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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 \u2018Financial
Instruments: Disclosures\u2019. 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, such as certain legal and regulatory
disclosures. Not all information in this section can be reconciled
back to the primary financial statements and corresponding notes,
as it has been prepared using risk data that differs from the
accounting basis of measurement. Disclosures in accordance with
Part Eight of the CRR3 and CRD VI, and as required by the
supervisory authority, are published in our \u2018Additional Pillar III
Report\u2019, which can be found on our corporate website ing.com.
Credit risk
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
39
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
38
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 & counterparty risk categories (*)
In the table below, we describe the different types of credit and
counterparty risk categories and include a reconciliation with the notes in
the financial statements:
Credit risk appetite and concentration risk framework (*)
The credit risk appetite and concentration risk framework is designed to
prevent undesired high levels of credit risk and credit concentrations within
various levels of the ING portfolio. It is derived from the concepts of
boundaries and instruments as described in the ING Risk Appetite
Framework.
Credit risk appetite is the maximum level of credit risk ING is willing to
accept for growth and value creation. The credit risk appetite is linked to
the overall bank-wide framework and is expressed in quantitative and
qualitative measures.
The credit risk appetite is set at different levels and dimensions within ING.
The credit risk appetite framework specifies the scope and focus of the
credit risk ING is willing to take, as well the composition of the credit
portfolio, including the concentration and diversification objectives across
business lines, locations, sectors, and products.
The credit concentration risk framework is composed of:
\u00a7 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.
\u00a7 Single name concentration (including secondary risk): ING has an
established credit concentration risk framework to identify, measure,
and monitor single name concentration, including secondary risk. The
same concept of boundaries and instruments is applicable.
\u00a7 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:
\u00a7 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.
\u00a7 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 \u2018(ultra) low 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 =
best rating; 22 = worst 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:
\u00a7 Investment grade (risk rating 1-10);
\u00a7 Non-investment grade (risk rating 11-17);
\u00a7 Performing Restructuring (risk rating 18-19); and
\u00a7 Non-performing (risk rating 20-22).
The first three categories (1-19) are risk ratings for performing loans.
Ratings are calculated in IT systems with internally developed models,
based on manually or automatically fed data, or for part of the non-
performing loans set by the global or regional credit restructuring
department. Under certain conditions, the outcome of a manually fed
model can be challenged through a rating appeal process. For
securitisation portfolios, the external ratings of the tranche in which ING
has invested are leading indicators.
Risk ratings assigned to clients are reviewed at least annually, with the
performance of the underlying models monitored regularly. Some of these
models are global in nature, such as those for large corporates,
commercial banks, insurance companies, central governments, funds,
fund managers, project finance, and leveraged companies. Other models
are more regional or country-specific: there are PD models for small and
medium enterprises (SMEs) in the Netherlands, Belgium and Poland, as
well as residential mortgage and consumer loan models in the various
retail markets.
Rating models for Retail clients are predominantly statistically driven and
automated, such that ratings can be updated on a monthly basis. Rating
models for large corporates, institutions and banks include both statistical
characteristics and expert input, with the ratings being manually updated
at least annually. More frequent reviews (e.g. quarterly) are performed
where considered necessary.
Credit risk portfolio (*)
Within ING, credit risk exposures are classified into four sources: 1)
Consumer Lending (to private individuals), 2) Business Lending, 3)
Investment and Money Market and 4) Pre-settlement. ING\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 2025, ING\u2019s portfolio size increased by \u20ac41.1 billion (4.1%) to
\u20ac1,002.9 billion outstanding. Foreign exchange rate changes had a \u20ac22.0
billion negative impact on the portfolio size, mainly driven by the
depreciation of the US dollar which had an impact of \u20ac16.6 billion mainly
in Wholesale Banking. Following this, net growth in Wholesale Banking was
\u20ac4.4 billion. Retail Banking outstandings increased by \u20ac38.4 billion mainly
due to underlying growth in residential mortgages.
Rating distribution (*)
Overall, the rating class distribution remained stable in 2025. The share of
investment grade rating classes increased from 78.1% to 79.3%, while the
share of non-investment grade decreased from 19.9% to 18.7%.
