR" } }, "f-599": { "value": "40213000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SeniorNonPreferredDebt1", "unit": "iso4217:EUR" } }, "f-600": { "value": "37806000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:SeniorNonPreferredDebt1", "unit": "iso4217:EUR" } }, "f-601": { "value": "57201000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:InterestReceivedClassifiedAsOperatingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-602": { "value": "51030000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:InterestReceivedClassifiedAsOperatingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00/2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-603": { "value": "28110000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:InterestReceivedClassifiedAsOperatingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-604": { "value": "41459000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:InterestPaidClassifiedAsOperatingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-605": { "value": "33859000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:InterestPaidClassifiedAsOperatingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00/2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-606": { "value": "14201000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:InterestPaidClassifiedAsOperatingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-607": { "value": "-15742000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:NetInterestReceivedPaidClassifiedAsOperatingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-608": { "value": "-17171000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:NetInterestReceivedPaidClassifiedAsOperatingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00/2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-609": { "value": "-13909000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:NetInterestReceivedPaidClassifiedAsOperatingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-610": { "value": "235000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:DividendsReceived", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-611": { "value": "205000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:DividendsReceived", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00/2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-612": { "value": "229000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:DividendsReceived", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-613": { "value": "5239000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:DividendsPaidClassifiedAsFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-614": { "value": "10272000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:DividendsPaidClassifiedAsFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00/2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-615": { "value": "6319000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:DividendsPaidClassifiedAsFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2022-01-01T00:00:00/2023-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-616": { "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\u00a0December 2024, 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.\u00a0
The ING Bank Consolidated financial statements, as at and for the year ended 31 December 2024, were
authorised for issue in accordance with a resolution of the Management Board Banking on 3\u00a0March 2025. 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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-617": { "value": "ING Bank N.V.", "dimensions": { "concept": "ifrs-full:NameOfReportingEntityOrOtherMeansOfIdentification", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-618": { "value": "Naamloze Vennootschap", "dimensions": { "concept": "ifrs-full:LegalFormOfEntity", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-619": { "value": "Amsterdam, the Netherlands", "dimensions": { "concept": "ifrs-full:DomicileOfEntity", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-620": { "value": "the Netherlands", "dimensions": { "concept": "ifrs-full:CountryOfIncorporation", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-621": { "value": "ING Groep N.V.", "dimensions": { "concept": "ifrs-full:NameOfUltimateParentOfGroup", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-622": { "value": "ING Groep N.V.", "dimensions": { "concept": "ifrs-full:NameOfParentEntity", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-623": { "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.", "dimensions": { "concept": "ifrs-full:DescriptionOfNatureOfEntitysOperationsAndPrincipalActivities", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-624": { "value": "
The ING Bank Consolidated financial statements, as at and for the year ended 31 December 2024, were
authorised for issue in accordance with a resolution of the Management Board Banking on 3\u00a0March 2025. 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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-625": { "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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-626": { "value": "
1.3\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 2024, ING Bank updated the presentation of the Consolidated statement of changes in equity to simplify
its structure and reduce duplication. Comparative figures have been updated accordingly. Furthermore, ING
has changed the presentation and classification of Senior non-preferred instruments respectively in the
consolidated statement of financial position and consolidated statement of cash flows. ING believes this
change further improves presentation about these instruments and related cash flows. Comparative figures
have been updated accordingly. In addition, presentation in Note 28 'Segments' was updated to reflect the
clarified requirements for segment disclosures as issued by the IFRIC in an agenda decision issued in July
2024.
1.3.1\u00a0 Changes in IFRS effective in 2024
The following amendments to IFRS became effective in the current reporting period (and have been EU
endorsed) with no significant impact for ING Bank:
\u2022 Amendments to IFRS 16 'Leases': Lease Liability in a Sale and Leaseback (issued in September 2022).
\u2022 Amendments to IAS 1 \u2018Presentation of Financial Statements\u2019: Classification of Liabilities as Current or Non-
current (issued in January 2020) and Non-current liabilities with Covenants (issued in October 2022).
\u2022 Amendments to IAS 7 'Statement of Cash flows' and IFRS 7 'Financial Instruments: Disclosures': Supplier
Finance Arrangements (issued in May 2023).
1.3.2\u00a0 Upcoming changes in IFRS after 2024
ING Bank has not early adopted any of the following Standards, interpretations or amendments that have
been issued, but are not yet effective and is assessing their potential impact on for ING Bank.
Effective in 2025 (endorsed by the EU):
\u2022 Amendments to IAS 21 'The Effects of Changes in Foreign Exchange Rates': Lack of Exchangeability
(issued in August 2023).
The implementation of the above amendments is expected to have no significant impact on ING Bank's
Consolidated financial statements when they become effective.
Effective in 2026 (not yet endorsed by the EU):
\u2022 Amendments to IFRS 9 'Financial Instruments' and IFRS 7 'Financial Instruments: Disclosure': Classification
and Measurement of Financial Instruments (issued in May 2024).
\u2022 Amendments to IFRS 9 'Financial Instruments' and IFRS 7 'Financial Instruments: Disclosure': Contracts
Referencing Nature-dependent Electricity (issued in December 2024).
\u2022 Annual Improvements to IFRS Accounting Standards: Volume 11 (issued in July 2024).
Effective in 2027 (not yet endorsed by the EU):
\u2022 New Standard IFRS 18 'Presentation and Disclosure in Financial Statements' (issued in April 2024).
In addition, in May 2024, the IASB also issued a new accounting Standard IFRS 19 'Subsidiaries without Public
Accountability: Disclosures'. However, it is not applicable for the consolidated financial statements of ING
Bank.
", "dimensions": { "concept": "ifrs-full:DisclosureOfChangesInAccountingPoliciesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-627": { "value": "
1.3\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 2024, ING Bank updated the presentation of the Consolidated statement of changes in equity to simplify
its structure and reduce duplication. Comparative figures have been updated accordingly. Furthermore, ING
has changed the presentation and classification of Senior non-preferred instruments respectively in the
consolidated statement of financial position and consolidated statement of cash flows. ING believes this
change further improves presentation about these instruments and related cash flows. Comparative figures
have been updated accordingly. In addition, presentation in Note 28 'Segments' was updated to reflect the
clarified requirements for segment disclosures as issued by the IFRIC in an agenda decision issued in July
2024.
", "dimensions": { "concept": "ifrs-full:DisclosureOfReclassificationsOrChangesInPresentationExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-628": { "value": "
1.4\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:
\u2022 Loan loss provisions (financial assets) (refer to Note 1.5.6 \u2018Impairment of financial assets');
\u2022 The determination of the fair values of financial assets and liabilities (refer to Note 1.5.3 for \u2018Fair values of
financial assets and liabilities\u2019);\u00a0
\u2022 Investment in associate - assessment of additional impairment losses or reversal of previous impairment
losses (refer to Note 1.10 \u2018Investments in associates and joint ventures); and
\u2022 Provisions (refer to Note 1.15 \u2018Provisions, contingent liabilities and contingent assets\u2019).
Significant judgements and critical accounting estimates and assumptions:
\u2022 Even if market prices are available, when markets are less liquid there may be a range of prices for the
same security from different price sources. Selecting the most appropriate price requires judgement
and could result in different estimates of fair value.\u00a0
\u2022 Valuation techniques are subjective in nature and significant judgement is involved in establishing fair
values for certain financial assets and liabilities. Valuation techniques involve various assumptions
regarding pricing factors. The use of different valuation techniques and assumptions could produce
significantly different estimates of fair value.\u00a0
\u2022 Price testing is performed to assess whether the process of valuation has led to an appropriate fair
value of the position and to minimise the potential risks of economic losses due to incorrect or misused
models.
\u2022 Assessing 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.
\u2022 Reference is made to Note 32 '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:
The calculation of ECL requires a number of judgements and estimates. In particular:
\u2022 ING Bank makes various assumptions about the risk of default, the credit loss rates in case of a
default and expected future cash flows. For collective provisions, ING Bank applies significant
judgement when estimating modelled parameters such as PD, LGD and EAD, including the selection
and calibration of relevant models. For stage 3 individual provisioning, the determination and
probabilities of restructuring and recovery scenarios as well as the amount and timing of expected
future cash flows may be particularly subjective.
\u2022 Forward-looking macroeconomic scenarios used in impairment assessments are uncertain in nature.
The use of alternate forward-looking macroeconomic scenarios can produce significantly different
estimates of ECL. This is demonstrated in the sensitivity analysis in the \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.
\u2022 When determining whether the credit risk on a financial asset has increased significantly (criteria for
identifying a significant increase in credit risk), ING Bank 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.
\u2022 Judgement is exercised in management\u2019s evaluation of whether there is objective evidence that
exposures are credit-impaired.
\u2022 To reflect the risks that are not properly captured by the ECL models (including climate risk), a number
of management adjustments to the model-based ECL were necessary as at 31 December 2024, which
required significant judgement. Reference is made to the \u2018Management adjustments applied this
reporting period\u2019 paragraph in the \u2018Risk management\u2019 section of the Annual Report.
Significant judgements and critical accounting estimates and assumptions:
Identification of impairment indicators as well as indicators of potential reversal of previous impairments
of ING Bank\u2019s investment in TMBThanachart Bank Public Company Limited (hereafter: TTB), an associate,
requires significant judgement. When there is objective evidence of impairment or indicators that prior
period impairment losses no longer exist or may have decreased, value in use (VIU) needs to be
determined. Estimation of VIU involves significant estimates and management assumptions. See Note 8
\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 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 39
'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:DisclosureOfAccountingJudgementsAndEstimatesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-629": { "value": "
1.5\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.
1.5.1\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.
1.5.2\u00a0 Classification and measurement of financial instruments
Financial assets
ING Bank classifies its financial assets in the following measurement categories:
\u2022 those to be measured subsequently at fair value (either through OCI, or through profit or loss); and
\u2022 those 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 \u2013 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:
\u2022 Amortised Cost (AC):
Debt instruments that are held for collection of contractual cash flows under a HtC business model where
those cash flows represent SPPI are measured at AC. Interest income from these financial assets is
included in Interest income using the Effective Interest Rate (EIR) method. Any gain or loss arising on
derecognition is recognised directly in profit or loss. Impairment losses are presented as a separate line
item in the statement of profit or loss.
\u2022 FVOCI:
Debt instruments that are held for collection of contractual cash flows and for selling the financial assets
under a HtC&S business model, where the assets\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.
\u2022 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 Other interest income or Other
interest expense in the period in which it arises. The interest arising on a debt instrument that is part of a
hedge relationship, but not subject to hedge accounting, is recognised in profit or loss and presented
within Other interest income or Other interest expense in the period in which it arises.
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 \u2013 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:
\u2022 the amount of change in the fair value that is attributable to changes in own credit risk of the liability
designated at FVPL is presented in OCI. Upon derecognition this Debit Valuation Adjustment (DVA) impact
does not recycle from OCI to profit or loss; and
\u2022 the 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 \u2018Other interest
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 'Impairment of financial assets') and (b) the amount
initially recognised less, when appropriate, cumulative amortisation recognised in accordance with the
revenue recognition principle of IFRS 15 \u2018Revenue from contracts with customers\u2019.
Repurchase transactions and reverse repurchase transactions
Securities sold subject to repurchase agreements (repo's), 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.
1.5.3\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.
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 such as Bid-Offer adjustments, Model Risk
Adjustments and Collateral Valuation Adjustments (CollVA).
Significant judgements and critical accounting estimates and assumptions:
\u2022 Even if market prices are available, when markets are less liquid there may be a range of prices for the
same security from different price sources. Selecting the most appropriate price requires judgement
and could result in different estimates of fair value.\u00a0
\u2022 Valuation techniques are subjective in nature and significant judgement is involved in establishing fair
values for certain financial assets and liabilities. Valuation techniques involve various assumptions
regarding pricing factors. The use of different valuation techniques and assumptions could produce
significantly different estimates of fair value.\u00a0
\u2022 Price testing is performed to assess whether the process of valuation has led to an appropriate fair
value of the position and to minimise the potential risks of economic losses due to incorrect or misused
models.
\u2022 Assessing 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.
\u2022 Reference is made to Note 32 '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.
1.5.4\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 or so-called economic hedges that are not in a formal hedge accounting relationship where a
component is presented separately in interest result in line with ING 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.
Benchmark rate reform \u2013 specific policies for hedges directly affected by the benchmark rate
reform
As explained in the \u2018Impact of the benchmark rate reform\u2019 paragraph of the \u2018Risk management\u2019 section, a
fundamental review of important interest rate benchmarks has been carried out, and is still ongoing for
some of them (for instance, WIBOR).
Given that the benchmark rate reform may have various accounting implications, the IASB has undertaken a
two-phase project. Phase 1 (issued in 2019) addresses those issues that affect financial reporting before the
replacement of an existing benchmark. Phase 2 (issued in 2020) focuses on issues that may affect financial
reporting when the existing benchmark rate is reformed or replaced.\u00a0
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:
\u2022 Highly 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.
\u2022 Prospective 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.
\u2022 Retrospective 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 benchmark rate
reform.
\u2022 Designation 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 the benchmark
interest rate exposure part of the benchmark rate 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 2024 (mainly for WIBOR hedges).
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 \u2018Risk management/ Impact of the benchmark
rate reform\u2019 for the disclosures relating to the application of the amendments as part of Phase 1.
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 benchmark rate
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. By applying these
mandatory amendments, ING Bank avoids hedge accounting discontinuations when modifying both hedged
items and hedging instruments (and related hedge documentation) as a consequence of the benchmark
rate reform that would otherwise be required in the absence of Phase 2 amendments. During 2024, 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.
More specifically, the following temporary reliefs are part of the Phase 2 amendments:
Relief from discontinuing hedging relationships
\u2022 Amendments in the hedge documentation as a consequence of changes required by the benchmark rate
reform do not result in the discontinuation of the hedge relationship nor the designation of a new hedge
relationship. The changes can be in the 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.
\u2022 When the hedged item is amended as a consequence of the benchmark rate 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.
\u2022 When the items within a designated group of hedged items are amended as a consequence of the
benchmark rate reform, the hedging strategy remains and is not discontinued. As items within the
hedged group transition at different times from the benchmark rates to RFRs, they are transferred to sub-
groups of instruments that reference RFRs as the hedged risk. The existing benchmark rates 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.
\u2022 For 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 decision is
made separately for each hedging relationship (i.e., on a hedge-by-hedge basis).
\u2022 Temporary 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.
As explained above, Phase 1 and Phase 2 benchmark rate amendments to IFRS provide specific hedge
accounting reliefs that allow hedge accounting relationships to continue when the benchmark rate reform is
ongoing. Phase 1 reliefs cease to apply when uncertainty arising from the benchmark rate reform is no
longer present with respect to the timing and amount of the benchmark rate-based cash flows of the
relevant instruments, or when the hedging instrument is discontinued. It is ING Bank\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. Refer to note \u2018Risk management/Impact of the benchmark rate reform\u2019 for
the disclosures relating to the application of the amendments as part of Phase 2.
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.
1.5.5\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 derivatives, repurchase and reverse repurchase agreements and cash pooling
agreements. A significant portion of offsetting is applied to derivatives and related cash margin balances,
which are either directly cleared through central clearing parties or cleared through clearing members of
central clearing parties. For more information, reference is made to Note 39 \u2018Offsetting financial assets and
liabilities\u2019.
1.5.6Impairment 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 ECL by considering on a discounted basis the cash shortfall it would
incur in case of a default and multiplying the shortfall by the probability of a default occurring. The ECL is the
sum of the probability-weighted outcomes. The ECL estimates are unbiased and include reasonable and
supportable information about past events, current conditions, and forecasts of future economic conditions.
ECL is recognised on the balance sheet as loan loss provisions (LLP).
Three stage approach
Financial assets are classified in one of the below three stages at each reporting date. A financial asset can
move between Stages during its lifetime. The Stages are based on changes in credit quality since initial
recognition and defined as follows:
\u2022 Stage 1
Financial assets that have not had a significant increase in credit risk since initial recognition (i.e. no
Stage 2 or 3 triggers apply). Assets are classified as Stage 1 upon initial recognition (with the exception
of purchased or originated credit impaired (POCI) assets) and ECL is determined by the probability that
a default occurs in the next 12 months (12 months ECL);
\u2022 Stage 2
Financial assets showing a significant increase in credit risk since initial recognition. For assets in Stage
2 ECL reflects an estimate on the credit losses over the remaining maturity of the asset (lifetime ECL);
or
\u2022 Stage 3
Financial assets that are credit-impaired. Also for these assets ECL is determined over the remaining
maturity of the asset.
Significant increase in credit risk
ING 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. Reference is made to the \u2018Criteria for identifying a significant increase in credit risk (SICR)\u2019 in
the \u2018Risk management\u2019 section of the Annual Report.
An asset that is in Stage 2 will move back to Stage 1 when none of the above criteria are in place anymore.
However, if the asset was moved to Stage 2 based on the forbearance status, then the asset stays in Stage 2
for at least 24 months. If the asset was classified as Stage 2 due to the '30 days past due' trigger, then the
asset is moved back to Stage 1 only after three months from when the trigger no longer applies.
Credit-impaired financial assets (Stage 3)
Financial assets are assessed for credit-impairment at each reporting date and more frequently when
circumstances warrant further assessment. Evidence of credit-impairment includes arrears of over 90 days
on any material credit obligation, indications that the borrower is experiencing significant financial difficulty,
a breach of contract, bankruptcy or distressed restructuring. The definition of 'credit-impaired' under IFRS 9
(Stage 3) is aligned with the definition of 'default' used by ING 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 enriched with the internal ING Bank view. A baseline, up-scenario and\u00a0 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.
The probability weights applied to each of the three scenarios
ING Bank uses three macroeconomic scenarios when determining IFRS 9 ECL (baseline, upside and
downside). The management approach used to determine the weights of each scenario and in selecting the
parts of the distribution of forecast errors from which the weights are derived is disclosed in the 'Alternative
Scenarios and Probability Weights' section. Additionally, this approach is detailed in the sensitivity analysis
within the 'Risk Management' section of the Annual Report.
Measurement of ECL
ING 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 the loan type, industry, geographic location,
collateral type, past due status and other relevant factors. These characteristics are relevant to the
estimation of future cash flows for groups of such assets by being indicative of the debtors\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 measurement 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 other things, repayment of the loan, collateral
recovery and the sale of the asset. Cash flows from collateral and other credit enhancements are included in
the measurement of ECL of the related financial asset when it is part of or integral to the contractual terms
of the financial asset and the credit enhancement is not recognised separately. For the individual
assessment, with granular (company or asset-specific) scenarios, specific factors can have a larger impact
on the future cash flows than macroeconomic factors.
When a financial asset is credit-impaired, interest income is no longer recognised based on the gross
carrying amount of the asset. Instead, interest income is calculated by applying the original effective
interest rate to the amortised cost of the asset, which is the gross carrying amount less the related loan loss
provision.
Purchased or Originated Credit Impaired (POCI) assets
POCI assets are financial assets that are credit-impaired on initial recognition. Impairment on a POCI asset is
determined based on lifetime ECL from initial recognition. POCI assets are recognised initially at an amount
net of ECL and are measured at AC using a credit-adjusted effective interest rate. In subsequent periods any
changes to the estimated lifetime ECL are recognised in profit or loss. Favourable changes are recognised as
an impairment gain if the lifetime ECL at the reporting date is lower than the estimated lifetime ECL at
origination.
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:
\u2022 After a restructuring has been completed and there is a high improbability of recovery of part of the
remaining loan exposure (including partial debt forgiveness);
\u2022 In a bankruptcy liquidation scenario;
\u2022 After divestment or sale of a credit facility at a discount;
\u2022 Specific fraud cases with no recourse options.
When a loan is uncollectable, it is written off against the related loan loss provision. Subsequent recoveries of
amounts previously written off are recognised in \u2018Addition to loan loss provisions\u2019 in the Consolidated
statement of profit or loss.
Debt forgiveness (or debt settlement) involves write-off, but also involves the forgiveness of a legal
obligation, in whole or in part. This means that ING Bank forfeits the legal right to recover the debt. As a
result, the financial asset needs to be derecognised.
Presentation of ECL
ECL for financial assets measured at AC is deducted from the gross carrying amount of the assets. For debt
instruments at FVOCI, the ECL is recognised in OCI, instead of deducting it from the carrying amount of the
asset. ECL also reflects any credit losses related to the portion of the loan commitment that is expected to
be drawn down over the remaining life of the instrument. The ECL on issued financial guarantee contracts, in
scope of IFRS 9 and not measured at FVPL, is recognised as liabilities and presented in Other provisions. ECL
are presented in profit or loss in Addition to loan loss provision.
Significant judgements and critical accounting estimates and assumptions:
The calculation of ECL requires a number of judgements and estimates. In particular:
\u2022 ING Bank makes various assumptions about the risk of default, the credit loss rates in case of a
default and expected future cash flows. For collective provisions, ING Bank applies significant
judgement when estimating modelled parameters such as PD, LGD and EAD, including the selection
and calibration of relevant models. For stage 3 individual provisioning, the determination and
probabilities of restructuring and recovery scenarios as well as the amount and timing of expected
future cash flows may be particularly subjective.
\u2022 Forward-looking macroeconomic scenarios used in impairment assessments are uncertain in nature.
The use of alternate forward-looking macroeconomic scenarios can produce significantly different
estimates of ECL. This is demonstrated in the sensitivity analysis in the \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.
\u2022 When determining whether the credit risk on a financial asset has increased significantly (criteria for
identifying a significant increase in credit risk), ING Bank 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.
\u2022 Judgement is exercised in management\u2019s evaluation of whether there is objective evidence that
exposures are credit-impaired.
\u2022 To reflect the risks that are not properly captured by the ECL models (including climate risk), a number
of management adjustments to the model-based ECL were necessary as at 31 December 2024, which
required significant judgement. Reference is made to the \u2018Management adjustments applied this
reporting period\u2019 paragraph in the \u2018Risk management\u2019 section of the Annual Report.
1.5.7\u00a0 Modification of financial instruments
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 are executed based on credit concerns they are also referred to as forbearance (refer to the \u2018Risk
Management\u2019 section of the Annual Report for more details) and require analysis on whether the contractual
terms have been substantially modified or not. A similar assessment is needed when contractual terms are
modified for reasons other than forbearance.
ING Bank determines whether there has been a substantial modification using both quantitative and
qualitative factors. If the modification results in a substantial modification of the terms of the loan, the
original loan is derecognised and a new loan is recognised at fair value at the modification date. In case of a
non-substantial modification, a modification gain or loss is recognised in profit or loss.
Benchmark rate reform\u2013 specific policies for modifications necessary to implement the benchmark rate
reform
As explained in the \u2018Benchmark rate reform \u2013 specific policies for hedges directly affected by the benchmark
rate reform\u2019 paragraph of section \u20181.5.4 Derivatives and hedge accounting\u2019, given that the benchmark rate
reform may have various accounting implications, the IASB undertook a two-phase project. Apart from
hedge accounting, Phase 2 amendments to IFRS relate to accounting for changes in the basis for
determining the contractual cash flows of financial assets and liabilities due to the benchmark rate reform.
Specifically, Phase 2 amendments require that the effective interest rate on debt financial instruments is
adjusted, but only to the extent that the modifications made to financial instruments are those necessary to
implement the benchmark rate reform and that the new basis for calculating cash flows is \u2018economically
equivalent\u2019 to the previous basis. By applying these mandatory amendments, ING Bank 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 the benchmark rate reform are treated as a
reset to the instrument\u2019s variable interest rate). Refer to note \u2018Risk management/Impact of the benchmark
rate reform\u2019 for the disclosures relating to the application of the amendments as part of Phase 2.
1.5.8\u00a0 Accounting for Targeted Longer-Term Refinancing Operations (TLTRO)
ING Bank participated in the Targeted Longer-Term Refinancing Operations (TLTRO III), which mainly affected
comparative periods as, in March 2024, ING repaid the final EUR 6 billion of its TLTRO III participation. ING
Bank considered TLTRO funding provided by the ECB to banks to be on market terms on the basis that the
ECB has established a separate market with TLTRO programmes. They have specific terms which are
different from other sources of funding available to banks, including those provided by the ECB.
Consequently, the rate under TLTRO was considered to be a market conforming rate and TLTRO funding was
recognised fully as a financial liability.
ING Bank interpreted the whole rate set by the ECB under TLTRO as a floating rate on the financial liability,
being the market rate for each specific period in time. This resulted in discrete rates for discrete interest
periods over the life of TLTRO. The change in the applicable rate between interest periods was seen as a
change in the floating rate and was accounted for prospectively. Similarly, if the ECB announced changes in
the rate for the amounts already drawn under the existing TLTRO, then such changes also represented a
change in a floating rate. Following this, such changes led to the recognition of an increased/decreased
interest in the relevant period of life of the exposure, rather than by the recognition of an immediate
modification gain or loss at the moment of the change of terms by the ECB. If the change related to the
periods already passed, the impact for those past periods was recognised in profit or loss immediately.
Reference is made to Note 12 \u2018Deposits from banks\u2019 and to Note 21 \u2018Net interest income\u2019 for the presentation
of ING Bank\u2019s participation in TLTRO programmes.
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1.5.1\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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1.5.2\u00a0 Classification and measurement of financial instruments
Financial assets
ING Bank classifies its financial assets in the following measurement categories:
\u2022 those to be measured subsequently at fair value (either through OCI, or through profit or loss); and
\u2022 those 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 \u2013 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:
\u2022 Amortised Cost (AC):
Debt instruments that are held for collection of contractual cash flows under a HtC business model where
those cash flows represent SPPI are measured at AC. Interest income from these financial assets is
included in Interest income using the Effective Interest Rate (EIR) method. Any gain or loss arising on
derecognition is recognised directly in profit or loss. Impairment losses are presented as a separate line
item in the statement of profit or loss.
\u2022 FVOCI:
Debt instruments that are held for collection of contractual cash flows and for selling the financial assets
under a HtC&S business model, where the assets\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.
\u2022 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 Other interest income or Other
interest expense in the period in which it arises. The interest arising on a debt instrument that is part of a
hedge relationship, but not subject to hedge accounting, is recognised in profit or loss and presented
within Other interest income or Other interest expense in the period in which it arises.
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 \u2013 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:
\u2022 the amount of change in the fair value that is attributable to changes in own credit risk of the liability
designated at FVPL is presented in OCI. Upon derecognition this Debit Valuation Adjustment (DVA) impact
does not recycle from OCI to profit or loss; and
\u2022 the 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 \u2018Other interest
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 'Impairment of financial assets') and (b) the amount
initially recognised less, when appropriate, cumulative amortisation recognised in accordance with the
revenue recognition principle of IFRS 15 \u2018Revenue from contracts with customers\u2019.
Repurchase transactions and reverse repurchase transactions
Securities sold subject to repurchase agreements (repo's), 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.
1.5.3\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.
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 such as Bid-Offer adjustments, Model Risk
Adjustments and Collateral Valuation Adjustments (CollVA).
Significant judgements and critical accounting estimates and assumptions:
\u2022 Even if market prices are available, when markets are less liquid there may be a range of prices for the
same security from different price sources. Selecting the most appropriate price requires judgement
and could result in different estimates of fair value.\u00a0
\u2022 Valuation techniques are subjective in nature and significant judgement is involved in establishing fair
values for certain financial assets and liabilities. Valuation techniques involve various assumptions
regarding pricing factors. The use of different valuation techniques and assumptions could produce
significantly different estimates of fair value.\u00a0
\u2022 Price testing is performed to assess whether the process of valuation has led to an appropriate fair
value of the position and to minimise the potential risks of economic losses due to incorrect or misused
models.
\u2022 Assessing 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.
\u2022 Reference is made to Note 32 '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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-632": { "value": "
Financial assets
ING Bank classifies its financial assets in the following measurement categories:
\u2022 those to be measured subsequently at fair value (either through OCI, or through profit or loss); and
\u2022 those 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 \u2013 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:
\u2022 Amortised Cost (AC):
Debt instruments that are held for collection of contractual cash flows under a HtC business model where
those cash flows represent SPPI are measured at AC. Interest income from these financial assets is
included in Interest income using the Effective Interest Rate (EIR) method. Any gain or loss arising on
derecognition is recognised directly in profit or loss. Impairment losses are presented as a separate line
item in the statement of profit or loss.
\u2022 FVOCI:
Debt instruments that are held for collection of contractual cash flows and for selling the financial assets
under a HtC&S business model, where the assets\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.
\u2022 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 Other interest income or Other
interest expense in the period in which it arises. The interest arising on a debt instrument that is part of a
hedge relationship, but not subject to hedge accounting, is recognised in profit or loss and presented
within Other interest income or Other interest expense in the period in which it arises.
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 \u2013 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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-633": { "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 Other interest income or Other
interest expense in the period in which it arises. The interest arising on a debt instrument that is part of a
hedge relationship, but not subject to hedge accounting, is recognised in profit or loss and presented
within Other interest income or Other interest expense in the period in which it arises.
Financial assets \u2013 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:
\u2022 the amount of change in the fair value that is attributable to changes in own credit risk of the liability
designated at FVPL is presented in OCI. Upon derecognition this Debit Valuation Adjustment (DVA) impact
does not recycle from OCI to profit or loss; and
\u2022 the 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 \u2018Other interest
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 'Impairment of financial assets') and (b) the amount
initially recognised less, when appropriate, cumulative amortisation recognised in accordance with the
revenue recognition principle of IFRS 15 \u2018Revenue from contracts with customers\u2019.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForFinancialInstrumentsAtFairValueThroughProfitOrLossExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-634": { "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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-636": { "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:
\u2022 the amount of change in the fair value that is attributable to changes in own credit risk of the liability
designated at FVPL is presented in OCI. Upon derecognition this Debit Valuation Adjustment (DVA) impact
does not recycle from OCI to profit or loss; and
\u2022 the 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 \u2018Other interest
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 'Impairment of financial assets') and (b) the amount
initially recognised less, when appropriate, cumulative amortisation recognised in accordance with the
revenue recognition principle of IFRS 15 \u2018Revenue from contracts with customers\u2019.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForFinancialLiabilitiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-635": { "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:
\u2022 the amount of change in the fair value that is attributable to changes in own credit risk of the liability
designated at FVPL is presented in OCI. Upon derecognition this Debit Valuation Adjustment (DVA) impact
does not recycle from OCI to profit or loss; and
\u2022 the 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 \u2018Other interest
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 'Impairment of financial assets') and (b) the amount
initially recognised less, when appropriate, cumulative amortisation recognised in accordance with the
revenue recognition principle of IFRS 15 \u2018Revenue from contracts with customers\u2019.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForFinancialGuaranteesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-637": { "value": "
Repurchase transactions and reverse repurchase transactions
Securities sold subject to repurchase agreements (repo's), 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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-638": { "value": "
1.5.3\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.
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 such as Bid-Offer adjustments, Model Risk
Adjustments and Collateral Valuation Adjustments (CollVA).
Significant judgements and critical accounting estimates and assumptions:
\u2022 Even if market prices are available, when markets are less liquid there may be a range of prices for the
same security from different price sources. Selecting the most appropriate price requires judgement
and could result in different estimates of fair value.\u00a0
\u2022 Valuation techniques are subjective in nature and significant judgement is involved in establishing fair
values for certain financial assets and liabilities. Valuation techniques involve various assumptions
regarding pricing factors. The use of different valuation techniques and assumptions could produce
significantly different estimates of fair value.\u00a0
\u2022 Price testing is performed to assess whether the process of valuation has led to an appropriate fair
value of the position and to minimise the potential risks of economic losses due to incorrect or misused
models.
\u2022 Assessing 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.
\u2022 Reference is made to Note 32 '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.
1.5.6Impairment 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 ECL by considering on a discounted basis the cash shortfall it would
incur in case of a default and multiplying the shortfall by the probability of a default occurring. The ECL is the
sum of the probability-weighted outcomes. The ECL estimates are unbiased and include reasonable and
supportable information about past events, current conditions, and forecasts of future economic conditions.
ECL is recognised on the balance sheet as loan loss provisions (LLP).
Three stage approach
Financial assets are classified in one of the below three stages at each reporting date. A financial asset can
move between Stages during its lifetime. The Stages are based on changes in credit quality since initial
recognition and defined as follows:
\u2022 Stage 1
Financial assets that have not had a significant increase in credit risk since initial recognition (i.e. no
Stage 2 or 3 triggers apply). Assets are classified as Stage 1 upon initial recognition (with the exception
of purchased or originated credit impaired (POCI) assets) and ECL is determined by the probability that
a default occurs in the next 12 months (12 months ECL);
\u2022 Stage 2
Financial assets showing a significant increase in credit risk since initial recognition. For assets in Stage
2 ECL reflects an estimate on the credit losses over the remaining maturity of the asset (lifetime ECL);
or
\u2022 Stage 3
Financial assets that are credit-impaired. Also for these assets ECL is determined over the remaining
maturity of the asset.
Significant increase in credit risk
ING 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. Reference is made to the \u2018Criteria for identifying a significant increase in credit risk (SICR)\u2019 in
the \u2018Risk management\u2019 section of the Annual Report.
An asset that is in Stage 2 will move back to Stage 1 when none of the above criteria are in place anymore.
However, if the asset was moved to Stage 2 based on the forbearance status, then the asset stays in Stage 2
for at least 24 months. If the asset was classified as Stage 2 due to the '30 days past due' trigger, then the
asset is moved back to Stage 1 only after three months from when the trigger no longer applies.
Credit-impaired financial assets (Stage 3)
Financial assets are assessed for credit-impairment at each reporting date and more frequently when
circumstances warrant further assessment. Evidence of credit-impairment includes arrears of over 90 days
on any material credit obligation, indications that the borrower is experiencing significant financial difficulty,
a breach of contract, bankruptcy or distressed restructuring. The definition of 'credit-impaired' under IFRS 9
(Stage 3) is aligned with the definition of 'default' used by ING 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 enriched with the internal ING Bank view. A baseline, up-scenario and\u00a0 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.
The probability weights applied to each of the three scenarios
ING Bank uses three macroeconomic scenarios when determining IFRS 9 ECL (baseline, upside and
downside). The management approach used to determine the weights of each scenario and in selecting the
parts of the distribution of forecast errors from which the weights are derived is disclosed in the 'Alternative
Scenarios and Probability Weights' section. Additionally, this approach is detailed in the sensitivity analysis
within the 'Risk Management' section of the Annual Report.
Measurement of ECL
ING 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 the loan type, industry, geographic location,
collateral type, past due status and other relevant factors. These characteristics are relevant to the
estimation of future cash flows for groups of such assets by being indicative of the debtors\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 measurement 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 other things, repayment of the loan, collateral
recovery and the sale of the asset. Cash flows from collateral and other credit enhancements are included in
the measurement of ECL of the related financial asset when it is part of or integral to the contractual terms
of the financial asset and the credit enhancement is not recognised separately. For the individual
assessment, with granular (company or asset-specific) scenarios, specific factors can have a larger impact
on the future cash flows than macroeconomic factors.
When a financial asset is credit-impaired, interest income is no longer recognised based on the gross
carrying amount of the asset. Instead, interest income is calculated by applying the original effective
interest rate to the amortised cost of the asset, which is the gross carrying amount less the related loan loss
provision.
Purchased or Originated Credit Impaired (POCI) assets
POCI assets are financial assets that are credit-impaired on initial recognition. Impairment on a POCI asset is
determined based on lifetime ECL from initial recognition. POCI assets are recognised initially at an amount
net of ECL and are measured at AC using a credit-adjusted effective interest rate. In subsequent periods any
changes to the estimated lifetime ECL are recognised in profit or loss. Favourable changes are recognised as
an impairment gain if the lifetime ECL at the reporting date is lower than the estimated lifetime ECL at
origination.
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:
\u2022 After a restructuring has been completed and there is a high improbability of recovery of part of the
remaining loan exposure (including partial debt forgiveness);
\u2022 In a bankruptcy liquidation scenario;
\u2022 After divestment or sale of a credit facility at a discount;
\u2022 Specific fraud cases with no recourse options.
When a loan is uncollectable, it is written off against the related loan loss provision. Subsequent recoveries of
amounts previously written off are recognised in \u2018Addition to loan loss provisions\u2019 in the Consolidated
statement of profit or loss.
Debt forgiveness (or debt settlement) involves write-off, but also involves the forgiveness of a legal
obligation, in whole or in part. This means that ING Bank forfeits the legal right to recover the debt. As a
result, the financial asset needs to be derecognised.
Presentation of ECL
ECL for financial assets measured at AC is deducted from the gross carrying amount of the assets. For debt
instruments at FVOCI, the ECL is recognised in OCI, instead of deducting it from the carrying amount of the
asset. ECL also reflects any credit losses related to the portion of the loan commitment that is expected to
be drawn down over the remaining life of the instrument. The ECL on issued financial guarantee contracts, in
scope of IFRS 9 and not measured at FVPL, is recognised as liabilities and presented in Other provisions. ECL
are presented in profit or loss in Addition to loan loss provision.
Significant judgements and critical accounting estimates and assumptions:
The calculation of ECL requires a number of judgements and estimates. In particular:
\u2022 ING Bank makes various assumptions about the risk of default, the credit loss rates in case of a
default and expected future cash flows. For collective provisions, ING Bank applies significant
judgement when estimating modelled parameters such as PD, LGD and EAD, including the selection
and calibration of relevant models. For stage 3 individual provisioning, the determination and
probabilities of restructuring and recovery scenarios as well as the amount and timing of expected
future cash flows may be particularly subjective.
\u2022 Forward-looking macroeconomic scenarios used in impairment assessments are uncertain in nature.
The use of alternate forward-looking macroeconomic scenarios can produce significantly different
estimates of ECL. This is demonstrated in the sensitivity analysis in the \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.
\u2022 When determining whether the credit risk on a financial asset has increased significantly (criteria for
identifying a significant increase in credit risk), ING Bank 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.
\u2022 Judgement is exercised in management\u2019s evaluation of whether there is objective evidence that
exposures are credit-impaired.
\u2022 To reflect the risks that are not properly captured by the ECL models (including climate risk), a number
of management adjustments to the model-based ECL were necessary as at 31 December 2024, which
required significant judgement. Reference is made to the \u2018Management adjustments applied this
reporting period\u2019 paragraph in the \u2018Risk management\u2019 section of the Annual Report.
1.5.7\u00a0 Modification of financial instruments
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 are executed based on credit concerns they are also referred to as forbearance (refer to the \u2018Risk
Management\u2019 section of the Annual Report for more details) and require analysis on whether the contractual
terms have been substantially modified or not. A similar assessment is needed when contractual terms are
modified for reasons other than forbearance.
ING Bank determines whether there has been a substantial modification using both quantitative and
qualitative factors. If the modification results in a substantial modification of the terms of the loan, the
original loan is derecognised and a new loan is recognised at fair value at the modification date. In case of a
non-substantial modification, a modification gain or loss is recognised in profit or loss.
Benchmark rate reform\u2013 specific policies for modifications necessary to implement the benchmark rate
reform
As explained in the \u2018Benchmark rate reform \u2013 specific policies for hedges directly affected by the benchmark
rate reform\u2019 paragraph of section \u20181.5.4 Derivatives and hedge accounting\u2019, given that the benchmark rate
reform may have various accounting implications, the IASB undertook a two-phase project. Apart from
hedge accounting, Phase 2 amendments to IFRS relate to accounting for changes in the basis for
determining the contractual cash flows of financial assets and liabilities due to the benchmark rate reform.
Specifically, Phase 2 amendments require that the effective interest rate on debt financial instruments is
adjusted, but only to the extent that the modifications made to financial instruments are those necessary to
implement the benchmark rate reform and that the new basis for calculating cash flows is \u2018economically
equivalent\u2019 to the previous basis. By applying these mandatory amendments, ING Bank 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 the benchmark rate reform are treated as a
reset to the instrument\u2019s variable interest rate). Refer to note \u2018Risk management/Impact of the benchmark
rate reform\u2019 for the disclosures relating to the application of the amendments as part of Phase 2.
1.10\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:
\u2022 Representation on the board of directors;\u00a0
\u2022 Participation in the policymaking process; and\u00a0
\u2022 Interchange of managerial personnel.\u00a0
Joint ventures are entities over which ING Bank has joint control.
Investments in associates and joint ventures are initially recognised at cost and subsequently accounted for
using the equity method of accounting.
ING 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:
Identification of impairment indicators as well as indicators of potential reversal of previous impairments
of ING Bank\u2019s investment in TMBThanachart Bank Public Company Limited (hereafter: TTB), an associate,
requires significant judgement. When there is objective evidence of impairment or indicators that prior
period impairment losses no longer exist or may have decreased, value in use (VIU) needs to be
determined. Estimation of VIU involves significant estimates and management assumptions. See Note 8
\u2018Investments in associates and joint ventures\u2019.
1.15\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 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 39
'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
2024
2023
Amounts held at central banks 1
68,708\u00a0
88,627\u00a0
Cash and bank balances
1,645\u00a0
1,587\u00a0
70,353
90,214
1 Amounts held at central banks include an amount of EUR -14 million (2023 : EUR -5 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
2024
2023
2024
2023
2024
2023
Loans and advances to banks
14,352
9,451
7,439
7,287
21,791
16,738
Loan loss provisions
-8
-11
-13
-18
-22
-30
14,343
9,440
7,426
7,268
21,769
16,708
Loans and advances include balances of reverse repurchase transactions. For more information, refer to
Note 4 'Financial assets at fair value through profit or loss'. Furthermore, it includes on-demand and term
loans, and cash collateral transactions. Reference is made to Note 7 'Loans and advances to customers' for
information on finance lease receivables included in Loans and advances to banks.
As at 31\u00a0December 2024 and at 31 December 2023, all loans and advances to banks are non-subordinated.
Financial assets at fair value through other comprehensive income by type
in EUR million
2024
2023
Equity securities
2,562
1,885
Debt securities 1
42,219
38,281
Loans and advances 1
1,608
951
46,389
41,116
1 Debt securities include an amount of EUR -12 million (2023: EUR -13 million) and the Loans and advances includes EUR -7 million
(2023: EUR -8 million) of Loan loss provisions.
Debt securities by type of exposure
Debt Securities at
FVPL 1
Debt Securities at
FVOCI
Debt Securities at
AC
Total
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
Government bonds
289
362
24,757
20,988
22,734
24,050
47,780
45,400
Central bank bonds
444
446
2,900
2,043
3,344
2,489
Sub-sovereign, Supranationals
and Agencies
1,027
1,354
11,513
11,587
15,445
14,639
27,985
27,580
Covered bonds
4,108
4,084
5,683
5,231
9,791
9,315
Corporate bonds
848
799
79
127
106
109
1,033
1,035
Financial institutions' bonds
2,141
1,645
980
483
139
186
3,261
2,314
ABS portfolio
757
758
794
1,025
3,281
2,077
4,832
3,860
5,506
5,363
42,231
38,293
50,288
48,335
98,026
91,991
Loan loss provisions
-12
-13
-15
-22
-27
-34
Debt securities portfolio
5,506
5,363
42,219
38,281
50,273
48,313
97,999
91,957
1 Debt securities at FVPL includes both debt securities designated - and mandatorily measured at fair value through profit or loss.
Loans and advances to customers by type
Netherlands
Rest of the world
Total
in EUR million
2024
2023
2024
2023
2024
2023
Loans and advances to public authorities
1,888
1,070
16,773
13,314
18,661
14,384
Residential mortgages
117,223
110,475
227,992
214,120
345,216
324,596
Other personal lending
5,007
5,036
31,789
31,535
36,797
36,571
Corporate Lending
66,987
62,728
218,473
209,795
285,459
272,523
191,105
179,309
495,027
468,764
686,132
648,074
Loan loss provisions
-811
-830
-5,023
-4,791
-5,833
-5,621
190,295
178,480
490,004
463,973
680,299
642,453
8\u00a0 Investment in associates and joint ventures
Investments in associates and joint ventures
in EUR million
2024
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%
1,164
1,266
49,147
42,554
1,474
1,050
Other investments in associates and
joint ventures
412
1,679
Investments in associates and joint ventures
in EUR million
2023
Interest
held (%)
Fair value of
listed invest-
ments
Balance
sheet\u00a0
value
Total
assets
Total
liabilities
Total
income
Total
expenses
TMBThanachart Bank Public
Company Limited
23%
976
1,128
46,666
40,776
1,386
943
Other investments in associates
and joint ventures
381
1,509
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's shareholding and representation on the Board. TTB is part of the Corporate Line segment.
Other investments in associates and joint ventures
Included in Other investments in associates and joint ventures are mainly financial services and (non-)
financial technology funds or vehicles operating predominantly in Europe, and are individually not significant
to ING 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, the rating agency and
regulatory views, which can change over time.
Changes in Investments in associates and joint ventures
in EUR million
2024
2023
Opening balance as at 1 January
1,509
1,500
Additions
26
55
Transfers
-7
0
Revaluations
0
4
Share of results
205
149
Dividends received
-91
-74
Disposals
-16
-89
Impairments
-35
-5
Exchange rate differences
87
-32
Other
0
Closing balance
1,679
1,509
Share of results from associates and joint ventures of EUR 205 million (2023: EUR 149 million) as included in
the table above is mainly attributable to our share in the results of TTB of EUR 123\u00a0million (2023: EUR 107
million) and our share in the result of an associate in Belgium of EUR 77 million following a one-off profit.
The total impairment losses of EUR 35 million relate to associates that are not individually significant.
Impairments and reversal thereof on the investment in TTB
Accumulated impairments on the investment in TTB of EUR 395\u00a0million (2023: EUR 395\u00a0million) were
recognised in previous years. There is no impairment trigger observed as per 31 December 2024. A Value in
Use ('VIU') was estimated following the prolonged increase of the quoted TTB share price over the original
cost price of the investment and the sustained improved broker consensus outlook. As VIU did not exceed
the carrying amount of the investment in TTB no reversal of impairment, was recognised.
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and VIU. Fair
value less costs of disposal is based on observable share price. The VIU calculation uses discounted cash flow
projections based on management\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:
\u2022 The estimation of future earnings over a 5-year forecast period; and
\u2022 the terminal value being the extrapolation of earnings into perpetuity applying a long-term growth rate.
The earnings that are used for extrapolation represent the stable long-term financial results and position
of TTB, i.e. a steady state. The terminal value comprises the majority of the total VIU.
Key assumptions used in the VIU calculation as at 31 December 2024
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:
\u2022 Expected future earnings of TTB: Short- to medium-term expectations are based on forecasts derived
from broker consensus. Longer-term and steady-state expectations into perpetuity are derived using
reasonable and supportable assumptions capturing a combination of TTB specific and market data points;
A capital maintenance charge is applied, which is management\u2019s forecast of the earnings that need to be
withheld in order for TTB to meet target regulatory requirements over the forecast period;
\u2022 Discount rate (cost of equity): 10.96%, based on the capital asset pricing model (CAPM) calculated for TTB
using current market data; and
\u2022 Terminal growth rate: 2.74% consistent with current long term government bond yield in Thailand as a
proxy for a risk-free rate.
The model was evaluated for reasonably possible changes to key assumptions in the model. This reflects the
sensitivity of the VIU to each key assumption on its own and it is possible that more than one favourable
and/or unfavourable change may occur at the same time. The selected rates of reasonably possible changes
to key assumptions are based on external analysts\u2019 forecasts and other relevant external data sources,
which can change period to period. The sensitivity of the VIU to each key assumption is as follows:
\u2022 A favourable change of 10% in the cash flows would result in an increase in VIU of EUR 57 million, while
an unfavourable change of -10% would result in a decrease in VIU of EUR -59 million;\u00a0
\u2022 A favourable change of -1% in the discount rate would result in an increase in VIU of EUR 95 million, while
an unfavourable change of 1% would result in a decrease in VIU of EUR -75 million;
\u2022 A favourable change of 1% in the terminal growth rate would result in an increase in VIU of EUR 68
million, while an unfavourable change of -1% would result in a decrease in VIU of EUR -53 million;
Provisions by type
in EUR million
2024
2023
Reorganisation provisions
201
231
Litigation provisions
288
193
Other provisions
118
334
606
758
Loan loss provisions for guarantees
146
142
752
899
Changes in provisions
Reorganisation
Litigation
Other provisions
Total
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
Opening balance as at 1 January
231
418
193
150
334
433
758
1,001
Additions 1
146
207
116
78
26
39
288
325
Interest
Releases 1
-4
-34
-15
-26
-46
-22
-64
-82
Utilised
-163
-356
-31
-23
-196
-11
-390
-389
Exchange rate differences
-1
1
1
-1
-3
-4
Other changes
-10
-3
25
13
-104
15
-94
Closing balance
201
231
288
193
118
334
606
758
1 Additions to provisions and unused amounts released are presented in Note 27 'Other operating expenses' in the Statement of Profit\u00a0
or Loss.
32\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.
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, the Global Valuation and Impairment Committee, the Market Data Committee and
the Valuation Model Committee. All relevant committees meet on a regular basis (monthly/quarterly), where
the 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 Global
Financial Markets Parameter Committee reviews the consolidated valuation outcome and resulting P&L for
Financial Market products, targeting a globally consistent treatment across Financial Markets. 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 (hereafter:
DOP). ING defers material DOP 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 DOP 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 2024 and the DOP reserve is disclosed in
the below table.
Deferred Day One Profit or Loss Reserve
The table below summarises the movement in the aggregate DOP not recognised when financial instruments
were initially recognised, because of the use of valuation techniques for which not all the inputs were market
observable data.
Deferred day one profit or loss reserve
in EUR million
2024
2023
Opening balance at 1 January
-90
-108
DOP deferred on new transactions during the period
-62
-83
DOP recognised in the statement of profit or loss during the period:
\u2013 of which release
27
85
\u2013 of which amortisation and exchange differences
32
15
Closing balance at 31 December
-94
-90
The following table presents the model reserves for financial assets and liabilities.
Valuation adjustment reserves on financial assets and liabilities
in EUR million
2024
2023
Deferred Day One Profit or Loss
-94
-90
Own credit adjustments
-17
34
Bid/Offer
-130
-154
Model Risk
-33
-26
CVA
-123
-131
DVA
50
55
CollVA
-3
-4
FVA
-64
-68
Other valuation adjustments
2
0
Total Valuation Adjustments
-412
-385
Own Credit Adjustment
Own issued debt and structured notes that are designated at fair value through profit or loss are adjusted for
ING`s own credit risk by means of DVA.
Bid-Offer Adjustment
For positions priced based upon mid-market input parameters, Bid-Offer adjustments are required in order to
reflect the valuation of that position based on bid price or offer price. In practice this adjustment accounts for
the difference in valuation from \u2018mid to bid\u2019 and \u2018mid to offer\u2019 for long and short exposures respectively. In
principle, assets are valued at the bid prices and liabilities are valued at the offer price. For certain assets or
liabilities, where a market-quoted price is not available, the price used is the fair value that is most
representative within the bid-offer spread.
Model Risk Adjustment
Financial instruments that are valued using a valuation model can be subject to model risk. Model risk is the
risk of possible financial loss resulting from a pricing model or model-based parameter deficiencies and/or
uncertainties.
Bilateral Valuation Adjustments (Credit and Debit Valuation Adjustments)
Bilateral Valuation Adjustment is the valuation adjustment reflecting the counterparty credit risk of
derivative contracts. It has a bilateral nature, where both the counterparty\u2019s credit risk (i.e. Credit Valuation
Adjustment or CVA) and ING\u2019s own credit risk (Debit Valuation Adjustment or DVA) are taken into account:
\u2022 CVA is the fair value adjustment applicable to derivative instruments to account for the possibility that the
counterparty defaults (i.e. it is the market value of the counterparty\u2019s credit risk).
\u2022 DVA is the fair value adjustment applicable to derivative instruments to account for the possibility that
ING defaults (i.e. it is the market value of ING\u2019s credit risk).
The calculation of CVA and DVA on derivatives is based on their expected exposures, and the counterparties\u2019
and ING\u2019s risk of default, taking into account the collateral agreements as well as netting agreements. The
counterparties\u2019 risk of default is measured by probability of default and expected loss given default, which is
based on market information including credit default swap (CDS) spreads. Where counterparty CDS spreads
are not available, relevant proxy spreads are used. Additionally, wrong-way risk (which occurs when the
probability of default by the counterparty increases or decreases when ING\u2019s exposure to the counterparty
increases (decreases)) and right-way risk (which occurs when the probability of default by the counterparty
increases (decreases) when ING\u2019s exposure to the counterparty decreases (increases)) are included in the
adjustment.
Collateral Valuation Adjustment (CollVA)
Collateral Valuation Adjustment is a fair valuation adjustment applied on derivative instruments to capture
specific features of CSA (Credit Support Annex) with a counterparty that the regular OIS discounting
framework does not capture. Non-standard CSA features may include deviations in relation to the currencies
in which ING posts or receives collateral, deviations in the remuneration rate on collateral which may pay
lower or higher rate than the overnight rate or even no interest at all; other deviations can be posting
securities rather than cash as collateral.
Funding Valuation Adjustment (FVA)
Funding Valuation Adjustment (FVA) is a fair valuation adjustment applied on derivative instruments to
address the asymmetry in funding costs or funding benefits between collateralised and uncollateralised
derivative portfolios. This adjustment is based on the expected exposure profiles of the uncollateralised or
partially collateralised OTC derivatives and market-based funding spreads.
Other Valuation Adjustments
This pertains to other valuation adjustments that are immaterial to ING. Most of the balance consists of the
Market Price Uncertainty (MPU) adjustment in fair value, which accounts for the price uncertainty risk
inherent in the valuation inputs to fair value.
d) Fair value hierarchy
ING Bank has categorised 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 of the valuation inputs. Highest priority is retained to unadjusted quoted prices in active
markets for identical assets or liabilities and the lowest priority to valuation techniques supported by
unobservable inputs.
Transfers into and transfers out of fair value hierarchy levels are made on a quarterly basis at the end of the
reporting period.
Level 1 \u2013 (Unadjusted) quoted prices in active markets
This category includes financial instruments whose fair value is determined directly by reference to
(unadjusted) quoted prices in an active market. A financial instrument is regarded as quoted in an active
market if quoted prices are readily and regularly available from an exchange, dealer markets, brokered
markets, or principal to principal markets. Those prices represent actual and regularly occurring market
transactions with sufficient frequency and volume to provide pricing information on an ongoing basis.
Transfers out of Level 1 into Level 2 or Level 3 occur when ING Bank establishes that markets are no longer
active and therefore (unadjusted) quoted prices no longer provide reliable pricing information.
Level 2 \u2013 Valuation technique supported by observable inputs
This category includes financial instruments whose fair value is based on market observable inputs, either
directly or indirectly, other than quoted prices included within Level 1. The fair value for financial instruments
in this category can be determined by reference to quoted prices for similar instruments in active markets,
quoted prices for identical or similar instruments in markets that are not active, inputs other than quoted
prices that are observable or market-corroborated inputs. ING analyses how the prices are derived and
determines whether the prices are liquid tradable prices or model-based consensus prices taking various
data as inputs.
For financial instruments that do not have a reference price available, fair value is determined using a
valuation technique (e.g., a model), where inputs in the model are taken from an active market or are
observable, such as interest rates and yield curves observable at commonly quoted intervals, implied
volatilities, and credit spreads.
Instruments where inputs are unobservable are classified in this category, provided that the impact of those
unobservable inputs on the overall valuation is insignificant. The notion of significant is particularly relevant
for the distinction between Level 2 and Level 3 assets and liabilities, as the significance assessment of the
valuation input on the entire fair value measurement will determine whether the instrument should be
classified as Level 2 or Level 3. Expert judgement is required on the significance assessment approach.
Level 3 \u2013 Valuation technique supported by unobservable inputs
This category includes financial instruments whose fair value is determined using a valuation technique for
which a significant part of the overall valuation is driven by unobservable valuation inputs. Where valuation
inputs are unobservable, the Group must use the best information available to value the instruments. This
may require internally derived inputs taking into account market participants' assumptions that are
reasonably available, including assumptions on the risk inherent in a particular valuation technique used to
measure fair value and the risk inherent in the inputs to the valuation technique. Unobservable inputs may
include, among others, volatility, correlation, spreads to discount rates, default rates, recovery rates,
prepayment rates, and certain credit spreads.
Financial instruments at fair value
The fair values of the financial instruments were determined as follows:
Methods applied in determining fair values of financial assets and liabilities (carried at fair value)
Level 1
Level 2
Level 3
Total
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
Financial Assets
Financial assets at fair value
through profit or loss
- Equity securities
20,798
15,449
15
3
141
150
20,954
15,602
- Debt securities
7,485
4,825
4,596
4,081
3,505
3,364
15,586
12,270
- Derivatives
1
39
31,792
27,134
475
535
32,268
27,708
- Loans and receivables
0
0
62,168
63,316
6,614
4,131
68,782
67,446
28,285
20,314
98,571
94,533
10,734
8,179
137,590
123,026
Financial assets at fair value
through other
comprehensive income
- Equity securities
2,292
1,622
270
263
2,562
1,885
- Debt securities
39,859
35,848
2,360
2,433
0
0
42,219
38,281
- Loans and receivables
0
0
1,608
275
0
676
1,608
951
42,151
37,470
3,967
2,707
270
938
46,389
41,116
Financial liabilities
Financial liabilities at fair
value through profit or loss
\u2013\u00a0 Debt securities
824
575
8,437
7,603
67
47
9,328
8,224
\u2013\u00a0 Deposits
45,648
57,607
13
45,648
57,620
\u2013\u00a0 Trading securities
3,631
3,604
12
41
10
3,653
3,645
\u2013\u00a0 Derivatives
45
41
27,528
24,437
694
670
28,267
25,148
4,501
4,220
81,625
89,687
770
729
86,896
94,637
The following methods and assumptions were used by ING 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 the 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 include 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 institution bonds are generally traded in active
markets. Where quoted prices are readily and regularly available, they are classified as Level 1. The
remaining positions are classified as Level 2 or Level 3 depending on the trading activity and observability of
prices. 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: Derivative 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, among 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 include 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 and
debt instruments, primarily comprised of structured notes, which are held at fair value under the fair value
option. Besides that, they include 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 a EUR 0.8 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 2024.
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 2024 of EUR 11.0 billion
(31\u00a0December 2023: EUR 9.1 billion), an amount of EUR 9.6 billion (87.2%) (31\u00a0December 2023: EUR 7.0 billion,
being 76.7%) 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 include EUR 0.1 billion (31\u00a0December 2023: EUR 0.3 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 1.3 billion (31\u00a0December 2023: EUR 1.8 billion) of the fair value classified in Level 3
financial assets is established using valuation techniques that incorporate certain inputs that are
unobservable.
Of the total amount of financial liabilities classified as Level 3 as at 31\u00a0December 2024 of EUR 0.8 billion
(31\u00a0December 2023: EUR 0.7 billion), an amount of EUR 0.6 billion (75.7%) (31\u00a0December 2023: EUR 0.4 billion,
being 50.0%) 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 include EUR 0.1 billion (31\u00a0December 2023: EUR 0.3 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 2023: 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
2024
2023
2024
2023
2024
2023
2024
2023
At fair value through profit or loss
Debt securities
3,504
3,364
10
0
Price based
Price (%)
0%
0%
120%
122%
Price (price per share)
327
97
520
236
Present value techniques
Credit spread (bps)
n.a.
94
n.a.
94
Price (%)
95.85%
n.a.
100%
n.a.
Equity securities
141
150
Price based
Price (price per share)
0
0
5,475
5,457
Loans and advances
1,565
2,298
0
13
Price based
Price (%)
0%
0%
107%
117%
Present value techniques
Credit spread (bps)
576
1
629
12
Prepayment rate (%)
2%
n.a.
100%
n.a.
(Reverse) repo's
5,050
1,832
Present value techniques
Interest rate (%)
2%
n.a.
2%
n.a.
Structured notes
67
47
Price based
Price (%)
93%
88%
104%
96%
Option pricing model
Equity volatility (%)
n.a.
9%
n.a.
23%
Equity/Equity correlation
0.7
0.8
0.7
0.9
Equity/FX correlation
n.a.
-0.2
n.a.
0.6
Dividend yield (%)
n.a.
0%
n.a.
4%
Present value techniques
Credit spreads (bps)
n.a.
100
n.a.
101
Prepayment rate (%)
99.59%
n.a.
100.09%
n.a.
Derivatives
\u2013\u00a0\u00a0Rates
413
283
389
301
Option pricing model
Interest rate volatility (bps)
n.a.
1
n.a.
3
Present value techniques
Reset spread (%)
2%
n.a.
2%
n.a.
Prepayment rate (%)
n.a.
0%
n.a.
0%
\u2013\u00a0\u00a0FX
6
2
8
3
Option pricing model
Implied volatility (%)
2%
3%
15%
18%
\u2013\u00a0\u00a0Credit
39
216
241
343
Present value techniques
Credit spread (bps)
0
3
91
149
Price based
Price (%)
0%
0%
100%
100%
\u2013\u00a0\u00a0Equity
10
20
47
17
Option pricing model
Equity volatility (%)
7%
12%
81%
75%
Equity/Equity correlation
0.0
0.2
1.0
1.0
Equity/FX correlation
-0.6
-0.5
0.6
1.0
Dividend yield (%)
0%
0%
33%
14%
Price based
Price (%)
n.a.
0%
n.a.
21%
\u2013\u00a0\u00a0Other
6
14
9
7
Option pricing model
Commodity volatility (%)
13.1%
11%
61%
94%
Com/FX correlation
-0.40
n.a.
-0.25
n.a.
Price based
Price (commodity)
68
n.a.
68
n.a.
At fair value through other comprehensive income
\u2013\u00a0\u00a0Loans and advances
676
Price based
Price (%)
n.a.
85%
n.a.
96%
\u2013\u00a0\u00a0Equity
270
263
Present value techniques
Credit spread (bps)
5.67
5.2
5.76
5.2
Interest rate (%)
1.5%
4%
3.5%
4%
Payout ratio (%)
70%
n.a.
90%
n.a.
Price based
Price (%)
122%
122%
122%
122%
Total
11,005
9,118
770
729
1 The abbreviation n.a. stands for not applicable or not available.
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 a strong positive (statistical) relationship, where underliers move, everything else equal,
into the same direction. The same holds for a high negative correlation.
Interest rate
An interest rate is the amount of interest due per period, as a proportion of the amount lent, deposited, or
borrowed.
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.
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.
Payout ratio
Dividend payout ratio is an input that shows the percentage of dividends a company is expected to pay out
each year relative to its net income.
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
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
Opening balance as at 1 January
848
873
286
421
3,499
1,849
3,547
3,492
938
891
9,118
7,526
Realised gain/loss\u00a0 recognised in the statement of profit or loss during the period 1
-175
235
-38
-142
294
-33
-54
-383
0
28
-322
Revaluation recognised in other comprehensive income during the period 2
-3
-6
-3
-6
Purchase of assets
486
1,246
198
76
4,424
2,208
1,600
873
154
331
6,862
4,735
Sale of assets
-111
-889
-257
-55
-1,605
-1,109
-10
-138
-418
-243
-2,402
-2,433
Maturity/settlement
-140
-1,005
-7
-15
-294
-576
-988
-292
-20
-22
-1,449
-1,910
Reclassifications
0
0
0
0
0
723
0
0
0
5
0
728
Transfers into Level 3
370
879
0
0
615
981
30
1
0
0
1,014
1,860
Transfers out of Level 3
-454
-459
-114
0
-1,214
-534
-3
0
-384
0
-2,169
-994
Exchange rate differences
0
-31
0
0
5
-9
-2
-9
9
-10
12
-59
Changes in the composition of the group and other changes
0
0
0
0
-1
0
0
2
-5
-8
-6
-6
Closing balance
824
848
68
286
5,721
3,499
4,121
3,547
270
938
11,005
9,118
1 Net gains/losses were recorded as \u2018Valuation results and net trading income\u2019 in the statement of profit or loss. The total amounts includes EUR -41 million (2023: EUR 316 million) of unrealised gains and losses recognised in the statement of profit or loss.
2 Revaluation recognised in other comprehensive income is included on the line \u2018Net change in fair value of debt instruments at fair value through other comprehensive income\u2019.
In 2024 and 2023, transfers into and out of Level 3 of financial assets mandatorily at fair value mainly relate
to (long- term) reverse repurchase transactions for which the valuation being significantly impacted by
unobservable inputs and no longer significantly impacted by unobservable inputs, respectively.
In 2024, the transfer into Level 3 trading assets consisted of cross currency swap trades, which were
transferred to Level 3 as a result of the valuation being significantly impacted by unobservable inputs.
Conversely, the transfer out of Level 3 in trading assets and non-trading derivatives primarily involved
derivative instruments, as their valuations were no longer significantly impacted by unobservable inputs.
In 2024, the transfer out of Level 3 of financial assets at FVOCI relates to HtC&S portfolio transferred to Level
2 resulting from change in methodology.
In 2023, the transfer into Level 3 trading assets is mainly driven by debt securities that are part of a structure
transferred into level 3 due to market illiquidity which decreased observability for an input.
Changes in Level 3 Financial liabilities
Trading liabilities
Non-trading
derivatives
Financial liabilities
designated as at fair
value through profit
or loss
Total
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
Opening balance as at 1
January
382
229
301
449
47
54
729
732
Realised gain/loss recognised
in the statement of profit or
loss during the period1
-104
224
-98
-151
-5
-2
-206
72
Additions
55
53
190
72
29
18
274
142
Redemptions
-12
-102
-209
-53
0
-2
-222
-156
Maturity/settlement
-15
-13
-7
-16
-4
-1
-26
-30
Transfers into Level 3
364
40
0
0
34
32
399
72
Transfers out of Level 3
-33
-49
-111
0
-34
-54
-179
-102
Exchange rate differences
0
0
0
0
0
0
0
0
Closing balance
637
382
67
301
67
47
770
729
1 Net gains/losses were recorded as \u2018Valuation results and net trading income\u2019 in the statement of profit or loss. The total amount
includes EUR -206 million (2023: EUR 72\u00a0million) of unrealised gains and losses recognised in the statement of profit or loss.
In 2024, the transfers into Level 3 mainly consisted of trading liabilities attributed to cross currency swap
trades transferred into Level 3 as a result of the valuation being significantly impacted by unobservable
inputs. The transfers out of Level 3 for non-trading derivatives are driven by interest rate swap trades, which
were reclassified out of Level 3 as their valuations were no longer influenced by significantly unobservable
inputs.
In 2023, transfers of financial liabilities into and out of Level 3 mainly consisted of structured notes,
measured as designated at fair value through profit or loss. The structured notes were transferred out of
Level 3 as the valuation was no longer impacted by significantly unobservable inputs.
g) Recognition of unrealised gains and losses in Level 3
Amounts recognised in the statement of profit or loss relating to unrealised gains and losses during the year
that relate to Level 3 assets and liabilities are included in the line item \u2018Valuation results and net trading
income\u2019 in the statement of profit or loss.
h) Level 3: Sensitivity analysis of unobservable inputs
Where the fair value of a financial instrument is determined using inputs which are unobservable and which
have a more than insignificant impact on the fair value of the instrument, the actual value of those inputs at
the balance date may be drawn from a range of reasonably possible alternatives. In line with market
practice, the upper and lower bounds of the range of alternative input values reflect a level of valuation
certainty. The actual levels chosen for the unobservable inputs in preparing the financial statements are
consistent with the valuation methodology used for fair valued financial instruments.
In practice, valuation uncertainty is measured and managed per exposure to individual valuation inputs (i.e.
risk factors) at portfolio-level across different product categories. Where the disclosure looks at individual
Level 3 inputs, the actual valuation adjustments may also reflect the benefits of portfolio offsets.
This disclosure does not attempt to indicate or predict future fair value movement. The numbers in isolation
give limited information as in most cases these Level 3 assets and liabilities should be seen in combination
with other instruments (for example as a hedge) that are classified as Level 2.
The valuation uncertainty in the table below is broken down by related risk class rather than by product. The
possible impact of a change of unobservable inputs in the fair value of financial instruments where
unobservable inputs are significant to the valuation is as follows:
Sensitivity analysis of Level 3 instruments
Positive fair\u00a0value
movements from
using reasonable
possible alternatives
Negative fair\u00a0value
movements from
using reasonable
possible alternatives
in EUR million
2024
2023
2024
2023
Equity (equity derivatives, structured notes)
21
18
-20
-9
Interest rates (Rates derivatives, FX derivatives)
5
3
0
0
Credit (Debt securities, Loans, structured notes, credit derivatives)
2
45
-27
-54
Loans and advances
0
3
0
-17
28
69
-47
-80
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.
Methods applied in determining fair values of financial assets and liabilities (carried at amortised cost)
Carrying Amount
Carrying amount
presented as fair value1
Level 1
Level 2
Level 3
Total fair value
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
Financial Assets
Loans and advances to banks
21,769
16,708
3,194
2,721
15,614
11,430
2,957
2,511
21,766
16,662
Loans and advances to customers
680,299
642,453
18,296
15,686
18,626
14,602
630,493
593,098
667,415
623,386
Securities at amortised cost
50,273
48,313
42,871
40,041
2,908
4,277
2,523
1,693
48,303
46,010
752,341
707,474
21,490
18,407
42,871
40,041
37,149
30,308
635,973
597,302
737,483
686,058
Financial liabilities
Deposits from banks
16,722
23,257
4,347
3,764
8,208
15,066
3,943
3,968
16,498
22,799
Customer deposits2
699,725
662,004
582,511
556,766
69,790
63,348
46,984
41,063
699,285
661,177
Debt securities in issue3
94,459
84,423
33,019
25,898
59,141
38,301
2,000
20,225
94,161
84,424
Senior non-preferred debt2
49,393
40,213
50,230
40,607
186
50,230
40,793
Subordinated loans
17,879
15,404
18,357
15,361
18,357
15,361
878,178
825,300
586,857
560,530
33,019
25,898
205,726
172,684
52,927
65,443
878,530
824,555
1 In accordance with IFRS and for the purpose of this disclosure, the carrying amount of financial instruments with an immediate on demand feature is presented as fair value
2 The presentation on senior non-preferred debt change has led to adjustments in the comparative figures for customer deposits and senior non-preferred debt.
3 In 2023, debt securities included a commercial paper issued classified as Level 3. Following a change in valuation technique in 2024, it transferred to Level 2.
The aggregation of the fair values presented above does not represent, and should not be construed as
representing, the underlying value of ING. These fair values were calculated for disclosure purposes only. The
carrying amount of financial instruments presented in the above table includes, when applicable, the fair
value hedge adjustment, this explains why (for these cases) 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.
Securities at amortised cost
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 include 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.
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 reflect ING\u2019s own credit
risk.
Customer deposits
In the current interest rate environment, there is significant embedded value in our on-demand deposits.
However, for the purpose of this disclosure and in accordance with IFRS, the carrying amounts of deposits
with an immediate on demand feature are presented as fair value.
The fair value of deposits with fixed contractual terms has 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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-639": { "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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-640": { "value": "Significant judgements and critical accounting estimates and assumptions: \u2022 Even if market prices are available, when markets are less liquid there may be a range of prices for the same security from different price sources. Selecting the most appropriate price requires judgement and could result in different estimates of fair value.\u00a0 \u2022 Valuation techniques are subjective in nature and significant judgement is involved in establishing fair values for certain financial assets and liabilities. Valuation techniques involve various assumptions regarding pricing factors. The use of different valuation techniques and assumptions could produce significantly different estimates of fair value.\u00a0 \u2022 Price testing is performed to assess whether the process of valuation has led to an appropriate fair value of the position and to minimise the potential risks of economic losses due to incorrect or misused models. \u2022 Assessing 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. \u2022 Reference is made to Note 32 '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:The calculation of ECL requires a number of judgements and estimates. In particular:\u2022 ING Bank makes various assumptions about the risk of default, the credit loss rates in case of a default and expected future cash flows. For collective provisions, ING Bank applies significant judgement when estimating modelled parameters such as PD, LGD and EAD, including the selection and calibration of relevant models. For stage 3 individual provisioning, the determination and probabilities of restructuring and recovery scenarios as well as the amount and timing of expected future cash flows may be particularly subjective. \u2022 Forward-looking macroeconomic scenarios used in impairment assessments are uncertain in nature. The use of alternate forward-looking macroeconomic scenarios can produce significantly different estimates of ECL. This is demonstrated in the sensitivity analysis in the \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. \u2022 When determining whether the credit risk on a financial asset has increased significantly (criteria for identifying a significant increase in credit risk), ING Bank 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. \u2022 Judgement is exercised in management\u2019s evaluation of whether there is objective evidence that exposures are credit-impaired. \u2022 To reflect the risks that are not properly captured by the ECL models (including climate risk), a number of management adjustments to the model-based ECL were necessary as at 31 December 2024, which required significant judgement. Reference is made to the \u2018Management adjustments applied this reporting period\u2019 paragraph in the \u2018Risk management\u2019 section of the Annual Report.Significant judgements and critical accounting estimates and assumptions:Identification of impairment indicators as well as indicators of potential reversal of previous impairments of ING Bank\u2019s investment in TMBThanachart Bank Public Company Limited (hereafter: TTB), an associate, requires significant judgement. When there is objective evidence of impairment or indicators that prior period impairment losses no longer exist or may have decreased, value in use (VIU) needs to be determined. Estimation of VIU involves significant estimates and management assumptions. See Note 8 \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 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 39 '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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-642": { "value": "
1.5.4\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 or so-called economic hedges that are not in a formal hedge accounting relationship where a
component is presented separately in interest result in line with ING 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.
Benchmark rate reform \u2013 specific policies for hedges directly affected by the benchmark rate
reform
As explained in the \u2018Impact of the benchmark rate reform\u2019 paragraph of the \u2018Risk management\u2019 section, a
fundamental review of important interest rate benchmarks has been carried out, and is still ongoing for
some of them (for instance, WIBOR).
Given that the benchmark rate reform may have various accounting implications, the IASB has undertaken a
two-phase project. Phase 1 (issued in 2019) addresses those issues that affect financial reporting before the
replacement of an existing benchmark. Phase 2 (issued in 2020) focuses on issues that may affect financial
reporting when the existing benchmark rate is reformed or replaced.\u00a0
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:
\u2022 Highly 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.
\u2022 Prospective 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.
\u2022 Retrospective 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 benchmark rate
reform.
\u2022 Designation 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 the benchmark
interest rate exposure part of the benchmark rate 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 2024 (mainly for WIBOR hedges).
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 \u2018Risk management/ Impact of the benchmark
rate reform\u2019 for the disclosures relating to the application of the amendments as part of Phase 1.
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 benchmark rate
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. By applying these
mandatory amendments, ING Bank avoids hedge accounting discontinuations when modifying both hedged
items and hedging instruments (and related hedge documentation) as a consequence of the benchmark
rate reform that would otherwise be required in the absence of Phase 2 amendments. During 2024, 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.
More specifically, the following temporary reliefs are part of the Phase 2 amendments:
Relief from discontinuing hedging relationships
\u2022 Amendments in the hedge documentation as a consequence of changes required by the benchmark rate
reform do not result in the discontinuation of the hedge relationship nor the designation of a new hedge
relationship. The changes can be in the 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.
\u2022 When the hedged item is amended as a consequence of the benchmark rate 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.
\u2022 When the items within a designated group of hedged items are amended as a consequence of the
benchmark rate reform, the hedging strategy remains and is not discontinued. As items within the
hedged group transition at different times from the benchmark rates to RFRs, they are transferred to sub-
groups of instruments that reference RFRs as the hedged risk. The existing benchmark rates 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.
\u2022 For 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 decision is
made separately for each hedging relationship (i.e., on a hedge-by-hedge basis).
\u2022 Temporary 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.
As explained above, Phase 1 and Phase 2 benchmark rate amendments to IFRS provide specific hedge
accounting reliefs that allow hedge accounting relationships to continue when the benchmark rate reform is
ongoing. Phase 1 reliefs cease to apply when uncertainty arising from the benchmark rate reform is no
longer present with respect to the timing and amount of the benchmark rate-based cash flows of the
relevant instruments, or when the hedging instrument is discontinued. It is ING Bank\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. Refer to note \u2018Risk management/Impact of the benchmark rate reform\u2019 for
the disclosures relating to the application of the amendments as part of Phase 2.
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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-641": { "value": "
1.5.4\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 or so-called economic hedges that are not in a formal hedge accounting relationship where a
component is presented separately in interest result in line with ING 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.
Benchmark rate reform \u2013 specific policies for hedges directly affected by the benchmark rate
reform
As explained in the \u2018Impact of the benchmark rate reform\u2019 paragraph of the \u2018Risk management\u2019 section, a
fundamental review of important interest rate benchmarks has been carried out, and is still ongoing for
some of them (for instance, WIBOR).
Given that the benchmark rate reform may have various accounting implications, the IASB has undertaken a
two-phase project. Phase 1 (issued in 2019) addresses those issues that affect financial reporting before the
replacement of an existing benchmark. Phase 2 (issued in 2020) focuses on issues that may affect financial
reporting when the existing benchmark rate is reformed or replaced.\u00a0
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:
\u2022 Highly 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.
\u2022 Prospective 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.
\u2022 Retrospective 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 benchmark rate
reform.
\u2022 Designation 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 the benchmark
interest rate exposure part of the benchmark rate 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 2024 (mainly for WIBOR hedges).
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 \u2018Risk management/ Impact of the benchmark
rate reform\u2019 for the disclosures relating to the application of the amendments as part of Phase 1.
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 benchmark rate
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. By applying these
mandatory amendments, ING Bank avoids hedge accounting discontinuations when modifying both hedged
items and hedging instruments (and related hedge documentation) as a consequence of the benchmark
rate reform that would otherwise be required in the absence of Phase 2 amendments. During 2024, 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.
More specifically, the following temporary reliefs are part of the Phase 2 amendments:
Relief from discontinuing hedging relationships
\u2022 Amendments in the hedge documentation as a consequence of changes required by the benchmark rate
reform do not result in the discontinuation of the hedge relationship nor the designation of a new hedge
relationship. The changes can be in the 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.
\u2022 When the hedged item is amended as a consequence of the benchmark rate 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.
\u2022 When the items within a designated group of hedged items are amended as a consequence of the
benchmark rate reform, the hedging strategy remains and is not discontinued. As items within the
hedged group transition at different times from the benchmark rates to RFRs, they are transferred to sub-
groups of instruments that reference RFRs as the hedged risk. The existing benchmark rates 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.
\u2022 For 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 decision is
made separately for each hedging relationship (i.e., on a hedge-by-hedge basis).
\u2022 Temporary 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.
As explained above, Phase 1 and Phase 2 benchmark rate amendments to IFRS provide specific hedge
accounting reliefs that allow hedge accounting relationships to continue when the benchmark rate reform is
ongoing. Phase 1 reliefs cease to apply when uncertainty arising from the benchmark rate reform is no
longer present with respect to the timing and amount of the benchmark rate-based cash flows of the
relevant instruments, or when the hedging instrument is discontinued. It is ING Bank\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. Refer to note \u2018Risk management/Impact of the benchmark rate reform\u2019 for
the disclosures relating to the application of the amendments as part of Phase 2.
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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-643": { "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.
Benchmark rate reform \u2013 specific policies for hedges directly affected by the benchmark rate
reform
As explained in the \u2018Impact of the benchmark rate reform\u2019 paragraph of the \u2018Risk management\u2019 section, a
fundamental review of important interest rate benchmarks has been carried out, and is still ongoing for
some of them (for instance, WIBOR).
Given that the benchmark rate reform may have various accounting implications, the IASB has undertaken a
two-phase project. Phase 1 (issued in 2019) addresses those issues that affect financial reporting before the
replacement of an existing benchmark. Phase 2 (issued in 2020) focuses on issues that may affect financial
reporting when the existing benchmark rate is reformed or replaced.\u00a0
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:
\u2022 Highly 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.
\u2022 Prospective 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.
\u2022 Retrospective 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 benchmark rate
reform.
\u2022 Designation 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 the benchmark
interest rate exposure part of the benchmark rate 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 2024 (mainly for WIBOR hedges).
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 \u2018Risk management/ Impact of the benchmark
rate reform\u2019 for the disclosures relating to the application of the amendments as part of Phase 1.
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 benchmark rate
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. By applying these
mandatory amendments, ING Bank avoids hedge accounting discontinuations when modifying both hedged
items and hedging instruments (and related hedge documentation) as a consequence of the benchmark
rate reform that would otherwise be required in the absence of Phase 2 amendments. During 2024, 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.
More specifically, the following temporary reliefs are part of the Phase 2 amendments:
Relief from discontinuing hedging relationships
\u2022 Amendments in the hedge documentation as a consequence of changes required by the benchmark rate
reform do not result in the discontinuation of the hedge relationship nor the designation of a new hedge
relationship. The changes can be in the 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.
\u2022 When the hedged item is amended as a consequence of the benchmark rate 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.
\u2022 When the items within a designated group of hedged items are amended as a consequence of the
benchmark rate reform, the hedging strategy remains and is not discontinued. As items within the
hedged group transition at different times from the benchmark rates to RFRs, they are transferred to sub-
groups of instruments that reference RFRs as the hedged risk. The existing benchmark rates 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.
\u2022 For 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 decision is
made separately for each hedging relationship (i.e., on a hedge-by-hedge basis).
\u2022 Temporary 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.
As explained above, Phase 1 and Phase 2 benchmark rate amendments to IFRS provide specific hedge
accounting reliefs that allow hedge accounting relationships to continue when the benchmark rate reform is
ongoing. Phase 1 reliefs cease to apply when uncertainty arising from the benchmark rate reform is no
longer present with respect to the timing and amount of the benchmark rate-based cash flows of the
relevant instruments, or when the hedging instrument is discontinued. It is ING Bank\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. Refer to note \u2018Risk management/Impact of the benchmark rate reform\u2019 for
the disclosures relating to the application of the amendments as part of Phase 2.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForHedgingExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-644": { "value": "
1.5.5\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 derivatives, repurchase and reverse repurchase agreements and cash pooling
agreements. A significant portion of offsetting is applied to derivatives and related cash margin balances,
which are either directly cleared through central clearing parties or cleared through clearing members of
central clearing parties. For more information, reference is made to Note 39 \u2018Offsetting financial assets and
liabilities\u2019.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForOffsettingOfFinancialInstrumentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-645": { "value": "
1.5.6Impairment 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 ECL by considering on a discounted basis the cash shortfall it would
incur in case of a default and multiplying the shortfall by the probability of a default occurring. The ECL is the
sum of the probability-weighted outcomes. The ECL estimates are unbiased and include reasonable and
supportable information about past events, current conditions, and forecasts of future economic conditions.
ECL is recognised on the balance sheet as loan loss provisions (LLP).
Three stage approach
Financial assets are classified in one of the below three stages at each reporting date. A financial asset can
move between Stages during its lifetime. The Stages are based on changes in credit quality since initial
recognition and defined as follows:
\u2022 Stage 1
Financial assets that have not had a significant increase in credit risk since initial recognition (i.e. no
Stage 2 or 3 triggers apply). Assets are classified as Stage 1 upon initial recognition (with the exception
of purchased or originated credit impaired (POCI) assets) and ECL is determined by the probability that
a default occurs in the next 12 months (12 months ECL);
\u2022 Stage 2
Financial assets showing a significant increase in credit risk since initial recognition. For assets in Stage
2 ECL reflects an estimate on the credit losses over the remaining maturity of the asset (lifetime ECL);
or
\u2022 Stage 3
Financial assets that are credit-impaired. Also for these assets ECL is determined over the remaining
maturity of the asset.
Significant increase in credit risk
ING 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. Reference is made to the \u2018Criteria for identifying a significant increase in credit risk (SICR)\u2019 in
the \u2018Risk management\u2019 section of the Annual Report.
An asset that is in Stage 2 will move back to Stage 1 when none of the above criteria are in place anymore.
However, if the asset was moved to Stage 2 based on the forbearance status, then the asset stays in Stage 2
for at least 24 months. If the asset was classified as Stage 2 due to the '30 days past due' trigger, then the
asset is moved back to Stage 1 only after three months from when the trigger no longer applies.
Credit-impaired financial assets (Stage 3)
Financial assets are assessed for credit-impairment at each reporting date and more frequently when
circumstances warrant further assessment. Evidence of credit-impairment includes arrears of over 90 days
on any material credit obligation, indications that the borrower is experiencing significant financial difficulty,
a breach of contract, bankruptcy or distressed restructuring. The definition of 'credit-impaired' under IFRS 9
(Stage 3) is aligned with the definition of 'default' used by ING 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 enriched with the internal ING Bank view. A baseline, up-scenario and\u00a0 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.
The probability weights applied to each of the three scenarios
ING Bank uses three macroeconomic scenarios when determining IFRS 9 ECL (baseline, upside and
downside). The management approach used to determine the weights of each scenario and in selecting the
parts of the distribution of forecast errors from which the weights are derived is disclosed in the 'Alternative
Scenarios and Probability Weights' section. Additionally, this approach is detailed in the sensitivity analysis
within the 'Risk Management' section of the Annual Report.
Measurement of ECL
ING 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 the loan type, industry, geographic location,
collateral type, past due status and other relevant factors. These characteristics are relevant to the
estimation of future cash flows for groups of such assets by being indicative of the debtors\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 measurement 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 other things, repayment of the loan, collateral
recovery and the sale of the asset. Cash flows from collateral and other credit enhancements are included in
the measurement of ECL of the related financial asset when it is part of or integral to the contractual terms
of the financial asset and the credit enhancement is not recognised separately. For the individual
assessment, with granular (company or asset-specific) scenarios, specific factors can have a larger impact
on the future cash flows than macroeconomic factors.
When a financial asset is credit-impaired, interest income is no longer recognised based on the gross
carrying amount of the asset. Instead, interest income is calculated by applying the original effective
interest rate to the amortised cost of the asset, which is the gross carrying amount less the related loan loss
provision.
Purchased or Originated Credit Impaired (POCI) assets
POCI assets are financial assets that are credit-impaired on initial recognition. Impairment on a POCI asset is
determined based on lifetime ECL from initial recognition. POCI assets are recognised initially at an amount
net of ECL and are measured at AC using a credit-adjusted effective interest rate. In subsequent periods any
changes to the estimated lifetime ECL are recognised in profit or loss. Favourable changes are recognised as
an impairment gain if the lifetime ECL at the reporting date is lower than the estimated lifetime ECL at
origination.
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:
\u2022 After a restructuring has been completed and there is a high improbability of recovery of part of the
remaining loan exposure (including partial debt forgiveness);
\u2022 In a bankruptcy liquidation scenario;
\u2022 After divestment or sale of a credit facility at a discount;
\u2022 Specific fraud cases with no recourse options.
When a loan is uncollectable, it is written off against the related loan loss provision. Subsequent recoveries of
amounts previously written off are recognised in \u2018Addition to loan loss provisions\u2019 in the Consolidated
statement of profit or loss.
Debt forgiveness (or debt settlement) involves write-off, but also involves the forgiveness of a legal
obligation, in whole or in part. This means that ING Bank forfeits the legal right to recover the debt. As a
result, the financial asset needs to be derecognised.
Presentation of ECL
ECL for financial assets measured at AC is deducted from the gross carrying amount of the assets. For debt
instruments at FVOCI, the ECL is recognised in OCI, instead of deducting it from the carrying amount of the
asset. ECL also reflects any credit losses related to the portion of the loan commitment that is expected to
be drawn down over the remaining life of the instrument. The ECL on issued financial guarantee contracts, in
scope of IFRS 9 and not measured at FVPL, is recognised as liabilities and presented in Other provisions. ECL
are presented in profit or loss in Addition to loan loss provision.
Significant judgements and critical accounting estimates and assumptions:
The calculation of ECL requires a number of judgements and estimates. In particular:
\u2022 ING Bank makes various assumptions about the risk of default, the credit loss rates in case of a
default and expected future cash flows. For collective provisions, ING Bank applies significant
judgement when estimating modelled parameters such as PD, LGD and EAD, including the selection
and calibration of relevant models. For stage 3 individual provisioning, the determination and
probabilities of restructuring and recovery scenarios as well as the amount and timing of expected
future cash flows may be particularly subjective.
\u2022 Forward-looking macroeconomic scenarios used in impairment assessments are uncertain in nature.
The use of alternate forward-looking macroeconomic scenarios can produce significantly different
estimates of ECL. This is demonstrated in the sensitivity analysis in the \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.
\u2022 When determining whether the credit risk on a financial asset has increased significantly (criteria for
identifying a significant increase in credit risk), ING Bank 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.
\u2022 Judgement is exercised in management\u2019s evaluation of whether there is objective evidence that
exposures are credit-impaired.
\u2022 To reflect the risks that are not properly captured by the ECL models (including climate risk), a number
of management adjustments to the model-based ECL were necessary as at 31 December 2024, which
required significant judgement. Reference is made to the \u2018Management adjustments applied this
reporting period\u2019 paragraph in the \u2018Risk management\u2019 section of the Annual Report.
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.
Significant judgements and critical accounting estimates and assumptions:
Identification of impairment indicators as well as indicators of potential reversal of previous impairments
of ING Bank\u2019s investment in TMBThanachart Bank Public Company Limited (hereafter: TTB), an associate,
requires significant judgement. When there is objective evidence of impairment or indicators that prior
period impairment losses no longer exist or may have decreased, value in use (VIU) needs to be
determined. Estimation of VIU involves significant estimates and management assumptions. See Note 8
\u2018Investments in associates and joint ventures\u2019.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForImpairmentOfFinancialAssetsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-646": { "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 the loan type, industry, geographic location,
collateral type, past due status and other relevant factors. These characteristics are relevant to the
estimation of future cash flows for groups of such assets by being indicative of the debtors\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 measurement 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 other things, repayment of the loan, collateral
recovery and the sale of the asset. Cash flows from collateral and other credit enhancements are included in
the measurement of ECL of the related financial asset when it is part of or integral to the contractual terms
of the financial asset and the credit enhancement is not recognised separately. For the individual
assessment, with granular (company or asset-specific) scenarios, specific factors can have a larger impact
on the future cash flows than macroeconomic factors.
When a financial asset is credit-impaired, interest income is no longer recognised based on the gross
carrying amount of the asset. Instead, interest income is calculated by applying the original effective
interest rate to the amortised cost of the asset, which is the gross carrying amount less the related loan loss
provision.
1.16\u00a0 Irrevocable Payment Commitments on contributions to SRF and DGS
ING makes contributions to the Single Resolution Fund (SRF) and Deposit Guarantee Schemes (DGS). The
annual contributions are paid in cash or, in some cases, partly using Irrevocable Payment Commitments
(IPCs) that become payable if and when called. Cash contributions are accounted for as levies as described in
section 1.15 above while IPCs are disclosed as contingent liabilities in Note 38 Contingent liabilities and
commitments. Cash collateral posted on IPCs to the SRF is accounted for as an interest bearing financial
asset at amortised cost. Government bonds posted as collateral on IPCs to DGS continue to be recognised as
assets of ING as securities at amortised cost.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForCollateralExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-648": { "value": "
1.6\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.
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 41 \u2018Principal subsidiaries\u2019 and a description of ING's activities
involving structured entities is included in Note 42 '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.
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 regarding the minimum capital requirements that are imposed
by industry regulators in the countries in which the subsidiaries operate, other limitations exist in certain
countries.
", "dimensions": { "concept": "ifrs-full:DisclosureOfBasisOfConsolidationExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-647": { "value": "
1.6\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.
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 41 \u2018Principal subsidiaries\u2019 and a description of ING's activities
involving structured entities is included in Note 42 '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.
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 regarding the minimum capital requirements that are imposed
by industry regulators in the countries in which the subsidiaries operate, other limitations exist in certain
countries.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForSubsidiariesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-649": { "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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-650": { "value": "
1.7\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)) who decide which resources to allocate 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 reviews and assesses ING Bank's performance primarily by line of business. As a result, ING
identified five operating segments which are are also disclosed as reportable segments. Additionally, the
CODM receives information by geographical area based on the location of the office where trasnsactions
originate.
Recognition and measurement of segment results are in line with the accounting policies as described in
Note 1 'Basis of preparation and material accounting policy information'. The results for the period for each
reportable segment are after intercompany and intersegment eliminations and are those reviewed by the
CODM to assess performance of the segments. Corporate expenses are allocated to business lines based on
time spent by head office personnel, the relative number of staff, or on the basis of income, expenses and/or
assets of the segment. Interest income per segment is reported as net interest income because
management relies primarily on net (rather than gross) interest revenue to assess the performance of the
segments.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForSegmentReportingExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-651": { "value": "
1.8\u00a0 Hyperinflation accounting
Since the second quarter of 2022, T\u00fcrkiye has been considered a hyperinflationary economy for accounting
purposes. As ING Bank has a subsidiary in T\u00fcrkiye, ING Bank has applied IAS 29 \u2018Financial Reporting in
Hyperinflationary Economies\u2019 to its operations since 2022 as if the economy in T\u00fcrkiye had always been
hyperinflationary. Given that ING Bank presents its results in EUR, comparatives do not get restated. As a
result, the impact of the first-time application of IAS 29, as well as the effect for that year were both
recognised in 2022. IAS 29 continued to be relevant for ING\u2019s operations in T\u00fcrkiye in 2023 and 2024. Under
IAS 29, the results of the operations in T\u00fcrkiye should be stated in terms of the current purchasing power at
the reporting date. For that, the consumer price index (CPI) as determined by the Turkish Statistical Institute
was used. The CPI for T\u00fcrkiye (2003=100) at 31 December 2024 was 2,684.55, at 31 December 2023 was
1,859.38 and for 2022 was 1,128.45 (movement 2024: 44.38%; movement 2023: 64.77%, movement 2022:
64.27%). The effect of such restatement for inflation in the current period of the statement of
comprehensive income and the balance sheet has been recognised in the statement of profit or loss within
\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
T\u00fcrkiye.
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 T\u00fcrkiye were translated and presented in EUR at the exchange rate on
31 December 2024. 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 chose to present both the restatement effect resulting from restating
ING Bank\u2019s interest in the equity of ING T\u00fcrkiye 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.", "dimensions": { "concept": "ifrs-full:DisclosureOfHyperinflationaryReportingExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-652": { "value": "
1.9\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 23 \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 20 'Equity', which discloses
the amounts included in the statement of profit or loss.
Group companies
The results and financial positions of all group companies that have a functional currency different from the
presentation currency are translated into the presentation currency as follows:
\u2022 Assets and liabilities are translated at the closing rate at the date of the statement of financial position;\u00a0
\u2022 Income and expenses are translated at average exchange rates (unless this average is not a reasonable
approximation of the cumulative effect of the rates prevailing on the transaction dates, in which case
income and expenses are translated at the dates of the transactions). However, under hyperinflation
accounting, income and expenses of ING T\u00fcrkiye are translated at the closing rate; and\u00a0
\u2022 All 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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-653": { "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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-656": { "value": "
1.10\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:
\u2022 Representation on the board of directors;\u00a0
\u2022 Participation in the policymaking process; and\u00a0
\u2022 Interchange of managerial personnel.\u00a0
Joint ventures are entities over which ING Bank has joint control.
Investments in associates and joint ventures are initially recognised at cost and subsequently accounted for
using the equity method of accounting.
ING 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:
Identification of impairment indicators as well as indicators of potential reversal of previous impairments
of ING Bank\u2019s investment in TMBThanachart Bank Public Company Limited (hereafter: TTB), an associate,
requires significant judgement. When there is objective evidence of impairment or indicators that prior
period impairment losses no longer exist or may have decreased, value in use (VIU) needs to be
determined. Estimation of VIU involves significant estimates and management assumptions. See Note 8
\u2018Investments in associates and joint ventures\u2019.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForInvestmentInAssociates", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-655": { "value": "
1.10\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:
\u2022 Representation on the board of directors;\u00a0
\u2022 Participation in the policymaking process; and\u00a0
\u2022 Interchange of managerial personnel.\u00a0
Joint ventures are entities over which ING Bank has joint control.
Investments in associates and joint ventures are initially recognised at cost and subsequently accounted for
using the equity method of accounting.
ING 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.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForInvestmentsInJointVentures", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-654": { "value": "
1.10\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:
\u2022 Representation on the board of directors;\u00a0
\u2022 Participation in the policymaking process; and\u00a0
\u2022 Interchange of managerial personnel.\u00a0
Joint ventures are entities over which ING Bank has joint control.
Investments in associates and joint ventures are initially recognised at cost and subsequently accounted for
using the equity method of accounting.
ING 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:
Identification of impairment indicators as well as indicators of potential reversal of previous impairments
of ING Bank\u2019s investment in TMBThanachart Bank Public Company Limited (hereafter: TTB), an associate,
requires significant judgement. When there is objective evidence of impairment or indicators that prior
period impairment losses no longer exist or may have decreased, value in use (VIU) needs to be
determined. Estimation of VIU involves significant estimates and management assumptions. See Note 8
\u2018Investments in associates and joint ventures\u2019.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForInvestmentInAssociatesAndJointVenturesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-657": { "value": "
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.
Significant judgements and critical accounting estimates and assumptions:
Identification of impairment indicators as well as indicators of potential reversal of previous impairments
of ING Bank\u2019s investment in TMBThanachart Bank Public Company Limited (hereafter: TTB), an associate,
requires significant judgement. When there is objective evidence of impairment or indicators that prior
period impairment losses no longer exist or may have decreased, value in use (VIU) needs to be
determined. Estimation of VIU involves significant estimates and management assumptions. See Note 8
\u2018Investments in associates and joint ventures\u2019.
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. 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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-659": { "value": "
1.11\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. Depreciation is
recognised on a straight-line basis over the estimated useful life (in general 20\u201350 years). On disposal, the
related revaluation reserve is transferred to retained earnings.
Equipment
Equipment is stated at cost less accumulated depreciation and any impairment losses. The cost of the assets
is depreciated on a straight line basis over their estimated useful lives, which are generally as follows: two to
five years for data processing equipment, and four to ten years for fixtures and fittings.\u00a0
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:
\u2022 Fixed payments (including in-substance fixed payments), less any lease incentives receivable;
\u2022 Variable lease payments that are based on an index or a rate;
\u2022 Amounts expected to be payable by the lessee under residual value guarantees;
\u2022 The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and
\u2022 Payments of penalties for terminating the lease, if the lease term reflects the lessee exercising that
option.