Performing restructuring outstandings remained constant at 0.6%\u00a0 of the
total portfolio in 2025, whereas non-performing loans (calculated including
Investment and Pre-Settlement exposures) decreased from 1.4% to 1.3%.
With respect to the rating distribution within the business lines, in
Wholesale Banking, investment grade increased to 84.3% from 83.7%,
while non-investment grade exposures decreased to 13.9% from 14.6%
compared to 2024. Performing restructuring assets increased from 0.6% to
0.7% of total Wholesale Banking assets where non-performing loans for
Wholesale Banking decreased from 1.2% to 1.1%. .
For Retail Banking, investment grade increased to 75.4% from 73.3%, while
non-investment grade exposures decreased to 22.5% from 24.4% as
compared to 2024. Performing restructuring decreased to 0.6% from 0.7%
whereas NPL remained constant at 1.5% in 2025.
Industry (*)
The industry breakdown is presented in accordance with the NAICS
definition. The increase of \u20ac41.1 billion in total volume during 2025 was
mainly due to the increase in Private Individuals (\u20ac28.7 billion) and Central
Governments (\u20ac13.4 billion) which was partially offset by the decrease in
Central Banks (\u20ac21.9 billion). The share of Private Individuals increased
from 39.5% last year to 40.7%.
Portfolio analysis per business line (*)
Outstandings per line of business (*)1, 2, 3
in EUR million
Wholesale Banking
Retail Banking
Corporate line
Total
Rating class
2025
2024
2025
2024
2025
2024
2025
2024
Investment grade
1 (AAA)
43,030
53,363
34,022
29,151
27
1,790
77,079
84,304
2-4 (AA)
70,691
72,462
68,484
63,187
1
4
139,175
135,653
5-7 (A)
130,372
101,831
149,694
140,479
555
157
280,620
242,467
8-10 (BBB)
119,661
129,429
175,823
155,375
3,055
3,452
298,539
288,256
Non-investment grade
11-13 (BB)
49,980
53,757
90,916
94,753
140,896
148,510
14-16 (B)
8,900
7,396
33,663
31,165
42,563
38,561
17 (CCC)
1,224
1,037
3,147
3,345
147
170
4,518
4,552
Performing Restructuring
loans
18 (CC)
2,209
1,792
1,945
2,001
4,154
3,794
19 (C)
637
560
1,678
1,760
2,315
2,320
Non-performing loans
20-22 (D)
4,602
5,204
8,393
8,100
12,995
13,303
Total
431,305
426,832
567,764
529,317
3,784
5,572
1,002,854
961,720
Industry
Private Individuals
1,893
2,116
406,589
377,712
408,482
379,827
Central Banks
40,270
61,091
15,713
15,044
1,785
55,983
77,919
Natural Resources
39,229
39,974
1,757
1,925
40,985
41,899
Real Estate
25,024
24,643
29,665
28,738
54,689
53,381
Commercial Banks
44,604
41,027
6,351
6,662
3,638
3,619
54,593
51,308
Non-Bank Financial
Institutions
65,037
64,217
1,973
2,212
77
79
67,086
66,509
Central Governments
59,600
48,389
10,280
8,107
1
1
69,880
56,497
Transportation & Logistics
25,427
27,499
6,507
6,037
31,934
33,536
Utilities
26,378
25,517
2,431
2,196
28,809
27,713
Food, Beverages & Personal
Care
13,798
13,827
11,298
10,419
25,096
24,246
Services
9,489
8,844
13,756
13,442
19
27
23,265
22,312
General Industries
13,235
10,512
9,655
8,812
22,890
19,324
Lower Public Administration
8,904
6,959
22,529
19,598
31,433
26,557
Other
58,418
52,218
29,261
28,412
50
62
87,730
80,691
Total
431,305
426,832
567,764
529,317
3,784
5,572
1,002,854
961,720
Outstandings per line of business (*) - continued1, 2, 3
in EUR million
Wholesale Banking
Retail Banking
Corporate line
Total
Region
2025
2024
2025
2024
2025
2024
2025
2024
Europe
Netherlands
35,256
44,486
180,030
164,590
526
1,906
215,812
210,981
Belgium
25,786
26,506
99,055
95,584
0
0
124,841
122,091
Germany
29,699
27,443
136,951
128,598
22
30
166,672
156,071
Poland
23,740
21,190
34,223
30,946
3
0
57,966
52,136
United Kingdom
30,475
28,257
252
265
78
91
30,805
28,613
France
26,462
24,351
3,742
3,122
3
3
30,207
27,476
Spain
15,568
11,990
31,015
28,507
38
36
46,620
40,533
Luxembourg
28,844
26,176
4,587
5,139
0
0
33,431
31,314
Rest of Europe
70,498
72,860
26,384
23,203
37
14
96,919
96,076
America
83,269
86,402
2,304
2,402
16
22
85,590
88,827
Asia
47,881
44,136
257
215
3,060
3,464
51,198
47,815
Australia
11,673
10,887
48,938
46,723
1
8
60,613
57,618
Africa
2,154
2,148
27
22
0
0
2,181
2,170
Total
431,305
426,832
567,764
529,317
3,784
5,572
1,002,854
961,720
1Based on credit risk measurement contained in lending, pre-settlement, money market and investment activities.