The lease payments are discounted using the interest rate implicit in the lease. If that rate cannot be readily
determined, the lessee\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.
Right-of-use assets are measured at cost comprising the amount of the initial measurement of the lease
liability, any lease payments made at or before the commencement date less any lease incentives received
and any initial direct costs and restoration costs.
The right-of-use asset is included in the statement of financial position line-item \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
decreases when payments are made. Any remeasurement of the lease liability due to a lease modification
or other reassessment results in a corresponding adjustment to the carrying amount of the right-of-use
asset.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForPropertyPlantAndEquipmentExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-658": { "value": "
1.11\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. Depreciation is
recognised on a straight-line basis over the estimated useful life (in general 20\u201350 years). On disposal, the
related revaluation reserve is transferred to retained earnings.
Equipment
Equipment is stated at cost less accumulated depreciation and any impairment losses. The cost of the assets
is depreciated on a straight line basis over their estimated useful lives, which are generally as follows: two to
five years for data processing equipment, and four to ten years for fixtures and fittings.\u00a0
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:
\u2022 Fixed payments (including in-substance fixed payments), less any lease incentives receivable;
\u2022 Variable lease payments that are based on an index or a rate;
\u2022 Amounts expected to be payable by the lessee under residual value guarantees;
\u2022 The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and
\u2022 Payments of penalties for terminating the lease, if the lease term reflects the lessee exercising that
option.
The lease payments are discounted using the interest rate implicit in the lease. If that rate cannot be readily
determined, the lessee\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.
Right-of-use assets are measured at cost comprising the amount of the initial measurement of the lease
liability, any lease payments made at or before the commencement date less any lease incentives received
and any initial direct costs and restoration costs.
The right-of-use asset is included in the statement of financial position line-item \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
decreases when payments are made. Any remeasurement of the lease liability due to a lease modification
or other reassessment results in a corresponding adjustment to the carrying amount of the right-of-use
asset.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForDepreciationExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-660": { "value": "
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:
\u2022 Fixed payments (including in-substance fixed payments), less any lease incentives receivable;
\u2022 Variable lease payments that are based on an index or a rate;
\u2022 Amounts expected to be payable by the lessee under residual value guarantees;
\u2022 The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and
\u2022 Payments of penalties for terminating the lease, if the lease term reflects the lessee exercising that
option.
The lease payments are discounted using the interest rate implicit in the lease. If that rate cannot be readily
determined, the lessee\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.
Right-of-use assets are measured at cost comprising the amount of the initial measurement of the lease
liability, any lease payments made at or before the commencement date less any lease incentives received
and any initial direct costs and restoration costs.
The right-of-use asset is included in the statement of financial position line-item \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
decreases when payments are made. Any remeasurement of the lease liability due to a lease modification
or other reassessment results in a corresponding adjustment to the carrying amount of the right-of-use
asset.
1.12\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.
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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-661": { "value": "
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:
\u2022 Fixed payments (including in-substance fixed payments), less any lease incentives receivable;
\u2022 Variable lease payments that are based on an index or a rate;
\u2022 Amounts expected to be payable by the lessee under residual value guarantees;
\u2022 The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and
\u2022 Payments of penalties for terminating the lease, if the lease term reflects the lessee exercising that
option.
The lease payments are discounted using the interest rate implicit in the lease. If that rate cannot be readily
determined, the lessee\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.
Right-of-use assets are measured at cost comprising the amount of the initial measurement of the lease
liability, any lease payments made at or before the commencement date less any lease incentives received
and any initial direct costs and restoration costs.
The right-of-use asset is included in the statement of financial position line-item \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
decreases when payments are made. Any remeasurement of the lease liability due to a lease modification
or other reassessment results in a corresponding adjustment to the carrying amount of the right-of-use
asset.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForBorrowingsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-662": { "value": "
1.13\u00a0 Goodwill and other intangible assets
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. Impairment of goodwill, if
applicable, is included in the statement of profit or loss in Other operating expenses and is not subsequently
reversed.
Computer software
Computer software that has been purchased or generated internally for own use is stated at cost less
amortisation and any impairment losses. Amortisation is calculated on a straight-line basis over its useful
life, which generally does not exceed five years. Amortisation is included in Other operating expenses.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForIntangibleAssetsAndGoodwillExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-664": { "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. 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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-663": { "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. 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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-665": { "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, which generally does not exceed five years. Amortisation is included in Other operating expenses.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForIntangibleAssetsOtherThanGoodwillExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-667": { "value": "
1.14\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.
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.
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.
ING Bank \u2019s business lines operate in different geographical areas: the Netherlands, Belgium, Germany, Rest
of Europe and Rest of the World. 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,\u00a0 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 do not include intercompany balances and reconcile to the total assets in the
consolidated statement of financial position of ING Bank.
ING Bank is subject to top-up tax (Global Anti-Base Erosion Model Rules (Pillar Two)) in relation to its
operations in countries where the effective tax rate falls below 15%. This includes Switzerland, Ireland and
Bulgaria as a result of their lower nominal tax rates, as well as Singapore, where special local tax rates for
certain types of income reduce the effective tax rate.
ING Bank has applied a temporary mandatory relief from deferred tax accounting for the impacts of the top-
up tax and accounts for it as a current tax when it is incurred. The total top-up tax that is expected to be paid
by ING Bank per jurisdiction over 2024 amounts to EUR 9.5 million.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForIncomeTaxExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-666": { "value": "
1.14\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.
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.
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.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForDeferredIncomeTaxExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-669": { "value": "
1.15\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.
1.16\u00a0 Irrevocable Payment Commitments on contributions to SRF and DGS
ING makes contributions to the Single Resolution Fund (SRF) and Deposit Guarantee Schemes (DGS). The
annual contributions are paid in cash or, in some cases, partly using Irrevocable Payment Commitments
(IPCs) that become payable if and when called. Cash contributions are accounted for as levies as described in
section 1.15 above while IPCs are disclosed as contingent liabilities in Note 38 Contingent liabilities and
commitments. Cash collateral posted on IPCs to the SRF is accounted for as an interest bearing financial
asset at amortised cost. Government bonds posted as collateral on IPCs to DGS continue to be recognised as
assets of ING as securities at amortised cost.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForContingentLiabilitiesAndContingentAssetsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-668": { "value": "
1.15\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 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 39
'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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-670": { "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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-671": { "value": "
1.17\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.
Changes in plan assets include mainly:
\u2022 Return on plan assets are recognised as staff costs in the statement of profit or loss. It is determined
using a high quality corporate bond rate (identical to the discount rate used in determining the defined
benefit obligation) at the start of the reporting period; and\u00a0
\u2022 Remeasurements 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.\u00a0
Changes in the defined benefit obligation include mainly:
\u2022 Service cost which is recognised as staff costs in the statement of profit or loss;\u00a0
\u2022 Interest expenses are recognised as staff costs in the Statement of profit or loss. It is determined using a
high quality corporate bond rate at the start of the period;
\u2022 Remeasurements which are recognised in Other comprehensive income (equity) and not recycled to the
Statement of profit or loss;
\u2022 Any past service cost relating to a plan amendment is recognised in profit or loss in the period of the plan
amendment; and
\u2022 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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-672": { "value": "
1.18\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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-673": { "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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-674": { "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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-675": { "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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-676": { "value": "
1.19\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 generally result from contracts with ING service providers, who
perform their 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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-677": { "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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-678": { "value": "
1.20\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 include deposits from banks and
loans and advances to banks that are on demand. Furthermore, it includes treasury bills and other eligible
bills shorter than three months. Investments qualify as a cash equivalent if they are readily convertible to a
known amount of cash and are subject to an insignificant risk of changes in value.
Cash flows arising from foreign currency transactions are translated into the functional currency using the
exchange rates at the date of the cash flows.
The net cash flow shown in respect of Loans and advances to customers relates only to transactions
involving actual payments or receipts. The Addition to loan loss provision, which is deducted from the item
Loans and advances to customers in the statement of financial position, has been adjusted accordingly from
the result before tax and is shown separately in the statement of cash flows.
The difference between the Net cash flow in accordance with the statement of cash flows and the change
between the opening and closing balance of Cash and cash equivalents in the statement of financial position
is due to exchange rate differences and is presented separately in the cash flow statement.
Liabilities arising from financing activities are debt securities, lease liabilities and subordinated loans.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForCashFlowsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-680": { "value": "
2\u00a0 Cash and balances with central banks
Cash and balances with central banks
in EUR million
2024
2023
Amounts held at central banks 1
68,708\u00a0
88,627\u00a0
Cash and bank balances
1,645\u00a0
1,587\u00a0
70,353
90,214
1 Amounts held at central banks include an amount of EUR -14 million (2023 : EUR -5 million) of Loan loss provisions.
Amounts held at central banks reflect on-demand balances. The movement reflects ING\u2019s active liquidity
management.
Reference is made to Note 36 '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
2024
2023
2024
2023
2024
2023
Loans and advances to banks
14,352
9,451
7,439
7,287
21,791
16,738
Loan loss provisions
-8
-11
-13
-18
-22
-30
14,343
9,440
7,426
7,268
21,769
16,708
Loans and advances include balances of reverse repurchase transactions. For more information, refer to
Note 4 'Financial assets at fair value through profit or loss'. Furthermore, it includes on-demand and term
loans, and cash collateral transactions. Reference is made to Note 7 'Loans and advances to customers' for
information on finance lease receivables included in Loans and advances to banks.
As at 31\u00a0December 2024 and at 31 December 2023, 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
2024
2023
Trading assets
72,906
60,240
Non-trading derivatives
2,463
2,028
Designated at fair value through profit or loss
5,740
5,775
Mandatorily measured at fair value through profit or loss
56,481
54,983
137,590
123,026
(Reverse) repurchase transactions
Financial assets at fair value through profit or loss include securities lending and sales and repurchase
transactions with securities. At ING, these types of transactions are recognised in several lines in the
statement of financial position depending on business model assessment and counterparty. Furthermore,
for repurchase agreements the gross amount of assets must be considered together with the gross amount
of related liabilities, which are presented separately on the statement of financial position since IFRS does
not always allow the netting of these positions in the statement of financial position. Netting is applicable to
repurchase agreements that are governed by an established Global Master Repurchase Agreement (GMRA).
This netting is restricted to transactions involving the same currency and maturity date, and must occur
within the same legal entity. Reference is made to Note 37 'Offsetting financial assets and liabilities'.
Securities purchased under agreements to resell (reverse repos), securities borrowings and similar
agreements are not recognised in the consolidated statement of financial position as the counterparty
continues to be exposed to substantially all risks and rewards of the transferred security. Based on the
business model assessment and counterparty, the consideration paid to purchase securities is recognised as
Loans and advances to customers, Loans and advances to banks, financial assets mandatorily at FVPL or
Trading assets.
Securities sold subject to repurchase agreements (repos), securities lending and similar agreements continue
to be recognised in the consolidated statement of financial position as ING Bank continues to be exposed to
substantially all risks and rewards of the transferred financial asset. The counterparty liability is designated
and measured at FVPL if the asset is measured mandatorily at FVPL. Otherwise, the counterparty liability is
included in Deposits from banks, Customer deposits or Trading.
Reference is made to Note 36 'Transfer of financial assets, assets pledged and received as collateral' for
information on transferred assets which were not derecognised.
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
2024
2023
Reverse repurchase transactions
Loans and advances to banks
10,777
5,251
Loans and advances to customers
3,471
499
Trading assets, loans and receivables
12,033
12,121
Loans and receivables mandatorily measured at fair value through profit or loss
53,393
51,536
79,675
69,407
Repurchase transactions
Deposits from banks
33
2,064
Customer deposits
1
97
Trading liabilities, funds on deposit
5,269
10,337
Funds entrusted designated and measured at fair value through profit or loss
38,420
45,729
43,723
58,227
Trading assets
Trading assets by type
in EUR million
2024
2023
Equity securities
20,726
15,423
Debt securities
10,080
6,907
Derivatives
29,805
25,680
Loans and receivables
12,295
12,231
72,906
60,240
Trading assets include assets that are closely related to servicing the needs of the clients of ING Bank. ING
offers institutional clients, corporate clients, and governments products that are traded on the financial
markets. A significant part of the derivatives in the trading portfolio is related to servicing corporate clients in
their risk management to hedge, for example, currency or interest rate exposures. In addition, ING provides
its customers access to equity and debt markets for issuing their own equity or debt securities (securities
underwriting).
Reference is made to Note 14 'Financial liabilities at fair value through profit or loss' for information on
trading liabilities.
Non-trading derivatives
Non-trading derivatives by type
in EUR million
2024
2023
Derivatives used in
-\u00a0 fair value hedges
617
716
-\u00a0 cash flow hedges
158
440
-\u00a0 hedges of net investments in foreign operations
82
100
Other non-trading derivatives
1,606
771
2,463
2,028
Reference is made to Note 33 'Derivatives and hedge accounting' for information on derivatives designated
in hedge accounting.
Other non-trading derivatives mainly includes interest rate swaps, foreign exchange swaps, and cross
currency swaps for which no hedge accounting is applied.
Designated at fair value through profit or loss
Designated at fair value through profit or loss by type
in EUR million
2024
2023
Debt securities
4,718
4,470
Loans and receivables
1,022
1,306
5,740
5,775
\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 5,740 million (2023: EUR 5,775 million). In 2024, the
change in fair value of these loans and debt securities amounts EUR 5 million (2023: EUR -48\u00a0million).\u00a0 \u00a0
ING has mitigated the credit risk exposure on part of the portfolio. The cost at initial recognition of the
financial assets designated at fair value through profit or loss that are economically hedged by credit
derivatives is EUR 3,797 million (31 December 2023: EUR 3,181 million) and the cumulative change in fair
value attributable to changes in credit risk is EUR 173 million (31 December 2023: EUR 150 million).
The notional value of the related credit derivatives is EUR 3,807 million (2023: EUR 3,679 million). The
cumulative change in fair value of the credit derivatives since the financial assets were first designated,
amounts to EUR -214\u00a0million (2023: EUR -119\u00a0million) and the change for the current year is EUR -95\u00a0million
( 2023: EUR -122\u00a0million).
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
2024
2023
Equity securities
228
179
Debt securities
789
894
Loans and receivables
55,464
53,911
56,481
54,983
Equity securities are individually insignificant for ING Bank . For total exposure to debt securities, reference is
made to Note 6 'Debt securities' . 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
2024
2023
Equity securities
2,562
1,885
Debt securities 1
42,219
38,281
Loans and advances 1
1,608
951
46,389
41,116
1 Debt securities include an amount of EUR -12 million (2023: EUR -13 million) and the Loans and advances includes EUR -7 million
(2023: EUR -8 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
2024
2023
2024
2023
Investment in Bank of Beijing
2,241
1,590
101
98
Other Investments
321
295
16
8
2,562
1,885
117
105
As at 31\u00a0December 2024 ING holds approximately 13% (2023: 13% ) of the shares of Bank of Beijing, a bank
listed on the stock exchange of Shanghai. The stake in Bank of Beijing is part of the Corporate Line segment.
As per regulatory requirements set by the China Banking and Insurance Regulatory Commission, ING, as a
shareholder holding more than 5% of the shares, is required to supply additional capital when necessary. No
request for additional capital was received in 2024 ( 2023: nil ).
Changes in fair value through other comprehensive income
The following table presents changes in financial assets at fair value through other comprehensive income.
Changes in fair value through other comprehensive income financial assets
FVOCI equity
securities
FVOCI debt
instruments 1
Total
in EUR million
2024
2023
2024
2023
2024
2023
Opening balance as at 1 January
1,885
1,887
39,231
29,739
41,116
31,625
Additions
11
28
21,080
19,967
21,091
19,995
Amortisation
77
31
77
31
Transfers and reclassifications\u00a0
5
1
1
5
Changes in unrealised revaluations 2
605
68
-96
657
509
725
Impairments
2
-1
2
-1
Reversals of impairments
-7
6
-7
6
Disposals and redemptions
-1
-2
-16,906
-11,912
-16,907
-11,913
Exchange rate differences
62
-100
443
751
506
651
Other changes
-6
-6
Closing balance
2,562
1,885
43,827
39,231
46,389
41,116
1 Fair value through other comprehensive income debt instruments includes both debt securities and loans and advances.
2 Changes in unrealised revaluations of FVOCI debt instruments include changes on hedged items which are recognised in the
statement of profit or loss. Reference is made to Note 20 'Equity' for details on the changes in revaluation reserve.
FVOCI equity securities
Exchange rate differences of EUR 62\u00a0million (31 December 2023: EUR -100\u00a0million) are mainly related to the
stake in Bank of Beijing following the appreciation of CNY versus EUR. In 2024, changes in unrealised
revaluations of equity securities are mainly related to a revaluation of the stake in Bank of Beijing of EUR
590\u00a0million (31 December 2023: EUR 77\u00a0million) following a change in the share price.
FVOCI debt instruments
In 2024, ING sold the remaining NNHB mortgages, amounting to EUR 263 million to Nationale Nederlanden.
ING agreed in 2012 to transfer a portfolio of NNHB mortgages to NN as part of the required restructuring of
ING Group by the European Commission after having received state support during the global financial crisis
(2008). The majority of these mortgages were not sold immediately but only at the interest reset date of
these mortgages.\u00a0
In 2024, interest rates in the shorter and longer tenors decreased which resulted in changes in unrealised
revaluations of debt securities of EUR -96\u00a0million. During 2023 interest rates in the longer tenors decreased
significantly resulting in unrealised revaluations of EUR 657\u00a0million.
Reference is made to Note 6 'Debt securities' for details on ING Bank\u2019s total exposure to debt securities.
6\u00a0 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
2024
2023
Debt securities at fair value through other comprehensive income
42,219
38,281
Debt securities at amortised cost
50,273
48,313
Debt securities at fair value through other comprehensive income and amortised cost
92,493
86,594
Trading assets
10,080
6,907
Debt securities designated and measured at fair value through profit or loss
4,718
4,470
Debt securities mandatorily measured at fair value through profit or loss
789
894
Total debt securities at fair value through profit or loss
15,586
12,270
108,078
98,864
ING Bank\u2019s total exposure to debt securities (excluding debt securities held in the trading portfolio) of EUR
97,999 million (31\u00a0December 2023: EUR 91,957 million) is specified as follows:
Debt securities by type of exposure
Debt Securities at
FVPL 1
Debt Securities at
FVOCI
Debt Securities at
AC
Total
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
Government bonds
289
362
24,757
20,988
22,734
24,050
47,780
45,400
Central bank bonds
444
446
2,900
2,043
3,344
2,489
Sub-sovereign, Supranationals
and Agencies
1,027
1,354
11,513
11,587
15,445
14,639
27,985
27,580
Covered bonds
4,108
4,084
5,683
5,231
9,791
9,315
Corporate bonds
848
799
79
127
106
109
1,033
1,035
Financial institutions' bonds
2,141
1,645
980
483
139
186
3,261
2,314
ABS portfolio
757
758
794
1,025
3,281
2,077
4,832
3,860
5,506
5,363
42,231
38,293
50,288
48,335
98,026
91,991
Loan loss provisions
-12
-13
-15
-22
-27
-34
Debt securities portfolio
5,506
5,363
42,219
38,281
50,273
48,313
97,999
91,957
1 Debt securities at FVPL includes both debt securities designated - and mandatorily measured at fair value through profit or loss.
7\u00a0 Loans and advances to customers
Loans and advances to customers by type
Netherlands
Rest of the world
Total
in EUR million
2024
2023
2024
2023
2024
2023
Loans and advances to public authorities
1,888
1,070
16,773
13,314
18,661
14,384
Residential mortgages
117,223
110,475
227,992
214,120
345,216
324,596
Other personal lending
5,007
5,036
31,789
31,535
36,797
36,571
Corporate Lending
66,987
62,728
218,473
209,795
285,459
272,523
191,105
179,309
495,027
468,764
686,132
648,074
Loan loss provisions
-811
-830
-5,023
-4,791
-5,833
-5,621
190,295
178,480
490,004
463,973
680,299
642,453
For details on credit quality and loan loss provisioning, refer to \u2018Risk management \u2013 Credit risk\u2019 \u2013 paragraphs
\u2018Credit quality\u2019 and 'Loan loss provisioning'.
As at 31\u00a0December 2024 EUR 680,085 million ( 2023: EUR 642,260 million) of loans and advances to
customers are non-subordinated.
Loans and advances to customers and, to a lesser extent, to banks include finance lease receivables which
are detailed as follows:
Finance lease receivables 1
in EUR million
2024
2023
Maturities of gross investment in finance lease receivables
-\u00a0 within 1 year
3,962
3,827
-\u00a0 between 1-2 years
2,961
2,742
-\u00a0 between 2-3 years
2,283
2,133
-\u00a0 between 3-4 years
1,577
1,475
-\u00a0 between 4-5 years
902
875
-\u00a0 more than 5 years
1,555
1,451
13,240
12,503
Unearned future finance income on finance leases
-1,145
-1,040
Net investment in finance leases
12,095
11,463
Included in Loans and advances to banks
5
5
Included in Loans and advances to customers
12,091
11,459
12,095
11,463
1 The total loan loss provision for finance lease receivables is EUR 193 million (2023: EUR\u00a0160 million).
The finance lease receivables mainly relate to the financing of equipment and real estate for third parties
where ING is the lessor and are mainly part of corporate lending. Interest income in 2024 on finance lease
receivables amounts to EUR 522 million (2023: EUR 429 million).
12\u00a0 Deposits from banks
Deposits from banks by type
Netherlands
Rest of the world
Total
in EUR million
2024
2023
2024
2023
2024
2023
Non-interest bearing
4
3
166
174
170
177
Interest bearing
5,845
7,803
10,707
15,277
16,553
23,080
5,849
7,806
10,873
15,451
16,722
23,257
Deposits from banks include non-subordinated deposits and repurchase transactions. For more information on
reverse repurchase transaction, refer to Note 4 'Financial assets at fair value through profit or loss'.
In 2023, deposits from banks included ING\u2019s participation in the Targeted Longer-Term Refinancing
Operations (TLTRO) of EUR 6.0 billion which was fully repaid in March 2024.
13\u00a0 Customer deposits
Customer deposits
in EUR million
2024
2023
Current accounts / Overnight deposits
227,951
222,478
Savings accounts
354,560
334,287
Time deposits
115,636
103,186
Other 1
1,579
2,053
699,725
662,004
1 ING changed the presentation for the senior non-preferred debt and the comparative figure for 2023 has been adjusted.
Current accounts / Overnight deposits, Saving accounts and Time deposits include balances with individuals,
respectively EUR 107,068\u00a0million (2023: EUR 107,711\u00a0million), EUR 324,134\u00a0million (2023: EUR
305,734\u00a0million) and EUR 56,599\u00a0million (2023: EUR 46,762\u00a0million).
Customer deposits by type
Netherlands
Rest of the world
Total
in EUR million
2024
2023
2024
2023
2024
2023
Non-interest bearing
26
239
27,142
25,316
27,168
25,556
Interest bearing 1 2
245,375
244,193
427,182
392,255
672,557
636,448
245,401
244,433
454,324
417,571
699,725
662,004
1 Interest bearing includes current accounts which are not remunerated. However ING holds the contractual right to revise the rates.
\u00a0 \u00a0 \u00a0 2 \u00a0 \u00a0 ING changed the presentation for the senior non-preferred debt and the comparative figures for 2023 have been adjusted.
14\u00a0 Financial liabilities at fair value through profit or loss
Financial liabilities at fair value through profit or loss
in EUR million
2024
2023
Trading liabilities
35,255
37,220
Non-trading derivatives
2,101
2,019
Designated at fair value through profit or loss
49,539
55,399
86,896
94,637
Trading liabilities
Trading liabilities by type
in EUR million
2024
2023
Equity securities
467
1,156
Debt securities
3,185
2,492
Funds on deposit
5,437
10,443
Derivatives
26,166
23,129
35,255
37,220
Non-trading derivatives
Non-trading derivatives by type
in EUR million
2024
2023
Derivatives used in:
-\u00a0 fair value hedges
79
113
-\u00a0 cash flow hedges
573
458
-\u00a0 hedges of net investments in foreign operations
117
92
Other non-trading derivatives
1,332
1,356
2,101
2,019
Reference is made to Note 33 'Derivatives and hedge accounting' for information on derivatives used for
hedge accounting.
Other non-trading derivatives mainly include interest-rate swaps, foreign-exchange swaps and cross-
currency swaps for which no hedge accounting is applied.
Designated at fair value through profit or loss
Designated at fair value through profit or loss by type
in EUR million
2024
2023
Debt securities
9,326
8,219
Funds entrusted
40,092
47,085
Subordinated liabilities
122
95
49,539
55,399
As at 31\u00a0December 2024 , 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 17 million on a cumulative basis ( 2023: EUR\u00a0 -34
million). This change has been determined as the amount of change in fair value of the financial liability that
is not attributable to changes in market conditions that gave rise to market risk (i.e. mainly interest-rate risk
based on yield curves).
The amount that ING 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 11,376 million (2023: EUR\u00a09,958 million).
Funds entrusted include mainly repurchase agreements. For more information on repurchase transactions
refer to Note 4 'Financial assets at fair value through profit or loss'.
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
2024
2023
Fixed rate debt securities
Within 1 year
26,358
29,790
More than 1 year but less than 2 years
5,718
4,660
More than 2 years but less than 3 years
4,429
6,279
More than 3 years but less than 4 years
5,907
4,068
More than 4 years but less than 5 years
6,105
4,722
More than 5 years
12,335
13,139
Total fixed rate debt securities
60,851
62,658
Floating rate debt securities
Within 1 year
26,262
17,871
More than 1 year but less than 2 years
2,343
226
More than 2 years but less than 3 years
1,080
2,176
More than 3 years but less than 4 years
117
75
More than 4 years but less than 5 years
902
0
More than 5 years
2,903
1,417
Total floating rate debt securities
33,607
21,765
Total debt securities
94,459
84,423
Reference is made to the consolidated statement of cash flows for further information on issuances,
redemptions and non-cash movements.
18\u00a0 Senior non-preferred debt
Senior non-preferred debt
In EUR million
2024
2023
Senior non-preferred debt
49,393
40,213
49,393
40,213
Senior non-preferred debt is lent on by ING Groep N.V. to ING Bank N.V. In the event of bankruptcy, such
senior non-preferred debt ranks senior to subordinated liabilities but junior to any other liabilities of ING Bank
N.V.
19\u00a0 Subordinated loans
Subordinated loans
In EUR million
2024
2023
Subordinated loans
17,879
15,404
17,879
15,404
Subordinated loans are bonds issued by ING Groep N.V. and its subsidiaries to raise Tier 1 and Tier 2 (CRR-\u00a0
eligible) capital. Under IFRS these securities are classified as liabilities and for regulatory purposes, they are
considered as capital. Subordinated loans of EUR 18,403 million (2023: EUR 16,240 million) have been placed
with ING Bank N.V. by ING Groep N.V.
In 2024 ING Groep N.V. issued USD 1.25 billion 8.00% Perpetual AT1 Contingent Convertible Capital Securities
in February, EUR 1.25 billion 4.38% Fixed Rate Subordinated Tier 2 Notes in May, EUR 1.25 billion\u00a0 4.25% Fixed
Rate Subordinated Tier 2 Notes in August and USD 1 billion 7.25% Perpetual AT1 Contingent Convertible
Capital Securities in September.
In 2024 ING T\u00fcrkiye issued USD 150\u00a0million 8.50% Fixed Rate Subordinated Tier 2 Notes in September.
In 2024 ING Groep N.V. redeemed USD 1.25 billion 6.75% Perpetual AT1 Contingent Convertible Capital
Securities in April, EUR 750 million 2.50% Fixed Subordinated Tier 2 notes in February and EUR 1 billion 1.63%
Fixed Subordinated Tier 2 notes in September on their first call dates.
Reference is made to the consolidated statement of cash flows for further information on issuances and
redemptions.
The average interest rate on subordinated loans is 4.59% (2023: 4.44%).
34\u00a0 Assets by contractual maturity
Amounts presented 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
in EUR million
2024
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
70,353
70,353
Loans and advances to banks
16,825
1,254
1,322
1,759
610
21,769
Financial assets at fair value through profit or loss
\u2013\u00a0 Trading assets
22,154
8,044
14,501
16,006
12,202
72,906
\u2013\u00a0 Non-trading derivatives
602
368
465
356
672
2,463
\u2013\u00a0 Mandatorily at fair value through profit or loss
30,002
11,263
7,222
5,931
1,835
228
56,481
\u2013\u00a0 Designated as at fair value through profit or loss
145
198
1,070
2,110
2,217
5,740
Financial assets at fair value through other comprehensive income
\u2013\u00a0 Equity securities
2,562
2,562
\u2013\u00a0 Debt securities
365
456
2,027
18,064
21,307
42,219
\u2013\u00a0 Loans and advances
2
4
94
871
637
1,608
Securities at amortised cost
2,075
2,646
5,729
22,838
16,985
50,273
Loans and advances to customers
53,738
26,456
61,544
216,035
322,526
680,299
Other assets 2
5,600
590
1,048
698
1,107
5,006
14,050
Total assets
201,860
51,279
95,021
284,668
380,098
7,796
1,020,724
2023
Cash and balances with central banks
90,214
90,214
Loans and advances to banks
11,985
1,021
1,744
1,527
431
16,708
Financial assets at fair value through profit or loss
\u2013\u00a0 Trading assets
17,000
7,363
11,448
13,216
11,213
60,240
\u2013\u00a0 Non-trading derivatives
138
80
297
613
900
2,028
\u2013\u00a0 Mandatorily at fair value through profit or loss
32,835
12,040
5,303
3,587
1,040
179
54,983
\u2013\u00a0 Designated as at fair value through profit or loss
550
200
792
2,092
2,141
5,775
Financial assets at fair value through other comprehensive income
\u2013\u00a0 Equity securities
1,885
1,885
\u2013\u00a0 Debt securities
579
232
2,021
13,686
21,763
38,281
\u2013\u00a0 Loans and advances
3
41
619
287
951
Securities at amortised cost
2,220
1,142
6,667
22,540
15,744
48,313
Loans and advances to customers
49,683
21,298
57,516
206,438
307,517
642,453
Other assets2
5,649
257
1,088
1,147
1,020
4,645
13,805
Total assets
210,852
43,636
86,917
265,466
362,056
6,709
975,636
1 Includes assets on demand.
2 Includes assets such as current and deferred tax assets as presented in the consolidated statement of the financial position. Additionally, assets are included in that position where maturities are not applicable such 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.
35\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:
\u2022 Perpetual liabilities are included in the column \u2018Maturity not applicable\u2019.
\u2022 Derivative 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.
\u2022 Undiscounted future coupon interest on financial liabilities payable is included in a separate line and in
the relevant maturity bucket.
\u2022 Non-financial liabilities are included based on a breakdown of the amounts per statement of financial
position, per expected maturity.
\u2022 Loans 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
2024
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
9,104\u00a0
1,367\u00a0
2,085\u00a0
1,637\u00a0
2,484\u00a0
46\u00a0
16,722\u00a0
Customer deposits
610,590\u00a0
23,479\u00a0
50,034\u00a0
11,141\u00a0
2,081\u00a0
2,399\u00a0
699,725\u00a0
Financial liabilities at fair value through profit or loss
\u2013\u00a0 Other trading liabilities
5,790\u00a0
230\u00a0
313\u00a0
1,325\u00a0
1,465\u00a0
-34\u00a0
9,089\u00a0
\u2013\u00a0 Trading derivatives
2,631\u00a0
2,367\u00a0
3,730\u00a0
7,641\u00a0
5,499\u00a0
4,298\u00a0
26,166\u00a0
\u2013\u00a0 Non-trading derivatives
419\u00a0
57\u00a0
-36\u00a0
711\u00a0
149\u00a0
801\u00a0
2,101\u00a0
\u2013\u00a0 Designated at fair value through profit or loss
32,644\u00a0
5,842\u00a0
1,798\u00a0
5,095\u00a0
4,365\u00a0
34\u00a0
-239\u00a0
49,539\u00a0
Debt securities in issue
1,949\u00a0
17,635\u00a0
33,037\u00a0
26,600\u00a0
15,704\u00a0
-466\u00a0
94,459\u00a0
Senior non preferred debt
\u00a0
975\u00a0
\u00a0
30,121\u00a0
19,153\u00a0
-856\u00a0
49,393\u00a0
Subordinated loans
\u00a0
\u00a0
\u00a0
\u00a0
9,962\u00a0
8,415\u00a0
-498\u00a0
17,879\u00a0
Lease liabilities
20\u00a0
44\u00a0
162\u00a0
607\u00a0
328\u00a0
-45\u00a0
1,116\u00a0
Financial liabilities
663,148\u00a0
51,995\u00a0
91,125\u00a0
84,879\u00a0
61,190\u00a0
8,448\u00a0
5,405\u00a0
966,190\u00a0
Other liabilities 3
7,294\u00a0
456\u00a0
2,073\u00a0
502\u00a0
470\u00a0
10,795\u00a0
Total liabilities
670,442\u00a0
52,451\u00a0
93,198\u00a0
85,381\u00a0
61,660\u00a0
8,448\u00a0
5,405\u00a0
976,986\u00a0
Coupon interest due on financial liabilities
2,278\u00a0
1,600\u00a0
5,981\u00a0
10,388\u00a0
8,065\u00a0
516\u00a0
28,829\u00a0
Contingent liabilities in respect of
\u2013\u00a0 Discounted bills
\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
\u2013\u00a0 Guarantees
26,355\u00a0
\u00a0
\u00a0
3\u00a0
550\u00a0
26,908\u00a0
\u2013\u00a0 Irrevocable letters of credit
16,388\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
16,388\u00a0
Irrevocable facilities
175,000\u00a0
9\u00a0
15\u00a0
143\u00a0
56\u00a0
175,222\u00a0
217,743
9
15
146
606
218,518
1Includes 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
2023
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
9,294
7,800
2,074
1,898
2,002
189
23,257
Customer deposits4
584,874
21,522
45,099
7,394
1,816
1,299
662,004
Financial liabilities at fair value through profit or loss
\u2013\u00a0 Other trading liabilities
10,981
697
545
1,003
897
-36
14,087
\u2013\u00a0 Trading derivatives
2,292
2,243
5,148
10,204
7,110
-3,865
23,132
\u2013\u00a0 Non-trading derivatives
505
96
139
1,002
355
-78
2,019
\u2013\u00a0 Designated at fair value through profit or loss
29,857
12,754
5,442
3,832
3,544
25
-56
55,399
Debt securities in issue
3,442
10,233
33,986
22,206
15,820
-1,264
84,423
Senior non preferred debt4
570
903
25,119
15,492
-1,871
40,213
Subordinated loans
9,104
6,988
-689
15,404
Lease liabilities
17
45
175
627
359
-61
1,162
Financial liabilities
641,263
55,959
93,511
73,285
56,500
7,013
-6,432
921,099
Other liabilities 3
9,696
619
2,269
399
420
13,402
Total liabilities
650,959
56,579
95,779
73,684
56,920
7,013
-6,432
934,501
Coupon interest due on financial liabilities
1,057
1,703
6,103
10,178
4,998
404
24,442
Contingent liabilities in respect of
\u2013\u00a0 Discounted bills
2
2
\u2013\u00a0 Guarantees
27,340
4
550
27,894
\u2013\u00a0 Irrevocable letters of credit
14,925
14,925
\u2013\u00a0 other
Irrevocable facilities
166,361
12
63
314
60
166,810
208,628
12
63
318
610
0
0
209,631
1Includes 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).
3Includes Other liabilities, Current and deferred tax liabilities, and Provisions as presented in the Consolidated statement of financial position.
4 The presentation on senior non-preferred debt change has led to adjustments in the comparative figures for customer deposits and senior non-preferred debt.
37\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 offset in the statement of financial position include transactions where:
\u2022 The counterparty has an offsetting exposure and a master netting or similar arrangement is in place with
a right to offset only in the event of default, insolvency or bankruptcy, or the offsetting criteria are
otherwise not satisfied; and
\u2022 In 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-collateralization is excluded.
The net amounts resulting after offsetting 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 to 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
2024
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
3,752
-31
3,721
3,683
38
7,057
10,777
Other
3,752
-31
3,721
3,683
38
7,057
10,777
Financial assets at fair value through
profit or loss
Trading and Non-trading
Reverse repurchase, securities
borrowing and similar agreements
98,679
-49,365
49,315
219
48,676
420
16,112
65,426
Derivatives 3
93,034
-66,877
26,157
17,598
3,643
4,916
6,111
32,268
191,713
-116,241
75,472
17,818
52,319
5,336
22,222
97,694
Loans and advances to customers 4
Reverse repurchase, securities
borrowing and similar agreements
4,444
-1,216
3,228
3,191
37
243
3,471
Cash pools
237,248
-234,838
2,410
65
1,730
615
2,410
241,691
-236,053
5,638
65
4,921
652
243
5,881
Other items where offsetting is applied in
the statement of financial position 5
6,666
-6,284
382
79
303
382
Total financial assets
443,822
-358,609
85,213
17,962
60,922
6,329
29,522
114,735
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.
2 At 31\u00a0December 2024, the total amount of \u2018Loans and advances to banks\u2019 excluding repurchase agreements is EUR 10,992 million which is not subject to offsetting.
3 Derivative assets and derivative liabilities include certain exchange traded future and option positions with the same underlying.
4 At 31\u00a0December 2024 , the total amount of \u2018Loans and advances to customers\u2019 excluding repurchase agreements is EUR 676,828 million of which the net cash pool position of EUR 2,410 million is subject to offsetting.
5 Other items 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 3,548 million in the statement of financial position of which EUR 382 million is
subject to offsetting as at 31\u00a0December 2024.
Financial assets subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million
2023
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
1,840
-29
1,811
1,811
3,440
5,251
Other
1,840
-29
1,811
1,811
3,440
5,251
Financial assets at fair value through profit
or loss
Trading and Non-trading
Reverse repurchase, securities
borrowing and similar agreements
76,304
-34,738
41,566
235
41,063
268
22,091
63,657
Derivatives
105,928
-83,312
22,617
14,868
2,915
4,834
5,091
27,708
182,232
-118,049
64,183
15,103
43,977
5,102
27,182
91,365
Loans and advances to customers 3
Reverse repurchase, securities
borrowing and similar agreements
499
499
Cash pools
236,233
-234,617
1,616
41
1,217
358
1,616
236,233
-234,617
1,616
41
1,217
358
499
2,115
Other items where offsetting is applied in
the statement of financial position 4
7,124
-6,428
695
21
675
695
Total financial assets
427,428
-359,124
68,305
15,165
47,005
6,135
31,121
99,425
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.
2 At 31 December 2023, the total amount of \u2018Loans and advances to banks\u2019 excluding repurchase agreements is EUR 11,458 million which is not subject to offsetting.
3 At 31 December 2023, the total amount of \u2018Loans and advances to customers\u2019 excluding repurchase agreements is EUR 641,954 million of which the net cash pool position of EUR 1,616 million is subject to offsetting.
4 Other items 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 3,869 million in the statement of financial position of which EUR 695 million is
subject to offsetting as at 31 December 2023.
Financial liabilities subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million
2024
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
64
-31
33
33
33
Other
62
-62
126
-93
33
33
33
Customer deposits 4
Repurchase, securities lending
and similar agreements
1,214
-1,214
1
1
Cash pools
251,655
-234,838
16,817
21
16,796
16,817
252,868
-236,052
16,817
21
16,796
1
16,818
Financial liabilities at fair value through profit or
loss
Trading and Non-trading
Repurchase, securities lending
and similar agreements
81,384
-49,365
32,019
219
31,669
130
11,670
43,689
Derivatives 3
89,386
-67,731
21,655
17,639
2,745
1,272
6,612
28,267
170,769
-117,095
53,674
17,858
34,414
1,402
18,282
71,956
Other items where offsetting is applied in the
statement of financial position 5
5,609
-5,368
242
83
159
242
Total financial liabilities
429,373
-358,608
70,765
17,962
34,447
18,357
18,283
89,049
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.
2 At 31\u00a0December 2024, the total amount of \u2018Deposits from banks\u2019 excluding repurchase agreements is EUR 16,689 million of which EUR 0 million is subject to offsetting.
3 Derivative assets and derivative liabilities include certain exchange traded future and option positions with the same underlying.
4 At 31\u00a0December 2024, the total amount of \u2018Customers deposits\u2019 excluding repurchase agreements is EUR 699,724 million of which the net cash pool position of EUR 16,817 million is subject to offsetting.
5 Other items 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 4,290 million in the statement of financial position of which EUR 242 million is
subject to offsetting as at 31\u00a0December 2024.
Financial liabilities subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million
2023
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
29
-29
2,064
2,064
Other
290
-290
319
-319
2,064
2,064
Customer deposits 3
Repurchase, securities lending
and similar agreements
Cash pools
249,734
-234,617
15,116
13
15,103
15,116
249,734
-234,617
15,116
13
15,103
15,116
Financial liabilities at fair value through profit or
loss
Trading and Non-trading
Repurchase, securities lending
and similar agreements
76,581
-34,738
41,844
235
41,653
-44
14,222
56,065
Derivatives
101,218
-82,677
18,541
14,881
3,455
204
6,607
25,148
177,799
-117,415
60,384
15,117
45,108
160
20,829
81,213
Other items where offsetting is applied in the
statement of financial position 4
7,285
-6,773
512
35
477
512
Total financial liabilities
435,137
-359,124
76,013
15,165
45,108
15,740
22,892
98,905
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.
2 At 31 December 2023, the total amount of \u2018Deposits from banks\u2019 excluding repurchase agreements is EUR 21,193 million of which EUR 0 million is subject to offsetting.
3 At 31 December 2023, the total amount of \u2018Customers deposits\u2019 excluding repurchase agreements is EUR 702,120 million of which the net cash pool position of EUR 15,116 million is subject to offsetting.
4 Other items 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 6,509 million in the statement of financial position of which EUR 512 million is
subject to offsetting as at 31 December 2023.
38\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
2024
2023
Contingent liabilities in respect of
\u2013\u00a0 Discounted Bills
2
\u2013\u00a0 Guarantees
26,908
27,894
\u2013\u00a0 Irrevocable letters of credit
16,388
14,925
43,296
42,821
Irrevocable facilities
175,222
166,810
218,518
209,631
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.
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.
ING uses Irrevocable Payment Commitments (IPCs) for a part of its contributions to the Single Resolution
Fund (SRF). ING Bank has EUR 346 million of IPCs outstanding to the SRF as at 31 December 2024 (31
December 2023: EUR 346 million). No IPCs were provided to the SRF during 2024 (2023: EUR 63 million). No
IPCs were called by the SRF in 2024 (2023: nil). Cash collateral provided to the SRF is equal to the outstanding
amount of IPCs.
ING also uses IPCs for a part of its contributions to the Deposit Guarantee Scheme in Germany. Contingent
liabilities for such outstanding IPCs amount to EUR 309 million as at 31 December 2024 (31 December 2023:
EUR 273 million). Of these, EUR 35 million of IPCs were provided to the DGS during 2024 (2023: EUR 36
million). No IPCs were called by the DGS in 2024 (2023: nil). ING posted government bonds as collateral for
the total nominal amount of EUR 336 million as at 31 December 2024 (31 December 2023: EUR 319 million).
Furthermore we refer to Note 39 'Legal proceedings' for any contingent liabilities in respect of legal
proceedings.
", "dimensions": { "concept": "ifrs-full:DisclosureOfFinancialInstrumentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-679": { "value": "
2\u00a0 Cash and balances with central banks
Cash and balances with central banks
in EUR million
2024
2023
Amounts held at central banks 1
68,708\u00a0
88,627\u00a0
Cash and bank balances
1,645\u00a0
1,587\u00a0
70,353
90,214
1 Amounts held at central banks include an amount of EUR -14 million (2023 : EUR -5 million) of Loan loss provisions.
Amounts held at central banks reflect on-demand balances. The movement reflects ING\u2019s active liquidity
management.
Reference is made to Note 36 '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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-681": { "value": "
3\u00a0 Loans and advances to banks
Loans and advances to banks
Netherlands
Rest of the world
Total
in EUR million
2024
2023
2024
2023
2024
2023
Loans and advances to banks
14,352
9,451
7,439
7,287
21,791
16,738
Loan loss provisions
-8
-11
-13
-18
-22
-30
14,343
9,440
7,426
7,268
21,769
16,708
Loans and advances include balances of reverse repurchase transactions. For more information, refer to
Note 4 'Financial assets at fair value through profit or loss'. Furthermore, it includes on-demand and term
loans, and cash collateral transactions. Reference is made to Note 7 'Loans and advances to customers' for
information on finance lease receivables included in Loans and advances to banks.
As at 31\u00a0December 2024 and at 31 December 2023, all loans and advances to banks are non-subordinated.
", "dimensions": { "concept": "ifrs-full:DisclosureOfLoansAndAdvancesToBanksExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-683": { "value": "
4\u00a0 Financial assets at fair value through profit or loss
Financial assets at fair value through profit or loss
in EUR million
2024
2023
Trading assets
72,906
60,240
Non-trading derivatives
2,463
2,028
Designated at fair value through profit or loss
5,740
5,775
Mandatorily measured at fair value through profit or loss
56,481
54,983
137,590
123,026
(Reverse) repurchase transactions
Financial assets at fair value through profit or loss include securities lending and sales and repurchase
transactions with securities. At ING, these types of transactions are recognised in several lines in the
statement of financial position depending on business model assessment and counterparty. Furthermore,
for repurchase agreements the gross amount of assets must be considered together with the gross amount
of related liabilities, which are presented separately on the statement of financial position since IFRS does
not always allow the netting of these positions in the statement of financial position. Netting is applicable to
repurchase agreements that are governed by an established Global Master Repurchase Agreement (GMRA).
This netting is restricted to transactions involving the same currency and maturity date, and must occur
within the same legal entity. Reference is made to Note 37 'Offsetting financial assets and liabilities'.
Securities purchased under agreements to resell (reverse repos), securities borrowings and similar
agreements are not recognised in the consolidated statement of financial position as the counterparty
continues to be exposed to substantially all risks and rewards of the transferred security. Based on the
business model assessment and counterparty, the consideration paid to purchase securities is recognised as
Loans and advances to customers, Loans and advances to banks, financial assets mandatorily at FVPL or
Trading assets.
Securities sold subject to repurchase agreements (repos), securities lending and similar agreements continue
to be recognised in the consolidated statement of financial position as ING Bank continues to be exposed to
substantially all risks and rewards of the transferred financial asset. The counterparty liability is designated
and measured at FVPL if the asset is measured mandatorily at FVPL. Otherwise, the counterparty liability is
included in Deposits from banks, Customer deposits or Trading.
Reference is made to Note 36 'Transfer of financial assets, assets pledged and received as collateral' for
information on transferred assets which were not derecognised.
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
2024
2023
Reverse repurchase transactions
Loans and advances to banks
10,777
5,251
Loans and advances to customers
3,471
499
Trading assets, loans and receivables
12,033
12,121
Loans and receivables mandatorily measured at fair value through profit or loss
53,393
51,536
79,675
69,407
Repurchase transactions
Deposits from banks
33
2,064
Customer deposits
1
97
Trading liabilities, funds on deposit
5,269
10,337
Funds entrusted designated and measured at fair value through profit or loss
38,420
45,729
43,723
58,227
Trading assets
Trading assets by type
in EUR million
2024
2023
Equity securities
20,726
15,423
Debt securities
10,080
6,907
Derivatives
29,805
25,680
Loans and receivables
12,295
12,231
72,906
60,240
Trading assets include assets that are closely related to servicing the needs of the clients of ING Bank. ING
offers institutional clients, corporate clients, and governments products that are traded on the financial
markets. A significant part of the derivatives in the trading portfolio is related to servicing corporate clients in
their risk management to hedge, for example, currency or interest rate exposures. In addition, ING provides
its customers access to equity and debt markets for issuing their own equity or debt securities (securities
underwriting).
Reference is made to Note 14 'Financial liabilities at fair value through profit or loss' for information on
trading liabilities.
Non-trading derivatives
Non-trading derivatives by type
in EUR million
2024
2023
Derivatives used in
-\u00a0 fair value hedges
617
716
-\u00a0 cash flow hedges
158
440
-\u00a0 hedges of net investments in foreign operations
82
100
Other non-trading derivatives
1,606
771
2,463
2,028
Reference is made to Note 33 'Derivatives and hedge accounting' for information on derivatives designated
in hedge accounting.
Other non-trading derivatives mainly includes interest rate swaps, foreign exchange swaps, and cross
currency swaps for which no hedge accounting is applied.
Designated at fair value through profit or loss
Designated at fair value through profit or loss by type
in EUR million
2024
2023
Debt securities
4,718
4,470
Loans and receivables
1,022
1,306
5,740
5,775
\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 5,740 million (2023: EUR 5,775 million). In 2024, the
change in fair value of these loans and debt securities amounts EUR 5 million (2023: EUR -48\u00a0million).\u00a0 \u00a0
ING has mitigated the credit risk exposure on part of the portfolio. The cost at initial recognition of the
financial assets designated at fair value through profit or loss that are economically hedged by credit
derivatives is EUR 3,797 million (31 December 2023: EUR 3,181 million) and the cumulative change in fair
value attributable to changes in credit risk is EUR 173 million (31 December 2023: EUR 150 million).
The notional value of the related credit derivatives is EUR 3,807 million (2023: EUR 3,679 million). The
cumulative change in fair value of the credit derivatives since the financial assets were first designated,
amounts to EUR -214\u00a0million (2023: EUR -119\u00a0million) and the change for the current year is EUR -95\u00a0million
( 2023: EUR -122\u00a0million).
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
2024
2023
Equity securities
228
179
Debt securities
789
894
Loans and receivables
55,464
53,911
56,481
54,983
Equity securities are individually insignificant for ING Bank . For total exposure to debt securities, reference is
made to Note 6 'Debt securities' . 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
2024
2023
Equity securities
2,562
1,885
Debt securities 1
42,219
38,281
Loans and advances 1
1,608
951
46,389
41,116
1 Debt securities include an amount of EUR -12 million (2023: EUR -13 million) and the Loans and advances includes EUR -7 million
(2023: EUR -8 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
2024
2023
2024
2023
Investment in Bank of Beijing
2,241
1,590
101
98
Other Investments
321
295
16
8
2,562
1,885
117
105
As at 31\u00a0December 2024 ING holds approximately 13% (2023: 13% ) of the shares of Bank of Beijing, a bank
listed on the stock exchange of Shanghai. The stake in Bank of Beijing is part of the Corporate Line segment.
As per regulatory requirements set by the China Banking and Insurance Regulatory Commission, ING, as a
shareholder holding more than 5% of the shares, is required to supply additional capital when necessary. No
request for additional capital was received in 2024 ( 2023: nil ).
Changes in fair value through other comprehensive income
The following table presents changes in financial assets at fair value through other comprehensive income.
Changes in fair value through other comprehensive income financial assets
FVOCI equity
securities
FVOCI debt
instruments 1
Total
in EUR million
2024
2023
2024
2023
2024
2023
Opening balance as at 1 January
1,885
1,887
39,231
29,739
41,116
31,625
Additions
11
28
21,080
19,967
21,091
19,995
Amortisation
77
31
77
31
Transfers and reclassifications\u00a0
5
1
1
5
Changes in unrealised revaluations 2
605
68
-96
657
509
725
Impairments
2
-1
2
-1
Reversals of impairments
-7
6
-7
6
Disposals and redemptions
-1
-2
-16,906
-11,912
-16,907
-11,913
Exchange rate differences
62
-100
443
751
506
651
Other changes
-6
-6
Closing balance
2,562
1,885
43,827
39,231
46,389
41,116
1 Fair value through other comprehensive income debt instruments includes both debt securities and loans and advances.
2 Changes in unrealised revaluations of FVOCI debt instruments include changes on hedged items which are recognised in the
statement of profit or loss. Reference is made to Note 20 'Equity' for details on the changes in revaluation reserve.
FVOCI equity securities
Exchange rate differences of EUR 62\u00a0million (31 December 2023: EUR -100\u00a0million) are mainly related to the
stake in Bank of Beijing following the appreciation of CNY versus EUR. In 2024, changes in unrealised
revaluations of equity securities are mainly related to a revaluation of the stake in Bank of Beijing of EUR
590\u00a0million (31 December 2023: EUR 77\u00a0million) following a change in the share price.
FVOCI debt instruments
In 2024, ING sold the remaining NNHB mortgages, amounting to EUR 263 million to Nationale Nederlanden.
ING agreed in 2012 to transfer a portfolio of NNHB mortgages to NN as part of the required restructuring of
ING Group by the European Commission after having received state support during the global financial crisis
(2008). The majority of these mortgages were not sold immediately but only at the interest reset date of
these mortgages.\u00a0
In 2024, interest rates in the shorter and longer tenors decreased which resulted in changes in unrealised
revaluations of debt securities of EUR -96\u00a0million. During 2023 interest rates in the longer tenors decreased
significantly resulting in unrealised revaluations of EUR 657\u00a0million.
Reference is made to Note 6 'Debt securities' 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
2024
2023
Trading liabilities
35,255
37,220
Non-trading derivatives
2,101
2,019
Designated at fair value through profit or loss
49,539
55,399
86,896
94,637
Trading liabilities
Trading liabilities by type
in EUR million
2024
2023
Equity securities
467
1,156
Debt securities
3,185
2,492
Funds on deposit
5,437
10,443
Derivatives
26,166
23,129
35,255
37,220
Non-trading derivatives
Non-trading derivatives by type
in EUR million
2024
2023
Derivatives used in:
-\u00a0 fair value hedges
79
113
-\u00a0 cash flow hedges
573
458
-\u00a0 hedges of net investments in foreign operations
117
92
Other non-trading derivatives
1,332
1,356
2,101
2,019
Reference is made to Note 33 'Derivatives and hedge accounting' for information on derivatives used for
hedge accounting.
Other non-trading derivatives mainly include interest-rate swaps, foreign-exchange swaps and cross-
currency swaps for which no hedge accounting is applied.
Designated at fair value through profit or loss
Designated at fair value through profit or loss by type
in EUR million
2024
2023
Debt securities
9,326
8,219
Funds entrusted
40,092
47,085
Subordinated liabilities
122
95
49,539
55,399
As at 31\u00a0December 2024 , 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 17 million on a cumulative basis ( 2023: EUR\u00a0 -34
million). This change has been determined as the amount of change in fair value of the financial liability that
is not attributable to changes in market conditions that gave rise to market risk (i.e. mainly interest-rate risk
based on yield curves).
The amount that ING 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 11,376 million (2023: EUR\u00a09,958 million).
Funds entrusted include mainly repurchase agreements. For more information on repurchase transactions
refer to Note 4 'Financial assets at fair value through profit or loss'.
23\u00a0 Valuation results and net trading income
Valuation results and net trading income
in EUR million
2024
2023
2022
Securities trading results
996
873
-356
Derivatives trading results
207
116
11
Other trading results
336
273
71
Change in fair value of derivatives relating to
\u2013\u00a0 fair value hedges
-766
-3,028
5,265
\u2013\u00a0 cash flow hedges (ineffective portion)
35
48
20
\u2013\u00a0 other non-trading derivatives
1,923
563
1,164
Change in fair value of assets and liabilities (hedged items)
750
2,962
-5,150
Valuation results on assets and liabilities designated at FVPL (excluding trading)
31
-127
444
Foreign exchange transactions results
-105
1,230
33
3,407
2,910
1,503
In general, the fair value movements are influenced by changes in the market conditions, such as stock
prices, credit spreads, interest rates and currency exchange rates.
Net trading income relates to trading assets and trading liabilities which include assets and liabilities that are
classified under IFRS as Trading but are closely related to servicing the needs of the clients of ING. ING offers
products that are traded on the financial markets to institutional clients, corporate clients, and governments.
ING\u2019s trading books are managed based on internal limits and comprise a mix of products with results which
could be offset. A significant part of the derivatives in the trading portfolio are related to servicing corporate
clients in their risk management to hedge for example currency or interest rate exposures. From a risk
perspective, the gross amount of trading assets must be considered together with the gross amount of
trading liabilities, which are presented separately on the statement of financial position. However, IFRS does
not always allow the netting of these positions in the statement of financial position. Reference is made to
Note 4 'Financial assets at fair value through profit or loss' and Note 14 'Financial liabilities at fair value
through profit or loss' for information on trading assets and trading liabilities respectively.
Securities trading results include the results of market making in instruments such as government securities,
equity securities, corporate debt securities, money-market instruments. Derivatives trading results include
the results of derivatives such as interest rate swaps, options, futures, and forward contracts. Trading gains
and losses relating to trading securities still held as at 31\u00a0December 2024 amount to EUR 20 million (2023:
EUR 160 million; 2022 : EUR\u00a0-157 million). The majority of the risks involved in security and currency trading
are economically hedged with derivatives. The securities trading results are partly offset by results on these
derivatives. The result of these derivatives is included in Derivatives trading results.
Other trading results include the results of trading loans and funds entrusted.
Foreign exchange transactions results include gains and losses from spot and forward contracts, options,
futures, and translated foreign currency assets and liabilities. The result on currency trading is included in
foreign exchange transactions results.
\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. In 2024, fluctuations in interest rate had a
significant impact on 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 33 'Derivatives and hedge accounting' for information on derivatives used for hedge accounting.
Furthermore, derivatives trading results are also impacted by fair value movements arising from changes in
credit spreads (CVA and DVA), bid offer spreads, model risk and incremental cost of funding on derivatives
(FVA and CollVA). Refer to Note 32 'Fair value of assets and liabilities' for information on these valuation
adjustments.
32\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.
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, the Global Valuation and Impairment Committee, the Market Data Committee and
the Valuation Model Committee. All relevant committees meet on a regular basis (monthly/quarterly), where
the 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 Global
Financial Markets Parameter Committee reviews the consolidated valuation outcome and resulting P&L for
Financial Market products, targeting a globally consistent treatment across Financial Markets. 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 (hereafter:
DOP). ING defers material DOP 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 DOP 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 2024 and the DOP reserve is disclosed in
the below table.
Deferred Day One Profit or Loss Reserve
The table below summarises the movement in the aggregate DOP not recognised when financial instruments
were initially recognised, because of the use of valuation techniques for which not all the inputs were market
observable data.
Deferred day one profit or loss reserve
in EUR million
2024
2023
Opening balance at 1 January
-90
-108
DOP deferred on new transactions during the period
-62
-83
DOP recognised in the statement of profit or loss during the period:
\u2013 of which release
27
85
\u2013 of which amortisation and exchange differences
32
15
Closing balance at 31 December
-94
-90
The following table presents the model reserves for financial assets and liabilities.
Valuation adjustment reserves on financial assets and liabilities
in EUR million
2024
2023
Deferred Day One Profit or Loss
-94
-90
Own credit adjustments
-17
34
Bid/Offer
-130
-154
Model Risk
-33
-26
CVA
-123
-131
DVA
50
55
CollVA
-3
-4
FVA
-64
-68
Other valuation adjustments
2
0
Total Valuation Adjustments
-412
-385
Own Credit Adjustment
Own issued debt and structured notes that are designated at fair value through profit or loss are adjusted for
ING`s own credit risk by means of DVA.
Bid-Offer Adjustment
For positions priced based upon mid-market input parameters, Bid-Offer adjustments are required in order to
reflect the valuation of that position based on bid price or offer price. In practice this adjustment accounts for
the difference in valuation from \u2018mid to bid\u2019 and \u2018mid to offer\u2019 for long and short exposures respectively. In
principle, assets are valued at the bid prices and liabilities are valued at the offer price. For certain assets or
liabilities, where a market-quoted price is not available, the price used is the fair value that is most
representative within the bid-offer spread.
Model Risk Adjustment
Financial instruments that are valued using a valuation model can be subject to model risk. Model risk is the
risk of possible financial loss resulting from a pricing model or model-based parameter deficiencies and/or
uncertainties.
Bilateral Valuation Adjustments (Credit and Debit Valuation Adjustments)
Bilateral Valuation Adjustment is the valuation adjustment reflecting the counterparty credit risk of
derivative contracts. It has a bilateral nature, where both the counterparty\u2019s credit risk (i.e. Credit Valuation
Adjustment or CVA) and ING\u2019s own credit risk (Debit Valuation Adjustment or DVA) are taken into account:
\u2022 CVA is the fair value adjustment applicable to derivative instruments to account for the possibility that the
counterparty defaults (i.e. it is the market value of the counterparty\u2019s credit risk).
\u2022 DVA is the fair value adjustment applicable to derivative instruments to account for the possibility that
ING defaults (i.e. it is the market value of ING\u2019s credit risk).
The calculation of CVA and DVA on derivatives is based on their expected exposures, and the counterparties\u2019
and ING\u2019s risk of default, taking into account the collateral agreements as well as netting agreements. The
counterparties\u2019 risk of default is measured by probability of default and expected loss given default, which is
based on market information including credit default swap (CDS) spreads. Where counterparty CDS spreads
are not available, relevant proxy spreads are used. Additionally, wrong-way risk (which occurs when the
probability of default by the counterparty increases or decreases when ING\u2019s exposure to the counterparty
increases (decreases)) and right-way risk (which occurs when the probability of default by the counterparty
increases (decreases) when ING\u2019s exposure to the counterparty decreases (increases)) are included in the
adjustment.
Collateral Valuation Adjustment (CollVA)
Collateral Valuation Adjustment is a fair valuation adjustment applied on derivative instruments to capture
specific features of CSA (Credit Support Annex) with a counterparty that the regular OIS discounting
framework does not capture. Non-standard CSA features may include deviations in relation to the currencies
in which ING posts or receives collateral, deviations in the remuneration rate on collateral which may pay
lower or higher rate than the overnight rate or even no interest at all; other deviations can be posting
securities rather than cash as collateral.
Funding Valuation Adjustment (FVA)
Funding Valuation Adjustment (FVA) is a fair valuation adjustment applied on derivative instruments to
address the asymmetry in funding costs or funding benefits between collateralised and uncollateralised
derivative portfolios. This adjustment is based on the expected exposure profiles of the uncollateralised or
partially collateralised OTC derivatives and market-based funding spreads.
Other Valuation Adjustments
This pertains to other valuation adjustments that are immaterial to ING. Most of the balance consists of the
Market Price Uncertainty (MPU) adjustment in fair value, which accounts for the price uncertainty risk
inherent in the valuation inputs to fair value.
d) Fair value hierarchy
ING Bank has categorised 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 of the valuation inputs. Highest priority is retained to unadjusted quoted prices in active
markets for identical assets or liabilities and the lowest priority to valuation techniques supported by
unobservable inputs.
Transfers into and transfers out of fair value hierarchy levels are made on a quarterly basis at the end of the
reporting period.
Level 1 \u2013 (Unadjusted) quoted prices in active markets
This category includes financial instruments whose fair value is determined directly by reference to
(unadjusted) quoted prices in an active market. A financial instrument is regarded as quoted in an active
market if quoted prices are readily and regularly available from an exchange, dealer markets, brokered
markets, or principal to principal markets. Those prices represent actual and regularly occurring market
transactions with sufficient frequency and volume to provide pricing information on an ongoing basis.
Transfers out of Level 1 into Level 2 or Level 3 occur when ING Bank establishes that markets are no longer
active and therefore (unadjusted) quoted prices no longer provide reliable pricing information.
Level 2 \u2013 Valuation technique supported by observable inputs
This category includes financial instruments whose fair value is based on market observable inputs, either
directly or indirectly, other than quoted prices included within Level 1. The fair value for financial instruments
in this category can be determined by reference to quoted prices for similar instruments in active markets,
quoted prices for identical or similar instruments in markets that are not active, inputs other than quoted
prices that are observable or market-corroborated inputs. ING analyses how the prices are derived and
determines whether the prices are liquid tradable prices or model-based consensus prices taking various
data as inputs.
For financial instruments that do not have a reference price available, fair value is determined using a
valuation technique (e.g., a model), where inputs in the model are taken from an active market or are
observable, such as interest rates and yield curves observable at commonly quoted intervals, implied
volatilities, and credit spreads.
Instruments where inputs are unobservable are classified in this category, provided that the impact of those
unobservable inputs on the overall valuation is insignificant. The notion of significant is particularly relevant
for the distinction between Level 2 and Level 3 assets and liabilities, as the significance assessment of the
valuation input on the entire fair value measurement will determine whether the instrument should be
classified as Level 2 or Level 3. Expert judgement is required on the significance assessment approach.
Level 3 \u2013 Valuation technique supported by unobservable inputs
This category includes financial instruments whose fair value is determined using a valuation technique for
which a significant part of the overall valuation is driven by unobservable valuation inputs. Where valuation
inputs are unobservable, the Group must use the best information available to value the instruments. This
may require internally derived inputs taking into account market participants' assumptions that are
reasonably available, including assumptions on the risk inherent in a particular valuation technique used to
measure fair value and the risk inherent in the inputs to the valuation technique. Unobservable inputs may
include, among others, volatility, correlation, spreads to discount rates, default rates, recovery rates,
prepayment rates, and certain credit spreads.
Financial instruments at fair value
The fair values of the financial instruments were determined as follows:
Methods applied in determining fair values of financial assets and liabilities (carried at fair value)
Level 1
Level 2
Level 3
Total
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
Financial Assets
Financial assets at fair value
through profit or loss
- Equity securities
20,798
15,449
15
3
141
150
20,954
15,602
- Debt securities
7,485
4,825
4,596
4,081
3,505
3,364
15,586
12,270
- Derivatives
1
39
31,792
27,134
475
535
32,268
27,708
- Loans and receivables
0
0
62,168
63,316
6,614
4,131
68,782
67,446
28,285
20,314
98,571
94,533
10,734
8,179
137,590
123,026
Financial assets at fair value
through other
comprehensive income
- Equity securities
2,292
1,622
270
263
2,562
1,885
- Debt securities
39,859
35,848
2,360
2,433
0
0
42,219
38,281
- Loans and receivables
0
0
1,608
275
0
676
1,608
951
42,151
37,470
3,967
2,707
270
938
46,389
41,116
Financial liabilities
Financial liabilities at fair
value through profit or loss
\u2013\u00a0 Debt securities
824
575
8,437
7,603
67
47
9,328
8,224
\u2013\u00a0 Deposits
45,648
57,607
13
45,648
57,620
\u2013\u00a0 Trading securities
3,631
3,604
12
41
10
3,653
3,645
\u2013\u00a0 Derivatives
45
41
27,528
24,437
694
670
28,267
25,148
4,501
4,220
81,625
89,687
770
729
86,896
94,637
The following methods and assumptions were used by ING 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 the 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 include 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 institution bonds are generally traded in active
markets. Where quoted prices are readily and regularly available, they are classified as Level 1. The
remaining positions are classified as Level 2 or Level 3 depending on the trading activity and observability of
prices. 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: Derivative 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, among 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 include 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 and
debt instruments, primarily comprised of structured notes, which are held at fair value under the fair value
option. Besides that, they include 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 a EUR 0.8 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 2024.
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 2024 of EUR 11.0 billion
(31\u00a0December 2023: EUR 9.1 billion), an amount of EUR 9.6 billion (87.2%) (31\u00a0December 2023: EUR 7.0 billion,
being 76.7%) 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 include EUR 0.1 billion (31\u00a0December 2023: EUR 0.3 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 1.3 billion (31\u00a0December 2023: EUR 1.8 billion) of the fair value classified in Level 3
financial assets is established using valuation techniques that incorporate certain inputs that are
unobservable.
Of the total amount of financial liabilities classified as Level 3 as at 31\u00a0December 2024 of EUR 0.8 billion
(31\u00a0December 2023: EUR 0.7 billion), an amount of EUR 0.6 billion (75.7%) (31\u00a0December 2023: EUR 0.4 billion,
being 50.0%) 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 include EUR 0.1 billion (31\u00a0December 2023: EUR 0.3 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 2023: 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
2024
2023
2024
2023
2024
2023
2024
2023
At fair value through profit or loss
Debt securities
3,504
3,364
10
0
Price based
Price (%)
0%
0%
120%
122%
Price (price per share)
327
97
520
236
Present value techniques
Credit spread (bps)
n.a.
94
n.a.
94
Price (%)
95.85%
n.a.
100%
n.a.
Equity securities
141
150
Price based
Price (price per share)
0
0
5,475
5,457
Loans and advances
1,565
2,298
0
13
Price based
Price (%)
0%
0%
107%
117%
Present value techniques
Credit spread (bps)
576
1
629
12
Prepayment rate (%)
2%
n.a.
100%
n.a.
(Reverse) repo's
5,050
1,832
Present value techniques
Interest rate (%)
2%
n.a.
2%
n.a.
Structured notes
67
47
Price based
Price (%)
93%
88%
104%
96%
Option pricing model
Equity volatility (%)
n.a.
9%
n.a.
23%
Equity/Equity correlation
0.7
0.8
0.7
0.9
Equity/FX correlation
n.a.
-0.2
n.a.
0.6
Dividend yield (%)
n.a.
0%
n.a.
4%
Present value techniques
Credit spreads (bps)
n.a.
100
n.a.
101
Prepayment rate (%)
99.59%
n.a.
100.09%
n.a.
Derivatives
\u2013\u00a0\u00a0Rates
413
283
389
301
Option pricing model
Interest rate volatility (bps)
n.a.
1
n.a.
3
Present value techniques
Reset spread (%)
2%
n.a.
2%
n.a.
Prepayment rate (%)
n.a.
0%
n.a.
0%
\u2013\u00a0\u00a0FX
6
2
8
3
Option pricing model
Implied volatility (%)
2%
3%
15%
18%
\u2013\u00a0\u00a0Credit
39
216
241
343
Present value techniques
Credit spread (bps)
0
3
91
149
Price based
Price (%)
0%
0%
100%
100%
\u2013\u00a0\u00a0Equity
10
20
47
17
Option pricing model
Equity volatility (%)
7%
12%
81%
75%
Equity/Equity correlation
0.0
0.2
1.0
1.0
Equity/FX correlation
-0.6
-0.5
0.6
1.0
Dividend yield (%)
0%
0%
33%
14%
Price based
Price (%)
n.a.
0%
n.a.
21%
\u2013\u00a0\u00a0Other
6
14
9
7
Option pricing model
Commodity volatility (%)
13.1%
11%
61%
94%
Com/FX correlation
-0.40
n.a.
-0.25
n.a.
Price based
Price (commodity)
68
n.a.
68
n.a.
At fair value through other comprehensive income
\u2013\u00a0\u00a0Loans and advances
676
Price based
Price (%)
n.a.
85%
n.a.
96%
\u2013\u00a0\u00a0Equity
270
263
Present value techniques
Credit spread (bps)
5.67
5.2
5.76
5.2
Interest rate (%)
1.5%
4%
3.5%
4%
Payout ratio (%)
70%
n.a.
90%
n.a.
Price based
Price (%)
122%
122%
122%
122%
Total
11,005
9,118
770
729
1 The abbreviation n.a. stands for not applicable or not available.
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 a strong positive (statistical) relationship, where underliers move, everything else equal,
into the same direction. The same holds for a high negative correlation.
Interest rate
An interest rate is the amount of interest due per period, as a proportion of the amount lent, deposited, or
borrowed.
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.
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.
Payout ratio
Dividend payout ratio is an input that shows the percentage of dividends a company is expected to pay out
each year relative to its net income.
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
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
Opening balance as at 1 January
848
873
286
421
3,499
1,849
3,547
3,492
938
891
9,118
7,526
Realised gain/loss\u00a0 recognised in the statement of profit or loss during the period 1
-175
235
-38
-142
294
-33
-54
-383
0
28
-322
Revaluation recognised in other comprehensive income during the period 2
-3
-6
-3
-6
Purchase of assets
486
1,246
198
76
4,424
2,208
1,600
873
154
331
6,862
4,735
Sale of assets
-111
-889
-257
-55
-1,605
-1,109
-10
-138
-418
-243
-2,402
-2,433
Maturity/settlement
-140
-1,005
-7
-15
-294
-576
-988
-292
-20
-22
-1,449
-1,910
Reclassifications
0
0
0
0
0
723
0
0
0
5
0
728
Transfers into Level 3
370
879
0
0
615
981
30
1
0
0
1,014
1,860
Transfers out of Level 3
-454
-459
-114
0
-1,214
-534
-3
0
-384
0
-2,169
-994
Exchange rate differences
0
-31
0
0
5
-9
-2
-9
9
-10
12
-59
Changes in the composition of the group and other changes
0
0
0
0
-1
0
0
2
-5
-8
-6
-6
Closing balance
824
848
68
286
5,721
3,499
4,121
3,547
270
938
11,005
9,118
1 Net gains/losses were recorded as \u2018Valuation results and net trading income\u2019 in the statement of profit or loss. The total amounts includes EUR -41 million (2023: EUR 316 million) of unrealised gains and losses recognised in the statement of profit or loss.
2 Revaluation recognised in other comprehensive income is included on the line \u2018Net change in fair value of debt instruments at fair value through other comprehensive income\u2019.
In 2024 and 2023, transfers into and out of Level 3 of financial assets mandatorily at fair value mainly relate
to (long- term) reverse repurchase transactions for which the valuation being significantly impacted by
unobservable inputs and no longer significantly impacted by unobservable inputs, respectively.
In 2024, the transfer into Level 3 trading assets consisted of cross currency swap trades, which were
transferred to Level 3 as a result of the valuation being significantly impacted by unobservable inputs.
Conversely, the transfer out of Level 3 in trading assets and non-trading derivatives primarily involved
derivative instruments, as their valuations were no longer significantly impacted by unobservable inputs.
In 2024, the transfer out of Level 3 of financial assets at FVOCI relates to HtC&S portfolio transferred to Level
2 resulting from change in methodology.
In 2023, the transfer into Level 3 trading assets is mainly driven by debt securities that are part of a structure
transferred into level 3 due to market illiquidity which decreased observability for an input.
Changes in Level 3 Financial liabilities
Trading liabilities
Non-trading
derivatives
Financial liabilities
designated as at fair
value through profit
or loss
Total
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
Opening balance as at 1
January
382
229
301
449
47
54
729
732
Realised gain/loss recognised
in the statement of profit or
loss during the period1
-104
224
-98
-151
-5
-2
-206
72
Additions
55
53
190
72
29
18
274
142
Redemptions
-12
-102
-209
-53
0
-2
-222
-156
Maturity/settlement
-15
-13
-7
-16
-4
-1
-26
-30
Transfers into Level 3
364
40
0
0
34
32
399
72
Transfers out of Level 3
-33
-49
-111
0
-34
-54
-179
-102
Exchange rate differences
0
0
0
0
0
0
0
0
Closing balance
637
382
67
301
67
47
770
729
1 Net gains/losses were recorded as \u2018Valuation results and net trading income\u2019 in the statement of profit or loss. The total amount
includes EUR -206 million (2023: EUR 72\u00a0million) of unrealised gains and losses recognised in the statement of profit or loss.
In 2024, the transfers into Level 3 mainly consisted of trading liabilities attributed to cross currency swap
trades transferred into Level 3 as a result of the valuation being significantly impacted by unobservable
inputs. The transfers out of Level 3 for non-trading derivatives are driven by interest rate swap trades, which
were reclassified out of Level 3 as their valuations were no longer influenced by significantly unobservable
inputs.
In 2023, transfers of financial liabilities into and out of Level 3 mainly consisted of structured notes,
measured as designated at fair value through profit or loss. The structured notes were transferred out of
Level 3 as the valuation was no longer impacted by significantly unobservable inputs.
g) Recognition of unrealised gains and losses in Level 3
Amounts recognised in the statement of profit or loss relating to unrealised gains and losses during the year
that relate to Level 3 assets and liabilities are included in the line item \u2018Valuation results and net trading
income\u2019 in the statement of profit or loss.
h) Level 3: Sensitivity analysis of unobservable inputs
Where the fair value of a financial instrument is determined using inputs which are unobservable and which
have a more than insignificant impact on the fair value of the instrument, the actual value of those inputs at
the balance date may be drawn from a range of reasonably possible alternatives. In line with market
practice, the upper and lower bounds of the range of alternative input values reflect a level of valuation
certainty. The actual levels chosen for the unobservable inputs in preparing the financial statements are
consistent with the valuation methodology used for fair valued financial instruments.
In practice, valuation uncertainty is measured and managed per exposure to individual valuation inputs (i.e.
risk factors) at portfolio-level across different product categories. Where the disclosure looks at individual
Level 3 inputs, the actual valuation adjustments may also reflect the benefits of portfolio offsets.
This disclosure does not attempt to indicate or predict future fair value movement. The numbers in isolation
give limited information as in most cases these Level 3 assets and liabilities should be seen in combination
with other instruments (for example as a hedge) that are classified as Level 2.
The valuation uncertainty in the table below is broken down by related risk class rather than by product. The
possible impact of a change of unobservable inputs in the fair value of financial instruments where
unobservable inputs are significant to the valuation is as follows:
Sensitivity analysis of Level 3 instruments
Positive fair\u00a0value
movements from
using reasonable
possible alternatives
Negative fair\u00a0value
movements from
using reasonable
possible alternatives
in EUR million
2024
2023
2024
2023
Equity (equity derivatives, structured notes)
21
18
-20
-9
Interest rates (Rates derivatives, FX derivatives)
5
3
0
0
Credit (Debt securities, Loans, structured notes, credit derivatives)
2
45
-27
-54
Loans and advances
0
3
0
-17
28
69
-47
-80
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.
Methods applied in determining fair values of financial assets and liabilities (carried at amortised cost)
Carrying Amount
Carrying amount
presented as fair value1
Level 1
Level 2
Level 3
Total fair value
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
Financial Assets
Loans and advances to banks
21,769
16,708
3,194
2,721
15,614
11,430
2,957
2,511
21,766
16,662
Loans and advances to customers
680,299
642,453
18,296
15,686
18,626
14,602
630,493
593,098
667,415
623,386
Securities at amortised cost
50,273
48,313
42,871
40,041
2,908
4,277
2,523
1,693
48,303
46,010
752,341
707,474
21,490
18,407
42,871
40,041
37,149
30,308
635,973
597,302
737,483
686,058
Financial liabilities
Deposits from banks
16,722
23,257
4,347
3,764
8,208
15,066
3,943
3,968
16,498
22,799
Customer deposits2
699,725
662,004
582,511
556,766
69,790
63,348
46,984
41,063
699,285
661,177
Debt securities in issue3
94,459
84,423
33,019
25,898
59,141
38,301
2,000
20,225
94,161
84,424
Senior non-preferred debt2
49,393
40,213
50,230
40,607
186
50,230
40,793
Subordinated loans
17,879
15,404
18,357
15,361
18,357
15,361
878,178
825,300
586,857
560,530
33,019
25,898
205,726
172,684
52,927
65,443
878,530
824,555
1 In accordance with IFRS and for the purpose of this disclosure, the carrying amount of financial instruments with an immediate on demand feature is presented as fair value
2 The presentation on senior non-preferred debt change has led to adjustments in the comparative figures for customer deposits and senior non-preferred debt.
3 In 2023, debt securities included a commercial paper issued classified as Level 3. Following a change in valuation technique in 2024, it transferred to Level 2.
The aggregation of the fair values presented above does not represent, and should not be construed as
representing, the underlying value of ING. These fair values were calculated for disclosure purposes only. The
carrying amount of financial instruments presented in the above table includes, when applicable, the fair
value hedge adjustment, this explains why (for these cases) 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.
Securities at amortised cost
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 include 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.
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 reflect ING\u2019s own credit
risk.
Customer deposits
In the current interest rate environment, there is significant embedded value in our on-demand deposits.
However, for the purpose of this disclosure and in accordance with IFRS, the carrying amounts of deposits
with an immediate on demand feature are presented as fair value.
The fair value of deposits with fixed contractual terms has 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:DisclosureOfFairValueOfFinancialInstrumentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-682": { "value": "
4\u00a0 Financial assets at fair value through profit or loss
Financial assets at fair value through profit or loss
in EUR million
2024
2023
Trading assets
72,906
60,240
Non-trading derivatives
2,463
2,028
Designated at fair value through profit or loss
5,740
5,775
Mandatorily measured at fair value through profit or loss
56,481
54,983
137,590
123,026
(Reverse) repurchase transactions
Financial assets at fair value through profit or loss include securities lending and sales and repurchase
transactions with securities. At ING, these types of transactions are recognised in several lines in the
statement of financial position depending on business model assessment and counterparty. Furthermore,
for repurchase agreements the gross amount of assets must be considered together with the gross amount
of related liabilities, which are presented separately on the statement of financial position since IFRS does
not always allow the netting of these positions in the statement of financial position. Netting is applicable to
repurchase agreements that are governed by an established Global Master Repurchase Agreement (GMRA).
This netting is restricted to transactions involving the same currency and maturity date, and must occur
within the same legal entity. Reference is made to Note 37 'Offsetting financial assets and liabilities'.
Securities purchased under agreements to resell (reverse repos), securities borrowings and similar
agreements are not recognised in the consolidated statement of financial position as the counterparty
continues to be exposed to substantially all risks and rewards of the transferred security. Based on the
business model assessment and counterparty, the consideration paid to purchase securities is recognised as
Loans and advances to customers, Loans and advances to banks, financial assets mandatorily at FVPL or
Trading assets.
Securities sold subject to repurchase agreements (repos), securities lending and similar agreements continue
to be recognised in the consolidated statement of financial position as ING Bank continues to be exposed to
substantially all risks and rewards of the transferred financial asset. The counterparty liability is designated
and measured at FVPL if the asset is measured mandatorily at FVPL. Otherwise, the counterparty liability is
included in Deposits from banks, Customer deposits or Trading.
Reference is made to Note 36 'Transfer of financial assets, assets pledged and received as collateral' for
information on transferred assets which were not derecognised.
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
2024
2023
Reverse repurchase transactions
Loans and advances to banks
10,777
5,251
Loans and advances to customers
3,471
499
Trading assets, loans and receivables
12,033
12,121
Loans and receivables mandatorily measured at fair value through profit or loss
53,393
51,536
79,675
69,407
Repurchase transactions
Deposits from banks
33
2,064
Customer deposits
1
97
Trading liabilities, funds on deposit
5,269
10,337
Funds entrusted designated and measured at fair value through profit or loss
38,420
45,729
43,723
58,227
Trading assets
Trading assets by type
in EUR million
2024
2023
Equity securities
20,726
15,423
Debt securities
10,080
6,907
Derivatives
29,805
25,680
Loans and receivables
12,295
12,231
72,906
60,240
Trading assets include assets that are closely related to servicing the needs of the clients of ING Bank. ING
offers institutional clients, corporate clients, and governments products that are traded on the financial
markets. A significant part of the derivatives in the trading portfolio is related to servicing corporate clients in
their risk management to hedge, for example, currency or interest rate exposures. In addition, ING provides
its customers access to equity and debt markets for issuing their own equity or debt securities (securities
underwriting).
Reference is made to Note 14 'Financial liabilities at fair value through profit or loss' for information on
trading liabilities.
Non-trading derivatives
Non-trading derivatives by type
in EUR million
2024
2023
Derivatives used in
-\u00a0 fair value hedges
617
716
-\u00a0 cash flow hedges
158
440
-\u00a0 hedges of net investments in foreign operations
82
100
Other non-trading derivatives
1,606
771
2,463
2,028
Reference is made to Note 33 'Derivatives and hedge accounting' for information on derivatives designated
in hedge accounting.
Other non-trading derivatives mainly includes interest rate swaps, foreign exchange swaps, and cross
currency swaps for which no hedge accounting is applied.
Designated at fair value through profit or loss
Designated at fair value through profit or loss by type
in EUR million
2024
2023
Debt securities
4,718
4,470
Loans and receivables
1,022
1,306
5,740
5,775
\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 5,740 million (2023: EUR 5,775 million). In 2024, the
change in fair value of these loans and debt securities amounts EUR 5 million (2023: EUR -48\u00a0million).\u00a0 \u00a0
ING has mitigated the credit risk exposure on part of the portfolio. The cost at initial recognition of the
financial assets designated at fair value through profit or loss that are economically hedged by credit
derivatives is EUR 3,797 million (31 December 2023: EUR 3,181 million) and the cumulative change in fair
value attributable to changes in credit risk is EUR 173 million (31 December 2023: EUR 150 million).
The notional value of the related credit derivatives is EUR 3,807 million (2023: EUR 3,679 million). The
cumulative change in fair value of the credit derivatives since the financial assets were first designated,
amounts to EUR -214\u00a0million (2023: EUR -119\u00a0million) and the change for the current year is EUR -95\u00a0million
( 2023: EUR -122\u00a0million).
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
2024
2023
Equity securities
228
179
Debt securities
789
894
Loans and receivables
55,464
53,911
56,481
54,983
Equity securities are individually insignificant for ING Bank . For total exposure to debt securities, reference is
made to Note 6 'Debt securities' . 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
2024
2023
Trading liabilities
35,255
37,220
Non-trading derivatives
2,101
2,019
Designated at fair value through profit or loss
49,539
55,399
86,896
94,637
Trading liabilities
Trading liabilities by type
in EUR million
2024
2023
Equity securities
467
1,156
Debt securities
3,185
2,492
Funds on deposit
5,437
10,443
Derivatives
26,166
23,129
35,255
37,220
Non-trading derivatives
Non-trading derivatives by type
in EUR million
2024
2023
Derivatives used in:
-\u00a0 fair value hedges
79
113
-\u00a0 cash flow hedges
573
458
-\u00a0 hedges of net investments in foreign operations
117
92
Other non-trading derivatives
1,332
1,356
2,101
2,019
Reference is made to Note 33 'Derivatives and hedge accounting' for information on derivatives used for
hedge accounting.
Other non-trading derivatives mainly include interest-rate swaps, foreign-exchange swaps and cross-
currency swaps for which no hedge accounting is applied.
Designated at fair value through profit or loss
Designated at fair value through profit or loss by type
in EUR million
2024
2023
Debt securities
9,326
8,219
Funds entrusted
40,092
47,085
Subordinated liabilities
122
95
49,539
55,399
As at 31\u00a0December 2024 , 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 17 million on a cumulative basis ( 2023: EUR\u00a0 -34
million). This change has been determined as the amount of change in fair value of the financial liability that
is not attributable to changes in market conditions that gave rise to market risk (i.e. mainly interest-rate risk
based on yield curves).
The amount that ING 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 11,376 million (2023: EUR\u00a09,958 million).
Funds entrusted include mainly repurchase agreements. For more information on repurchase transactions
refer to Note 4 'Financial assets at fair value through profit or loss'.
", "dimensions": { "concept": "ifrs-full:DisclosureOfFinancialInstrumentsAtFairValueThroughProfitOrLossExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-684": { "value": "
(Reverse) repurchase transactions
Financial assets at fair value through profit or loss include securities lending and sales and repurchase
transactions with securities. At ING, these types of transactions are recognised in several lines in the
statement of financial position depending on business model assessment and counterparty. Furthermore,
for repurchase agreements the gross amount of assets must be considered together with the gross amount
of related liabilities, which are presented separately on the statement of financial position since IFRS does
not always allow the netting of these positions in the statement of financial position. Netting is applicable to
repurchase agreements that are governed by an established Global Master Repurchase Agreement (GMRA).
This netting is restricted to transactions involving the same currency and maturity date, and must occur
within the same legal entity. Reference is made to Note 37 'Offsetting financial assets and liabilities'.
Securities purchased under agreements to resell (reverse repos), securities borrowings and similar
agreements are not recognised in the consolidated statement of financial position as the counterparty
continues to be exposed to substantially all risks and rewards of the transferred security. Based on the
business model assessment and counterparty, the consideration paid to purchase securities is recognised as
Loans and advances to customers, Loans and advances to banks, financial assets mandatorily at FVPL or
Trading assets.
Securities sold subject to repurchase agreements (repos), securities lending and similar agreements continue
to be recognised in the consolidated statement of financial position as ING Bank continues to be exposed to
substantially all risks and rewards of the transferred financial asset. The counterparty liability is designated
and measured at FVPL if the asset is measured mandatorily at FVPL. Otherwise, the counterparty liability is
included in Deposits from banks, Customer deposits or Trading.
Reference is made to Note 36 'Transfer of financial assets, assets pledged and received as collateral' for
information on transferred assets which were not derecognised.
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
2024
2023
Reverse repurchase transactions
Loans and advances to banks
10,777
5,251
Loans and advances to customers
3,471
499
Trading assets, loans and receivables
12,033
12,121
Loans and receivables mandatorily measured at fair value through profit or loss
53,393
51,536
79,675
69,407
Repurchase transactions
Deposits from banks
33
2,064
Customer deposits
1
97
Trading liabilities, funds on deposit
5,269
10,337
Funds entrusted designated and measured at fair value through profit or loss
38,420
45,729
43,723
58,227
", "dimensions": { "concept": "ifrs-full:DisclosureOfRepurchaseAndReverseRepurchaseAgreementsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-686": { "value": "
Trading assets
Trading assets by type
in EUR million
2024
2023
Equity securities
20,726
15,423
Debt securities
10,080
6,907
Derivatives
29,805
25,680
Loans and receivables
12,295
12,231
72,906
60,240
Trading assets include assets that are closely related to servicing the needs of the clients of ING Bank. ING
offers institutional clients, corporate clients, and governments products that are traded on the financial
markets. A significant part of the derivatives in the trading portfolio is related to servicing corporate clients in
their risk management to hedge, for example, currency or interest rate exposures. In addition, ING provides
its customers access to equity and debt markets for issuing their own equity or debt securities (securities
underwriting).
Reference is made to Note 14 'Financial liabilities at fair value through profit or loss' for information on
trading liabilities.
Trading liabilities
Trading liabilities by type
in EUR million
2024
2023
Equity securities
467
1,156
Debt securities
3,185
2,492
Funds on deposit
5,437
10,443
Derivatives
26,166
23,129
35,255
37,220
", "dimensions": { "concept": "ifrs-full:DisclosureOfFinancialInstrumentsHeldForTradingExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-685": { "value": "
Trading assets
Trading assets by type
in EUR million
2024
2023
Equity securities
20,726
15,423
Debt securities
10,080
6,907
Derivatives
29,805
25,680
Loans and receivables
12,295
12,231
72,906
60,240
Trading assets include assets that are closely related to servicing the needs of the clients of ING Bank. ING
offers institutional clients, corporate clients, and governments products that are traded on the financial
markets. A significant part of the derivatives in the trading portfolio is related to servicing corporate clients in
their risk management to hedge, for example, currency or interest rate exposures. In addition, ING provides
its customers access to equity and debt markets for issuing their own equity or debt securities (securities
underwriting).
Reference is made to Note 14 'Financial liabilities at fair value through profit or loss' for information on
trading liabilities.
", "dimensions": { "concept": "ifrs-full:DisclosureOfFinancialAssetsHeldForTradingExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-687": { "value": "
Non-trading derivatives
Non-trading derivatives by type
in EUR million
2024
2023
Derivatives used in
-\u00a0 fair value hedges
617
716
-\u00a0 cash flow hedges
158
440
-\u00a0 hedges of net investments in foreign operations
82
100
Other non-trading derivatives
1,606
771
2,463
2,028
Reference is made to Note 33 'Derivatives and hedge accounting' for information on derivatives designated
in hedge accounting.
Other non-trading derivatives mainly includes interest rate swaps, foreign exchange swaps, and cross
currency swaps for which no hedge accounting is applied.
Non-trading derivatives
Non-trading derivatives by type
in EUR million
2024
2023
Derivatives used in:
-\u00a0 fair value hedges
79
113
-\u00a0 cash flow hedges
573
458
-\u00a0 hedges of net investments in foreign operations
117
92
Other non-trading derivatives
1,332
1,356
2,101
2,019
Reference is made to Note 33 'Derivatives and hedge accounting' for information on derivatives used for
hedge accounting.
Other non-trading derivatives mainly include interest-rate swaps, foreign-exchange swaps and cross-
currency swaps for which no hedge accounting is applied.
33\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 arise
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 1.5 \u2018Financial instruments\u2019 of Note 1 \u2018Basis of preparation and
material accounting policy information\u2019.
The benchmark rate reform
Reference is made to note 'Risk management / The impact of the benchmark rate reform' for information on
how ING is managing the transition to alternative benchmark rates and ING\u2019s progress in completing the
transition with respect to derivatives in hedge accounting relationships.
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
managing 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, because
the fair value of a fixed-rate instrument varies directly in response to changes in its benchmark interest rate.
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 values 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
2024
Liabilities
2024
Assets
2023
Liabilities
2023
As at 31 December
Hedging instrument on interest rate risk
\u2013 Interest rate swaps
26,963
24,107
32,612
27,350
\u2013 Other interest derivatives
207
23
284
34
Hedging instrument on FX rate risk
\u2013 Cross currency swaps
12
3
The derivatives used for fair value 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 for EUR 617 million (2023:
EUR 716 million) respectively \u2018Financial liabilities at fair value through profit or loss \u2013 Non-trading derivatives\u2019
EUR 79 million (2023: EUR 113 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 our main currencies the average fixed rate for interest rate swaps used in fair value hedge accounting
are 1.69% (2023: 1.32%) for EUR and 4.22% (2023: 3.93%) for USD.
The following table shows the net notional amount of derivatives designated in fair value 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 fair value hedging
in EUR million
As at 31 December 2024
Less
than 1
month
1 to 3
months
3 to 12
months
1 to 2
years
2 to 3
years
3 to 4
years
4 to 5
years
>5 years
Total
Hedging instrument on
interest rate risk
\u2013 Interest rate swaps
43
1,224
4,308
15,305
2,179
4,580
3,259
-51,039
-20,140
\u2013 Other interest derivatives
-4
29
182
248
91
-193
121
383
858
Hedging instrument on FX
rate risk
\u2013 Cross currency swaps
-142
-60
-98
-299
As at 31 December 2023
Hedging instrument on
interest rate risk
- Interest rate swaps
-670
253
8,381
4,156
3,193
-800
7,559
-58,679
-36,609
\u2013 Other interest derivatives
25
190
116
302
250
-144
974
1,712
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 of
the hedged item for
measuring
ineffectiveness for the
period
Change in fair value
hedging instruments for
the period
Hedge ineffectiveness
recognised in the
statement of profit or
loss gain (+) / loss (-)
in EUR million
Assets
Liabilities
Assets
Liabilities
As at 31 December 2024
Interest rate risk and FX rate risk
\u2013 Debt securities at fair value through other comprehensive
income
35,119
n/a
269
\u2013 Loans at FVOCI
n/a
1
\u2013 Loans and advances to customers
73,364
-5,177
1,771
\u2013 Debt instruments at amortised cost
13,802
-179
49
\u2013 Debt securities in issue
38,246
-915
-594
\u2013 Senior non-preferred debt
45,423
-1,320
-544
\u2013 Subordinated loans
17,143
-665
-188
\u2013 Customer deposits and other funds on deposit
29
-1
-14
\u2013 Discontinued hedges
1,851
-5
Total
122,285
100,842
-3,505
-2,906
750
-766
-17
As at 31 December 2023
Interest rate risk and FX rate risk
\u2013 Debt securities at fair value through other comprehensive
income
31,224
n/a
1,224
\u2013 Loans at FVOCI
5
n/a
1
\u2013 Loans and advances to customers
78,787
-7,104
4,705
\u2013 Debt instruments at amortised cost
8,272
-205
234
\u2013 Debt securities in issue
32,432
-1,511
-1,279
\u2013 Senior non-preferred debt 1
37,850
-1,872
-1,402
\u2013 Subordinated loans
14,646
-834
-473
\u2013 Customer deposits and other funds on deposit 1
1,527
-17
-49
\u2013 Discontinued hedges
2,285
3
Total
118,287
86,455
-5,024
-4,230
2,962
-3,028
-66
1 ING changed the presentation for the senior non-preferred debt and the comparative figure for 2023 has been adjusted.
During 2024, the interest rate movements significantly affected the fair value changes of both the
derivatives and the hedged items designated in fair value hedges. However, no material hedging relationship
was discontinued as a result of the interest rate movements in 2024. Refer to Note 23 'Valuation results and
net trading income'.
In addition, the net decrease in hedged items is mainly due to higher volumes in debt securities in issue
designated in hedge accounting. Discontinued hedges 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:
\u2022 differences in maturities of the hedged item(s) and hedging instrument(s);
\u2022 different interest rate curves applied to discount the hedged item(s) and hedging instrument(s);
\u2022 differences 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 a 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 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 the 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
2024
2024
2023
2023
As at 31\u00a0December
Hedging instrument on interest rate risk
\u2013 Interest rate swaps
10,635
12,814
11,839
14,051
Hedging instrument on FX rate risk
\u2013 Cross currency swaps
472
339
324
39
Hedging instrument on combined interest and FX rate risk
\u2013 Cross currency interest rate swaps
10
57
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 158 million (2023: EUR
440 million) respectively \u2018Financial liabilities at fair value through profit or loss \u2013 Non-trading derivatives\u2019 EUR
573 million (2023: EUR 458 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 1.79% (2023: 1.26%) for EUR, 4.37% (2023: 4.09%) for PLN, 3.99% (2023: 4.33%) for USD and 3.29%
(2023: 2.80%) for AUD. The average currency exchange rates for cross currency swaps used in cash flow
hedge accounting is for EUR/USD 1.03 (2023: 0.98) and for EUR/AUD 1.52 (2023: 1.58).