2Based on the total amount of credit risk in the respective column using ING\u2019s internal credit risk measurement methodologies. Economic sectors (industry) below 2% are not shown separately but grouped in Other.
3Geographical areas are based on country of residence, except for private individuals for which the geographical areas are based on the primary country of risk.
Portfolio analysis per geographical area (*)
The portfolio analysis per geographical area re-emphasises the
international distribution of ING\u2019s credit portfolio. The Netherlands
maintains the largest portfolio share in a single country with 21.5%
(2024: 21.9%) of the total amount, followed by Germany with 16.6%
(2024: 16.2%), and Belgium with 12.4% (2024: 12.7%).
In terms of region, the majority of the portfolio balance remained in
Europe with 80.1% (2024: 80.0%), followed by the Americas with 8.5%
(2024: 9.3%) and Australia with 6.0% (2024: 6.0%).
The top five countries within Rest of Europe based on outstandings were
Italy (\u20ac25.2 billion), Romania (\u20ac14.0 billion), Switzerland (\u20ac10.9 billion),
T\u00fcrkiye (\u20ac9.7 billion), and Ireland (\u20ac5.2 billion).
The main contributors for the overall increase in outstanding are Germany
(\u20ac10.6 billion),\u00a0 Spain (\u20ac6.1 billion), Poland (\u20ac5.8 billion), and the
Netherlands (\u20ac4.8 billion).
Private Individuals remained the largest composition of portfolio balances
for the Netherlands at 61.9% (2024: 58.3%), Belgium at 37.7% (2024:
37.4%), Germany at 68.5% (2024: 68.8%), and Australia at 68.1%
(2024: 66.1%). The decrease in Central Banks is mainly attributed to the
Netherlands (\u20ac13.8 billion), Belgium (\u20ac3.6 billion) and Asia (\u20ac3.1 billion).\u00a0
In individual countries, the total share of investment grade/non-
investment grade remains substantial for the Netherlands at 98.5% (2024:
98.5%), Germany at 98.7% (2024:98.9%), and Belgium 96.8% (2024:
96.6%).
In Europe, the increase in investment grade outstandings was mainly
observed in\u00a0 Germany (\u20ac11.9 billion), Spain (\u20ac8.4 billion), Poland (\u20ac5.2
billion) and France (\u20ac3.0 billion).
The net decrease in non-investment grade outstandings was mainly
observed in Spain (\u20ac2.4 billion), America (\u20ac1.9 billion), and Germany
(\u20ac1.7\u00a0billion).