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 2024
Less
than 1
month
1 to 3
months
3 to 12
months
1 to 2
years
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
-1,805
-768
-10,590
-13,389
-10,551
-6,040
-4,522
-3,222
-50,886
Hedging instrument on FX rate
risk
\u2013 Cross currency swaps
-241
-972
122
-1,029
-262
-238
-999
-3,619
Hedging instrument on combined
interest and FX rate risk
\u2013 Cross currency interest rate
swaps
-25
-1,283
-1,578
-2,887
As at 31 December 2023
Hedging instrument on interest
rate risk
\u2013 Interest rate swaps
-214
184
-8,557
-18,551
-6,636
-7,246
-4,896
-3,384
-49,300
Hedging instrument on FX rate
risk
\u2013 Cross currency swaps
249
1,029
-932
503
-683
167
-693
-362
Hedging instrument on combined
interest and FX rate risk
\u2013 Cross currency interest rate
swaps
-24
-1,232
-1,479
-2,736
The following table shows the cash flow hedge accounting impact on profit or loss and comprehensive income:
Cash flow hedging \u2013 impact of hedging instruments on the statement of profit or loss and other comprehensive
income
in EUR million
Change in
value of
hedged item
used for
calculating
hedge
ineffectivenes
s for the
period
Carrying
amount cash
flow hedge
reserve at the
end of the
reporting
period1
Amount
reclassified
from CFH
reserve to
profit or loss 2
Change in
value of
hedging
instrument
recognised in
OCI for the
period
Hedge
ineffectivenes
s recognised
in the
statement of
profit or loss,
gain (+) / loss
(-)
As at 31 December 2024
Interest rate risk on:
\u2013 Floating rate lending
-668
-2,850
496
\u2013 Floating rate borrowing
114
125
-425
\u2013 Other
1
1
\u2013 Discontinued hedges
89
-51
Total interest rate risk
-553
-2,635
20
526
39
FX rate risk on:
\u2013 Floating rate lending
-79
-55
-121
\u2013 Floating rate borrowing
12
5
-37
\u2013 Other
\u2013 Discontinued hedges
-4
Total FX risk
-67
-51
-162
220
-3
Combined interest and FX rate risk on:
\u2013 Floating rate lending
70
72
-68
\u2013 Floating rate borrowing
\u2013 Other
\u2013 Discontinued hedges
Total combined interest and FX risk
70
72
-68
-3
-2
Total cash flow hedge
-550
-2,614
-209
743
35
Cash flow hedging \u2013 impact of hedging instruments on the statement of profit or loss and other comprehensive
income
in EUR million
Change in
value of
hedged item
used for
calculating
hedge
ineffectivenes
s for the
period
Carrying
amount cash
flow hedge
reserve at the
end of the
reporting
period1
Amount
reclassified
from CFH
reserve to
profit or loss 2
Change in
value of
hedging
instrument
recognised in
OCI for the
period
Hedge
ineffectivenes
s recognised
in the
statement of
profit or loss,
gain (+) / loss
(-)
As at 31 December 2023
Interest rate risk on:
\u2013 Floating rate lending
-2,694
-3,545
590
\u2013 Floating rate borrowing
933
151
-497
\u2013 Other
\u2013 Discontinued hedges
194
-150
Total interest rate risk
-1,760
-3,200
-57
1,654
58
FX rate risk on:
\u2013 Floating rate lending
27
-42
-185
\u2013 Floating rate borrowing
-25
1
-33
\u2013 Other
\u2013 Discontinued hedges
7
-5
Total FX risk
2
-35
-223
200
-12
Combined interest and FX rate risk on:
\u2013 Floating rate lending
-20
78
-46
\u2013 Floating rate borrowing
1
\u2013 Other
\u2013 Discontinued hedges
-1
Total combined interest and FX risk
-20
78
-46
68
2
Total cash flow hedge
-1,778
-3,157
-325
1,922
48
1 The carrying amount is the gross amount, excluding tax adjustments.
2 The amounts are reclassified to Net interest income - interest income and/or expense on non-trading derivatives (hedge accounting).
In 2024 and 2023 there are no amounts reclassified from CFH reserve to profit or loss for cash flows that are
no longer expected to occur.
The increase in the carrying amount of the cash flow hedge reserve is driven by the interest rate
movements. No material hedging relationship was discontinued as a result of the interest rate movements
in 2024.
The main sources of ineffectiveness for cash flow hedges are:
\u2022 differences in timing of cash flows of the hedged item(s) and hedging instrument(s);
\u2022 mismatches in reset frequency between hedged item and hedging instrument.
The following table shows the movement of the cash flow hedge reserve:
Movement cash flow hedge reserve
in EUR million
2024
2023
Opening balance
-2,058
-3,055
Value changes recognised in OCI
743
1,922
Amounts recycled to profit or loss
-209
-325
Income tax
-140
-381
Exchange rate and other changes
-14
-103
Adjustment for non controlling interest
-14
-116
Movement for the year
365
997
Ending balance
-1,693
-2,058
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 these
are 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
2024
2024
2023
2023
As at 31 December
\u2013 FX forwards and Cross currency swaps
82
117
100
92
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 82 million (2023:
EUR 100 million) respectively \u2018Financial liabilities at fair value through profit or loss \u2013 Non trading derivatives\u2019
EUR 117 million (2023: EUR 92 million).
For ING\u2019s main currencies the average exchange rates used in net investment hedge accounting for 2024 are EUR/
USD 1.08 (2023: 1.08), EUR/PLN 4.31 (2023: 4.54), EUR/AUD 1.64 (2023: 1.63) and EUR/THB 38.00 (2023: 37.65).
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 2024
Less than
1 month
1 to 3
months
3 to 12
months
1 to 2
years
2 to 3
years
3 to\u00a0 4
years
4 to 5
years
>5 years
Total
\u2013 FX forwards and
cross currency
swaps
-8,681
-4,158
-76
-12,916
As at 31
December 2023
\u2013 FX forwards and
Cross currency
swaps
-6,009
-4,576
-87
-10,672
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 2024
Change in
value of
hedged item
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
295
-95
-295
0
Discontinued hedges
302
As at 31 December 2023
Investment in foreign operations
-183
123
183
Discontinued hedges
263
1The carrying amount is the gross amount, excluding tax adjustments.
", "dimensions": { "concept": "ifrs-full:DisclosureOfDerivativeFinancialInstrumentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-688": { "value": "
Designated at fair value through profit or loss
Designated at fair value through profit or loss by type
in EUR million
2024
2023
Debt securities
4,718
4,470
Loans and receivables
1,022
1,306
5,740
5,775
\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 5,740 million (2023: EUR 5,775 million). In 2024, the
change in fair value of these loans and debt securities amounts EUR 5 million (2023: EUR -48\u00a0million).\u00a0 \u00a0
ING has mitigated the credit risk exposure on part of the portfolio. The cost at initial recognition of the
financial assets designated at fair value through profit or loss that are economically hedged by credit
derivatives is EUR 3,797 million (31 December 2023: EUR 3,181 million) and the cumulative change in fair
value attributable to changes in credit risk is EUR 173 million (31 December 2023: EUR 150 million).
The notional value of the related credit derivatives is EUR 3,807 million (2023: EUR 3,679 million). The
cumulative change in fair value of the credit derivatives since the financial assets were first designated,
amounts to EUR -214\u00a0million (2023: EUR -119\u00a0million) and the change for the current year is EUR -95\u00a0million
( 2023: EUR -122\u00a0million).
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
2024
2023
Debt securities
9,326
8,219
Funds entrusted
40,092
47,085
Subordinated liabilities
122
95
49,539
55,399
As at 31\u00a0December 2024 , 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 17 million on a cumulative basis ( 2023: EUR\u00a0 -34
million). This change has been determined as the amount of change in fair value of the financial liability that
is not attributable to changes in market conditions that gave rise to market risk (i.e. mainly interest-rate risk
based on yield curves).
The amount that ING 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 11,376 million (2023: EUR\u00a09,958 million).
Funds entrusted include mainly repurchase agreements. For more information on repurchase transactions
refer to Note 4 'Financial assets at fair value through profit or loss'.
", "dimensions": { "concept": "ifrs-full:DisclosureOfFinancialInstrumentsDesignatedAtFairValueThroughProfitOrLossExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-689": { "value": "
6\u00a0 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
2024
2023
Debt securities at fair value through other comprehensive income
42,219
38,281
Debt securities at amortised cost
50,273
48,313
Debt securities at fair value through other comprehensive income and amortised cost
92,493
86,594
Trading assets
10,080
6,907
Debt securities designated and measured at fair value through profit or loss
4,718
4,470
Debt securities mandatorily measured at fair value through profit or loss
789
894
Total debt securities at fair value through profit or loss
15,586
12,270
108,078
98,864
ING Bank\u2019s total exposure to debt securities (excluding debt securities held in the trading portfolio) of EUR
97,999 million (31\u00a0December 2023: EUR 91,957 million) is specified as follows:
Debt securities by type of exposure
Debt Securities at
FVPL 1
Debt Securities at
FVOCI
Debt Securities at
AC
Total
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
Government bonds
289
362
24,757
20,988
22,734
24,050
47,780
45,400
Central bank bonds
444
446
2,900
2,043
3,344
2,489
Sub-sovereign, Supranationals
and Agencies
1,027
1,354
11,513
11,587
15,445
14,639
27,985
27,580
Covered bonds
4,108
4,084
5,683
5,231
9,791
9,315
Corporate bonds
848
799
79
127
106
109
1,033
1,035
Financial institutions' bonds
2,141
1,645
980
483
139
186
3,261
2,314
ABS portfolio
757
758
794
1,025
3,281
2,077
4,832
3,860
5,506
5,363
42,231
38,293
50,288
48,335
98,026
91,991
Loan loss provisions
-12
-13
-15
-22
-27
-34
Debt securities portfolio
5,506
5,363
42,219
38,281
50,273
48,313
97,999
91,957
1 Debt securities at FVPL includes both debt securities designated - and mandatorily measured at fair value through profit or loss.
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
2024
2023
Fixed rate debt securities
Within 1 year
26,358
29,790
More than 1 year but less than 2 years
5,718
4,660
More than 2 years but less than 3 years
4,429
6,279
More than 3 years but less than 4 years
5,907
4,068
More than 4 years but less than 5 years
6,105
4,722
More than 5 years
12,335
13,139
Total fixed rate debt securities
60,851
62,658
Floating rate debt securities
Within 1 year
26,262
17,871
More than 1 year but less than 2 years
2,343
226
More than 2 years but less than 3 years
1,080
2,176
More than 3 years but less than 4 years
117
75
More than 4 years but less than 5 years
902
0
More than 5 years
2,903
1,417
Total floating rate debt securities
33,607
21,765
Total debt securities
94,459
84,423
Reference is made to the consolidated statement of cash flows for further information on issuances,
redemptions and non-cash movements.
18\u00a0 Senior non-preferred debt
Senior non-preferred debt
In EUR million
2024
2023
Senior non-preferred debt
49,393
40,213
49,393
40,213
Senior non-preferred debt is lent on by ING Groep N.V. to ING Bank N.V. In the event of bankruptcy, such
senior non-preferred debt ranks senior to subordinated liabilities but junior to any other liabilities of ING Bank
N.V.", "dimensions": { "concept": "ifrs-full:DisclosureOfDebtSecuritiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-690": { "value": "
7\u00a0 Loans and advances to customers
Loans and advances to customers by type
Netherlands
Rest of the world
Total
in EUR million
2024
2023
2024
2023
2024
2023
Loans and advances to public authorities
1,888
1,070
16,773
13,314
18,661
14,384
Residential mortgages
117,223
110,475
227,992
214,120
345,216
324,596
Other personal lending
5,007
5,036
31,789
31,535
36,797
36,571
Corporate Lending
66,987
62,728
218,473
209,795
285,459
272,523
191,105
179,309
495,027
468,764
686,132
648,074
Loan loss provisions
-811
-830
-5,023
-4,791
-5,833
-5,621
190,295
178,480
490,004
463,973
680,299
642,453
For details on credit quality and loan loss provisioning, refer to \u2018Risk management \u2013 Credit risk\u2019 \u2013 paragraphs
\u2018Credit quality\u2019 and 'Loan loss provisioning'.
As at 31\u00a0December 2024 EUR 680,085 million ( 2023: EUR 642,260 million) of loans and advances to
customers are non-subordinated.
Loans and advances to customers and, to a lesser extent, to banks include finance lease receivables which
are detailed as follows:
Finance lease receivables 1
in EUR million
2024
2023
Maturities of gross investment in finance lease receivables
-\u00a0 within 1 year
3,962
3,827
-\u00a0 between 1-2 years
2,961
2,742
-\u00a0 between 2-3 years
2,283
2,133
-\u00a0 between 3-4 years
1,577
1,475
-\u00a0 between 4-5 years
902
875
-\u00a0 more than 5 years
1,555
1,451
13,240
12,503
Unearned future finance income on finance leases
-1,145
-1,040
Net investment in finance leases
12,095
11,463
Included in Loans and advances to banks
5
5
Included in Loans and advances to customers
12,091
11,459
12,095
11,463
1 The total loan loss provision for finance lease receivables is EUR 193 million (2023: EUR\u00a0160 million).
The finance lease receivables mainly relate to the financing of equipment and real estate for third parties
where ING is the lessor and are mainly part of corporate lending. Interest income in 2024 on finance lease
receivables amounts to EUR 522 million (2023: EUR 429 million).
", "dimensions": { "concept": "ifrs-full:DisclosureOfLoansAndAdvancesToCustomersExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-691": { "value": "
Finance lease receivables 1
in EUR million
2024
2023
Maturities of gross investment in finance lease receivables
-\u00a0 within 1 year
3,962
3,827
-\u00a0 between 1-2 years
2,961
2,742
-\u00a0 between 2-3 years
2,283
2,133
-\u00a0 between 3-4 years
1,577
1,475
-\u00a0 between 4-5 years
902
875
-\u00a0 more than 5 years
1,555
1,451
13,240
12,503
Unearned future finance income on finance leases
-1,145
-1,040
Net investment in finance leases
12,095
11,463
Included in Loans and advances to banks
5
5
Included in Loans and advances to customers
12,091
11,459
12,095
11,463
1 The total loan loss provision for finance lease receivables is EUR 193 million (2023: EUR\u00a0160 million).
The finance lease receivables mainly relate to the financing of equipment and real estate for third parties
where ING is the lessor and are mainly part of corporate lending. Interest income in 2024 on finance lease
receivables amounts to EUR 522 million (2023: EUR 429 million).
9\u00a0 Property and equipment
Property and equipment by type
in EUR million
2024
2023
Property in own use
758
616
Equipment:
- Data processing equipment
218
213
- Other equipment
426
492
Right- of- use assets:
- ROU property
895
972
- ROU cars
124
97
- ROU other leases
13
9
2,434
2,399
Changes in property and equipment
Property in own use
Equipment
Right-of-use assets
Total
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
Opening balance as at 1 January
616
681
705
689
1,078
1,076
2,399
2,446
Additions
92
4
240
241
141
279
473
525
Transfers
83
-1
-78
-4
-4
-4
1
-9
Depreciation
-11
-12
-204
-204
-242
-246
-457
-461
Impairments1
-9
-19
-10
-10
-4
-12
-23
-41
Reversals of impairments 1
5
10
5
10
Remeasurements
5
4
75
9
80
13
Disposals
-36
-47
-14
-10
-18
-20
-68
-78
Exchange rate differences
13
-4
5
4
8
-4
25
-5
Closing balance
758
616
643
705
1,033
1,078
2,434
2,399
Cost price
871
753
3,027
3,140
1,933
1,851
5,831
5,744
Accumulated depreciation
-298
-305
-2,376
-2,430
-1,098
-904
-3,772
-3,639
Accumulated impairments
-97
-99
-8
-6
-31
-32
-136
-136
Accumulated revaluation surplus
282
267
282
267
Accumulated remeasurement
229
163
229
163
Net carrying value
758
616
643
705
1,033
1,078
2,434
2,399
1 Impairments and reversals of impairments of property and equipment are presented as Other operating expenses in the statement of
Profit or Loss.
ING considers valuations from third-party experts in determining the fair values of property in own use. The
vast majority of the land and buildings were appraised during 2024. Property in own use purchase costs
amounted to EUR 871 million (2023: EUR\u00a0753 million). Cost or the purchase price less accumulated
depreciation and impairments would have been EUR 476 million ( 2023: EUR 350 million) had property in own
use been valued at cost instead of at fair value.
The reported impairment losses of EUR -23 million ( 2023: EUR -41 million) mainly result from the closure of
branches and unfavourable office market developments.
16\u00a0 Other liabilities
Other liabilities by type
In EUR million
2024
2023
Net defined benefit liability
152
164
Other post-employment benefits
38
30
Other staff-related liabilities
784
719
Other taxation and social security contributions
899
641
Rents received in advance
14
14
Costs payable
1,763
2,170
Amounts to be settled
4,290
6,509
Lease liabilities
1,116
1,162
Other
1,538
1,721
10,596
13,130
Disclosures in respect of Net defined benefit liabilities are provided in Note 30 'Pensions and other post-
employment benefits'.
Other staff-related liabilities includes vacation leave provisions, jubilee provisions, disability/illness provisions
and liabilities related with variable compensations.
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 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 2024 was EUR 290\u00a0million (2023: EUR
291\u00a0million).
The line Other relates mainly to amounts payable to customers.
", "dimensions": { "concept": "ifrs-full:DisclosureOfLeasesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-693": { "value": "
8\u00a0 Investment in associates and joint ventures
Investments in associates and joint ventures
in EUR million
2024
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%
1,164
1,266
49,147
42,554
1,474
1,050
Other investments in associates and
joint ventures
412
1,679
Investments in associates and joint ventures
in EUR million
2023
Interest
held (%)
Fair value of
listed invest-
ments
Balance
sheet\u00a0
value
Total
assets
Total
liabilities
Total
income
Total
expenses
TMBThanachart Bank Public
Company Limited
23%
976
1,128
46,666
40,776
1,386
943
Other investments in associates
and joint ventures
381
1,509
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's shareholding and representation on the Board. TTB is part of the Corporate Line segment.
Other investments in associates and joint ventures
Included in Other investments in associates and joint ventures are mainly financial services and (non-)
financial technology funds or vehicles operating predominantly in Europe, and are individually not significant
to ING 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, the rating agency and
regulatory views, which can change over time.
Changes in Investments in associates and joint ventures
in EUR million
2024
2023
Opening balance as at 1 January
1,509
1,500
Additions
26
55
Transfers
-7
0
Revaluations
0
4
Share of results
205
149
Dividends received
-91
-74
Disposals
-16
-89
Impairments
-35
-5
Exchange rate differences
87
-32
Other
0
Closing balance
1,679
1,509
Share of results from associates and joint ventures of EUR 205 million (2023: EUR 149 million) as included in
the table above is mainly attributable to our share in the results of TTB of EUR 123\u00a0million (2023: EUR 107
million) and our share in the result of an associate in Belgium of EUR 77 million following a one-off profit.
The total impairment losses of EUR 35 million relate to associates that are not individually significant.
Impairments and reversal thereof on the investment in TTB
Accumulated impairments on the investment in TTB of EUR 395\u00a0million (2023: EUR 395\u00a0million) were
recognised in previous years. There is no impairment trigger observed as per 31 December 2024. A Value in
Use ('VIU') was estimated following the prolonged increase of the quoted TTB share price over the original
cost price of the investment and the sustained improved broker consensus outlook. As VIU did not exceed
the carrying amount of the investment in TTB no reversal of impairment, was recognised.
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and VIU. Fair
value less costs of disposal is based on observable share price. The VIU calculation uses discounted cash flow
projections based on management\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:
\u2022 The estimation of future earnings over a 5-year forecast period; and
\u2022 the terminal value being the extrapolation of earnings into perpetuity applying a long-term growth rate.
The earnings that are used for extrapolation represent the stable long-term financial results and position
of TTB, i.e. a steady state. The terminal value comprises the majority of the total VIU.
Key assumptions used in the VIU calculation as at 31 December 2024
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:
\u2022 Expected future earnings of TTB: Short- to medium-term expectations are based on forecasts derived
from broker consensus. Longer-term and steady-state expectations into perpetuity are derived using
reasonable and supportable assumptions capturing a combination of TTB specific and market data points;
A capital maintenance charge is applied, which is management\u2019s forecast of the earnings that need to be
withheld in order for TTB to meet target regulatory requirements over the forecast period;
\u2022 Discount rate (cost of equity): 10.96%, based on the capital asset pricing model (CAPM) calculated for TTB
using current market data; and
\u2022 Terminal growth rate: 2.74% consistent with current long term government bond yield in Thailand as a
proxy for a risk-free rate.
The model was evaluated for reasonably possible changes to key assumptions in the model. This reflects the
sensitivity of the VIU to each key assumption on its own and it is possible that more than one favourable
and/or unfavourable change may occur at the same time. The selected rates of reasonably possible changes
to key assumptions are based on external analysts\u2019 forecasts and other relevant external data sources,
which can change period to period. The sensitivity of the VIU to each key assumption is as follows:
\u2022 A favourable change of 10% in the cash flows would result in an increase in VIU of EUR 57 million, while
an unfavourable change of -10% would result in a decrease in VIU of EUR -59 million;\u00a0
\u2022 A favourable change of -1% in the discount rate would result in an increase in VIU of EUR 95 million, while
an unfavourable change of 1% would result in a decrease in VIU of EUR -75 million;
\u2022 A favourable change of 1% in the terminal growth rate would result in an increase in VIU of EUR 68
million, while an unfavourable change of -1% would result in a decrease in VIU of EUR -53 million;", "dimensions": { "concept": "ifrs-full:DisclosureOfInvestmentsAccountedForUsingEquityMethodExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-692": { "value": "
8\u00a0 Investment in associates and joint ventures
Investments in associates and joint ventures
in EUR million
2024
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%
1,164
1,266
49,147
42,554
1,474
1,050
Other investments in associates and
joint ventures
412
1,679
Investments in associates and joint ventures
in EUR million
2023
Interest
held (%)
Fair value of
listed invest-
ments
Balance
sheet\u00a0
value
Total
assets
Total
liabilities
Total
income
Total
expenses
TMBThanachart Bank Public
Company Limited
23%
976
1,128
46,666
40,776
1,386
943
Other investments in associates
and joint ventures
381
1,509
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's shareholding and representation on the Board. TTB is part of the Corporate Line segment.
Other investments in associates and joint ventures
Included in Other investments in associates and joint ventures are mainly financial services and (non-)
financial technology funds or vehicles operating predominantly in Europe, and are individually not significant
to ING 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, the rating agency and
regulatory views, which can change over time.
Changes in Investments in associates and joint ventures
in EUR million
2024
2023
Opening balance as at 1 January
1,509
1,500
Additions
26
55
Transfers
-7
0
Revaluations
0
4
Share of results
205
149
Dividends received
-91
-74
Disposals
-16
-89
Impairments
-35
-5
Exchange rate differences
87
-32
Other
0
Closing balance
1,679
1,509
Share of results from associates and joint ventures of EUR 205 million (2023: EUR 149 million) as included in
the table above is mainly attributable to our share in the results of TTB of EUR 123\u00a0million (2023: EUR 107
million) and our share in the result of an associate in Belgium of EUR 77 million following a one-off profit.
The total impairment losses of EUR 35 million relate to associates that are not individually significant.
Impairments and reversal thereof on the investment in TTB
Accumulated impairments on the investment in TTB of EUR 395\u00a0million (2023: EUR 395\u00a0million) were
recognised in previous years. There is no impairment trigger observed as per 31 December 2024. A Value in
Use ('VIU') was estimated following the prolonged increase of the quoted TTB share price over the original
cost price of the investment and the sustained improved broker consensus outlook. As VIU did not exceed
the carrying amount of the investment in TTB no reversal of impairment, was recognised.
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and VIU. Fair
value less costs of disposal is based on observable share price. The VIU calculation uses discounted cash flow
projections based on management\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:
\u2022 The estimation of future earnings over a 5-year forecast period; and
\u2022 the terminal value being the extrapolation of earnings into perpetuity applying a long-term growth rate.
The earnings that are used for extrapolation represent the stable long-term financial results and position
of TTB, i.e. a steady state. The terminal value comprises the majority of the total VIU.
Key assumptions used in the VIU calculation as at 31 December 2024
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:
\u2022 Expected future earnings of TTB: Short- to medium-term expectations are based on forecasts derived
from broker consensus. Longer-term and steady-state expectations into perpetuity are derived using
reasonable and supportable assumptions capturing a combination of TTB specific and market data points;
A capital maintenance charge is applied, which is management\u2019s forecast of the earnings that need to be
withheld in order for TTB to meet target regulatory requirements over the forecast period;
\u2022 Discount rate (cost of equity): 10.96%, based on the capital asset pricing model (CAPM) calculated for TTB
using current market data; and
\u2022 Terminal growth rate: 2.74% consistent with current long term government bond yield in Thailand as a
proxy for a risk-free rate.
The model was evaluated for reasonably possible changes to key assumptions in the model. This reflects the
sensitivity of the VIU to each key assumption on its own and it is possible that more than one favourable
and/or unfavourable change may occur at the same time. The selected rates of reasonably possible changes
to key assumptions are based on external analysts\u2019 forecasts and other relevant external data sources,
which can change period to period. The sensitivity of the VIU to each key assumption is as follows:
\u2022 A favourable change of 10% in the cash flows would result in an increase in VIU of EUR 57 million, while
an unfavourable change of -10% would result in a decrease in VIU of EUR -59 million;\u00a0
\u2022 A favourable change of -1% in the discount rate would result in an increase in VIU of EUR 95 million, while
an unfavourable change of 1% would result in a decrease in VIU of EUR -75 million;
\u2022 A favourable change of 1% in the terminal growth rate would result in an increase in VIU of EUR 68
million, while an unfavourable change of -1% would result in a decrease in VIU of EUR -53 million;", "dimensions": { "concept": "ifrs-full:DisclosureOfSignificantInvestmentsInAssociatesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-694": { "value": "
Investments in associates and joint ventures
in EUR million
2024
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%
1,164
1,266
49,147
42,554
1,474
1,050
Other investments in associates and
joint ventures
412
1,679
Other investments in associates and joint ventures
Included in Other investments in associates and joint ventures are mainly financial services and (non-)
financial technology funds or vehicles operating predominantly in Europe, and are individually not significant
to ING 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, the rating agency and
regulatory views, which can change over time.
Changes in Investments in associates and joint ventures
in EUR million
2024
2023
Opening balance as at 1 January
1,509
1,500
Additions
26
55
Transfers
-7
0
Revaluations
0
4
Share of results
205
149
Dividends received
-91
-74
Disposals
-16
-89
Impairments
-35
-5
Exchange rate differences
87
-32
Other
0
Closing balance
1,679
1,509
Share of results from associates and joint ventures of EUR 205 million (2023: EUR 149 million) as included in
the table above is mainly attributable to our share in the results of TTB of EUR 123\u00a0million (2023: EUR 107
million) and our share in the result of an associate in Belgium of EUR 77 million following a one-off profit.
The total impairment losses of EUR 35 million relate to associates that are not individually significant.
", "dimensions": { "concept": "ifrs-full:DisclosureOfJointVenturesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-695": { "value": "
Impairments and reversal thereof on the investment in TTB
Accumulated impairments on the investment in TTB of EUR 395\u00a0million (2023: EUR 395\u00a0million) were
recognised in previous years. There is no impairment trigger observed as per 31 December 2024. A Value in
Use ('VIU') was estimated following the prolonged increase of the quoted TTB share price over the original
cost price of the investment and the sustained improved broker consensus outlook. As VIU did not exceed
the carrying amount of the investment in TTB no reversal of impairment, was recognised.
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and VIU. Fair
value less costs of disposal is based on observable share price. The VIU calculation uses discounted cash flow
projections based on management\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:
\u2022 The estimation of future earnings over a 5-year forecast period; and
\u2022 the terminal value being the extrapolation of earnings into perpetuity applying a long-term growth rate.
The earnings that are used for extrapolation represent the stable long-term financial results and position
of TTB, i.e. a steady state. The terminal value comprises the majority of the total VIU.
Key assumptions used in the VIU calculation as at 31 December 2024
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:
\u2022 Expected future earnings of TTB: Short- to medium-term expectations are based on forecasts derived
from broker consensus. Longer-term and steady-state expectations into perpetuity are derived using
reasonable and supportable assumptions capturing a combination of TTB specific and market data points;
A capital maintenance charge is applied, which is management\u2019s forecast of the earnings that need to be
withheld in order for TTB to meet target regulatory requirements over the forecast period;
\u2022 Discount rate (cost of equity): 10.96%, based on the capital asset pricing model (CAPM) calculated for TTB
using current market data; and
\u2022 Terminal growth rate: 2.74% consistent with current long term government bond yield in Thailand as a
proxy for a risk-free rate.
The model was evaluated for reasonably possible changes to key assumptions in the model. This reflects the
sensitivity of the VIU to each key assumption on its own and it is possible that more than one favourable
and/or unfavourable change may occur at the same time. The selected rates of reasonably possible changes
to key assumptions are based on external analysts\u2019 forecasts and other relevant external data sources,
which can change period to period. The sensitivity of the VIU to each key assumption is as follows:
\u2022 A favourable change of 10% in the cash flows would result in an increase in VIU of EUR 57 million, while
an unfavourable change of -10% would result in a decrease in VIU of EUR -59 million;\u00a0
\u2022 A favourable change of -1% in the discount rate would result in an increase in VIU of EUR 95 million, while
an unfavourable change of 1% would result in a decrease in VIU of EUR -75 million;
\u2022 A favourable change of 1% in the terminal growth rate would result in an increase in VIU of EUR 68
million, while an unfavourable change of -1% would result in a decrease in VIU of EUR -53 million;
The reported impairment losses of EUR -23 million ( 2023: EUR -41 million) mainly result from the closure of
branches and unfavourable office market developments.
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. In 2024, no triggering events were identified.
At the annual impairment test in the fourth quarter, the recoverable amount exceeds the carrying value of
the CGUs as at 31 December 2024 and therefore no impairment is required (31 December 2023: nil).
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and Value in Use
(VIU). The VIU calculation is based on a Dividend Discount model using three-year management-approved
plans, updated for expected changes in the macroeconomic environment. When estimating the VIU of a
CGU, local conditions and requirements determine the capital requirements, discount rates, and terminal
growth rates. These local conditions and requirements determine the ability to upstream excess capital and
profits to ING 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 is based on the long-term inflation rate obtained from market
sources. The impacts of climate risk are included to the extent that they are observable in discount rates and
assets prices.
Sensitivity of key assumptions
Key assumptions in the goodwill impairment test model are the projected locally available cash flows (based
on local capital requirements and projected profits), discount rates (cost of equity), and long-term growth
rates.
The recoverable amounts of the CGUs are sensitive to the above key assumptions. A decrease in the
available cash flows of 10%, an increase in the discount rate of 1 percent point or a reduction of the future
growth rate to zero are considered reasonably possible changes in key assumptions. If the aforementioned
changes occur to one of the above key assumptions holding the other key assumptions constant, goodwill of
the remaining CGUs will continue to be recoverable.
Software is reviewed for indicators of impairment. Irrespective of whether there is an indication of
impairment, software under development is tested annually for impairment. In 2024, individually immaterial
items were impaired for an amount of EUR 12\u00a0million (31 December 2023: EUR 5\u00a0million).
", "dimensions": { "concept": "ifrs-full:DisclosureOfImpairmentOfAssetsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-696": { "value": "
9\u00a0 Property and equipment
Property and equipment by type
in EUR million
2024
2023
Property in own use
758
616
Equipment:
- Data processing equipment
218
213
- Other equipment
426
492
Right- of- use assets:
- ROU property
895
972
- ROU cars
124
97
- ROU other leases
13
9
2,434
2,399
Changes in property and equipment
Property in own use
Equipment
Right-of-use assets
Total
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
Opening balance as at 1 January
616
681
705
689
1,078
1,076
2,399
2,446
Additions
92
4
240
241
141
279
473
525
Transfers
83
-1
-78
-4
-4
-4
1
-9
Depreciation
-11
-12
-204
-204
-242
-246
-457
-461
Impairments1
-9
-19
-10
-10
-4
-12
-23
-41
Reversals of impairments 1
5
10
5
10
Remeasurements
5
4
75
9
80
13
Disposals
-36
-47
-14
-10
-18
-20
-68
-78
Exchange rate differences
13
-4
5
4
8
-4
25
-5
Closing balance
758
616
643
705
1,033
1,078
2,434
2,399
Cost price
871
753
3,027
3,140
1,933
1,851
5,831
5,744
Accumulated depreciation
-298
-305
-2,376
-2,430
-1,098
-904
-3,772
-3,639
Accumulated impairments
-97
-99
-8
-6
-31
-32
-136
-136
Accumulated revaluation surplus
282
267
282
267
Accumulated remeasurement
229
163
229
163
Net carrying value
758
616
643
705
1,033
1,078
2,434
2,399
1 Impairments and reversals of impairments of property and equipment are presented as Other operating expenses in the statement of
Profit or Loss.
ING considers valuations from third-party experts in determining the fair values of property in own use. The
vast majority of the land and buildings were appraised during 2024. Property in own use purchase costs
amounted to EUR 871 million (2023: EUR\u00a0753 million). Cost or the purchase price less accumulated
depreciation and impairments would have been EUR 476 million ( 2023: EUR 350 million) had property in own
use been valued at cost instead of at fair value.
The reported impairment losses of EUR -23 million ( 2023: EUR -41 million) mainly result from the closure of
branches and unfavourable office market developments.
", "dimensions": { "concept": "ifrs-full:DisclosureOfPropertyPlantAndEquipmentExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-699": { "value": "
10\u00a0 Intangible assets
Changes in intangible assets
Goodwill
Software
Other
Total
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
Opening balance as at 1 January
469
464
727
636
2
2
1,198
1,102
Additions
6
43
64
1
50
64
Capitalised expenses
324
246
324
246
Amortisation
-215
-213
-216
-213
Impairments 1
-12
-5
-12
-5
Exchange rate differences
1
5
8
2
9
7
Disposals
-9
-10
-9
-10
Changes in the composition of
the group and other changes
-10
8
1
-10
8
Closing balance
476
469
855
727
3
2
1,334
1,198
Gross carrying amount
476
469
2,986
2,646
8
8
3,471
3,123
Accumulated amortisation
-2,079
-1,876
-4
-4
-2,084
-1,879
Accumulated impairments
-52
-43
-2
-2
-53
-45
Net carrying value
476
469
855
727
3
2
1,334
1,198
1 Impairments of intangible assets are presented within Other operating expenses in the statement of Profit or Loss.
Goodwill
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 CGUs
2024
2023
Retail Netherlands
Value in use
7.81%
2.00%
30
30
Retail Germany
Value in use
7.77%
2.00%
356
349
Retail Poland
Value in use
9.30%
2.50%
76
75
Retail Romania
Value in use
11.45%
3.00%
15
15
476
469
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. In 2024, no triggering events were identified.
At the annual impairment test in the fourth quarter, the recoverable amount exceeds the carrying value of
the CGUs as at 31 December 2024 and therefore no impairment is required (31 December 2023: nil).
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and Value in Use
(VIU). The VIU calculation is based on a Dividend Discount model using three-year management-approved
plans, updated for expected changes in the macroeconomic environment. When estimating the VIU of a
CGU, local conditions and requirements determine the capital requirements, discount rates, and terminal
growth rates. These local conditions and requirements determine the ability to upstream excess capital and
profits to ING 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 is based on the long-term inflation rate obtained from market
sources. The impacts of climate risk are included to the extent that they are observable in discount rates and
assets prices.
Sensitivity of key assumptions
Key assumptions in the goodwill impairment test model are the projected locally available cash flows (based
on local capital requirements and projected profits), discount rates (cost of equity), and long-term growth
rates.
The recoverable amounts of the CGUs are sensitive to the above key assumptions. A decrease in the
available cash flows of 10%, an increase in the discount rate of 1 percent point or a reduction of the future
growth rate to zero are considered reasonably possible changes in key assumptions. If the aforementioned
changes occur to one of the above key assumptions holding the other key assumptions constant, goodwill of
the remaining CGUs will continue to be recoverable.
", "dimensions": { "concept": "ifrs-full:DisclosureOfGoodwillExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-698": { "value": "
10\u00a0 Intangible assets
Changes in intangible assets
Goodwill
Software
Other
Total
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
Opening balance as at 1 January
469
464
727
636
2
2
1,198
1,102
Additions
6
43
64
1
50
64
Capitalised expenses
324
246
324
246
Amortisation
-215
-213
-216
-213
Impairments 1
-12
-5
-12
-5
Exchange rate differences
1
5
8
2
9
7
Disposals
-9
-10
-9
-10
Changes in the composition of
the group and other changes
-10
8
1
-10
8
Closing balance
476
469
855
727
3
2
1,334
1,198
Gross carrying amount
476
469
2,986
2,646
8
8
3,471
3,123
Accumulated amortisation
-2,079
-1,876
-4
-4
-2,084
-1,879
Accumulated impairments
-52
-43
-2
-2
-53
-45
Net carrying value
476
469
855
727
3
2
1,334
1,198
1 Impairments of intangible assets are presented within Other operating expenses in the statement of Profit or Loss.
Goodwill
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 CGUs
2024
2023
Retail Netherlands
Value in use
7.81%
2.00%
30
30
Retail Germany
Value in use
7.77%
2.00%
356
349
Retail Poland
Value in use
9.30%
2.50%
76
75
Retail Romania
Value in use
11.45%
3.00%
15
15
476
469
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. In 2024, no triggering events were identified.
At the annual impairment test in the fourth quarter, the recoverable amount exceeds the carrying value of
the CGUs as at 31 December 2024 and therefore no impairment is required (31 December 2023: nil).
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and Value in Use
(VIU). The VIU calculation is based on a Dividend Discount model using three-year management-approved
plans, updated for expected changes in the macroeconomic environment. When estimating the VIU of a
CGU, local conditions and requirements determine the capital requirements, discount rates, and terminal
growth rates. These local conditions and requirements determine the ability to upstream excess capital and
profits to ING 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 is based on the long-term inflation rate obtained from market
sources. The impacts of climate risk are included to the extent that they are observable in discount rates and
assets prices.
Sensitivity of key assumptions
Key assumptions in the goodwill impairment test model are the projected locally available cash flows (based
on local capital requirements and projected profits), discount rates (cost of equity), and long-term growth
rates.
The recoverable amounts of the CGUs are sensitive to the above key assumptions. A decrease in the
available cash flows of 10%, an increase in the discount rate of 1 percent point or a reduction of the future
growth rate to zero are considered reasonably possible changes in key assumptions. If the aforementioned
changes occur to one of the above key assumptions holding the other key assumptions constant, goodwill of
the remaining CGUs will continue to be recoverable.
Software
Software includes internally developed software amounting to EUR 768 million (2023: EUR 628 million).
Software is reviewed for indicators of impairment. Irrespective of whether there is an indication of
impairment, software under development is tested annually for impairment. In 2024, individually immaterial
items were impaired for an amount of EUR 12\u00a0million (31 December 2023: EUR 5\u00a0million).
", "dimensions": { "concept": "ifrs-full:DisclosureOfIntangibleAssetsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-697": { "value": "
10\u00a0 Intangible assets
Changes in intangible assets
Goodwill
Software
Other
Total
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
Opening balance as at 1 January
469
464
727
636
2
2
1,198
1,102
Additions
6
43
64
1
50
64
Capitalised expenses
324
246
324
246
Amortisation
-215
-213
-216
-213
Impairments 1
-12
-5
-12
-5
Exchange rate differences
1
5
8
2
9
7
Disposals
-9
-10
-9
-10
Changes in the composition of
the group and other changes
-10
8
1
-10
8
Closing balance
476
469
855
727
3
2
1,334
1,198
Gross carrying amount
476
469
2,986
2,646
8
8
3,471
3,123
Accumulated amortisation
-2,079
-1,876
-4
-4
-2,084
-1,879
Accumulated impairments
-52
-43
-2
-2
-53
-45
Net carrying value
476
469
855
727
3
2
1,334
1,198
1 Impairments of intangible assets are presented within Other operating expenses in the statement of Profit or Loss.
Goodwill
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 CGUs
2024
2023
Retail Netherlands
Value in use
7.81%
2.00%
30
30
Retail Germany
Value in use
7.77%
2.00%
356
349
Retail Poland
Value in use
9.30%
2.50%
76
75
Retail Romania
Value in use
11.45%
3.00%
15
15
476
469
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. In 2024, no triggering events were identified.
At the annual impairment test in the fourth quarter, the recoverable amount exceeds the carrying value of
the CGUs as at 31 December 2024 and therefore no impairment is required (31 December 2023: nil).
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and Value in Use
(VIU). The VIU calculation is based on a Dividend Discount model using three-year management-approved
plans, updated for expected changes in the macroeconomic environment. When estimating the VIU of a
CGU, local conditions and requirements determine the capital requirements, discount rates, and terminal
growth rates. These local conditions and requirements determine the ability to upstream excess capital and
profits to ING 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 is based on the long-term inflation rate obtained from market
sources. The impacts of climate risk are included to the extent that they are observable in discount rates and
assets prices.
Sensitivity of key assumptions
Key assumptions in the goodwill impairment test model are the projected locally available cash flows (based
on local capital requirements and projected profits), discount rates (cost of equity), and long-term growth
rates.
The recoverable amounts of the CGUs are sensitive to the above key assumptions. A decrease in the
available cash flows of 10%, an increase in the discount rate of 1 percent point or a reduction of the future
growth rate to zero are considered reasonably possible changes in key assumptions. If the aforementioned
changes occur to one of the above key assumptions holding the other key assumptions constant, goodwill of
the remaining CGUs will continue to be recoverable.
Software
Software includes internally developed software amounting to EUR 768 million (2023: EUR 628 million).
Software is reviewed for indicators of impairment. Irrespective of whether there is an indication of
impairment, software under development is tested annually for impairment. In 2024, individually immaterial
items were impaired for an amount of EUR 12\u00a0million (31 December 2023: EUR 5\u00a0million).
", "dimensions": { "concept": "ifrs-full:DisclosureOfIntangibleAssetsAndGoodwillExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-700": { "value": "
11\u00a0 Other assets
Other assets by type
in EUR million
2024
2023
Net defined benefit assets
568
554
Investment properties
19
14
Property development and obtained from foreclosures
18
32
Prepayments
412
436
Accrued assets
496
521
Amounts to be settled
3,548
3,869
Other
1,875
1,683
6,935
7,109
Disclosures in respect of Net defined benefit assets are provided in Note 30 'Pensions and other post-
employment benefits'.
Amounts to be settled include primarily transactions not settled at the balance sheet date. The nature of
these transactions is short term and they are expected to settle shortly after the closing date of the balance
sheet. Other relates to various receivables in the normal course of business, including short-term receivables
from mortgages issued to notary accounts pending transfer to customers and other amounts receivable
from customers.", "dimensions": { "concept": "ifrs-full:DisclosureOfOtherAssetsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-701": { "value": "
12\u00a0 Deposits from banks
Deposits from banks by type
Netherlands
Rest of the world
Total
in EUR million
2024
2023
2024
2023
2024
2023
Non-interest bearing
4
3
166
174
170
177
Interest bearing
5,845
7,803
10,707
15,277
16,553
23,080
5,849
7,806
10,873
15,451
16,722
23,257
Deposits from banks include non-subordinated deposits and repurchase transactions. For more information on
reverse repurchase transaction, refer to Note 4 'Financial assets at fair value through profit or loss'.
In 2023, deposits from banks included ING\u2019s participation in the Targeted Longer-Term Refinancing
Operations (TLTRO) of EUR 6.0 billion which was fully repaid in March 2024.", "dimensions": { "concept": "ifrs-full:DisclosureOfDepositsFromBanksExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-702": { "value": "
13\u00a0 Customer deposits
Customer deposits
in EUR million
2024
2023
Current accounts / Overnight deposits
227,951
222,478
Savings accounts
354,560
334,287
Time deposits
115,636
103,186
Other 1
1,579
2,053
699,725
662,004
1 ING changed the presentation for the senior non-preferred debt and the comparative figure for 2023 has been adjusted.
Current accounts / Overnight deposits, Saving accounts and Time deposits include balances with individuals,
respectively EUR 107,068\u00a0million (2023: EUR 107,711\u00a0million), EUR 324,134\u00a0million (2023: EUR
305,734\u00a0million) and EUR 56,599\u00a0million (2023: EUR 46,762\u00a0million).
Customer deposits by type
Netherlands
Rest of the world
Total
in EUR million
2024
2023
2024
2023
2024
2023
Non-interest bearing
26
239
27,142
25,316
27,168
25,556
Interest bearing 1 2
245,375
244,193
427,182
392,255
672,557
636,448
245,401
244,433
454,324
417,571
699,725
662,004
1 Interest bearing includes current accounts which are not remunerated. However ING holds the contractual right to revise the rates.
\u00a0 \u00a0 \u00a0 2 \u00a0 \u00a0 ING changed the presentation for the senior non-preferred debt and the comparative figures for 2023 have been adjusted.
", "dimensions": { "concept": "ifrs-full:DisclosureOfDepositsFromCustomersExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-703": { "value": "
Trading liabilities
Trading liabilities by type
in EUR million
2024
2023
Equity securities
467
1,156
Debt securities
3,185
2,492
Funds on deposit
5,437
10,443
Derivatives
26,166
23,129
35,255
37,220
", "dimensions": { "concept": "ifrs-full:DisclosureOfFinancialLiabilitiesHeldForTradingExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-704": { "value": "
15\u00a0 Provisions
Provisions by type
in EUR million
2024
2023
Reorganisation provisions
201
231
Litigation provisions
288
193
Other provisions
118
334
606
758
Loan loss provisions for guarantees
146
142
752
899
Changes in provisions
Reorganisation
Litigation
Other provisions
Total
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
Opening balance as at 1 January
231
418
193
150
334
433
758
1,001
Additions 1
146
207
116
78
26
39
288
325
Interest
Releases 1
-4
-34
-15
-26
-46
-22
-64
-82
Utilised
-163
-356
-31
-23
-196
-11
-390
-389
Exchange rate differences
-1
1
1
-1
-3
-4
Other changes
-10
-3
25
13
-104
15
-94
Closing balance
201
231
288
193
118
334
606
758
1 Additions to provisions and unused amounts released are presented in Note 27 'Other operating expenses' in the Statement of Profit\u00a0
or Loss.
As at 31\u00a0December 2024, amounts expected to be settled within 12 months in provisions amount to EUR 552
million ( 2023: EUR 699 million). The amounts included are based on best estimates with regard to amounts
and timing of cash flows required to settle the obligation.
Reorganisation provisions
The additions in 2024 mainly relate to restructuring activities in Belgium, the Netherlands, and at head office.
In 2023, the additions to the reorganisation provisions mainly relate to restructuring activities in Belgium,
Poland, and the Netherlands.
These initiatives are implemented over a period of several years and the estimate of the reorganisation
provisions is inherently uncertain.
Litigation provisions
Reference is made to Note 39 'Legal proceedings' for developments in litigation provisions.
Other provisions
In 2024, the utilisations in the Other provisions mainly relate to the provision for the compensation of Dutch
retail customers for past interest charges that did not sufficiently track market rates. This provision of EUR
180 million was recognized in 2021 and subsequently had been increased by EUR 75 million in 2023.
In 2023, ING Bank voluntarily changed its accounting policy for non-financial guarantees that are subject to
contractual indemnification rights from IAS 37 principles to loan commitment accounting under IFRS 9. The
change from IAS 37 to IFRS 9 resulted in derecognition of the existing IAS 37 provision of EUR 109 million as
per 1 January 2023 and recognition of a provision for expected credit losses of EUR 151 million for non-
financial guarantees as per 1 January 2023 (EUR 42 million pre-tax impact on Equity at the beginning of
2023). This change is included in Other changes in the movement table.
For details and changes on loan loss provisioning, refer to \u2018Risk management \u2013 Credit risk\u2019 paragraph 'Loan
loss provisioning'.
", "dimensions": { "concept": "ifrs-full:DisclosureOfProvisionsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-706": { "value": "
16\u00a0 Other liabilities
Other liabilities by type
In EUR million
2024
2023
Net defined benefit liability
152
164
Other post-employment benefits
38
30
Other staff-related liabilities
784
719
Other taxation and social security contributions
899
641
Rents received in advance
14
14
Costs payable
1,763
2,170
Amounts to be settled
4,290
6,509
Lease liabilities
1,116
1,162
Other
1,538
1,721
10,596
13,130
Disclosures in respect of Net defined benefit liabilities are provided in Note 30 'Pensions and other post-
employment benefits'.
Other staff-related liabilities includes vacation leave provisions, jubilee provisions, disability/illness provisions
and liabilities related with variable compensations.
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 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 2024 was EUR 290\u00a0million (2023: EUR
291\u00a0million).
The line Other relates mainly to amounts payable to customers.
", "dimensions": { "concept": "ifrs-full:DisclosureOfAccruedExpensesAndOtherLiabilitiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-705": { "value": "
16\u00a0 Other liabilities
Other liabilities by type
In EUR million
2024
2023
Net defined benefit liability
152
164
Other post-employment benefits
38
30
Other staff-related liabilities
784
719
Other taxation and social security contributions
899
641
Rents received in advance
14
14
Costs payable
1,763
2,170
Amounts to be settled
4,290
6,509
Lease liabilities
1,116
1,162
Other
1,538
1,721
10,596
13,130
Disclosures in respect of Net defined benefit liabilities are provided in Note 30 'Pensions and other post-
employment benefits'.
Other staff-related liabilities includes vacation leave provisions, jubilee provisions, disability/illness provisions
and liabilities related with variable compensations.
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 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 2024 was EUR 290\u00a0million (2023: EUR
291\u00a0million).
The line Other relates mainly to amounts payable to customers.
", "dimensions": { "concept": "ifrs-full:DisclosureOfOtherLiabilitiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-707": { "value": "-290000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:IncreaseDecreaseThroughRedemptionsOrDisposalsLiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ifrs-full:LeaseLiabilitiesMember", "unit": "iso4217:EUR" } }, "f-708": { "value": "-291000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:IncreaseDecreaseThroughRedemptionsOrDisposalsLiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00/2024-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ifrs-full:LeaseLiabilitiesMember", "unit": "iso4217:EUR" } }, "f-709": { "value": "
19\u00a0 Subordinated loans
Subordinated loans
In EUR million
2024
2023
Subordinated loans
17,879
15,404
17,879
15,404
Subordinated loans are bonds issued by ING Groep N.V. and its subsidiaries to raise Tier 1 and Tier 2 (CRR-\u00a0
eligible) capital. Under IFRS these securities are classified as liabilities and for regulatory purposes, they are
considered as capital. Subordinated loans of EUR 18,403 million (2023: EUR 16,240 million) have been placed
with ING Bank N.V. by ING Groep N.V.
In 2024 ING Groep N.V. issued USD 1.25 billion 8.00% Perpetual AT1 Contingent Convertible Capital Securities
in February, EUR 1.25 billion 4.38% Fixed Rate Subordinated Tier 2 Notes in May, EUR 1.25 billion\u00a0 4.25% Fixed
Rate Subordinated Tier 2 Notes in August and USD 1 billion 7.25% Perpetual AT1 Contingent Convertible
Capital Securities in September.
In 2024 ING T\u00fcrkiye issued USD 150\u00a0million 8.50% Fixed Rate Subordinated Tier 2 Notes in September.
In 2024 ING Groep N.V. redeemed USD 1.25 billion 6.75% Perpetual AT1 Contingent Convertible Capital
Securities in April, EUR 750 million 2.50% Fixed Subordinated Tier 2 notes in February and EUR 1 billion 1.63%
Fixed Subordinated Tier 2 notes in September on their first call dates.
Reference is made to the consolidated statement of cash flows for further information on issuances and
redemptions.
The average interest rate on subordinated loans is 4.59% (2023: 4.44%).", "dimensions": { "concept": "ifrs-full:DisclosureOfSubordinatedLiabilitiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-710": { "value": "
20\u00a0 Equity
Total equity
In EUR million
2024
2023
2022
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
1,816
1,152
1,187
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Revaluation reserve: Debt instruments at FVOCI
-479
-277
-339
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Revaluation reserve: Cash flow hedge
-1,693
-2,058
-3,055
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Revaluation reserve: Credit liability
-15
31
70
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Revaluation reserve: Property in own use
161
178
176
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Net defined benefit asset/liability remeasurement reserve
-333
-317
-232
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Currency translation reserve
-1,986
-2,527
-2,395
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Share of associates and joint ventures and other reserves
2,607
3,048
3,604
78
-769
-984
Retained earnings
25,598
23,893
26,462
Shareholders\u2019 equity (parent)
42,743
40,191
42,546
Non-controlling interests
995
944
504
Total equity
43,738
41,135
43,050
Adjustments for hyperinflation
ING applies IAS 29 \u2018Hyperinflation\u2019 on its investment in T\u00fcrkiye since 2022. The IAS 29 indexation impact on
equity was EUR 50 million (2023: EUR 54 million; 2022: EUR 100 million) of which EUR 202 million (2023: EUR
284 million; 2022: EUR 1,011 million) in the currency translation reserve, EUR 0 million (2023: EUR 0 million;
2022: EUR -563 million) in retained earnings, EUR 4 million (2023: EUR 3 million; 2022: EUR -17 million) in
revaluation reserves and EUR -156 million (2023: EUR -234\u00a0million; 2022: EUR -331 million) in profit or loss.
Share capital and share premium
Share capital
Ordinary shares (par value EUR\u00a01.13)
Number x 1,000
Amount
2024
2023
2022
2024
2023
2022
Authorised share capital
1,600,000
1,600,000
1,600,000
1,808
1,808
1,808
Unissued share capital
1,134,965
1,134,965
1,134,965
1,283
1,283
1,283
Issued share capital
465,035
465,035
465,035
525
525
525
No change occurred in the issued share capital and share premium in 2024, 2023 and 2022.
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
December 2024, 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
December 2024, 7 preference shares were issued and fully paid (2023: 7 preference shares; 2022: 7
preference shares) amounting to EUR 8 (2023: EUR 8 and 2022: 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.
Revaluation reserves
Changes in revaluation reserve: Equity securities and Debt instruments at FVOCI
Equity securities at FVOCI
Debt instruments at FVOCI
In EUR million
2024
2023
2022
2024
2023
2022
Opening balance
1,152
1,187
1,282
-277
-339
92
Unrealised revaluations
664
-35
-118
-265
53
-406
Realised gains/losses transferred to the
statement of profit or loss
62
9
-25
Realised revaluations transferred to retained
earnings
0
1
23
Closing balance
1,816
1,152
1,187
-479
-277
-339
Equity securities at FVOCI
In 2024, the unrealised revaluation of EUR 664\u00a0million (2023: EUR -35 million; 2022: EUR -118 million)
includes revaluation of shares in Bank of Beijing for EUR 652 million (2023: EUR -24 million; 2022: EUR -86
million).
Changes in cash flow hedge and credit liability reserve
Cash flow hedge
Credit liability
In EUR million
2024
2023
2022
2024
2023
2022
Opening balance
-2,058
-3,055
-153
31
70
-80
Changes in credit liability reserve
-46
-39
165
Unrealised revaluations
365
997
-2,901
Realised revaluations transferred to retained
earnings
-15
Closing balance
-1,693
-2,058
-3,055
-15
31
70
Cash flow hedge
ING mainly hedges floating rate lending with interest rate swaps. Due to a decrease in forward interest rates
in 2024, the interest rate swaps had a positive revaluation of EUR 365\u00a0million which is recognised in the cash
flow hedge reserve.
Changes in Property in own use reserve
In EUR million
2024
2023
2022
Opening balance
178
176
208
Impact IAS 29 on opening balance 1
-20
Unrealised revaluations
3
10
15
Realised revaluations transferred to retained earnings
-20
-8
-26
Closing balance
161
178
176
1 Impact of application of hyperinflation accounting under IAS 29.
Net defined benefit asset/liability remeasurement reserve
Reference is made to Note 30 'Pensions and other post-employment benefits'.
Currency translation reserve
Changes in currency translation reserve
In EUR million
2024
2023
2022
Opening balance
-2,527
-2,395
-3,483
Impact IAS 29 on opening balance 1
647
Unrealised revaluations
-222
183
-7
Realised gains/losses transferred to the statement of profit or loss
1
4
Exchange rate differences
763
-316
444
Closing balance
-1,986
-2,527
-2,395
1 Impact of application of hyperinflation accounting under IAS 29.
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 unrealised revaluations and Exchange rate differences of EUR 541
million is related to several currencies including USD (EUR 354 million), TRY (EUR 148 million including EUR
202 million IAS 29 indexation effect), GBP (EUR 75 million), PLN (EUR 18\u00a0 million), CHF (EUR -10 million), AUD
(EUR -35 million), RUB (EUR -47 million), THB (EUR 31 million), CNY (EUR 3 million) and other currencies (EUR 4
million).
Share of associates and joint ventures and other reserves
Changes in share of associates, joint ventures and other reserves
In EUR million
2024
2023
2022
Opening balance
3,048
3,604
3,416
Result for the year
125
336
161
Transfer to/from retained earnings
-565
-892
26
Closing balance
2,607
3,048
3,604
The Share of associates, joint ventures and other reserves includes non-distributable profits from associates
and joint ventures of EUR 940 million (2023: EUR 815 million; 2022: EUR 797 million). Other reserves includes
a statutory reserve of EUR 897 million (2023: EUR 1,602 million; 2022: EUR 2,264 million) related to the
former Stichting Regio Bank and the former Stichting Vakbondsspaarbank SPN and a legal reserve of EUR 768
million (2023: EUR 628 million; 2022: EUR 540 million) related to internally developed software. The transfer
to retained earnings of EUR -565 million includes the release of the Regio bank and Vakbondsspaarbank SPN
reserve of EUR -830 million (2023:EUR -998 million; 2022: EUR 0 million) against regulatory expenses which
are recognised in the statement of profit or loss.
Retained earnings
Changes in retained earnings
In EUR million
2024
2023
2022
Opening balance
23,893
26,462
29,778
Impact on opening balance 1
-45
-563
Transfer to/from other reserves
585
899
-8
Result for the year
6,062
6,821
3,506
Dividend and other cash distributions
-4,986
-10,269
-6,277
Employee share plans
45
30
27
Changes in composition of the group and other changes
-1
-5
-1
Closing balance
25,598
23,893
26,462
1 2023: Changes in policy following the adoption of IFRS 17 and change in policy for non-financial guarantees. 2022: impact of
application of hyperinflation accounting under IAS 29.
Restrictions with respect to dividend and repayment of capital
The following equity components cannot be freely distributed: Revaluation reserves, Net defined benefit
asset/liability remeasurement reserve, Currency translation reserve, Share of associates and joint ventures
reserve and Other reserves including the part related to the former Stichting Regio Bank and the former
Stichting Vakbondsspaarbank SPN.
As at 31 December 2024, an amount of EUR 897 million (2023: EUR 1,602 million) related to the former
Stichting Regio Bank and the former Stichting Vakbondsspaarbank SPN is included.
ING Bank N.V. is subject to legal restrictions regarding the amount of dividends it can pay to its shareholder.
Pursuant to the Dutch Civil Code, 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. Moreover, ING Bank
N.V.\u2019s ability to pay dividends is dependent on the dividend payment ability of its subsidiaries, associates and
joint ventures. ING Bank N.V. is legally required to create a non-distributable reserve insofar as profits of its
subsidiaries, associates and joint ventures are subject to dividend payment restrictions which apply to those
subsidiaries, associates and joint ventures themselves.
Non distributable reserves, determined in accordance with the financial reporting requirements included in
Part 9 of Book 2 of the Dutch Civil Code, from ING Bank\u2019s subsidiaries, associates and joint ventures amounts
to EUR 5,672 million (2023: EUR 6,727 million).
Furthermore there are restrictions to the ability of subsidiaries, associates and joint ventures to distribute
reserves to ING Bank N.V. as a result of minimum capital requirements that are imposed by industry
regulators in the countries in which the subsidiaries operate.
In addition to the legal and regulatory restrictions on distributing dividends from subsidiaries, associates and
joint ventures to ING Bank N.V. there are various other considerations and limitations that are taken into
account in determining the appropriate levels of equity in the Bank\u2019s subsidiaries, associates and joint
ventures. These considerations and limitations include, but are not restricted to, minimum capital
requirements that are imposed by industry regulators in the countries in which the subsidiaries, associates
and joint ventures operate, or other limitations which may exist in certain countries and may or may not be
temporary in nature. It is not possible to disclose a reliable quantification of these limitations.\u00a0 Refer to Note
44 'Capital management' for an overview of the minimal capital requirements of ING Bank.
Without prejudice to the authority of the Executive Board to allocate profits to reserves and to the fact that
the shares are the most junior securities issued by ING Bank N.V., no specific dividend payment restrictions
with respect to the shares exist.
Furthermore, ING Bank N.V. is subject to legal restrictions with respect to repayment of capital to Its
shareholder. Pursuant to the Dutch Civil Code, capital may only be repaid if none of ING Bank N.V.\u2019s creditors
opposes such a repayment within two months following the announcement of a resolution to that effect.
", "dimensions": { "concept": "ifrs-full:DisclosureOfShareCapitalReservesAndOtherEquityInterestExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-711": { "value": "
Share capital
Ordinary shares (par value EUR\u00a01.13)
Number x 1,000
Amount
2024
2023
2022
2024
2023
2022
Authorised share capital
1,600,000
1,600,000
1,600,000
1,808
1,808
1,808
Unissued share capital
1,134,965
1,134,965
1,134,965
1,283
1,283
1,283
Issued share capital
465,035
465,035
465,035
525
525
525
No change occurred in the issued share capital and share premium in 2024, 2023 and 2022.
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
December 2024, 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
December 2024, 7 preference shares were issued and fully paid (2023: 7 preference shares; 2022: 7
preference shares) amounting to EUR 8 (2023: EUR 8 and 2022: EUR 8).
", "dimensions": { "concept": "ifrs-full:DisclosureOfIssuedCapitalExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-712": { "value": "
No change occurred in the issued share capital and share premium in 2024, 2023 and 2022.
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
December 2024, 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
December 2024, 7 preference shares were issued and fully paid (2023: 7 preference shares; 2022: 7
preference shares) amounting to EUR 8 (2023: EUR 8 and 2022: EUR 8).
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForIssuedCapitalExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-713": { "value": "
Revaluation reserves
Changes in revaluation reserve: Equity securities and Debt instruments at FVOCI
Equity securities at FVOCI
Debt instruments at FVOCI
In EUR million
2024
2023
2022
2024
2023
2022
Opening balance
1,152
1,187
1,282
-277
-339
92
Unrealised revaluations
664
-35
-118
-265
53
-406
Realised gains/losses transferred to the
statement of profit or loss
62
9
-25
Realised revaluations transferred to retained
earnings
0
1
23
Closing balance
1,816
1,152
1,187
-479
-277
-339
Equity securities at FVOCI
In 2024, the unrealised revaluation of EUR 664\u00a0million (2023: EUR -35 million; 2022: EUR -118 million)
includes revaluation of shares in Bank of Beijing for EUR 652 million (2023: EUR -24 million; 2022: EUR -86
million).
Changes in cash flow hedge and credit liability reserve
Cash flow hedge
Credit liability
In EUR million
2024
2023
2022
2024
2023
2022
Opening balance
-2,058
-3,055
-153
31
70
-80
Changes in credit liability reserve
-46
-39
165
Unrealised revaluations
365
997
-2,901
Realised revaluations transferred to retained
earnings
-15
Closing balance
-1,693
-2,058
-3,055
-15
31
70
Cash flow hedge
ING mainly hedges floating rate lending with interest rate swaps. Due to a decrease in forward interest rates
in 2024, the interest rate swaps had a positive revaluation of EUR 365\u00a0million which is recognised in the cash
flow hedge reserve.
Changes in Property in own use reserve
In EUR million
2024
2023
2022
Opening balance
178
176
208
Impact IAS 29 on opening balance 1
-20
Unrealised revaluations
3
10
15
Realised revaluations transferred to retained earnings
-20
-8
-26
Closing balance
161
178
176
1 Impact of application of hyperinflation accounting under IAS 29.
Net defined benefit asset/liability remeasurement reserve
Reference is made to Note 30 'Pensions and other post-employment benefits'.
Currency translation reserve
Changes in currency translation reserve
In EUR million
2024
2023
2022
Opening balance
-2,527
-2,395
-3,483
Impact IAS 29 on opening balance 1
647
Unrealised revaluations
-222
183
-7
Realised gains/losses transferred to the statement of profit or loss
1
4
Exchange rate differences
763
-316
444
Closing balance
-1,986
-2,527
-2,395
1 Impact of application of hyperinflation accounting under IAS 29.
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 unrealised revaluations and Exchange rate differences of EUR 541
million is related to several currencies including USD (EUR 354 million), TRY (EUR 148 million including EUR
202 million IAS 29 indexation effect), GBP (EUR 75 million), PLN (EUR 18\u00a0 million), CHF (EUR -10 million), AUD
(EUR -35 million), RUB (EUR -47 million), THB (EUR 31 million), CNY (EUR 3 million) and other currencies (EUR 4
million).
Share of associates and joint ventures and other reserves
Changes in share of associates, joint ventures and other reserves
In EUR million
2024
2023
2022
Opening balance
3,048
3,604
3,416
Result for the year
125
336
161
Transfer to/from retained earnings
-565
-892
26
Closing balance
2,607
3,048
3,604
The Share of associates, joint ventures and other reserves includes non-distributable profits from associates
and joint ventures of EUR 940 million (2023: EUR 815 million; 2022: EUR 797 million). Other reserves includes
a statutory reserve of EUR 897 million (2023: EUR 1,602 million; 2022: EUR 2,264 million) related to the
former Stichting Regio Bank and the former Stichting Vakbondsspaarbank SPN and a legal reserve of EUR 768
million (2023: EUR 628 million; 2022: EUR 540 million) related to internally developed software. The transfer
to retained earnings of EUR -565 million includes the release of the Regio bank and Vakbondsspaarbank SPN
reserve of EUR -830 million (2023:EUR -998 million; 2022: EUR 0 million) against regulatory expenses which
are recognised in the statement of profit or loss.
Non distributable reserves, determined in accordance with the financial reporting requirements included in
Part 9 of Book 2 of the Dutch Civil Code, from ING Bank\u2019s subsidiaries, associates and joint ventures amounts
to EUR 5,672 million (2023: EUR 6,727 million).
", "dimensions": { "concept": "ifrs-full:DisclosureOfReservesAndOtherEquityInterestExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-714": { "value": "
Currency translation reserve
Changes in currency translation reserve
In EUR million
2024
2023
2022
Opening balance
-2,527
-2,395
-3,483
Impact IAS 29 on opening balance 1
647
Unrealised revaluations
-222
183
-7
Realised gains/losses transferred to the statement of profit or loss
1
4
Exchange rate differences
763
-316
444
Closing balance
-1,986
-2,527
-2,395
1 Impact of application of hyperinflation accounting under IAS 29.
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 unrealised revaluations and Exchange rate differences of EUR 541
million is related to several currencies including USD (EUR 354 million), TRY (EUR 148 million including EUR
202 million IAS 29 indexation effect), GBP (EUR 75 million), PLN (EUR 18\u00a0 million), CHF (EUR -10 million), AUD
(EUR -35 million), RUB (EUR -47 million), THB (EUR 31 million), CNY (EUR 3 million) and other currencies (EUR 4
million).", "dimensions": { "concept": "ifrs-full:DisclosureOfEffectOfChangesInForeignExchangeRatesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-715": { "value": "
21\u00a0 Net interest income
Net interest income1
in EUR million
2024
2023
2022
2024
2023
2022
Interest income on loans2
33,892
31,850
19,429
Interest expense on deposits3
16,849
13,282
5,321
Interest income on debt securities at amortised cost
1,204
877
591
Interest expense on debt securities in issue
3,796
2,856
859
Interest income on financial assets at fair value through OCI
1,481
1,078
510
Interest expense on subordinated loans
752
707
646
Interest income on non-trading derivatives (hedge accounting)
12,644
10,682
4,011
Interest expense on non-trading derivatives (hedge accounting)
13,767
11,849
4,144
Total interest income using effective interest rate method
49,221
44,486
24,541
Total interest expense using effective interest rate method
35,164
28,693
10,969
Interest income on financial assets at fair value through profit or loss
6,343
4,934
1,444
Interest expense on financial liabilities at fair value through profit or loss
5,479
4,410
1,237
Interest income on non-trading derivatives (no hedge accounting)
3,168
2,637
2,390
Interest expense on non-trading derivatives (no hedge accounting)
3,308
3,131
2,411
Interest income other
173
171
101
Interest expense on lease liabilities
27
28
15
Total other interest income
9,685
7,741
3,935
Interest expense other
178
157
98
Total other interest expense
8,993
7,726
3,761
Total interest income
58,905
52,228
28,476
Total interest expense
44,157
36,419
14,730
Net interest income
14,749
15,809
13,745
1 Table has been updated to a more aggregated view for presentation purposes and comparatives have been adjusted accordingly. Negative interest on assets and liabilities is no longer presented separately. Furthermore, interest expense on deposits from customers and banks is
now presented on a combined basis within Interest expense on deposits. Refer to footnote 2 and 3.
2 Includes interest income on loans to customers and banks, cash balances as well as negative interest on liabilities. Negative interest on liabilities amounted to EUR 8 million (2023: EUR 19 million; 2022: EUR 892 million).
3 Includes interest paid on deposits from customers and banks, senior non-preferred debt and negative interest on assets. Negative interest on assets amounted to EUR 1 million (2023: EUR nil; 2022: EUR 285 million).
In 2022, a one-off adjustment was recorded in interest income on loans regarding the credit moratoria in
Poland (EUR -343 million).
Due to prevalent rates during the comparative years, Negative interest on liabilities includes the ECB funding
rate benefit from the TLTRO III programme of EUR 314 million in 2022, while for 2024 Interest expense on
deposits includes interest paid under the TLTRO III programme of EUR 59 million (2023: EUR 557 million). The
funding under this programme was fully repaid during the first quarter of 2024.
The ECB funding rate benefit in 2022 caused the discontinuation of the fair value hedge accounting
relationship on TLTRO III, impacting net interest income of 2022 for an amount of EUR -483 million.
22\u00a0 Net fee and commission income
Net fee and commission income
in EUR million
2024
2023
2022
Fee and commission income
Payment Services
2,219
2,062
1,888
Securities business
734
584
632
Insurance and other broking
594
529
682
Portfolio management
699
625
600
Lending business
650
602
556
Financial guarantees and other commitments
454
459
496
Other fee and commission income
249
239
232
Total fee and commission income
5,598
5,100
5,085
Fee and commission expenses
Payment Services
756
704
600
Securities business
147
129
160
Distribution of products
475
480
555
Other fee and commission expenses
218
202
184
Total fee and commission expenses
1,596
1,514
1,499
Net fee and commission income
4,002
3,586
3,586
Payment services fees are earned for providing services for deposit accounts and cards, cash management
and transaction processing including interchange. Securities fees and commissions are fees for securities
brokerage and securities underwriting. Portfolio management fees include fees earned for asset
management activities, fiduciary and related activities in which ING holds or invests assets on behalf of its
customers. Fees and commissions from lending (syndication) business include income earned for lending
advisory, origination, underwriting and loan commitments which are not part of the effective interest rate.
Financial guarantees and other commitments fees and commissions are earned from bank guarantees,
letters of credit and other trade finance related products, factoring and leasing. Fees paid for distribution of
products are all fees paid for the distribution of ING\u2019s products and services through external providers.
Reference is made to Note 28 'Segments' which includes net fee and commission income, as reported to the
the Management Board Banking, disaggregated by line of business and by geographical segment.
23\u00a0 Valuation results and net trading income
Valuation results and net trading income
in EUR million
2024
2023
2022
Securities trading results
996
873
-356
Derivatives trading results
207
116
11
Other trading results
336
273
71
Change in fair value of derivatives relating to
\u2013\u00a0 fair value hedges
-766
-3,028
5,265
\u2013\u00a0 cash flow hedges (ineffective portion)
35
48
20
\u2013\u00a0 other non-trading derivatives
1,923
563
1,164
Change in fair value of assets and liabilities (hedged items)
750
2,962
-5,150
Valuation results on assets and liabilities designated at FVPL (excluding trading)
31
-127
444
Foreign exchange transactions results
-105
1,230
33
3,407
2,910
1,503
In general, the fair value movements are influenced by changes in the market conditions, such as stock
prices, credit spreads, interest rates and currency exchange rates.
Net trading income relates to trading assets and trading liabilities which include assets and liabilities that are
classified under IFRS as Trading but are closely related to servicing the needs of the clients of ING. ING offers
products that are traded on the financial markets to institutional clients, corporate clients, and governments.
ING\u2019s trading books are managed based on internal limits and comprise a mix of products with results which
could be offset. A significant part of the derivatives in the trading portfolio are related to servicing corporate
clients in their risk management to hedge for example currency or interest rate exposures. From a risk
perspective, the gross amount of trading assets must be considered together with the gross amount of
trading liabilities, which are presented separately on the statement of financial position. However, IFRS does
not always allow the netting of these positions in the statement of financial position. Reference is made to
Note 4 'Financial assets at fair value through profit or loss' and Note 14 'Financial liabilities at fair value
through profit or loss' for information on trading assets and trading liabilities respectively.
Securities trading results include the results of market making in instruments such as government securities,
equity securities, corporate debt securities, money-market instruments. Derivatives trading results include
the results of derivatives such as interest rate swaps, options, futures, and forward contracts. Trading gains
and losses relating to trading securities still held as at 31\u00a0December 2024 amount to EUR 20 million (2023:
EUR 160 million; 2022 : EUR\u00a0-157 million). The majority of the risks involved in security and currency trading
are economically hedged with derivatives. The securities trading results are partly offset by results on these
derivatives. The result of these derivatives is included in Derivatives trading results.
Other trading results include the results of trading loans and funds entrusted.
Foreign exchange transactions results include gains and losses from spot and forward contracts, options,
futures, and translated foreign currency assets and liabilities. The result on currency trading is included in
foreign exchange transactions results.
\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. In 2024, fluctuations in interest rate had a
significant impact on 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 33 'Derivatives and hedge accounting' for information on derivatives used for hedge accounting.
Furthermore, derivatives trading results are also impacted by fair value movements arising from changes in
credit spreads (CVA and DVA), bid offer spreads, model risk and incremental cost of funding on derivatives
(FVA and CollVA). Refer to Note 32 'Fair value of assets and liabilities' for information on these valuation
adjustments.
24\u00a0 Investment income
Investment income
in EUR million
2024
2023
2022
Dividend income
117
105
149
Realised gains/losses on disposal of debt instruments measured at FVOCI
-104
-11
32
Income from and fair value gains/losses on investment properties
-1
13
95
181
In 2024, 2023 and 2022 dividend income mainly consists of dividend received from ING\u2019s equity stake in Bank
of Beijing.
25\u00a0 Other net income
In 2024, Other net income of EUR -3 million (2023: EUR -146 million; 2022 : EUR -369 million) includes EUR
-159 million (2023: EUR -244 million ; 2022: EUR -333 million) net monetary loss reflecting the IAS 29
hyperinflation impact in T\u00fcrkiye related to the indexation of T\u00fcrkiye's statement of financial position and
statement of profit or loss with an offsetting effect in the currency translation reserve. Other net income in
2024 also includes EUR 53 million receivable related to a prior insolvency of a financial institution in the
Netherlands and a result of EUR 21 million on the sale of the remaining NNHB mortgages. Furthermore, it
includes the positive recovery of defaulted receivables of EUR 27 million (2023 EUR 25 million; 2022 EUR 32
million).
Other net income as per 31 December 2022 includes an amount of EUR -307 million loss recognised to
unwind a macro fair value hedge of deposits, which led to a timing difference with expected fair value.
Furthermore, it includes the proceeds of the agreement with Boursorama after our exit from the retail
banking market in France of EUR 125 million and a gain of EUR 67 million from a legacy entity in Retail
Belgium.
", "dimensions": { "concept": "ifrs-full:DisclosureOfRevenueExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-718": { "value": "
21\u00a0 Net interest income
Net interest income1
in EUR million
2024
2023
2022
2024
2023
2022
Interest income on loans2
33,892
31,850
19,429
Interest expense on deposits3
16,849
13,282
5,321
Interest income on debt securities at amortised cost
1,204
877
591
Interest expense on debt securities in issue
3,796
2,856
859
Interest income on financial assets at fair value through OCI
1,481
1,078
510
Interest expense on subordinated loans
752
707
646
Interest income on non-trading derivatives (hedge accounting)
12,644
10,682
4,011
Interest expense on non-trading derivatives (hedge accounting)
13,767
11,849
4,144
Total interest income using effective interest rate method
49,221
44,486
24,541
Total interest expense using effective interest rate method
35,164
28,693
10,969
Interest income on financial assets at fair value through profit or loss
6,343
4,934
1,444
Interest expense on financial liabilities at fair value through profit or loss
5,479
4,410
1,237
Interest income on non-trading derivatives (no hedge accounting)
3,168
2,637
2,390
Interest expense on non-trading derivatives (no hedge accounting)
3,308
3,131
2,411
Interest income other
173
171
101
Interest expense on lease liabilities
27
28
15
Total other interest income
9,685
7,741
3,935
Interest expense other
178
157
98
Total other interest expense
8,993
7,726
3,761
Total interest income
58,905
52,228
28,476
Total interest expense
44,157
36,419
14,730
Net interest income
14,749
15,809
13,745
1 Table has been updated to a more aggregated view for presentation purposes and comparatives have been adjusted accordingly. Negative interest on assets and liabilities is no longer presented separately. Furthermore, interest expense on deposits from customers and banks is
now presented on a combined basis within Interest expense on deposits. Refer to footnote 2 and 3.
2 Includes interest income on loans to customers and banks, cash balances as well as negative interest on liabilities. Negative interest on liabilities amounted to EUR 8 million (2023: EUR 19 million; 2022: EUR 892 million).
3 Includes interest paid on deposits from customers and banks, senior non-preferred debt and negative interest on assets. Negative interest on assets amounted to EUR 1 million (2023: EUR nil; 2022: EUR 285 million).
In 2022, a one-off adjustment was recorded in interest income on loans regarding the credit moratoria in
Poland (EUR -343 million).
Due to prevalent rates during the comparative years, Negative interest on liabilities includes the ECB funding
rate benefit from the TLTRO III programme of EUR 314 million in 2022, while for 2024 Interest expense on
deposits includes interest paid under the TLTRO III programme of EUR 59 million (2023: EUR 557 million). The
funding under this programme was fully repaid during the first quarter of 2024.
The ECB funding rate benefit in 2022 caused the discontinuation of the fair value hedge accounting
relationship on TLTRO III, impacting net interest income of 2022 for an amount of EUR -483 million", "dimensions": { "concept": "ifrs-full:DisclosureOfInterestIncomeExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-717": { "value": "
21\u00a0 Net interest income
Net interest income1
in EUR million
2024
2023
2022
2024
2023
2022
Interest income on loans2
33,892
31,850
19,429
Interest expense on deposits3
16,849
13,282
5,321
Interest income on debt securities at amortised cost
1,204
877
591
Interest expense on debt securities in issue
3,796
2,856
859
Interest income on financial assets at fair value through OCI
1,481
1,078
510
Interest expense on subordinated loans
752
707
646
Interest income on non-trading derivatives (hedge accounting)
12,644
10,682
4,011
Interest expense on non-trading derivatives (hedge accounting)
13,767
11,849
4,144
Total interest income using effective interest rate method
49,221
44,486
24,541
Total interest expense using effective interest rate method
35,164
28,693
10,969
Interest income on financial assets at fair value through profit or loss
6,343
4,934
1,444
Interest expense on financial liabilities at fair value through profit or loss
5,479
4,410
1,237
Interest income on non-trading derivatives (no hedge accounting)
3,168
2,637
2,390
Interest expense on non-trading derivatives (no hedge accounting)
3,308
3,131
2,411
Interest income other
173
171
101
Interest expense on lease liabilities
27
28
15
Total other interest income
9,685
7,741
3,935
Interest expense other
178
157
98
Total other interest expense
8,993
7,726
3,761
Total interest income
58,905
52,228
28,476
Total interest expense
44,157
36,419
14,730
Net interest income
14,749
15,809
13,745
1 Table has been updated to a more aggregated view for presentation purposes and comparatives have been adjusted accordingly. Negative interest on assets and liabilities is no longer presented separately. Furthermore, interest expense on deposits from customers and banks is
now presented on a combined basis within Interest expense on deposits. Refer to footnote 2 and 3.
2 Includes interest income on loans to customers and banks, cash balances as well as negative interest on liabilities. Negative interest on liabilities amounted to EUR 8 million (2023: EUR 19 million; 2022: EUR 892 million).
3 Includes interest paid on deposits from customers and banks, senior non-preferred debt and negative interest on assets. Negative interest on assets amounted to EUR 1 million (2023: EUR nil; 2022: EUR 285 million).
In 2022, a one-off adjustment was recorded in interest income on loans regarding the credit moratoria in
Poland (EUR -343 million).
Due to prevalent rates during the comparative years, Negative interest on liabilities includes the ECB funding
rate benefit from the TLTRO III programme of EUR 314 million in 2022, while for 2024 Interest expense on
deposits includes interest paid under the TLTRO III programme of EUR 59 million (2023: EUR 557 million). The
funding under this programme was fully repaid during the first quarter of 2024.
The ECB funding rate benefit in 2022 caused the discontinuation of the fair value hedge accounting
relationship on TLTRO III, impacting net interest income of 2022 for an amount of EUR -483 million.", "dimensions": { "concept": "ifrs-full:DisclosureOfInterestExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-716": { "value": "
21\u00a0 Net interest income
Net interest income1
in EUR million
2024
2023
2022
2024
2023
2022
Interest income on loans2
33,892
31,850
19,429
Interest expense on deposits3
16,849
13,282
5,321
Interest income on debt securities at amortised cost
1,204
877
591
Interest expense on debt securities in issue
3,796
2,856
859
Interest income on financial assets at fair value through OCI
1,481
1,078
510
Interest expense on subordinated loans
752
707
646
Interest income on non-trading derivatives (hedge accounting)
12,644
10,682
4,011
Interest expense on non-trading derivatives (hedge accounting)
13,767
11,849
4,144
Total interest income using effective interest rate method
49,221
44,486
24,541
Total interest expense using effective interest rate method
35,164
28,693
10,969
Interest income on financial assets at fair value through profit or loss
6,343
4,934
1,444
Interest expense on financial liabilities at fair value through profit or loss
5,479
4,410
1,237
Interest income on non-trading derivatives (no hedge accounting)
3,168
2,637
2,390
Interest expense on non-trading derivatives (no hedge accounting)
3,308
3,131
2,411
Interest income other
173
171
101
Interest expense on lease liabilities
27
28
15
Total other interest income
9,685
7,741
3,935
Interest expense other
178
157
98
Total other interest expense
8,993
7,726
3,761
Total interest income
58,905
52,228
28,476
Total interest expense
44,157
36,419
14,730
Net interest income
14,749
15,809
13,745
1 Table has been updated to a more aggregated view for presentation purposes and comparatives have been adjusted accordingly. Negative interest on assets and liabilities is no longer presented separately. Furthermore, interest expense on deposits from customers and banks is
now presented on a combined basis within Interest expense on deposits. Refer to footnote 2 and 3.
2 Includes interest income on loans to customers and banks, cash balances as well as negative interest on liabilities. Negative interest on liabilities amounted to EUR 8 million (2023: EUR 19 million; 2022: EUR 892 million).
3 Includes interest paid on deposits from customers and banks, senior non-preferred debt and negative interest on assets. Negative interest on assets amounted to EUR 1 million (2023: EUR nil; 2022: EUR 285 million).
In 2022, a one-off adjustment was recorded in interest income on loans regarding the credit moratoria in
Poland (EUR -343 million).
Due to prevalent rates during the comparative years, Negative interest on liabilities includes the ECB funding
rate benefit from the TLTRO III programme of EUR 314 million in 2022, while for 2024 Interest expense on
deposits includes interest paid under the TLTRO III programme of EUR 59 million (2023: EUR 557 million). The
funding under this programme was fully repaid during the first quarter of 2024.
The ECB funding rate benefit in 2022 caused the discontinuation of the fair value hedge accounting
relationship on TLTRO III, impacting net interest income of 2022 for an amount of EUR -483 million.", "dimensions": { "concept": "ifrs-full:DisclosureOfInterestIncomeExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-720": { "value": "
22\u00a0 Net fee and commission income
Net fee and commission income
in EUR million
2024
2023
2022
Fee and commission income
Payment Services
2,219
2,062
1,888
Securities business
734
584
632
Insurance and other broking
594
529
682
Portfolio management
699
625
600
Lending business
650
602
556
Financial guarantees and other commitments
454
459
496
Other fee and commission income
249
239
232
Total fee and commission income
5,598
5,100
5,085
Fee and commission expenses
Payment Services
756
704
600
Securities business
147
129
160
Distribution of products
475
480
555
Other fee and commission expenses
218
202
184
Total fee and commission expenses
1,596
1,514
1,499
Net fee and commission income
4,002
3,586
3,586
Payment services fees are earned for providing services for deposit accounts and cards, cash management
and transaction processing including interchange. Securities fees and commissions are fees for securities
brokerage and securities underwriting. Portfolio management fees include fees earned for asset
management activities, fiduciary and related activities in which ING holds or invests assets on behalf of its
customers. Fees and commissions from lending (syndication) business include income earned for lending
advisory, origination, underwriting and loan commitments which are not part of the effective interest rate.
Financial guarantees and other commitments fees and commissions are earned from bank guarantees,
letters of credit and other trade finance related products, factoring and leasing. Fees paid for distribution of
products are all fees paid for the distribution of ING\u2019s products and services through external providers.
Reference is made to Note 28 'Segments' which includes net fee and commission income, as reported to the
the Management Board Banking, disaggregated by line of business and by geographical segment.
", "dimensions": { "concept": "ifrs-full:DisclosureOfFeeAndCommissionIncomeExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-719": { "value": "
22\u00a0 Net fee and commission income
Net fee and commission income
in EUR million
2024
2023
2022
Fee and commission income
Payment Services
2,219
2,062
1,888
Securities business
734
584
632
Insurance and other broking
594
529
682
Portfolio management
699
625
600
Lending business
650
602
556
Financial guarantees and other commitments
454
459
496
Other fee and commission income
249
239
232
Total fee and commission income
5,598
5,100
5,085
Fee and commission expenses
Payment Services
756
704
600
Securities business
147
129
160
Distribution of products
475
480
555
Other fee and commission expenses
218
202
184
Total fee and commission expenses
1,596
1,514
1,499
Net fee and commission income
4,002
3,586
3,586
Payment services fees are earned for providing services for deposit accounts and cards, cash management
and transaction processing including interchange. Securities fees and commissions are fees for securities
brokerage and securities underwriting. Portfolio management fees include fees earned for asset
management activities, fiduciary and related activities in which ING holds or invests assets on behalf of its
customers. Fees and commissions from lending (syndication) business include income earned for lending
advisory, origination, underwriting and loan commitments which are not part of the effective interest rate.
Financial guarantees and other commitments fees and commissions are earned from bank guarantees,
letters of credit and other trade finance related products, factoring and leasing. Fees paid for distribution of
products are all fees paid for the distribution of ING\u2019s products and services through external providers.
Reference is made to Note 28 'Segments' which includes net fee and commission income, as reported to the
the Management Board Banking, disaggregated by line of business and by geographical segment.
", "dimensions": { "concept": "ifrs-full:DisclosureOfRevenueFromContractsWithCustomersExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-721": { "value": "
23\u00a0 Valuation results and net trading income
Valuation results and net trading income
in EUR million
2024
2023
2022
Securities trading results
996
873
-356
Derivatives trading results
207
116
11
Other trading results
336
273
71
Change in fair value of derivatives relating to
\u2013\u00a0 fair value hedges
-766
-3,028
5,265
\u2013\u00a0 cash flow hedges (ineffective portion)
35
48
20
\u2013\u00a0 other non-trading derivatives
1,923
563
1,164
Change in fair value of assets and liabilities (hedged items)
750
2,962
-5,150
Valuation results on assets and liabilities designated at FVPL (excluding trading)
31
-127
444
Foreign exchange transactions results
-105
1,230
33
3,407
2,910
1,503
In general, the fair value movements are influenced by changes in the market conditions, such as stock
prices, credit spreads, interest rates and currency exchange rates.
Net trading income relates to trading assets and trading liabilities which include assets and liabilities that are
classified under IFRS as Trading but are closely related to servicing the needs of the clients of ING. ING offers
products that are traded on the financial markets to institutional clients, corporate clients, and governments.
ING\u2019s trading books are managed based on internal limits and comprise a mix of products with results which
could be offset. A significant part of the derivatives in the trading portfolio are related to servicing corporate
clients in their risk management to hedge for example currency or interest rate exposures. From a risk
perspective, the gross amount of trading assets must be considered together with the gross amount of
trading liabilities, which are presented separately on the statement of financial position. However, IFRS does
not always allow the netting of these positions in the statement of financial position. Reference is made to
Note 4 'Financial assets at fair value through profit or loss' and Note 14 'Financial liabilities at fair value
through profit or loss' for information on trading assets and trading liabilities respectively.
Securities trading results include the results of market making in instruments such as government securities,
equity securities, corporate debt securities, money-market instruments. Derivatives trading results include
the results of derivatives such as interest rate swaps, options, futures, and forward contracts. Trading gains
and losses relating to trading securities still held as at 31\u00a0December 2024 amount to EUR 20 million (2023:
EUR 160 million; 2022 : EUR\u00a0-157 million). The majority of the risks involved in security and currency trading
are economically hedged with derivatives. The securities trading results are partly offset by results on these
derivatives. The result of these derivatives is included in Derivatives trading results.
Other trading results include the results of trading loans and funds entrusted.
Foreign exchange transactions results include gains and losses from spot and forward contracts, options,
futures, and translated foreign currency assets and liabilities. The result on currency trading is included in
foreign exchange transactions results.
\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. In 2024, fluctuations in interest rate had a
significant impact on 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 33 'Derivatives and hedge accounting' for information on derivatives used for hedge accounting.
Furthermore, derivatives trading results are also impacted by fair value movements arising from changes in
credit spreads (CVA and DVA), bid offer spreads, model risk and incremental cost of funding on derivatives
(FVA and CollVA). Refer to Note 32 'Fair value of assets and liabilities' for information on these valuation
adjustments.", "dimensions": { "concept": "ifrs-full:DisclosureOfTradingIncomeExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-723": { "value": "
26\u00a0 Staff expenses
Staff expenses
in EUR million
2024
2023
2022
Salaries
4,906
4,559
4,145
Pension costs and other staff-related benefit costs
455
418
390
Social security costs
690
635
584
Share-based compensation arrangements
45
30
27
External employees
720
776
738
Education
49
50
47
Other staff costs
319
256
222
7,184
6,725
6,152
Share-based compensation arrangements include EUR 45\u00a0million (2023: EUR 30 million; 2022: EUR 26 million)
relating to equity-settled share-based payment arrangements. Cash-settled share-based payment
arrangements were terminated in 2023.
Number of employees
Netherlands
Rest of the world
Total
2024
2023
2022
2024
2023
2022
2024
2023
2022
Total average number of
internal employees at full
time equivalent basis
14,821
14,449
14,488
46,301
44,985
43,081
61,121
59,434
57,569
Remuneration of senior management, Management Board Banking and Supervisory
Board
Reference is made to Note 43 'Related parties'.
Share plans
ING grants various types of share awards, namely deferred and upfront shares, which form part of the
variable remuneration offering via the Long-term Sustainable Performance Plan (LSPP). The entitlement to
the LSPP share awards is granted conditionally. If the participant remains in employment for an
uninterrupted period between the grant date and the vesting date, the entitlement becomes unconditional,
with the exception of the upfront shares which are immediately vested upon grant. Upfront and deferred
shares awarded to the 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 for
staff and up to 60 months for Board. ING has the authority to apply a holdback to awarded but unvested
shares and a clawback to vested shares.
The share awards granted in 2024 relate to the performance year 2023. In 2024, 180,994 share awards
(2023: 224,796; 2022: 193,157) were granted to the members of the Management Board Banking. To senior
management and other employees 4,248,400 share awards (2023: 3,244,951; 2022: 2,913,926) were
granted.
Changes in share awards
Share awards (in numbers)
Weighted average grant date fair values
(in euros)
2024
2023
2022
2024
2023
2022
Opening balance as at 1 January
3,895,787
3,697,542
3,672,659
8.81
7.97
7.60
Granted
4,429,394
3,469,747
3,107,083
13.75
9.71
8.99
Vested
-3,343,429
-3,113,115
-2,962,698
12.29
8.83
8.60
Forfeited
-128,223
-158,387
-119,502
10.73
8.54
7.63
Closing balance
4,853,529
3,895,787
3,697,542
10.88
8.81
7.97
The fair value of share awards granted is recognised as an expense under Staff expenses and is allocated
over the vesting period of the share awards. The fair value calculation takes into account the current share
prices, expected volatilities and the dividend yield of ING shares.
As at 31\u00a0December 2024, total unrecognised compensation costs related to share awards amount to EUR 25
million (2023: EUR 15 million; 2022: EUR 13 million). These costs are expected to be recognised over a
weighted average period of 2.0 years (2023: 2.0 years; 2022: 1.9 years).
30\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 post-employment
benefits are primarily discounts on ING products.
Defined contribution plans
ING, as part of the labour agreements with its employees, 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's contribution is
recognised as an expense which amounted in 2024 to EUR 423 million (2023: EUR 391 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
2024
2023
2024
2023
2024
2023
The Netherlands
325
331
415
426
-90
-95
United States
250
257
235
245
15
12
United Kingdom
1,206
1,257
751
790
455
467
Belgium
513
516
450
473
63
43
Other countries
341
317
368
353
-26
-37
Funded status (Net defined benefit asset/liability)
2,636
2,678
2,219
2,288
416
390
Presented as:
- Other assets
568
554
- Other liabilities
-152
-164
416
390
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 2024. 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.
Changes in the fair value of plan assets for the period were as follows:
Changes in fair value of plan assets
in EUR million
2024
2023
Opening balance as at 1 January
2,678
2,637
Interest income
106
115
Remeasurements: Return on plan assets excluding amounts included in interest income
-118
-8
Employer's contribution
23
28
Participants contributions
4
4
Benefits paid
-128
-119
Effect of curtailment or settlement
-8
Exchange rate differences
79
22
Closing balance
2,636
2,678
Actual return on the plan assets
-12
107
As at 31\u00a0December 2024 the defined benefit plans did not hold any direct investments in ING Groep N.V.
(2023: nil). During 2024 and 2023 there were no purchases or sales of assets between ING and the pension
funds.
ING does not manage the pension funds and thus receives no compensation for fund management. The
pension funds have not engaged ING in any swap or derivative transactions to manage the risk of the
pension funds.
No plan assets are expected to be returned to ING Bank during 2025.
Changes in the present value of the defined benefit obligation and other post-employment benefits for the
period were as follows:
Changes in defined benefit obligation and other post-employment benefits
Defined benefit
obligation
Other post-
employment
benefits
in EUR million
2024
2023
2024
2023
Opening balance as at 1 January
2,288
2,159
30
29
Current service cost
28
27
1
1
Interest cost
87
92
3
2
Remeasurements: Actuarial gains and losses arising from changes in
demographic assumptions
-3
-9
Remeasurements: Actuarial gains and losses arising from changes in
financial assumptions
-94
127
5
1
Participants\u2019 contributions
3
3
Benefits paid
-132
-123
-1
-1
Past service cost
1
1
Effect of curtailment or settlement
-9
Exchange rate differences and other changes
51
12
1
-2
Closing balance
2,219
2,288
38
30
Amounts recognised directly in Other comprehensive income were as follows:
Changes in the net defined benefit assets/liability remeasurement reserve
in EUR million
2024
2023
Opening balance as at 1 January
-317
-232
Remeasurement of plan assets
-118
-8
Actuarial gains and losses arising from changes in demographic assumptions
3
9
Actuarial gains and losses arising from changes in financial assumptions
94
-127
Taxation and Exchange rate differences
5
40
Total Other comprehensive income movement for the year
-16
-85
Closing balance
-333
-317
In 2024, the EUR -118\u00a0 million (2023: EUR -8\u00a0 million) of remeasurements of plan assets, that is recognised as
a loss in other comprehensive income, is driven by yield changes on investments. The EUR 94\u00a0 million (2023:
EUR -127\u00a0 million) of actuarial gains arising from changes in financial assumptions in the calculation of the
defined benefit obligation is mainly due to an increase in discount rates.
The accumulated amount of remeasurements recognised directly in Other comprehensive income is EUR
-447\u00a0million(EUR -333\u00a0million after tax) as at 31\u00a0December 2024 (2023: EUR -397\u00a0 million; EUR -317\u00a0 million
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
2024
2023
2022
2024
2023
2022
2024
2023
2022
Current service cost
28
27
33
1
1
1
29
28
34
Past service cost
1
1
-1
1
1
Net Interest cost
-19
-23
-8
3
2
1
-16
-21
-6
Effect of curtailment or settlement
-1
-1
Defined benefit plans
9
5
26
4
3
2
13
8
27
Defined contribution plans
423
391
364
Pension and other post employment
benefits
435
399
392
Other staff related benefits
20
19
-2
Pension and other staff-related benefits
455
418
390
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 2024 was 4.4% (2023: 4.0%) 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 2024 was 5.7% (2023:
5.2%).
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 with 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
EUR 212 million (increase) and EUR 253 million (decrease), respectively.
Expected cash flows
ING Bank\u2019s subsidiaries should fund the cost of the entitlements expected to be earned on a yearly basis.
For 2025, the expected contributions to defined benefit pension plans are EUR -48 million.
The benefit payments for defined benefit and other post-employment benefits expected to be made by the
plan between 2025-2029 are estimated to be between EUR 145 million and EUR 156 million per year. From
2029 to 2033, the total payments made by the plan are expected to be EUR -768 million.
", "dimensions": { "concept": "ifrs-full:DisclosureOfEmployeeBenefitsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-722": { "value": "
26\u00a0 Staff expenses
Staff expenses
in EUR million
2024
2023
2022
Salaries
4,906
4,559
4,145
Pension costs and other staff-related benefit costs
455
418
390
Social security costs
690
635
584
Share-based compensation arrangements
45
30
27
External employees
720
776
738
Education
49
50
47
Other staff costs
319
256
222
7,184
6,725
6,152
Share-based compensation arrangements include EUR 45\u00a0million (2023: EUR 30 million; 2022: EUR 26 million)
relating to equity-settled share-based payment arrangements. Cash-settled share-based payment
arrangements were terminated in 2023.