Outstandings by economic sectors and geographical area (*) 1
in EUR million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United
Kingdom
Luxembourg
France
Rest of
Europe
America
Asia
Australia
Africa
2025
Private Individuals
133,644
47,047
114,235
18,871
29,412
117
2,734
2,038
18,761
183
128
41,294
20
408,482
Central Banks
8,742
6,621
13,938
1,499
577
3,791
6,088
0
6,912
0
6,426
1,388
0
55,983
Natural Resources
2,220
1,257
869
909
156
2,848
2,254
261
10,730
8,974
8,830
1,396
281
40,985
Real Estate
17,212
14,082
1,184
2,356
1,749
679
3,257
3,055
3,805
2,591
1,409
3,309
0
54,689
Commercial Banks
1,573
504
5,605
493
754
4,917
6,808
5,228
8,205
9,182
10,762
398
164
54,593
Non-Bank Financial Institutions
3,577
1,536
5,717
2,295
880
8,040
6,819
6,255
5,738
21,109
3,451
1,659
10
67,086
Central Governments
3,297
14,525
374
11,768
6,692
31
186
5,485
11,463
14,146
935
400
580
69,880
Transportation & Logistics
4,652
2,132
1,239
1,759
698
2,384
967
839
6,048
3,665
6,196
663
692
31,934
Utilities
1,678
1,868
3,890
1,127
1,932
3,184
539
593
4,291
6,144
1,376
2,067
121
28,809
Food, Beverages & Personal Care
8,415
3,675
604
2,425
340
261
1,472
801
2,998
2,358
1,269
476
1
25,096
Services
5,322
8,420
1,906
1,639
127
1,123
306
394
1,464
1,106
873
585
1
23,265
General Industries
5,118
3,232
1,304
2,957
208
262
476
550
4,399
2,575
1,461
322
25
22,890
Lower Public Administration
2,236
7,362
10,121
815
682
0
235
3,432
520
1,462
38
4,528
0
31,433
Other
18,125
12,579
5,685
9,053
2,413
3,169
1,290
1,277
11,584
12,097
8,044
2,127
287
87,730
Total
215,812
124,841
166,672
57,966
46,620
30,805
33,431
30,207
96,919
85,590
51,198
60,613
2,181
1,002,854
Rating class
Investment grade
171,707
74,908
148,033
41,249
41,114
25,930
29,551
24,917
71,116
71,085
45,214
50,441
147
795,414
Non-investment grade
40,889
45,899
16,505
14,477
4,771
4,664
3,586
5,048
22,521
12,841
5,430
9,527
1,821
187,976
Performing Restructuring
1,528
928
680
694
265
30
53
134
1,486
406
66
162
39
6,469
Non-performing loans
1,689
3,107
1,454
1,546
470
181
242
108
1,795
1,257
488
483
175
12,995
Total
215,812
124,841
166,672
57,966
46,620
30,805
33,431
30,207
96,919
85,590
51,198
60,613
2,181
1,002,854
1Geographical areas are based on country of residence, except for private individuals for which the geographical areas are based on the primary country of risk.
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
10,913
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
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
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
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
1Geographical areas are based on country of residence, except for Private Individuals for which the geographical areas are based on the primary country of risk.
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 relying on the value of the cover.
Cover forms (*)
Within ING, there are two distinct forms of covers. First, where the asset
has been pledged to ING as collateral or security, ING has the right to
liquidate it should the customer be unable to fulfil its financial obligation.
As such, the proceeds can be applied towards full or partial compensation
of the customer's outstanding exposure. This may be tangible (such as
cash, securities, receivables, inventory, plant and machinery, and
mortgages on real estate properties) or intangible (such as patents,
trademarks, contract rights, and licences). Second, where there is a third-
party obligation, indemnification or undertaking (either by contract and/or
by law), ING has the right to claim from that third party an amount if the
customer fails in its obligations. The most common examples are
guarantees, such as parent guarantees, export credit insurances, or third-
party pledged mortgages. Insurance or reinsurance covers, including
comprehensive private risk insurance (CPRI) may be recognised as
guarantees and effectively function in an equivalent manner. ING accepts
credit risk insurance companies and export credit agencies (ECAs) as cover
providers.
Cover valuation methodology (*)
General guidelines for cover valuation are established with the objective of
ensuring consistent application within ING. These also require that the
value of the cover is monitored on a regular basis. Covers are revalued
periodically and whenever there is reason to believe that the market is
subject to significant changes in conditions. The frequency of monitoring
and revaluation depends on the type of cover.
The valuation method also depends on the type of covers. For asset
collateral, the valuation sources can be the customer\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
(market values), financial collateral (cash and securities), guarantees, and
other covers (mainly pledges). The scope of covers in this overview has
been revised due to CRR3 implementation to align with regulatory
reporting. This explains the decrease in the values of 'other covers', which
had only a limited effect on the fully covered part of the portfolio, as ING's
portfolio remains well collateralised. Collateral covering financial market
transactions is valued on a daily basis (margining), and is as such not
included in the following tables. To mitigate the credit risk arising from
financial markets transactions, the bank enters into legal agreements
governing the exchange of financial collateral (high-quality government
bonds and cash).