Number of employees
Netherlands
Rest of the world
Total
2024
2023
2022
2024
2023
2022
2024
2023
2022
Total average number of
internal employees at full
time equivalent basis
14,821
14,449
14,488
46,301
44,985
43,081
61,121
59,434
57,569
Remuneration of senior management, Management Board Banking and Supervisory
Board
Reference is made to Note 43 'Related parties'.
Share plans
ING grants various types of share awards, namely deferred and upfront shares, which form part of the
variable remuneration offering via the Long-term Sustainable Performance Plan (LSPP). The entitlement to
the LSPP share awards is granted conditionally. If the participant remains in employment for an
uninterrupted period between the grant date and the vesting date, the entitlement becomes unconditional,
with the exception of the upfront shares which are immediately vested upon grant. Upfront and deferred
shares awarded to the 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 for
staff and up to 60 months for Board. ING has the authority to apply a holdback to awarded but unvested
shares and a clawback to vested shares.
The share awards granted in 2024 relate to the performance year 2023. In 2024, 180,994 share awards
(2023: 224,796; 2022: 193,157) were granted to the members of the Management Board Banking. To senior
management and other employees 4,248,400 share awards (2023: 3,244,951; 2022: 2,913,926) were
granted.
Changes in share awards
Share awards (in numbers)
Weighted average grant date fair values
(in euros)
2024
2023
2022
2024
2023
2022
Opening balance as at 1 January
3,895,787
3,697,542
3,672,659
8.81
7.97
7.60
Granted
4,429,394
3,469,747
3,107,083
13.75
9.71
8.99
Vested
-3,343,429
-3,113,115
-2,962,698
12.29
8.83
8.60
Forfeited
-128,223
-158,387
-119,502
10.73
8.54
7.63
Closing balance
4,853,529
3,895,787
3,697,542
10.88
8.81
7.97
The fair value of share awards granted is recognised as an expense under Staff expenses and is allocated
over the vesting period of the share awards. The fair value calculation takes into account the current share
prices, expected volatilities and the dividend yield of ING shares.
As at 31\u00a0December 2024, total unrecognised compensation costs related to share awards amount to EUR 25
million (2023: EUR 15 million; 2022: EUR 13 million). These costs are expected to be recognised over a
weighted average period of 2.0 years (2023: 2.0 years; 2022: 1.9 years).
27\u00a0 Other operating expenses
Other operating expenses
in EUR million
2024
2023
2022
Regulatory costs
882
1,042
1,250
Audit and non-audit services
43
36
31
IT related expenses
1,048
948
818
Advertising and public relations
441
369
331
External advisory fees
315
294
306
Office expenses
277
289
273
Travel and accommodation expenses
126
125
91
Contributions and subscriptions
133
122
109
Postal charges
39
36
31
Depreciation of property and equipment
457
461
485
Amortisation of intangible assets
216
213
226
(Reversals of) impairments of property and equipment
18
32
19
(Reversals of) impairments of intangible assets
13
6
60
Addition to / (unused amounts reversed of) provision for reorganisations
142
173
170
Addition to / (unused amounts reversed of) other provisions
76
70
117
Other
705
622
723
4,931
4,838
5,040
Reference is made to Note 9 'Property and equipment' for (reversals of) impairments of property and
equipment and Note 10 'Intangible assets' for (reversals of) impairments of intangible assets.
For 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 39 '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 2024, are
contributions to DGS of EUR 230 million (2023: EUR 320 million; 2022: EUR 425 million) mainly related to the
Netherlands, Germany, Belgium and Poland and contributions to the SRF and local resolution funds of EUR
35 million (2023: EUR 251 million; 2022: EUR 354 million). In 2024 local bank taxes increased by EUR 145
million from EUR 472 million in 2023 to EUR 617 million (2022: EUR 470 million).
Audit and non-audit services
Audit and non-audit services include fees for services provided by the Bank\u2019s auditors and increases are due
to one-off additional audit procedures and inflation.", "dimensions": { "concept": "ifrs-full:DisclosureOfExpensesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-724": { "value": "
Number of employees
Netherlands
Rest of the world
Total
2024
2023
2022
2024
2023
2022
2024
2023
2022
Total average number of
internal employees at full
time equivalent basis
14,821
14,449
14,488
46,301
44,985
43,081
61,121
59,434
57,569
", "dimensions": { "concept": "ifrs-full:DisclosureOfInformationAboutEmployeesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-725": { "value": "
Share plans
ING grants various types of share awards, namely deferred and upfront shares, which form part of the
variable remuneration offering via the Long-term Sustainable Performance Plan (LSPP). The entitlement to
the LSPP share awards is granted conditionally. If the participant remains in employment for an
uninterrupted period between the grant date and the vesting date, the entitlement becomes unconditional,
with the exception of the upfront shares which are immediately vested upon grant. Upfront and deferred
shares awarded to the 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 for
staff and up to 60 months for Board. ING has the authority to apply a holdback to awarded but unvested
shares and a clawback to vested shares.
The share awards granted in 2024 relate to the performance year 2023. In 2024, 180,994 share awards
(2023: 224,796; 2022: 193,157) were granted to the members of the Management Board Banking. To senior
management and other employees 4,248,400 share awards (2023: 3,244,951; 2022: 2,913,926) were
granted.
Changes in share awards
Share awards (in numbers)
Weighted average grant date fair values
(in euros)
2024
2023
2022
2024
2023
2022
Opening balance as at 1 January
3,895,787
3,697,542
3,672,659
8.81
7.97
7.60
Granted
4,429,394
3,469,747
3,107,083
13.75
9.71
8.99
Vested
-3,343,429
-3,113,115
-2,962,698
12.29
8.83
8.60
Forfeited
-128,223
-158,387
-119,502
10.73
8.54
7.63
Closing balance
4,853,529
3,895,787
3,697,542
10.88
8.81
7.97
The fair value of share awards granted is recognised as an expense under Staff expenses and is allocated
over the vesting period of the share awards. The fair value calculation takes into account the current share
prices, expected volatilities and the dividend yield of ING shares.
As at 31\u00a0December 2024, total unrecognised compensation costs related to share awards amount to EUR 25
million (2023: EUR 15 million; 2022: EUR 13 million). These costs are expected to be recognised over a
weighted average period of 2.0 years (2023: 2.0 years; 2022: 1.9 years).", "dimensions": { "concept": "ifrs-full:DisclosureOfSharebasedPaymentArrangementsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-727": { "value": "
27\u00a0 Other operating expenses
Other operating expenses
in EUR million
2024
2023
2022
Regulatory costs
882
1,042
1,250
Audit and non-audit services
43
36
31
IT related expenses
1,048
948
818
Advertising and public relations
441
369
331
External advisory fees
315
294
306
Office expenses
277
289
273
Travel and accommodation expenses
126
125
91
Contributions and subscriptions
133
122
109
Postal charges
39
36
31
Depreciation of property and equipment
457
461
485
Amortisation of intangible assets
216
213
226
(Reversals of) impairments of property and equipment
18
32
19
(Reversals of) impairments of intangible assets
13
6
60
Addition to / (unused amounts reversed of) provision for reorganisations
142
173
170
Addition to / (unused amounts reversed of) other provisions
76
70
117
Other
705
622
723
4,931
4,838
5,040
Reference is made to Note 9 'Property and equipment' for (reversals of) impairments of property and
equipment and Note 10 'Intangible assets' for (reversals of) impairments of intangible assets.
For 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 39 '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 2024, are
contributions to DGS of EUR 230 million (2023: EUR 320 million; 2022: EUR 425 million) mainly related to the
Netherlands, Germany, Belgium and Poland and contributions to the SRF and local resolution funds of EUR
35 million (2023: EUR 251 million; 2022: EUR 354 million). In 2024 local bank taxes increased by EUR 145
million from EUR 472 million in 2023 to EUR 617 million (2022: EUR 470 million).
Audit and non-audit services
Audit and non-audit services include fees for services provided by the Bank\u2019s auditors and increases are due
to one-off additional audit procedures and inflation.", "dimensions": { "concept": "ifrs-full:DisclosureOfOtherOperatingExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-726": { "value": "
27\u00a0 Other operating expenses
Other operating expenses
in EUR million
2024
2023
2022
Regulatory costs
882
1,042
1,250
Audit and non-audit services
43
36
31
IT related expenses
1,048
948
818
Advertising and public relations
441
369
331
External advisory fees
315
294
306
Office expenses
277
289
273
Travel and accommodation expenses
126
125
91
Contributions and subscriptions
133
122
109
Postal charges
39
36
31
Depreciation of property and equipment
457
461
485
Amortisation of intangible assets
216
213
226
(Reversals of) impairments of property and equipment
18
32
19
(Reversals of) impairments of intangible assets
13
6
60
Addition to / (unused amounts reversed of) provision for reorganisations
142
173
170
Addition to / (unused amounts reversed of) other provisions
76
70
117
Other
705
622
723
4,931
4,838
5,040
Reference is made to Note 9 'Property and equipment' for (reversals of) impairments of property and
equipment and Note 10 'Intangible assets' for (reversals of) impairments of intangible assets.
For 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 39 '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 2024, are
contributions to DGS of EUR 230 million (2023: EUR 320 million; 2022: EUR 425 million) mainly related to the
Netherlands, Germany, Belgium and Poland and contributions to the SRF and local resolution funds of EUR
35 million (2023: EUR 251 million; 2022: EUR 354 million). In 2024 local bank taxes increased by EUR 145
million from EUR 472 million in 2023 to EUR 617 million (2022: EUR 470 million).
Audit and non-audit services
Audit and non-audit services include fees for services provided by the Bank\u2019s auditors and increases are due
to one-off additional audit procedures and inflation.", "dimensions": { "concept": "ifrs-full:DisclosureOfDepreciationAndAmortisationExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-728": { "value": "
Other operating expenses
in EUR million
2024
2023
2022
Regulatory costs
882
1,042
1,250
Audit and non-audit services
43
36
31
IT related expenses
1,048
948
818
Advertising and public relations
441
369
331
External advisory fees
315
294
306
Office expenses
277
289
273
Travel and accommodation expenses
126
125
91
Contributions and subscriptions
133
122
109
Postal charges
39
36
31
Depreciation of property and equipment
457
461
485
Amortisation of intangible assets
216
213
226
(Reversals of) impairments of property and equipment
18
32
19
(Reversals of) impairments of intangible assets
13
6
60
Addition to / (unused amounts reversed of) provision for reorganisations
142
173
170
Addition to / (unused amounts reversed of) other provisions
76
70
117
Other
705
622
723
4,931
4,838
5,040
Audit and non-audit services
Audit and non-audit services include fees for services provided by the Bank\u2019s auditors and increases are due
to one-off additional audit procedures and inflation.", "dimensions": { "concept": "ifrs-full:DisclosureOfAuditorsRemunerationExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-729": { "value": "
28\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 'Basis of preparation and material accounting policy information'. The results for the period for each
reportable segment are after intercompany and intersegment eliminations and are those reviewed by the
CODM to assess performance of the segments. Corporate expenses are allocated to business lines based on
time spent by head office personnel, the relative number of staff, or on the basis of income, expenses and/or
assets of the segment. Interest income per segment is reported as net interest income because
management relies primarily on net (rather than gross) interest revenue to assess the performance of the
segments.
The following table specifies the segments by line of business and the 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
Income from products and services provided to private individuals, business banking clients
and private banking clients in the Netherlands. The main products and services offered are
daily banking, lending, savings, investments and insurance.
Retail Belgium
Income from products and services provided to private individuals, business banking clients
and private banking clients in Belgium and Luxembourg. The main products and services
offered are similar to those in the Netherlands.
Retail Germany
Income from products and services provided to private individuals, business banking clients
and private banking clients in Germany. The main products and services offered are similar to
those in the Netherlands.
Retail Other
Income from products and services provided to private individuals, business banking clients
and private banking clients in the other retail countries. The main products and services offered
are similar to those in the Netherlands.
Wholesale Banking
Income from wholesale banking activities of which the main products are: lending, payments &
cash management, working capital solutions, trade finance, financial markets, corporate
finance and treasury.
Specification of geographical split of the segments
Geographical split of the segments
Main countries
The Netherlands
Belgium
Including Luxembourg
Germany
Other Challengers 1
Australia, Italy, Spain and Portugal
Growth Markets 1
Poland, Romania and T\u00fcrkiye
Wholesale Banking Rest of World
Other countries in Europe & Middle East, Americas, Asia
Other
Corporate Line
1 In 2022, ING discontinued its retail activities in France (Other Challengers) and the Philippines (Growth Markets).
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
includes capital management activities, as ING Bank 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.
Corporate Line includes certain other income and expenses that are not allocated to the banking businesses.
Furthermore, as from 2022, results in the Corporate Line have been impacted by the application of
hyperinflation accounting in the consolidation of our subsidiary in T\u00fcrkiye (IAS 29). Total income for
Corporate Line in 2024 amounted to EUR 97 million compared with EUR 275 million in 2023. This included a
hyperinflation accounting impact of EUR -117 million in 2024 versus EUR -179 million in 2023. Excluding
hyperinflation accounting impact, total income declined by EUR 240 million, mainly attributable to a lower
net interest income from Treasury, partly offset by the recognition of a EUR 53 million receivable related to a
prior insolvency of a financial institution in the Netherlands (recorded in other income). Operating expenses
for Corporate Line were EUR 528 million, 2.4% down from EUR 541 million in 2023. Expenses in 2024 included
a hyperinflation impact of EUR 35 million, EUR 25 million of restructuring costs, EUR 22 million for a one-off
CLA related payment to our staff in the Netherlands and a EUR 21 million litigation provision. Expenses in
2023 had included a hyperinflation impact of EUR 48 million and EUR 51 million that had been provisioned.
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
12 month period
2024
2023
2022
in EUR million
Retail
Nether-
lands
Retail
Belgium
Retail
Germany
Retail
Other
Wholesale
Banking
Corporate
Line
Total
Retail
Nether-
lands
Retail
Belgium
Retail
Germany
Retail
Other
Wholesale
Banking
Corporate
Line
Total
Retail
Nether-
lands
Retail
Belgium
Retail
Germany
Retail
Other 1
Wholesale
Banking
Corporate
Line
Total
Income
Net interest income
3,027
1,959
2,647
3,817
3,259
40
14,749
3,096
2,063
2,862
3,437
4,028
323
15,809
2,888
1,668
1,666
2,725
4,260
539
13,745
Net fee and
commission income
1,049
603
433
609
1,317
-9
4,002
959
502
357
519
1,259
-10
3,586
892
511
437
535
1,217
-6
3,586
Total investment and
other income
835
189
-173
263
2,405
65
3,584
945
117
-67
277
1,771
-37
3,006
417
-32
69
377
849
-464
1,215
\u2013 of which share of
result from associates
and joint ventures
81
8
-36
118
170
0
7
31
107
144
1
5
18
-125
-101
\u2013 of which
revaluations and
trading income
810
81
-160
253
2,478
-55
3,407
898
61
-57
264
1,730
13
2,910
327
113
57
200
952
-146
1,503
Total income
4,910
2,751
2,906
4,688
6,981
97
22,334
5,001
2,683
3,152
4,233
7,057
275
22,401
4,196
2,147
2,172
3,637
6,325
69
18,546
Expenditure
Operating expenses
2,124
1,811
1,303
2,792
3,558
528
12,116
2,135
1,852
1,243
2,479
3,313
541
11,563
2,115
1,786
1,140
2,509
3,114
529
11,193
\u2013 of which Regulatory
expenses
114
206
88
261
212
1
882
212
211
96
252
271
0
1,042
250
244
93
369
293
0
1,250
Addition to loan loss
provisions
-8
134
149
291
627
1
1,194
5
169
119
313
-92
5
520
67
139
131
302
1,220
2
1,861
Total expenses
2,117
1,944
1,452
3,083
4,185
528
13,310
2,140
2,022
1,362
2,792
3,222
546
12,083
2,182
1,924
1,271
2,812
4,334
531
13,053
Result before taxation
2,793
807
1,455
1,605
2,796
-431
9,025
2,861
661
1,790
1,441
3,836
-270
10,318
2,014
223
901
825
1,991
-462
5,493
Taxation
723
210
505
381
693
67
2,580
740
182
631
359
900
114
2,926
540
72
202
254
581
74
1,723
Non-controlling
interests
0
1
221
35
258
0
0
174
61
235
0
3
47
52
1
102
Net result2
2,070
597
949
1,002
2,068
-499
6,187
2,121
479
1,159
908
2,875
-385
7,157
1,474
151
696
525
1,358
-537
3,667
1In 2022, ING discontinued its retail activities in France (Other Challengers) and the Philippines (Growth Markets).
2 Net result reflects the net result attributable to shareholders of the parent.
Geographical split of the segments
12 month period
2024
2023
2022
in EUR million
Nether-
lands
Belgium
Ger-
many
Other
Challen
gers
Growth
markets
Wholesale
Banking
Rest of
World
Other
Total
Nether-
lands
Belgium
Ger-
many
Other
Challen
gers
Growth
markets
Wholesale
Banking
Rest of
World
Other
Total
Nether-
lands
Belgium
Ger-
many
Other
Challen
gers 1
Growth
markets
1
Wholesale
Banking
Rest of
World
Other
Total
Income
Net interest income
3,063
2,478
3,182
2,131
2,409
1,448
37
14,749
3,773
2,712
3,375
2,121
1,961
1,548
320
15,809
3,782
2,065
2,126
1,842
1,462
1,933
534
13,745
Net fee and commission
income
1,329
832
484
337
445
585
-9
4,002
1,239
715
400
285
384
573
-10
3,586
1,171
714
494
290
375
548
-6
3,586
Total investment and other
income
1,889
207
-188
27
408
1,167
73
3,584
1,627
145
-81
21
487
829
-24
3,006
577
-14
94
182
386
449
-460
1,215
\u2013 of which share of result
from associates and joint
ventures
-45
87
8
120
170
31
7
107
144
16
1
5
-123
-101
\u2013 of which revaluations
and trading income
1,916
119
-191
2
403
1,217
-59
3,407
1,568
95
-83
4
479
841
6
2,910
453
174
65
3
377
532
-101
1,503
Total income
6,282
3,517
3,478
2,495
3,262
3,200
102
22,334
6,639
3,573
3,694
2,427
2,833
2,950
286
22,401
5,531
2,765
2,714
2,314
2,223
2,930
69
18,546
Expenditure
Operating expenses
3,026
2,170
1,512
1,454
1,759
1,669
526
12,116
3,065
2,195
1,437
1,320
1,495
1,509
543
11,563
3,001
2,120
1,318
1,380
1,426
1,418
529
11,193
\u2013 of which Regulatory
expenses
159
228
90
61
260
83
1
882
296
243
103
92
207
101
0
1,042
357
283
99
88
324
98
0
1,250
Addition to loan loss
provisions
42
148
222
188
214
378
1
1,194
-111
139
35
166
189
96
5
520
181
230
460
140
230
618
2
1,861
Total expenses
3,068
2,319
1,734
1,642
1,973
2,047
526
13,310
2,954
2,334
1,472
1,486
1,683
1,605
548
12,083
3,182
2,350
1,778
1,519
1,657
2,036
531
13,053
Result before taxation
3,213
1,198
1,744
853
1,289
1,153
-425
9,025
3,685
1,239
2,222
941
1,149
1,345
-263
10,318
2,349
415
936
795
567
894
-463
5,493
Retail Banking
2,793
807
1,455
534
1,071
6,660
2,861
661
1,790
649
792
6,753
2,014
223
901
547
278
0
3,964
Wholesale Banking
420
391
289
319
218
1,153
7
2,796
824
577
432
292
357
1,345
8
3,836
335
192
34
248
288
894
0
1,991
Corporate Line
-431
-431
-270
-270
-462
-462
Result before taxation
3,213
1,198
1,744
853
1,289
1,153
-425
9,025
3,685
1,239
2,222
941
1,149
1,345
-263
10,318
2,349
415
936
795
567
894
-463
5,493
Taxation
847
308
563
272
256
267
66
2,580
909
349
723
282
225
335
104
2,926
658
114
297
258
153
186
58
1,723
Non-controlling interests
0
1
256
258
0
0
234
235
0
3
98
1
102
Net result2
2,367
889
1,179
581
777
886
-491
6,187
2,776
889
1,499
659
690
1,011
-367
7,157
1,691
301
636
537
316
708
-522
3,667
1 In 2022, ING discontinued its retail activities in France (Other Challengers) and the Philippines (Growth Markets).
2 Net result reflects the net result attributable to shareholders of the parent.
", "dimensions": { "concept": "ifrs-full:DisclosureOfEntitysReportableSegmentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-730": { "value": "
29\u00a0 Information on geographical areas
ING Bank \u2019s business lines operate in different geographical areas: the Netherlands, Belgium, Germany, Rest
of Europe and Rest of the World. 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,\u00a0 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 do not include intercompany balances and reconcile to the total assets in the
consolidated statement of financial position of ING Bank.
ING Bank is subject to top-up tax (Global Anti-Base Erosion Model Rules (Pillar Two)) in relation to its
operations in countries where the effective tax rate falls below 15%. This includes Switzerland, Ireland and
Bulgaria as a result of their lower nominal tax rates, as well as Singapore, where special local tax rates for
certain types of income reduce the effective tax rate.
ING Bank has applied a temporary mandatory relief from deferred tax accounting for the impacts of the top-
up tax and accounts for it as a current tax when it is incurred. The total top-up tax that is expected to be paid
by ING Bank per jurisdiction over 2024 amounts to EUR 9.5 million.
Overview Top up tax to be paid per jurisdiction
Country
Top-up tax\u00a0 (EUR million)
Singapore1
6.5
Ireland2
2.1
Bulgaria2
0.6
Switzerland2
0.3
9.5
1 Booked and to be paid in the Netherlands.
2 Booked and to be paid locally.
31\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
2024
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
63
71
-8
126
Financial assets and liabilities at FVPL
-3
-28
12
-19
Depreciation
-13
-9
-22
Cash flow hedges
502
-138
-1
363
Pension and post-employment
benefits
-33
6
1
-5
-1
-32
Other provisions
48
12
1
1
62
Loans and advances
475
-49
427
Unused tax losses carried forward
209
-128
3
85
Other
-154
-41
-9
-5
1
-208
Total
1,096
-102
-219
6
781
Presented in the statement of
financial position as:
\u2013\u00a0 Deferred tax liabilities
-184
-287
\u2013\u00a0 Deferred tax assets
1,280
1,069
1,096
781
The above table shows netted deferred tax amounts related to right-of-use assets and lease liabilities
included in the row \u2018Other\u2019, and includes a deferred tax amount for right-of-use assets of EUR 178 million
(2023: EUR 195 million and 2022: EUR 205 million ) and a deferred tax amount for lease liabilities of EUR 197
million (2023: EUR 217 million and 2022: EUR 231 million).
The deferred tax on cash flow hedges relate to floating rate lending with interest rate swaps. Due to
decreased (longer-term) interest rate yield curve in 2024 there was a positive revaluation of the cash flow
hedge through other comprehensive income. This resulted in a decline in the deferred tax asset by EUR -138
million compared to the decline deferred tax assets in 2023 by EUR -251 million due to the decline in the
interest yield curve. The deferred tax asset in cash flow hedges decreased from EUR 502\u00a0 million in 2023 to
EUR 363\u00a0 million in 2024.
The deferred tax on Loans and advances changes through net result in 2024 EUR -49\u00a0 million (2023: EUR
-140\u00a0 million) relates mainly to valuation changes of collectively assessed expected credit losses.
Unused tax losses carried forward declined by EUR 124 million mainly due to realised results on derivatives
used in Cash flow hedging which in previous years led to a tax loss in Poland.
The deferred tax\u00a0 changes through equity - Other in 2024 of EUR -41 million (2023: EUR 13 million) is due to
FX developments following the USD appreciation and the application of IAS 29 Hyperinflation in T\u00fcrkiye and
also due to the decline in the Credit Liability Reserve due to credit spread tightening.
Changes in deferred tax
in EUR million
2023
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
80
-10
-3
-4
63
Financial assets and liabilities at FVPL
28
-44
13
-3
Depreciation
-13
-6
3
4
-13
Cash flow hedges
752
-251
1
502
Pension and post-employment
benefits
-54
31
-7
-4
-33
Other provisions
59
-12
-3
4
48
Loans and advances
612
8
-140
-6
2
475
Unused tax losses carried forward
327
-128
11
-1
209
Other
-251
13
90
-2
-4
-154
Total
1,539
-209
-249
10
5
1,096
Presented in the statement of financial
position as:
\u2013\u00a0 deferred tax liabilities
-257
-184
\u2013\u00a0 deferred tax assets
1,796
1,280
1,539
1,096
Deferred tax in connection with unused tax losses carried forward
in EUR million
2024
2023
Total unused tax losses carried forward
1,345
1,870
Unused tax losses carried forward not recognised as a deferred tax asset
951
815
Unused tax losses carried forward recognised as a deferred tax asset
394
1,055
Average tax rate
21.6%
19.9%
Deferred tax asset
85
209
Total unused tax losses carried forward analysed by expiry terms
No deferred tax\u00a0
asset recognised
Deferred tax asset
recognised
in EUR million
2024
2023
2024
2023
Within 1 year
More than 1 year but less than 5 years
135
126
14
633
More than 5 years but less than 10 years
9
9
66
2
More than 10 years but less than 20 years
Unlimited
808
681
313
421
951
815
394
1,055
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
2024
2023
Poland
244
Slovakia
1
China
9
2
Australia
1
1
Hong Kong
5
8
United States of America
1
T\u00fcrkiye
40
41
Taiwan
10
11
66
308
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 2024 as in 2023, ING Bank Slaski (Poland) realised a tax profit following the value changes of the cash flow
hedge derivatives which are settled net via a central clearing party, whereas in the years before, ING Bank
Slaski incurred a tax loss following the large value changes of the cash flow hedge derivatives. In 2024 ING
Slaski utilised the tax assets related to the 2023 unused tax losses carried forward.
At 31 December 2024 and 2023, ING Bank had no significant temporary differences associated with the
parent company\u2019s investments in subsidiaries and associates 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
2024
2023
2022
2024
2023
2022
2024
2023
2022
Current taxation
384
558
496
1,977
2,120
1,510
2,361
2,677
2,006
Deferred taxation
-13
-45
-79
232
293
-204
219
249
-283
371
513
417
2,209
2,413
1,306
2,580
2,926
1,723
Reconciliation of the weighted average statutory income tax rate to ING Bank\u2019s effective income tax rate
in EUR million
2024
2023
2022
Result before tax from continuing operations
9,025
10,318
5,493
Weighted average statutory tax rate
25.1%
25.5%
24.8%
Weighted average statutory tax amount
2,263
2,634
1,363
Permanent differences affecting current tax
Participation exemption
-87
-43
-64
Other income not subject to tax
-64
-68
-40
Expenses not deductible for tax purposes
424
398
403
Current tax from previously unrecognised amounts
-1
1
10
State and local taxes
77
99
68
Adjustments to prior periods
-34
-72
-29
Differences affecting deferred tax
Impact on deferred tax from change in tax rates
-1
2
5
Deferred tax benefit from previously unrecognised amounts
-1
-30
-3
Write-off/reversal of deferred tax assets
4
4
10
Effective tax amount
2,580
2,926
1,723
Effective tax rate
28.6%
28.4%
31.4%
The weighted average statutory tax rate in 2024 (25.1%) declined compared to that of 2023 ( 25.5%).
The effective tax rate of 28.6% in 2024 is higher than the weighted average statutory tax rate. This is mainly
caused by the impact in 2024 of the following non-deductible items for income tax purposes: hyperinflation
accounting loss in T\u00fcrkiye, interest expenses, and bank- and local taxes in various countries.
The weighted average statutory tax rate in 2023 (25.5%) was higher than the rate of 24.8% in 2022.
The effective tax rate of 28.4% in 2023 was higher than the weighted average statutory tax rate. This is
mainly caused by the impact in 2023 of the following non-deductible items income tax purposes:
hyperinflation accounting loss in T\u00fcrkiye, interest expenses, and bank- and local taxes in various countries.
Adjustments to prior periods mainly relate to a tax refund in Spain.
The effective tax rate of 31.4% in 2022 was higher than the weighted average tax rate. This is mainly caused
by the impact in 2022 of the following non-deductible items for income tax purpose: hyperinflation
accounting loss in T\u00fcrkiye, impairments on TTB and interest expenses in various countries.
Equity \u2013 Other comprehensive income
Income tax related to components of other comprehensive income
in EUR million
2024
2023
2022
Unrealised revaluations financial assets at fair value through other comprehensive
income and other revaluations
100
-7
140
Realised gains/losses transferred to the statement of profit or loss (reclassifications
from equity to profit or loss)
-29
-3
8
Changes in cash flow hedge reserve
-138
-251
875
Remeasurement of the net defined benefit asset/liability
6
31
6
Changes in fair value of own credit risk of financial liabilities at fair value through
profit or loss
5
2
19
Exchange rate differences and other
-46
19
-141
Total income tax related to components of other comprehensive income
-102
-209
907
", "dimensions": { "concept": "ifrs-full:DisclosureOfIncomeTaxExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-731": { "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
2024
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
63
71
-8
126
Financial assets and liabilities at FVPL
-3
-28
12
-19
Depreciation
-13
-9
-22
Cash flow hedges
502
-138
-1
363
Pension and post-employment
benefits
-33
6
1
-5
-1
-32
Other provisions
48
12
1
1
62
Loans and advances
475
-49
427
Unused tax losses carried forward
209
-128
3
85
Other
-154
-41
-9
-5
1
-208
Total
1,096
-102
-219
6
781
Presented in the statement of
financial position as:
\u2013\u00a0 Deferred tax liabilities
-184
-287
\u2013\u00a0 Deferred tax assets
1,280
1,069
1,096
781
The above table shows netted deferred tax amounts related to right-of-use assets and lease liabilities
included in the row \u2018Other\u2019, and includes a deferred tax amount for right-of-use assets of EUR 178 million
(2023: EUR 195 million and 2022: EUR 205 million ) and a deferred tax amount for lease liabilities of EUR 197
million (2023: EUR 217 million and 2022: EUR 231 million).
The deferred tax on cash flow hedges relate to floating rate lending with interest rate swaps. Due to
decreased (longer-term) interest rate yield curve in 2024 there was a positive revaluation of the cash flow
hedge through other comprehensive income. This resulted in a decline in the deferred tax asset by EUR -138
million compared to the decline deferred tax assets in 2023 by EUR -251 million due to the decline in the
interest yield curve. The deferred tax asset in cash flow hedges decreased from EUR 502\u00a0 million in 2023 to
EUR 363\u00a0 million in 2024.
The deferred tax on Loans and advances changes through net result in 2024 EUR -49\u00a0 million (2023: EUR
-140\u00a0 million) relates mainly to valuation changes of collectively assessed expected credit losses.
Unused tax losses carried forward declined by EUR 124 million mainly due to realised results on derivatives
used in Cash flow hedging which in previous years led to a tax loss in Poland.
The deferred tax\u00a0 changes through equity - Other in 2024 of EUR -41 million (2023: EUR 13 million) is due to
FX developments following the USD appreciation and the application of IAS 29 Hyperinflation in T\u00fcrkiye and
also due to the decline in the Credit Liability Reserve due to credit spread tightening.
Changes in deferred tax
in EUR million
2023
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
80
-10
-3
-4
63
Financial assets and liabilities at FVPL
28
-44
13
-3
Depreciation
-13
-6
3
4
-13
Cash flow hedges
752
-251
1
502
Pension and post-employment
benefits
-54
31
-7
-4
-33
Other provisions
59
-12
-3
4
48
Loans and advances
612
8
-140
-6
2
475
Unused tax losses carried forward
327
-128
11
-1
209
Other
-251
13
90
-2
-4
-154
Total
1,539
-209
-249
10
5
1,096
Presented in the statement of financial
position as:
\u2013\u00a0 deferred tax liabilities
-257
-184
\u2013\u00a0 deferred tax assets
1,796
1,280
1,539
1,096
Deferred tax in connection with unused tax losses carried forward
in EUR million
2024
2023
Total unused tax losses carried forward
1,345
1,870
Unused tax losses carried forward not recognised as a deferred tax asset
951
815
Unused tax losses carried forward recognised as a deferred tax asset
394
1,055
Average tax rate
21.6%
19.9%
Deferred tax asset
85
209
Total unused tax losses carried forward analysed by expiry terms
No deferred tax\u00a0
asset recognised
Deferred tax asset
recognised
in EUR million
2024
2023
2024
2023
Within 1 year
More than 1 year but less than 5 years
135
126
14
633
More than 5 years but less than 10 years
9
9
66
2
More than 10 years but less than 20 years
Unlimited
808
681
313
421
951
815
394
1,055
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
2024
2023
Poland
244
Slovakia
1
China
9
2
Australia
1
1
Hong Kong
5
8
United States of America
1
T\u00fcrkiye
40
41
Taiwan
10
11
66
308
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 2024 as in 2023, ING Bank Slaski (Poland) realised a tax profit following the value changes of the cash flow
hedge derivatives which are settled net via a central clearing party, whereas in the years before, ING Bank
Slaski incurred a tax loss following the large value changes of the cash flow hedge derivatives. In 2024 ING
Slaski utilised the tax assets related to the 2023 unused tax losses carried forward.
At 31 December 2024 and 2023, ING Bank had no significant temporary differences associated with the
parent company\u2019s investments in subsidiaries and associates 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": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-732": { "value": "
32\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.
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, the Global Valuation and Impairment Committee, the Market Data Committee and
the Valuation Model Committee. All relevant committees meet on a regular basis (monthly/quarterly), where
the 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 Global
Financial Markets Parameter Committee reviews the consolidated valuation outcome and resulting P&L for
Financial Market products, targeting a globally consistent treatment across Financial Markets. 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 (hereafter:
DOP). ING defers material DOP 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 DOP 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 2024 and the DOP reserve is disclosed in
the below table.
Deferred Day One Profit or Loss Reserve
The table below summarises the movement in the aggregate DOP not recognised when financial instruments
were initially recognised, because of the use of valuation techniques for which not all the inputs were market
observable data.
Deferred day one profit or loss reserve
in EUR million
2024
2023
Opening balance at 1 January
-90
-108
DOP deferred on new transactions during the period
-62
-83
DOP recognised in the statement of profit or loss during the period:
\u2013 of which release
27
85
\u2013 of which amortisation and exchange differences
32
15
Closing balance at 31 December
-94
-90
The following table presents the model reserves for financial assets and liabilities.
Valuation adjustment reserves on financial assets and liabilities
in EUR million
2024
2023
Deferred Day One Profit or Loss
-94
-90
Own credit adjustments
-17
34
Bid/Offer
-130
-154
Model Risk
-33
-26
CVA
-123
-131
DVA
50
55
CollVA
-3
-4
FVA
-64
-68
Other valuation adjustments
2
0
Total Valuation Adjustments
-412
-385
Own Credit Adjustment
Own issued debt and structured notes that are designated at fair value through profit or loss are adjusted for
ING`s own credit risk by means of DVA.
Bid-Offer Adjustment
For positions priced based upon mid-market input parameters, Bid-Offer adjustments are required in order to
reflect the valuation of that position based on bid price or offer price. In practice this adjustment accounts for
the difference in valuation from \u2018mid to bid\u2019 and \u2018mid to offer\u2019 for long and short exposures respectively. In
principle, assets are valued at the bid prices and liabilities are valued at the offer price. For certain assets or
liabilities, where a market-quoted price is not available, the price used is the fair value that is most
representative within the bid-offer spread.
Model Risk Adjustment
Financial instruments that are valued using a valuation model can be subject to model risk. Model risk is the
risk of possible financial loss resulting from a pricing model or model-based parameter deficiencies and/or
uncertainties.
Bilateral Valuation Adjustments (Credit and Debit Valuation Adjustments)
Bilateral Valuation Adjustment is the valuation adjustment reflecting the counterparty credit risk of
derivative contracts. It has a bilateral nature, where both the counterparty\u2019s credit risk (i.e. Credit Valuation
Adjustment or CVA) and ING\u2019s own credit risk (Debit Valuation Adjustment or DVA) are taken into account:
\u2022 CVA is the fair value adjustment applicable to derivative instruments to account for the possibility that the
counterparty defaults (i.e. it is the market value of the counterparty\u2019s credit risk).
\u2022 DVA is the fair value adjustment applicable to derivative instruments to account for the possibility that
ING defaults (i.e. it is the market value of ING\u2019s credit risk).
The calculation of CVA and DVA on derivatives is based on their expected exposures, and the counterparties\u2019
and ING\u2019s risk of default, taking into account the collateral agreements as well as netting agreements. The
counterparties\u2019 risk of default is measured by probability of default and expected loss given default, which is
based on market information including credit default swap (CDS) spreads. Where counterparty CDS spreads
are not available, relevant proxy spreads are used. Additionally, wrong-way risk (which occurs when the
probability of default by the counterparty increases or decreases when ING\u2019s exposure to the counterparty
increases (decreases)) and right-way risk (which occurs when the probability of default by the counterparty
increases (decreases) when ING\u2019s exposure to the counterparty decreases (increases)) are included in the
adjustment.
Collateral Valuation Adjustment (CollVA)
Collateral Valuation Adjustment is a fair valuation adjustment applied on derivative instruments to capture
specific features of CSA (Credit Support Annex) with a counterparty that the regular OIS discounting
framework does not capture. Non-standard CSA features may include deviations in relation to the currencies
in which ING posts or receives collateral, deviations in the remuneration rate on collateral which may pay
lower or higher rate than the overnight rate or even no interest at all; other deviations can be posting
securities rather than cash as collateral.
Funding Valuation Adjustment (FVA)
Funding Valuation Adjustment (FVA) is a fair valuation adjustment applied on derivative instruments to
address the asymmetry in funding costs or funding benefits between collateralised and uncollateralised
derivative portfolios. This adjustment is based on the expected exposure profiles of the uncollateralised or
partially collateralised OTC derivatives and market-based funding spreads.
Other Valuation Adjustments
This pertains to other valuation adjustments that are immaterial to ING. Most of the balance consists of the
Market Price Uncertainty (MPU) adjustment in fair value, which accounts for the price uncertainty risk
inherent in the valuation inputs to fair value.
d) Fair value hierarchy
ING Bank has categorised 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 of the valuation inputs. Highest priority is retained to unadjusted quoted prices in active
markets for identical assets or liabilities and the lowest priority to valuation techniques supported by
unobservable inputs.
Transfers into and transfers out of fair value hierarchy levels are made on a quarterly basis at the end of the
reporting period.
Level 1 \u2013 (Unadjusted) quoted prices in active markets
This category includes financial instruments whose fair value is determined directly by reference to
(unadjusted) quoted prices in an active market. A financial instrument is regarded as quoted in an active
market if quoted prices are readily and regularly available from an exchange, dealer markets, brokered
markets, or principal to principal markets. Those prices represent actual and regularly occurring market
transactions with sufficient frequency and volume to provide pricing information on an ongoing basis.
Transfers out of Level 1 into Level 2 or Level 3 occur when ING Bank establishes that markets are no longer
active and therefore (unadjusted) quoted prices no longer provide reliable pricing information.
Level 2 \u2013 Valuation technique supported by observable inputs
This category includes financial instruments whose fair value is based on market observable inputs, either
directly or indirectly, other than quoted prices included within Level 1. The fair value for financial instruments
in this category can be determined by reference to quoted prices for similar instruments in active markets,
quoted prices for identical or similar instruments in markets that are not active, inputs other than quoted
prices that are observable or market-corroborated inputs. ING analyses how the prices are derived and
determines whether the prices are liquid tradable prices or model-based consensus prices taking various
data as inputs.
For financial instruments that do not have a reference price available, fair value is determined using a
valuation technique (e.g., a model), where inputs in the model are taken from an active market or are
observable, such as interest rates and yield curves observable at commonly quoted intervals, implied
volatilities, and credit spreads.
Instruments where inputs are unobservable are classified in this category, provided that the impact of those
unobservable inputs on the overall valuation is insignificant. The notion of significant is particularly relevant
for the distinction between Level 2 and Level 3 assets and liabilities, as the significance assessment of the
valuation input on the entire fair value measurement will determine whether the instrument should be
classified as Level 2 or Level 3. Expert judgement is required on the significance assessment approach.
Level 3 \u2013 Valuation technique supported by unobservable inputs
This category includes financial instruments whose fair value is determined using a valuation technique for
which a significant part of the overall valuation is driven by unobservable valuation inputs. Where valuation
inputs are unobservable, the Group must use the best information available to value the instruments. This
may require internally derived inputs taking into account market participants' assumptions that are
reasonably available, including assumptions on the risk inherent in a particular valuation technique used to
measure fair value and the risk inherent in the inputs to the valuation technique. Unobservable inputs may
include, among others, volatility, correlation, spreads to discount rates, default rates, recovery rates,
prepayment rates, and certain credit spreads.
Financial instruments at fair value
The fair values of the financial instruments were determined as follows:
Methods applied in determining fair values of financial assets and liabilities (carried at fair value)
Level 1
Level 2
Level 3
Total
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
Financial Assets
Financial assets at fair value
through profit or loss
- Equity securities
20,798
15,449
15
3
141
150
20,954
15,602
- Debt securities
7,485
4,825
4,596
4,081
3,505
3,364
15,586
12,270
- Derivatives
1
39
31,792
27,134
475
535
32,268
27,708
- Loans and receivables
0
0
62,168
63,316
6,614
4,131
68,782
67,446
28,285
20,314
98,571
94,533
10,734
8,179
137,590
123,026
Financial assets at fair value
through other
comprehensive income
- Equity securities
2,292
1,622
270
263
2,562
1,885
- Debt securities
39,859
35,848
2,360
2,433
0
0
42,219
38,281
- Loans and receivables
0
0
1,608
275
0
676
1,608
951
42,151
37,470
3,967
2,707
270
938
46,389
41,116
Financial liabilities
Financial liabilities at fair
value through profit or loss
\u2013\u00a0 Debt securities
824
575
8,437
7,603
67
47
9,328
8,224
\u2013\u00a0 Deposits
45,648
57,607
13
45,648
57,620
\u2013\u00a0 Trading securities
3,631
3,604
12
41
10
3,653
3,645
\u2013\u00a0 Derivatives
45
41
27,528
24,437
694
670
28,267
25,148
4,501
4,220
81,625
89,687
770
729
86,896
94,637
The following methods and assumptions were used by ING 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 the 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 include 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 institution bonds are generally traded in active
markets. Where quoted prices are readily and regularly available, they are classified as Level 1. The
remaining positions are classified as Level 2 or Level 3 depending on the trading activity and observability of
prices. 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: Derivative 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, among 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 include 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 and
debt instruments, primarily comprised of structured notes, which are held at fair value under the fair value
option. Besides that, they include 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 a EUR 0.8 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 2024.
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 2024 of EUR 11.0 billion
(31\u00a0December 2023: EUR 9.1 billion), an amount of EUR 9.6 billion (87.2%) (31\u00a0December 2023: EUR 7.0 billion,
being 76.7%) 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 include EUR 0.1 billion (31\u00a0December 2023: EUR 0.3 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 1.3 billion (31\u00a0December 2023: EUR 1.8 billion) of the fair value classified in Level 3
financial assets is established using valuation techniques that incorporate certain inputs that are
unobservable.
Of the total amount of financial liabilities classified as Level 3 as at 31\u00a0December 2024 of EUR 0.8 billion
(31\u00a0December 2023: EUR 0.7 billion), an amount of EUR 0.6 billion (75.7%) (31\u00a0December 2023: EUR 0.4 billion,
being 50.0%) 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 include EUR 0.1 billion (31\u00a0December 2023: EUR 0.3 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 2023: 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
2024
2023
2024
2023
2024
2023
2024
2023
At fair value through profit or loss
Debt securities
3,504
3,364
10
0
Price based
Price (%)
0%
0%
120%
122%
Price (price per share)
327
97
520
236
Present value techniques
Credit spread (bps)
n.a.
94
n.a.
94
Price (%)
95.85%
n.a.
100%
n.a.
Equity securities
141
150
Price based
Price (price per share)
0
0
5,475
5,457
Loans and advances
1,565
2,298
0
13
Price based
Price (%)
0%
0%
107%
117%
Present value techniques
Credit spread (bps)
576
1
629
12
Prepayment rate (%)
2%
n.a.
100%
n.a.
(Reverse) repo's
5,050
1,832
Present value techniques
Interest rate (%)
2%
n.a.
2%
n.a.
Structured notes
67
47
Price based
Price (%)
93%
88%
104%
96%
Option pricing model
Equity volatility (%)
n.a.
9%
n.a.
23%
Equity/Equity correlation
0.7
0.8
0.7
0.9
Equity/FX correlation
n.a.
-0.2
n.a.
0.6
Dividend yield (%)
n.a.
0%
n.a.
4%
Present value techniques
Credit spreads (bps)
n.a.
100
n.a.
101
Prepayment rate (%)
99.59%
n.a.
100.09%
n.a.
Derivatives
\u2013\u00a0\u00a0Rates
413
283
389
301
Option pricing model
Interest rate volatility (bps)
n.a.
1
n.a.
3
Present value techniques
Reset spread (%)
2%
n.a.
2%
n.a.
Prepayment rate (%)
n.a.
0%
n.a.
0%
\u2013\u00a0\u00a0FX
6
2
8
3
Option pricing model
Implied volatility (%)
2%
3%
15%
18%
\u2013\u00a0\u00a0Credit
39
216
241
343
Present value techniques
Credit spread (bps)
0
3
91
149
Price based
Price (%)
0%
0%
100%
100%
\u2013\u00a0\u00a0Equity
10
20
47
17
Option pricing model
Equity volatility (%)
7%
12%
81%
75%
Equity/Equity correlation
0.0
0.2
1.0
1.0
Equity/FX correlation
-0.6
-0.5
0.6
1.0
Dividend yield (%)
0%
0%
33%
14%
Price based
Price (%)
n.a.
0%
n.a.
21%
\u2013\u00a0\u00a0Other
6
14
9
7
Option pricing model
Commodity volatility (%)
13.1%
11%
61%
94%
Com/FX correlation
-0.40
n.a.
-0.25
n.a.
Price based
Price (commodity)
68
n.a.
68
n.a.
At fair value through other comprehensive income
\u2013\u00a0\u00a0Loans and advances
676
Price based
Price (%)
n.a.
85%
n.a.
96%
\u2013\u00a0\u00a0Equity
270
263
Present value techniques
Credit spread (bps)
5.67
5.2
5.76
5.2
Interest rate (%)
1.5%
4%
3.5%
4%
Payout ratio (%)
70%
n.a.
90%
n.a.
Price based
Price (%)
122%
122%
122%
122%
Total
11,005
9,118
770
729
1 The abbreviation n.a. stands for not applicable or not available.
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 a strong positive (statistical) relationship, where underliers move, everything else equal,
into the same direction. The same holds for a high negative correlation.
Interest rate
An interest rate is the amount of interest due per period, as a proportion of the amount lent, deposited, or
borrowed.
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.
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.
Payout ratio
Dividend payout ratio is an input that shows the percentage of dividends a company is expected to pay out
each year relative to its net income.
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
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
Opening balance as at 1 January
848
873
286
421
3,499
1,849
3,547
3,492
938
891
9,118
7,526
Realised gain/loss\u00a0 recognised in the statement of profit or loss during the period 1
-175
235
-38
-142
294
-33
-54
-383
0
28
-322
Revaluation recognised in other comprehensive income during the period 2
-3
-6
-3
-6
Purchase of assets
486
1,246
198
76
4,424
2,208
1,600
873
154
331
6,862
4,735
Sale of assets
-111
-889
-257
-55
-1,605
-1,109
-10
-138
-418
-243
-2,402
-2,433
Maturity/settlement
-140
-1,005
-7
-15
-294
-576
-988
-292
-20
-22
-1,449
-1,910
Reclassifications
0
0
0
0
0
723
0
0
0
5
0
728
Transfers into Level 3
370
879
0
0
615
981
30
1
0
0
1,014
1,860
Transfers out of Level 3
-454
-459
-114
0
-1,214
-534
-3
0
-384
0
-2,169
-994
Exchange rate differences
0
-31
0
0
5
-9
-2
-9
9
-10
12
-59
Changes in the composition of the group and other changes
0
0
0
0
-1
0
0
2
-5
-8
-6
-6
Closing balance
824
848
68
286
5,721
3,499
4,121
3,547
270
938
11,005
9,118
1 Net gains/losses were recorded as \u2018Valuation results and net trading income\u2019 in the statement of profit or loss. The total amounts includes EUR -41 million (2023: EUR 316 million) of unrealised gains and losses recognised in the statement of profit or loss.
2 Revaluation recognised in other comprehensive income is included on the line \u2018Net change in fair value of debt instruments at fair value through other comprehensive income\u2019.
In 2024 and 2023, transfers into and out of Level 3 of financial assets mandatorily at fair value mainly relate
to (long- term) reverse repurchase transactions for which the valuation being significantly impacted by
unobservable inputs and no longer significantly impacted by unobservable inputs, respectively.
In 2024, the transfer into Level 3 trading assets consisted of cross currency swap trades, which were
transferred to Level 3 as a result of the valuation being significantly impacted by unobservable inputs.
Conversely, the transfer out of Level 3 in trading assets and non-trading derivatives primarily involved
derivative instruments, as their valuations were no longer significantly impacted by unobservable inputs.
In 2024, the transfer out of Level 3 of financial assets at FVOCI relates to HtC&S portfolio transferred to Level
2 resulting from change in methodology.
In 2023, the transfer into Level 3 trading assets is mainly driven by debt securities that are part of a structure
transferred into level 3 due to market illiquidity which decreased observability for an input.
Changes in Level 3 Financial liabilities
Trading liabilities
Non-trading
derivatives
Financial liabilities
designated as at fair
value through profit
or loss
Total
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
Opening balance as at 1
January
382
229
301
449
47
54
729
732
Realised gain/loss recognised
in the statement of profit or
loss during the period1
-104
224
-98
-151
-5
-2
-206
72
Additions
55
53
190
72
29
18
274
142
Redemptions
-12
-102
-209
-53
0
-2
-222
-156
Maturity/settlement
-15
-13
-7
-16
-4
-1
-26
-30
Transfers into Level 3
364
40
0
0
34
32
399
72
Transfers out of Level 3
-33
-49
-111
0
-34
-54
-179
-102
Exchange rate differences
0
0
0
0
0
0
0
0
Closing balance
637
382
67
301
67
47
770
729
1 Net gains/losses were recorded as \u2018Valuation results and net trading income\u2019 in the statement of profit or loss. The total amount
includes EUR -206 million (2023: EUR 72\u00a0million) of unrealised gains and losses recognised in the statement of profit or loss.
In 2024, the transfers into Level 3 mainly consisted of trading liabilities attributed to cross currency swap
trades transferred into Level 3 as a result of the valuation being significantly impacted by unobservable
inputs. The transfers out of Level 3 for non-trading derivatives are driven by interest rate swap trades, which
were reclassified out of Level 3 as their valuations were no longer influenced by significantly unobservable
inputs.
In 2023, transfers of financial liabilities into and out of Level 3 mainly consisted of structured notes,
measured as designated at fair value through profit or loss. The structured notes were transferred out of
Level 3 as the valuation was no longer impacted by significantly unobservable inputs.
g) Recognition of unrealised gains and losses in Level 3
Amounts recognised in the statement of profit or loss relating to unrealised gains and losses during the year
that relate to Level 3 assets and liabilities are included in the line item \u2018Valuation results and net trading
income\u2019 in the statement of profit or loss.
h) Level 3: Sensitivity analysis of unobservable inputs
Where the fair value of a financial instrument is determined using inputs which are unobservable and which
have a more than insignificant impact on the fair value of the instrument, the actual value of those inputs at
the balance date may be drawn from a range of reasonably possible alternatives. In line with market
practice, the upper and lower bounds of the range of alternative input values reflect a level of valuation
certainty. The actual levels chosen for the unobservable inputs in preparing the financial statements are
consistent with the valuation methodology used for fair valued financial instruments.
In practice, valuation uncertainty is measured and managed per exposure to individual valuation inputs (i.e.
risk factors) at portfolio-level across different product categories. Where the disclosure looks at individual
Level 3 inputs, the actual valuation adjustments may also reflect the benefits of portfolio offsets.
This disclosure does not attempt to indicate or predict future fair value movement. The numbers in isolation
give limited information as in most cases these Level 3 assets and liabilities should be seen in combination
with other instruments (for example as a hedge) that are classified as Level 2.
The valuation uncertainty in the table below is broken down by related risk class rather than by product. The
possible impact of a change of unobservable inputs in the fair value of financial instruments where
unobservable inputs are significant to the valuation is as follows:
Sensitivity analysis of Level 3 instruments
Positive fair\u00a0value
movements from
using reasonable
possible alternatives
Negative fair\u00a0value
movements from
using reasonable
possible alternatives
in EUR million
2024
2023
2024
2023
Equity (equity derivatives, structured notes)
21
18
-20
-9
Interest rates (Rates derivatives, FX derivatives)
5
3
0
0
Credit (Debt securities, Loans, structured notes, credit derivatives)
2
45
-27
-54
Loans and advances
0
3
0
-17
28
69
-47
-80
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.
Methods applied in determining fair values of financial assets and liabilities (carried at amortised cost)
Carrying Amount
Carrying amount
presented as fair value1
Level 1
Level 2
Level 3
Total fair value
in EUR million
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
Financial Assets
Loans and advances to banks
21,769
16,708
3,194
2,721
15,614
11,430
2,957
2,511
21,766
16,662
Loans and advances to customers
680,299
642,453
18,296
15,686
18,626
14,602
630,493
593,098
667,415
623,386
Securities at amortised cost
50,273
48,313
42,871
40,041
2,908
4,277
2,523
1,693
48,303
46,010
752,341
707,474
21,490
18,407
42,871
40,041
37,149
30,308
635,973
597,302
737,483
686,058
Financial liabilities
Deposits from banks
16,722
23,257
4,347
3,764
8,208
15,066
3,943
3,968
16,498
22,799
Customer deposits2
699,725
662,004
582,511
556,766
69,790
63,348
46,984
41,063
699,285
661,177
Debt securities in issue3
94,459
84,423
33,019
25,898
59,141
38,301
2,000
20,225
94,161
84,424
Senior non-preferred debt2
49,393
40,213
50,230
40,607
186
50,230
40,793
Subordinated loans
17,879
15,404
18,357
15,361
18,357
15,361
878,178
825,300
586,857
560,530
33,019
25,898
205,726
172,684
52,927
65,443
878,530
824,555
1 In accordance with IFRS and for the purpose of this disclosure, the carrying amount of financial instruments with an immediate on demand feature is presented as fair value
2 The presentation on senior non-preferred debt change has led to adjustments in the comparative figures for customer deposits and senior non-preferred debt.
3 In 2023, debt securities included a commercial paper issued classified as Level 3. Following a change in valuation technique in 2024, it transferred to Level 2.
The aggregation of the fair values presented above does not represent, and should not be construed as
representing, the underlying value of ING. These fair values were calculated for disclosure purposes only. The
carrying amount of financial instruments presented in the above table includes, when applicable, the fair
value hedge adjustment, this explains why (for these cases) 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.
Securities at amortised cost
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 include 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.
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 reflect ING\u2019s own credit
risk.
Customer deposits
In the current interest rate environment, there is significant embedded value in our on-demand deposits.
However, for the purpose of this disclosure and in accordance with IFRS, the carrying amounts of deposits
with an immediate on demand feature are presented as fair value.
The fair value of deposits with fixed contractual terms has 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:DisclosureOfFairValueMeasurementExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-733": { "value": "
35\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:
\u2022 Perpetual liabilities are included in the column \u2018Maturity not applicable\u2019.
\u2022 Derivative 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.
\u2022 Undiscounted future coupon interest on financial liabilities payable is included in a separate line and in
the relevant maturity bucket.
\u2022 Non-financial liabilities are included based on a breakdown of the amounts per statement of financial
position, per expected maturity.
\u2022 Loans 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
2024
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
9,104\u00a0
1,367\u00a0
2,085\u00a0
1,637\u00a0
2,484\u00a0
46\u00a0
16,722\u00a0
Customer deposits
610,590\u00a0
23,479\u00a0
50,034\u00a0
11,141\u00a0
2,081\u00a0
2,399\u00a0
699,725\u00a0
Financial liabilities at fair value through profit or loss
\u2013\u00a0 Other trading liabilities
5,790\u00a0
230\u00a0
313\u00a0
1,325\u00a0
1,465\u00a0
-34\u00a0
9,089\u00a0
\u2013\u00a0 Trading derivatives
2,631\u00a0
2,367\u00a0
3,730\u00a0
7,641\u00a0
5,499\u00a0
4,298\u00a0
26,166\u00a0
\u2013\u00a0 Non-trading derivatives
419\u00a0
57\u00a0
-36\u00a0
711\u00a0
149\u00a0
801\u00a0
2,101\u00a0
\u2013\u00a0 Designated at fair value through profit or loss
32,644\u00a0
5,842\u00a0
1,798\u00a0
5,095\u00a0
4,365\u00a0
34\u00a0
-239\u00a0
49,539\u00a0
Debt securities in issue
1,949\u00a0
17,635\u00a0
33,037\u00a0
26,600\u00a0
15,704\u00a0
-466\u00a0
94,459\u00a0
Senior non preferred debt
\u00a0
975\u00a0
\u00a0
30,121\u00a0
19,153\u00a0
-856\u00a0
49,393\u00a0
Subordinated loans
\u00a0
\u00a0
\u00a0
\u00a0
9,962\u00a0
8,415\u00a0
-498\u00a0
17,879\u00a0
Lease liabilities
20\u00a0
44\u00a0
162\u00a0
607\u00a0
328\u00a0
-45\u00a0
1,116\u00a0
Financial liabilities
663,148\u00a0
51,995\u00a0
91,125\u00a0
84,879\u00a0
61,190\u00a0
8,448\u00a0
5,405\u00a0
966,190\u00a0
Other liabilities 3
7,294\u00a0
456\u00a0
2,073\u00a0
502\u00a0
470\u00a0
10,795\u00a0
Total liabilities
670,442\u00a0
52,451\u00a0
93,198\u00a0
85,381\u00a0
61,660\u00a0
8,448\u00a0
5,405\u00a0
976,986\u00a0
Coupon interest due on financial liabilities
2,278\u00a0
1,600\u00a0
5,981\u00a0
10,388\u00a0
8,065\u00a0
516\u00a0
28,829\u00a0
Contingent liabilities in respect of
\u2013\u00a0 Discounted bills
\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
\u2013\u00a0 Guarantees
26,355\u00a0
\u00a0
\u00a0
3\u00a0
550\u00a0
26,908\u00a0
\u2013\u00a0 Irrevocable letters of credit
16,388\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
16,388\u00a0
Irrevocable facilities
175,000\u00a0
9\u00a0
15\u00a0
143\u00a0
56\u00a0
175,222\u00a0
217,743
9
15
146
606
218,518
1Includes 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
2023
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
9,294
7,800
2,074
1,898
2,002
189
23,257
Customer deposits4
584,874
21,522
45,099
7,394
1,816
1,299
662,004
Financial liabilities at fair value through profit or loss
\u2013\u00a0 Other trading liabilities
10,981
697
545
1,003
897
-36
14,087
\u2013\u00a0 Trading derivatives
2,292
2,243
5,148
10,204
7,110
-3,865
23,132
\u2013\u00a0 Non-trading derivatives
505
96
139
1,002
355
-78
2,019
\u2013\u00a0 Designated at fair value through profit or loss
29,857
12,754
5,442
3,832
3,544
25
-56
55,399
Debt securities in issue
3,442
10,233
33,986
22,206
15,820
-1,264
84,423
Senior non preferred debt4
570
903
25,119
15,492
-1,871
40,213
Subordinated loans
9,104
6,988
-689
15,404
Lease liabilities
17
45
175
627
359
-61
1,162
Financial liabilities
641,263
55,959
93,511
73,285
56,500
7,013
-6,432
921,099
Other liabilities 3
9,696
619
2,269
399
420
13,402
Total liabilities
650,959
56,579
95,779
73,684
56,920
7,013
-6,432
934,501
Coupon interest due on financial liabilities
1,057
1,703
6,103
10,178
4,998
404
24,442
Contingent liabilities in respect of
\u2013\u00a0 Discounted bills
2
2
\u2013\u00a0 Guarantees
27,340
4
550
27,894
\u2013\u00a0 Irrevocable letters of credit
14,925
14,925
\u2013\u00a0 other
Irrevocable facilities
166,361
12
63
314
60
166,810
208,628
12
63
318
610
0
0
209,631
1Includes 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).
3Includes Other liabilities, Current and deferred tax liabilities, and Provisions as presented in the Consolidated statement of financial position.
4 The presentation on senior non-preferred debt change has led to adjustments in the comparative figures for customer deposits and senior non-preferred debt.
38\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
2024
2023
Contingent liabilities in respect of
\u2013\u00a0 Discounted Bills
2
\u2013\u00a0 Guarantees
26,908
27,894
\u2013\u00a0 Irrevocable letters of credit
16,388
14,925
43,296
42,821
Irrevocable facilities
175,222
166,810
218,518
209,631
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.
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.
ING uses Irrevocable Payment Commitments (IPCs) for a part of its contributions to the Single Resolution
Fund (SRF). ING Bank has EUR 346 million of IPCs outstanding to the SRF as at 31 December 2024 (31
December 2023: EUR 346 million). No IPCs were provided to the SRF during 2024 (2023: EUR 63 million). No
IPCs were called by the SRF in 2024 (2023: nil). Cash collateral provided to the SRF is equal to the outstanding
amount of IPCs.
ING also uses IPCs for a part of its contributions to the Deposit Guarantee Scheme in Germany. Contingent
liabilities for such outstanding IPCs amount to EUR 309 million as at 31 December 2024 (31 December 2023:
EUR 273 million). Of these, EUR 35 million of IPCs were provided to the DGS during 2024 (2023: EUR 36
million). No IPCs were called by the DGS in 2024 (2023: nil). ING posted government bonds as collateral for
the total nominal amount of EUR 336 million as at 31 December 2024 (31 December 2023: EUR 319 million).
Furthermore we refer to Note 39 'Legal proceedings' for any contingent liabilities in respect of legal
proceedings.
", "dimensions": { "concept": "ifrs-full:DisclosureOfCommitmentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-734": { "value": "
36\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 mortgages pledged to secure covered bonds
and securitisations, deposits from the Dutch Central Bank and other banks, as well as debt and equity
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
2024
2023
Banks
\u2013\u00a0 Cash and balances with central banks
397
322
\u2013\u00a0 Loans and advances to banks
2,211
3,305
Financial assets at fair value through profit or loss
28,905
23,641
Financial assets at fair value through OCI
3,037
1,896
Securities at amortised cost
3,184
2,672
Loans and advances to customers
67,706
73,860
Other assets
503
357
105,944
106,052
In some jurisdictions ING Bank N.V. has an obligation to maintain a reserve with central banks. As at
31\u00a0December 2024 , the minimum mandatory reserve deposits with various central banks amount to EUR
11,648 million (2023: EUR 11,653 million).
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 an unrestricted right to sell or repledge it, provided that the collateral
(or equivalent collateral) is returned to the counterparty at term.
Financial assets received as collateral
in EUR million
2024
2023
Total received collateral available for sale or repledge at fair value
\u2013\u00a0 equity securities
22,815
33,234
\u2013\u00a0 debt securities
140,285
119,908
of which sold or repledged at fair value
\u2013\u00a0 equity securities
12,024
20,526
\u2013\u00a0 debt securities
90,708
86,448
Transfer of financial assets
The majority of ING's financial assets that have been transferred, but do not qualify for derecognition are
debt and equity 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
2024
2023
2024
2023
2024
2023
2024
2023
Transferred assets at carrying
amount
Financial assets at fair value through
profit or loss
4,141
3,894
3
7,273
7,357
16,929
11,780
Financial assets at fair value through
other comprehensive income
603
328
1,956
470
Loans and advances to customers
2,396
Securities at amortised cost
635
431
819
465
Associated liabilities at carrying
amount1
Financial liabilities at fair value
through profit or loss
n/a
n/a
n/a
n/a
7,005
11,010
11,901
9,467
1 The table includes the associated liabilities which are reported after offsetting, compared to the gross positions of the encumbered
assets.
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 42 'Structured entities'
ING uses Irrevocable Payment Commitments (IPCs) for a part of its contributions to the Single Resolution
Fund (SRF). ING Bank has EUR 346 million of IPCs outstanding to the SRF as at 31 December 2024 (31
December 2023: EUR 346 million). No IPCs were provided to the SRF during 2024 (2023: EUR 63 million). No
IPCs were called by the SRF in 2024 (2023: nil). Cash collateral provided to the SRF is equal to the outstanding
amount of IPCs.
ING also uses IPCs for a part of its contributions to the Deposit Guarantee Scheme in Germany. Contingent
liabilities for such outstanding IPCs amount to EUR 309 million as at 31 December 2024 (31 December 2023:
EUR 273 million). Of these, EUR 35 million of IPCs were provided to the DGS during 2024 (2023: EUR 36
million). No IPCs were called by the DGS in 2024 (2023: nil). ING posted government bonds as collateral for
the total nominal amount of EUR 336 million as at 31 December 2024 (31 December 2023: EUR 319 million).
", "dimensions": { "concept": "ifrs-full:DisclosureOfCollateralExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-735": { "value": "
Financial assets pledged as collateral
The financial assets pledged as collateral consist primarily of mortgages pledged to secure covered bonds
and securitisations, deposits from the Dutch Central Bank and other banks, as well as debt and equity
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
2024
2023
Banks
\u2013\u00a0 Cash and balances with central banks
397
322
\u2013\u00a0 Loans and advances to banks
2,211
3,305
Financial assets at fair value through profit or loss
28,905
23,641
Financial assets at fair value through OCI
3,037
1,896
Securities at amortised cost
3,184
2,672
Loans and advances to customers
67,706
73,860
Other assets
503
357
105,944
106,052
In some jurisdictions ING Bank N.V. has an obligation to maintain a reserve with central banks. As at
31\u00a0December 2024 , the minimum mandatory reserve deposits with various central banks amount to EUR
11,648 million (2023: EUR 11,653 million).
", "dimensions": { "concept": "ifrs-full:DisclosureOfRestrictedCashAndCashEquivalentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-738": { "value": "
38\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
2024
2023
Contingent liabilities in respect of
\u2013\u00a0 Discounted Bills
2
\u2013\u00a0 Guarantees
26,908
27,894
\u2013\u00a0 Irrevocable letters of credit
16,388
14,925
43,296
42,821
Irrevocable facilities
175,222
166,810
218,518
209,631
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.
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.
ING uses Irrevocable Payment Commitments (IPCs) for a part of its contributions to the Single Resolution
Fund (SRF). ING Bank has EUR 346 million of IPCs outstanding to the SRF as at 31 December 2024 (31
December 2023: EUR 346 million). No IPCs were provided to the SRF during 2024 (2023: EUR 63 million). No
IPCs were called by the SRF in 2024 (2023: nil). Cash collateral provided to the SRF is equal to the outstanding
amount of IPCs.
ING also uses IPCs for a part of its contributions to the Deposit Guarantee Scheme in Germany. Contingent
liabilities for such outstanding IPCs amount to EUR 309 million as at 31 December 2024 (31 December 2023:
EUR 273 million). Of these, EUR 35 million of IPCs were provided to the DGS during 2024 (2023: EUR 36
million). No IPCs were called by the DGS in 2024 (2023: nil). ING posted government bonds as collateral for
the total nominal amount of EUR 336 million as at 31 December 2024 (31 December 2023: EUR 319 million).
Furthermore we refer to Note 39 'Legal proceedings' for any contingent liabilities in respect of legal
proceedings.
", "dimensions": { "concept": "ifrs-full:DisclosureOfContingentLiabilitiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-737": { "value": "
38\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
2024
2023
Contingent liabilities in respect of
\u2013\u00a0 Discounted Bills
2
\u2013\u00a0 Guarantees
26,908
27,894
\u2013\u00a0 Irrevocable letters of credit
16,388
14,925
43,296
42,821
Irrevocable facilities
175,222
166,810
218,518
209,631
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.
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.
ING uses Irrevocable Payment Commitments (IPCs) for a part of its contributions to the Single Resolution
Fund (SRF). ING Bank has EUR 346 million of IPCs outstanding to the SRF as at 31 December 2024 (31
December 2023: EUR 346 million). No IPCs were provided to the SRF during 2024 (2023: EUR 63 million). No
IPCs were called by the SRF in 2024 (2023: nil). Cash collateral provided to the SRF is equal to the outstanding
amount of IPCs.
ING also uses IPCs for a part of its contributions to the Deposit Guarantee Scheme in Germany. Contingent
liabilities for such outstanding IPCs amount to EUR 309 million as at 31 December 2024 (31 December 2023:
EUR 273 million). Of these, EUR 35 million of IPCs were provided to the DGS during 2024 (2023: EUR 36
million). No IPCs were called by the DGS in 2024 (2023: nil). ING posted government bonds as collateral for
the total nominal amount of EUR 336 million as at 31 December 2024 (31 December 2023: EUR 319 million).
Furthermore we refer to Note 39 'Legal proceedings' for any contingent liabilities in respect of legal
proceedings.
", "dimensions": { "concept": "ifrs-full:DisclosureOfCommitmentsAndContingentLiabilitiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-736": { "value": "
38\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
2024
2023
Contingent liabilities in respect of
\u2013\u00a0 Discounted Bills
2
\u2013\u00a0 Guarantees
26,908
27,894
\u2013\u00a0 Irrevocable letters of credit
16,388
14,925
43,296
42,821
Irrevocable facilities
175,222
166,810
218,518
209,631
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.
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.
ING uses Irrevocable Payment Commitments (IPCs) for a part of its contributions to the Single Resolution
Fund (SRF). ING Bank has EUR 346 million of IPCs outstanding to the SRF as at 31 December 2024 (31
December 2023: EUR 346 million). No IPCs were provided to the SRF during 2024 (2023: EUR 63 million). No
IPCs were called by the SRF in 2024 (2023: nil). Cash collateral provided to the SRF is equal to the outstanding
amount of IPCs.
ING also uses IPCs for a part of its contributions to the Deposit Guarantee Scheme in Germany. Contingent
liabilities for such outstanding IPCs amount to EUR 309 million as at 31 December 2024 (31 December 2023:
EUR 273 million). Of these, EUR 35 million of IPCs were provided to the DGS during 2024 (2023: EUR 36
million). No IPCs were called by the DGS in 2024 (2023: nil). ING posted government bonds as collateral for
the total nominal amount of EUR 336 million as at 31 December 2024 (31 December 2023: EUR 319 million).
Furthermore we refer to Note 39 'Legal proceedings' for any contingent liabilities in respect of legal
proceedings.
39\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 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. In December
2024, the Dutch Public Prosecution Service announced that they will ask the Court\u2019s approval not to
prosecute ING\u2019s former CEO.
Litigation by investors: In February and March 2024, ING and certain (former) board members were served
with a writ of summons for litigation in The Netherlands on behalf of investors who claim to have suffered
financial losses in connection with ING's disclosures on historic shortcomings in its financial economic crime
policies, related risk management and control systems, the investigation by and settlement with the Dutch
authorities in 2018 and related risks for ING. We do not agree with the allegations and will defend ourselves
against these and the claimed damages of EUR 587 million. In February 2025, ING and the (former) board
members have filed their statement of defense against the allegations. Separately, but relating to the same
matters, in July 2024 another group of investors claiming to have suffered financial losses requested
disclosure of certain ING documents and to question witnesses. ING has subsequently filed its response to
the requests made with the court. We follow IFRS rules for taking legal provisions and would disclose
material amounts in this regard if and when applicable - which currently is not the case.
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 the AML process at
ING Luxembourg. In November 2024, the Court decided to refer the case to the \u2018Tribunal Correctionnel\u2019 for
alleged shortcomings in a limited number of individual client files. ING Luxembourg filed an appeal against
this procedural decision. 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.
ING's subsidiary Payvision was 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 cooperated
with such investigation. In October 2021, the phasing out of Payvision was announced. The phasing out of
activities and the transfer of customers to a new service provider were completed in 2022. At the request of
Payvision, its license has been withdrawn. In April 2024, the Dutch authorities closed the investigation,
without charges against Payvision, but with the issuance of a penalty order against two former directors of
Payvision.
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 ING 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.
Claims regarding accounts with predecessors of ING Bank T\u00fcrkiye: ING Bank T\u00fcrkiye has received
numerous claims from (former) customers of legal predecessors of ING Bank T\u00fcrkiye. 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 T\u00fcrkiye in 2007 from OYAK. Pursuant to the acquisition contract,
ING Bank T\u00fcrkiye can claim compensation from SDIF if a court orders ING Bank T\u00fcrkiye to pay amounts to
the offshore account holders. SDIF has made payments to ING Bank T\u00fcrkiye pursuant to such compensation
requests, but filed various lawsuits to receive those amounts back. 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. As of January 2025, three lawsuits have been
finalized in favour of ING Bank T\u00fcrkiye with the Turkish Supreme Court\u2019s verdict, which are likely to be
precedent decisions for the other ongoing files.
In 2024 SDIF initiated enforcement procedures against ING Bank T\u00fcrkiye, based on the decision in April 2022
by the Turkish Supreme Court referred to above. SDIF alleges that this decision means that ING Bank T\u00fcrkiye
has to return certain payments made by SDIF regarding the offshore depositors' receivables cases, as the
statute of limitations had already expired.
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: In the past a uniform recovery framework for Dutch SME clients with
interest rate derivatives was established by a committee of independent experts appointed by the Dutch
Ministry of Finance. In the context of this recovery framework most claims have been settled, however ING is
still 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. In one case, the business
client filed an appeal in cassation with the Dutch Supreme Court in January 2024. In December 2024, the
Supreme Court rejected such appeal. As there are only two lawsuits still pending, we do not expect that
these cases will have a significant impact in the future.
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 favour of another Dutch bank, addressing the question whether or not a bank is
allowed to increase interest surcharges unilaterally. The Dutch Supreme Court ruled affirmatively 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 and this ruling has been confirmed by the Dutch Supreme Court in its ruling of 22
December 2023. ING will continue to deal with all claims individually. In the last pending case against ING,
the claimant filed an appeal in cassation with the Dutch Supreme Court in April 2024. The Supreme Court
rejected the appeal in cassation in February 2025. There are no other lawsuits related to client surcharges on
the Euribor rates of so-called Euroflex loans. We therefore do not expect that this issue will have a significant
impact in the future.
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 first instance
court proceedings 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 (\"CJEU\") 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 Spanish Supreme Court published a press release stating its decision to ask the CJEU 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. In January 2024, the
CJEU ruled that the limitation period for the judicial claim for reimbursement of expenses cannot begin to
run from a Supreme Court decision declaring the clause null and void, nor from the moment of the payment
of the expenses. The CJEU indicated that it is up to national case-law to determine the criterion that should
be applied for the calculation of the limitation period. In April 2024, the CJEU ruled that it was not against
European Union laws that the period of prescription began to be calculated from the moment the clause was
declared null. Following the CJEU approach, on 14 June 2024 the Spanish Supreme Court issued its final
decision stating in short that the 5-year period to claim the reimbursement of costs can only begin from the
date each individual clause is declared null by a judge. The Spanish Supreme Court also leaves a small door
open for banks in case they can demonstrate that a specific individual indeed had knowledge of the
unfairness of the clause before that moment. ING is reviewing the best way to address the latest
developments.
ING Spain was also 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 the association withdrew from the proceedings. With respect to the third 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 has been
appealed in the Supreme Court.
A provision has been established in the past and has been adjusted where appropriate.
Imtech claims: 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. 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 2022, these claimants reiterated and further substantiated their claim in a
letter to ING. Each of the claimants allege inter alia that shareholders they represent were misled by the
prospectus of the rights issues of Imtech in July 2013 and October 2014. Underwriters, including ING are held
liable by these claimants for the damages that shareholders would have suffered. ING responded to these
claimants denying any and all responsibility in relation to the allegations made in the relevant letters. In
March 2024, Imtech trustees, VEB and other parties entered into a settlement agreement that contained a
release for claims regarding this subject matter. This release, by way of third-party clause, applies to ING as
well. The other claimants (one of which is now dissolved) are not party to this agreement and at this
moment it is not possible to assess whether the remaining claims would lead to any court case and what the
outcome of such court cases would be.
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. 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.
In June 2023, the CJEU issued a ruling. It ruled that under EU law when a loan agreement indexed to the
Swiss franc is declared null and void, 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. In September and
December 2023, the CJEU issued rulings providing further clarity on the limitation period and about the
question of when a contract clause can be considered unfair. In April 2024, the Polish Supreme Court issued a
ruling stating that if it is impossible to establish a binding foreign currency exchange rate for the parties in
the indexed or denominated loan agreement, the agreement is also not binding in other respects. ING has
recorded a portfolio provision. In October and November 2024, seven new preliminary questions were
referred to the CJEU which focus on the claims of banks in a situation of annulment of a credit agreement.
Certain Consumer Credit Products: In October 2021, ING announced that it would offer compensation to 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 several
rulings by the Dutch Institute for Financial Disputes (Kifid) regarding similar products at other banks. 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 reached an agreement with the Dutch Consumers\u2019 Association
(Consumentenbond) on the compensation methodology for revolving credits. Based on a Kifid ruling
regarding similar products, ING has amended 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 facility or a revolving credit card
with a variable interest rate. ING has started compensating such customers in line with Kifid rulings about
revolving credits including \u2018interest-on-interest\u2019-effect in these cases. Timelines for compensation vary
depending on customer and product segmentation and are dependent on the availability of data. In 2024
the compensation process was expedited. The compensation process is still ongoing.
Climate litigation: In January 2024, Friends of the Earth Netherlands (Milieudefensie) announced that it
holds ING liable for alleged contribution to climate change and threatens to initiate legal proceedings against
ING. In January 2025, Milieudefensie sent a new letter in which it reiterated its threat to initiate legal
proceedings against ING, but revised its demands. If necessary, ING will defend its science-based climate
approach in court.
Russian claims: Several ING entities have received claims from, and are involved in litigation with, certain
Russia-linked entities. They claim the payment of principal or interest or other amounts that they have not
received pursuant to sanctions. Claims are also made related to the settlement of contracts that have been
terminated after sanctions were imposed. In at least one case, the claimant seized assets in Russia of ING
entities. We do not agree with these claims, as they do not comply with the underlying contracts or
applicable laws, including sanctions. We follow IFRS rules for taking legal provisions and would disclose
material amounts in that regard if and when applicable which currently is not the case.
", "dimensions": { "concept": "ifrs-full:DisclosureOfOtherProvisionsContingentLiabilitiesAndContingentAssetsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-740": { "value": "
41\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:
\u2022 Representation on the board of directors;
\u2022 Participation in the policymaking process; and
\u2022 Interchange 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
2024
2023
Subsidiary
Statutory place of
Incorporation
Country of operation
Bank Mendes Gans N.V.3
Amsterdam
the Netherlands
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
T\u00fcrkiye
100%
100%
ING Bank (Australia) Ltd
Sydney
Australia
100%
100%
ING Commercial Finance B.V.
Amsterdam
the Netherlands
100%
100%
ING Groenbank N.V.3
Amsterdam
the Netherlands
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 information
we refer to Note 29 'Information on geographical areas'
2 Reference is made to Note 8 'Investment in associates and joint ventures'.
3 In 2024, Bank Mendes Gans N.V. and ING Groenbank N.V merged with ING Bank N.V.
42\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 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 retained 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 2024, these consisted of EUR 74 billion (2023:
EUR 67 billion) of senior and subordinated notes, of which EUR 4 billion (2023: EUR 2 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 2024, there are no non-controlling interests as part of the securitisation structured entities that are
significant to ING Bank.
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., ING SB Covered Bond Company B.V. and ING SB2 Covered Bond Company B.V.\u00a0
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
2024
2023
Dutch Covered Bond programmes
27,172
27,148
Diba Mortgage Pfandbriefe
15,050
18,276
ING Belgium Residential Pandbrieven Programme
9,024
7,347
IBAL Covered Bond
3,676
3,781
ING Bank Hipoteczny CBP
602
544
55,524
57,096
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 ABCP 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 3,119 million (2023: EUR 2,268 million). The drawn
liquidity amount is nil as at 31\u00a0December 2024 (2023: 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 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 ongoing involvement in the
transferred assets: as counterparty to the SPE of a non-standard interest rate swap, which is recognised as a
non-trading derivative, 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 2024 amounted to EUR -11\u00a0million (2023: EUR -26\u00a0million); fair value changes on this
swap recognised in the statement of profit or loss in 2024 were EUR 14 million (2023: EUR 14 million). Service
fee income recognised, for the role as administrative agent, in the statement of profit or loss in 2024
amounted to EUR 1 million (2023: EUR 1 million). The cumulative income recognised in profit or loss since
derecognition amounts to EUR 20 million (2023: EUR 19 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.
", "dimensions": { "concept": "ifrs-full:DisclosureOfInterestsInOtherEntitiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-739": { "value": "
41\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:
\u2022 Representation on the board of directors;
\u2022 Participation in the policymaking process; and
\u2022 Interchange 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
2024
2023
Subsidiary
Statutory place of
Incorporation
Country of operation
Bank Mendes Gans N.V.3
Amsterdam
the Netherlands
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
T\u00fcrkiye
100%
100%
ING Bank (Australia) Ltd
Sydney
Australia
100%
100%
ING Commercial Finance B.V.
Amsterdam
the Netherlands
100%
100%
ING Groenbank N.V.3
Amsterdam
the Netherlands
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 information
we refer to Note 29 'Information on geographical areas'
2 Reference is made to Note 8 'Investment in associates and joint ventures'.
3 In 2024, Bank Mendes Gans N.V. and ING Groenbank N.V merged with ING Bank N.V.
", "dimensions": { "concept": "ifrs-full:DisclosureOfSignificantInvestmentsInSubsidiariesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-741": { "value": "
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 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.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForInvestmentsOtherThanInvestmentsAccountedForUsingEquityMethodExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-742": { "value": "
4. Unconsolidated Securitisation programme
In 2013 ING transferred financial assets (mortgage loans) for an amount of 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 ongoing involvement in the
transferred assets: as counterparty to the SPE of a non-standard interest rate swap, which is recognised as a
non-trading derivative, 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 2024 amounted to EUR -11\u00a0million (2023: EUR -26\u00a0million); fair value changes on this
swap recognised in the statement of profit or loss in 2024 were EUR 14 million (2023: EUR 14 million). Service
fee income recognised, for the role as administrative agent, in the statement of profit or loss in 2024
amounted to EUR 1 million (2023: EUR 1 million). The cumulative income recognised in profit or loss since
derecognition amounts to EUR 20 million (2023: EUR 19 million).
", "dimensions": { "concept": "ifrs-full:DisclosureOfInvestmentsOtherThanInvestmentsAccountedForUsingEquityMethodExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-744": { "value": "
43\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 30 '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
2024
2023
Assets
72
56
Liabilities
77,739
70,524
Income received
0
1
Expenses paid
2,507
2,026
Liabilities to ING Groep N.V. mainly comprise long-term funding.
Associates and joint ventures
Transactions with ING Bank\u2019s main associates and joint ventures
Associates
Joint ventures
in EUR million
2024
2023
2024
2023
Assets
142
121
Liabilities
263
424
10
1
Off-balance sheet commitments
23
20
Income received
16
10
Expenses paid
2
3
Assets, liabilities, commitments, and income related to Associates and joint ventures result from
transactions which are executed as part of the normal Banking business. Dividends received by associates
and joint ventures are included in Note 8 'Investment in associates and joint ventures'.
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. In 2024, 2023 and 2022, 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)
2024
in EUR thousands
Executive Board of
ING Groep N.V.
Management Board
Banking 1
Total
Fixed Compensation
\u2013\u00a0 Base salary
4,388
3,598
7,987
\u2013\u00a0 Collective fixed allowances 2
1,033
790
1,823
\u2013\u00a0 Pension costs
84
95
179
\u2013\u00a0 Severance benefits
Variable compensation
\u2013\u00a0 Upfront cash
0
609
609
\u2013\u00a0 Upfront shares
302
609
911
\u2013\u00a0 Deferred cash
0
914
914
\u2013\u00a0 Deferred shares
453
914
1,367
\u2013\u00a0 Other emoluments 3
306
418
724
Total compensation
6,566
7,948
14,513
1 Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.
2 The 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 the\u00a0 loss of pension benefits with respect to salary in excess
of EUR 137,800.
3 This includes expatriate allowances (such as housing, school/tuition fees and international health insurances, if applicable); banking
and insurance benefits from ING (on the same terms as for other employees of ING in the Netherlands); tax and financial planning
services to ensure compliance with the relevant legislative requirements; and the use of a company car or driver service.
Key management personnel compensation (Executive Board and Management Board Banking)
2023
in EUR thousands
Executive Board of
ING Groep N.V.
Management Board
Banking 1
Total
Fixed Compensation
\u2013\u00a0 Base salary
4,220
4,200
8,420
\u2013\u00a0 Collective fixed allowances 2
1,002
887
1,889
\u2013\u00a0 Pension costs
78
107
185
\u2013\u00a0 Severance benefits
734
734
Variable compensation
\u2013\u00a0 Upfront cash
598
598
\u2013\u00a0 Upfront shares
293
598
891
\u2013\u00a0 Deferred cash
897
897
\u2013\u00a0 Deferred shares
439
897
1,336
\u2013\u00a0 Other emoluments 3
344
487
832
Total compensation
6,376
9,405
15,782
1 Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.
2 The 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 the loss of pension benefits with respect to salary in excess
of EUR 128,810.
3 This includes expatriate allowances (such as housing, school/tuition fees and international health insurances, if applicable); banking
and insurance benefits from ING (on the same terms as for other employees of ING in the Netherlands); tax and financial planning
services to ensure compliance with the relevant legislative requirements; reimbursement of costs under the Directors & Officers
indemnity provided by ING; and the use of a company car or driver service.
Key management personnel compensation (Executive Board and Management Board Banking)
2022
Executive Board of
ING Groep N.V.
Management Board
Banking 1
Total
in EUR thousands
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
1 Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.
2 The 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.
3 This includes amongst others: housing, school/tuition fees, international health insurance, relocation costs and tax and financial
planning.
ING indemnifies the members of the EB against direct financial losses in connection with claims from third
parties filed, or threatened to be filed, against them by virtue of their service as a member of the EB, as far as
permitted by law, on the conditions laid down in the Articles of Association and their commission contract.
ING has taken out liability insurance for the members of the EB.
In accordance with the Articles of Association ING indemnifies the members of the Supervisory Board as far
as legally permitted against direct financial losses in connection with claims from third parties filed or
threatened to be filed against them by virtue of their service as a member of the Supervisory Board.
Key management personnel compensation is generally included in Staff expenses in the statement of profit
or loss. The total remuneration of the Executive Board and Management Board Banking is disclosed in the
table above. Under IFRS, certain components of variable remuneration are not recognised in the statement
of profit or loss directly, but are allocated over the vesting period of the award. The comparable amount
recognised in Staff expenses in 2024 relating to the fixed expenses of 2024 and the vesting of variable
remuneration of earlier performance years, is EUR 12 million in 2024 (2023: EUR 14 million; 2022: EUR 14\u00a0
million).\u00a0
The table below shows the total of fixed remuneration, expense allowances and attendance fees for the
Supervisory Board in 2024, 2023 and 2022.
Key management personnel compensation (Supervisory Board)
in EUR thousands
2024
2023
2022
Total compensation
1,191
1,152
1,048
Loans and advances to key management personnel
As at 31 December 2024 Loans and advances outstanding to key management personnel amounted to EUR
1.1 million (2023: EUR 1.7 million) with an average interest rate of 2.1% (2023: 2.1%) and loan commitments
to key management personnel amounted to EUR 145 thousand (2023: EUR 138\u00a0thousand). Total interest
received in 2024 on these loans and advances amounted to EUR 28 thousand (2023: EUR 30 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.
Deposits outstanding to key management personnel
As at 31 December 2024 Deposits outstanding from key management personnel amounted to EUR 15.8
million (2023: EUR 13.9 million). Total interest paid in 2024 on these deposits amounted to EUR 324\u00a0thousand
(2023: EUR 197 thousand).
ING shares held by key management personnel
Number of ING Groep N.V. shares to key management personnel
ING Groep N.V. shares
in numbers
2024
2023
Executive Board members
152,652
128,241
Management Board Banking
343,055
262,507
Supervisory Board members
5,295
5,295
", "dimensions": { "concept": "ifrs-full:DisclosureOfRelatedPartyExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-743": { "value": "
43\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 30 '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.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForTransactionsWithRelatedPartiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-745": { "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. In 2024, 2023 and 2022, 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)
2024
in EUR thousands
Executive Board of
ING Groep N.V.
Management Board
Banking 1
Total
Fixed Compensation
\u2013\u00a0 Base salary
4,388
3,598
7,987
\u2013\u00a0 Collective fixed allowances 2
1,033
790
1,823
\u2013\u00a0 Pension costs
84
95
179
\u2013\u00a0 Severance benefits
Variable compensation
\u2013\u00a0 Upfront cash
0
609
609
\u2013\u00a0 Upfront shares
302
609
911
\u2013\u00a0 Deferred cash
0
914
914
\u2013\u00a0 Deferred shares
453
914
1,367
\u2013\u00a0 Other emoluments 3
306
418
724
Total compensation
6,566
7,948
14,513
1 Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.
2 The 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 the\u00a0 loss of pension benefits with respect to salary in excess
of EUR 137,800.
3 This includes expatriate allowances (such as housing, school/tuition fees and international health insurances, if applicable); banking
and insurance benefits from ING (on the same terms as for other employees of ING in the Netherlands); tax and financial planning
services to ensure compliance with the relevant legislative requirements; and the use of a company car or driver service.
Key management personnel compensation (Executive Board and Management Board Banking)
2023
in EUR thousands
Executive Board of
ING Groep N.V.
Management Board
Banking 1
Total
Fixed Compensation
\u2013\u00a0 Base salary
4,220
4,200
8,420
\u2013\u00a0 Collective fixed allowances 2
1,002
887
1,889
\u2013\u00a0 Pension costs
78
107
185
\u2013\u00a0 Severance benefits
734
734
Variable compensation
\u2013\u00a0 Upfront cash
598
598
\u2013\u00a0 Upfront shares
293
598
891
\u2013\u00a0 Deferred cash
897
897
\u2013\u00a0 Deferred shares
439
897
1,336
\u2013\u00a0 Other emoluments 3
344
487
832
Total compensation
6,376
9,405
15,782
1 Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.
2 The 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 the loss of pension benefits with respect to salary in excess
of EUR 128,810.
3 This includes expatriate allowances (such as housing, school/tuition fees and international health insurances, if applicable); banking
and insurance benefits from ING (on the same terms as for other employees of ING in the Netherlands); tax and financial planning
services to ensure compliance with the relevant legislative requirements; reimbursement of costs under the Directors & Officers
indemnity provided by ING; and the use of a company car or driver service.
Key management personnel compensation (Executive Board and Management Board Banking)
2022
Executive Board of
ING Groep N.V.
Management Board
Banking 1
Total
in EUR thousands
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
1 Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.
2 The 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.
3 This includes amongst others: housing, school/tuition fees, international health insurance, relocation costs and tax and financial
planning.
ING indemnifies the members of the EB against direct financial losses in connection with claims from third
parties filed, or threatened to be filed, against them by virtue of their service as a member of the EB, as far as
permitted by law, on the conditions laid down in the Articles of Association and their commission contract.
ING has taken out liability insurance for the members of the EB.
In accordance with the Articles of Association ING indemnifies the members of the Supervisory Board as far
as legally permitted against direct financial losses in connection with claims from third parties filed or
threatened to be filed against them by virtue of their service as a member of the Supervisory Board.
Key management personnel compensation is generally included in Staff expenses in the statement of profit
or loss. The total remuneration of the Executive Board and Management Board Banking is disclosed in the
table above. Under IFRS, certain components of variable remuneration are not recognised in the statement
of profit or loss directly, but are allocated over the vesting period of the award. The comparable amount
recognised in Staff expenses in 2024 relating to the fixed expenses of 2024 and the vesting of variable
remuneration of earlier performance years, is EUR 12 million in 2024 (2023: EUR 14 million; 2022: EUR 14\u00a0
million).\u00a0
The table below shows the total of fixed remuneration, expense allowances and attendance fees for the
Supervisory Board in 2024, 2023 and 2022.
Key management personnel compensation (Supervisory Board)
in EUR thousands
2024
2023
2022
Total compensation
1,191
1,152
1,048
Loans and advances to key management personnel
As at 31 December 2024 Loans and advances outstanding to key management personnel amounted to EUR
1.1 million (2023: EUR 1.7 million) with an average interest rate of 2.1% (2023: 2.1%) and loan commitments
to key management personnel amounted to EUR 145 thousand (2023: EUR 138\u00a0thousand). Total interest
received in 2024 on these loans and advances amounted to EUR 28 thousand (2023: EUR 30 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.
Deposits outstanding to key management personnel
As at 31 December 2024 Deposits outstanding from key management personnel amounted to EUR 15.8
million (2023: EUR 13.9 million). Total interest paid in 2024 on these deposits amounted to EUR 324\u00a0thousand
(2023: EUR 197 thousand).
ING shares held by key management personnel
Number of ING Groep N.V. shares to key management personnel
ING Groep N.V. shares
in numbers
2024
2023
Executive Board members
152,652
128,241
Management Board Banking
343,055
262,507
Supervisory Board members
5,295
5,295
", "dimensions": { "concept": "ifrs-full:DisclosureOfInformationAboutKeyManagementPersonnelExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00" } }, "f-746": { "value": "
44\u00a0 Capital management
Capital management strategy
Group Treasury (GT) 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 executing
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 takes into account both regulatory and internal, economic-based
metrics and requirements as well as the interests of key stakeholders, such as customers, shareholders and
rating agencies.
ING applies the following main capital definitions:
\u2022 Common 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.
\u2022 Tier 1 capital 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.
\u2022 Total capital is Tier 1 capital plus subordinated Tier 2 liabilities and regulatory adjustments. Total capital
divided by risk-weighted assets equals the Total capital ratio.
\u2022 ING's fully loaded CET1 ratio target is built on the CET1 requirements specified for ING, potential increase
in the regulatory requirement of the countercyclical buffer, the potential impact of a standardised and
pre-determined stress scenario and available mitigating actions, and general uncertainties.
\u2022 Leverage ratio (LR) is defined as Tier 1 capital divided by the leverage exposure.
\u2022 Minimum Required Eligible Liabilities (MREL)/ Total Loss Absorbing Capacity (TLAC) is Total capital plus
senior unsecured bonds and amortisations. MREL/ TLAC ratios are based on both risk-weighted assets and
leverage exposure .
Capital position as per 31 December 2024
ING Bank capital position according to CRR II / CRD V
in EUR million
2024
2023
Shareholders\u2019 equity 1
42,743
40,191
- Interim profits not included in CET 1 capital
0
-766
- Other adjustments
-2,146
-1,029
Regulatory adjustments
-2,146
-1,795
Available common equity Tier 1 capital
40,597
38,396
Additional Tier 1 securities
7,967
6,962
Regulatory adjustments additional Tier 1
106
86
Available Tier 1 capital
48,671
45,444
Supplementary capital Tier 2 bonds\u00a0 2
9,853
9,115
Regulatory adjustments Tier 2
81
54
Available Total capital
58,604
54,613
Risk weighted assets
334,770
321,358
Common equity Tier 1 ratio
12.1%
11.9%
Tier 1 ratio
14.5%
14.1%
Total capital ratio
17.5%
17.0%
1 Shareholders' equity is determined in accordance with IFRS-EU.
2 All T2 securities are CRR/CRD V-compliant for 2024.
In accordance with the applicable regulation, credit and operational risk models used in the capital ratios
calculations are not audited.
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 SREP CET1 requirement (including buffer requirements) for ING Bank N.V. at a consolidated level
was 9.83% at the end of 2024. This requirement is the sum of a 4.5% Pillar I requirement, a 2.5% capital
conservation buffer (CCB), a 0.83% countercyclical buffer (CCyB) and a 2.0% O-SII (Other Systemically
Important Institutions) buffer (based on December 2024 positions).
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45\u00a0 Subsequent events
On January 28, 2025 ING announced that it has reached an agreement on the sale of its business in Russia
to Global Development JSC, a Russian company owned by a Moscow-based financial investor with a
background in factoring services. This transaction will effectively end ING\u2019s activities in the Russian market.
Under the terms of the agreement, Global Development will acquire all shares of ING Bank (Eurasia) JSC,
taking over all Russian onshore activities and staff. Global Development intends to continue to serve
customers in Russia under a new brand. The transaction, which has been preceded by extensive due
diligence, is subject to various regulatory approvals and is expected to be closed in the third quarter of 2025.
ING has taken on no new business with Russian companies, has scaled down operations and has taken
actions to separate the business from ING\u2019s networks and systems.
ING estimates a negative impact to the Result on disposal of Group companies of EUR 0.7 billion post tax.
This includes an estimated book loss of EUR 0.4 billion, representing the expected difference between the
sale price and the book value of the business. It also includes an estimated negative impact of EUR 0.3 billion
from recycling the currency translation adjustment net of the Net Investment hedge reserve through P&L,
that is currently booked in equity for past changes of the value of ING Bank (Eurasia) JSC as a result of
changes in exchange rates.
On 2 March 2025, ING agreed with a minority shareholder to acquire their 17.6% stake in Van Lanschot
Kempen N.V. Per the agreement, ING has directly acquired 7.2% with the remainder of the transaction
subject to regulatory approval. Together with ING\u2019s existing stake of 2.7%, ING is expected to hold a total of
20.3% after completion of the transaction.
There are no other subsequent events to report other than those already disclosed in Note 39 'Legal
proceedings' of the consolidated financial statements.
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1 Changes in policy following the adoption of IFRS 17 and change in policy for non-financial guarantees.
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