The cover values are presented for the total portfolio of ING, both the
performing and non-performing portfolio.
Cover values including guarantees received (*)
in EUR million
Cover type and value
Collateralisation
2025
Outstandings
Mortgages
Financial Collateral
Guarantees
Other covers
No cover
Partially covered
Fully covered
Consumer lending
407,552
905,028
5,317
37,473
842
7.8%
2.0%
90.2%
Business lending
383,443
186,276
31,834
166,953
215,177
42.1%
15.8%
42.1%
Investment and money market
151,639
\u2014
\u2014
1,506
\u2014
99.6%
\u2014%
0.4%
Total lending, investment and money market
942,634
1,091,304
37,151
205,932
216,019
36.6%
7.3%
56.1%
of which NPL
12,981
9,827
196
2,771
3,591
33.0%
18.5%
48.5%
Pre-settlement
60,220
Total Bank
1,002,854
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
\u2014
\u2014
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
The above tables gives an overview of the collateralisation of ING\u2019s total
portfolio. Excluding the pre-settlement portfolio, 56.1% (2024: 55.9%) of
ING\u2019s outstandings were fully collateralised in 2025. Since investments
traditionally do not require covers, the \u2018no covers\u2019 percentage in this
portfolio is over 99.6%.
Consumer lending portfolio (*)
The consumer lending portfolio accounts for 40.6% (2024: 39.4%) of ING\u2019s
total outstanding, primarily consisting of residential mortgage loans and
consequently most collateral consists of mortgages. Mortgage values are
collected in an internal central database and in most cases external data is
used to index the market value.
A significant part of ING\u2019s residential mortgage portfolio is in the
Netherlands (2025: 35.0%, 2024: 35.0%), Germany (2025: 27.0%,
2024: 27.3%), Belgium (including Luxembourg) (2025: 12.0%, 2024: 12.2%)
and Australia (2025: 10.9%, 2024: 10.6%).
Business lending portfolio (*)
Business lending accounts for 38.2% (2024: 38.3%) of ING\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 makes use of Early
Warning Indicators (EWIs) in daily credit risk management processes,
which relate to a change in (internal and/or external) circumstances or
outlook of the specific obligor, the sector or the portfolio. ING usually
classifies a client with a 'watch list' status (Business lending only) when
there are early warning indicators triggered that detect an increased risk
profile. Watch list status requires more than usual attention, increased
monitoring and quarterly reviews. Some clients with a watch list or EWI
status may develop into a performing restructuring status or a non-
performing status. When there is increasing doubt as to the performance
and collectability of the client\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
2025
2024
Performing not past due
879,284
823,336
Business lending performing past due
8,071
9,174
Consumer lending performing past due
895
802
Non-performing
12,981
13,295
Total lending and investment
901,232
846,607
Money market
41,402
54,145
Pre-settlement
60,220
60,968
Total
1,002,854
961,720
Past due obligations (*)
Retail Banking measures its portfolio in terms of payment arrears and
determines on a monthly basis if there are any significant changes in the
level of arrears. This methodology applies to Private Individuals as well as
Business lending. An obligation is considered \u2018past due\u2019 if it is more than
one day late, subject to materiality thresholds in line with Definition of
Default Regulation. ING aims to help its customers as soon as they are past
due by reminding them of their payment obligations. In its contact with
customers, ING aims to solve the (potential) financial difficulties by offering
a range of measures (e.g. payment arrangements, restructuring). If the
issues cannot be resolved because the customer is unable or unwilling to
pay, for example, the contract is sent to the recovery unit. The facility is
downgraded to risk rating 20 (non-performing) when the facility or obligor
\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.
The past due but performing consumer lending outstanding increased by
\u20ac93 million, due to the increase in 1-30 days (\u20ac90 million) and 31-60 days
(\u20ac3 million).
The largest single country increase was in Belgium (\u20ac42 million), followed
by the Netherlands (\u20ac22 million), mainly in the 1-30 days bucket.\u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0
The largest decrease was seen in Australia (\u20ac21 million).
Ageing analysis (past due but performing): Consumer lending portfolio by geographic area, outstandings (*)
in EUR million
2025
2024
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
Netherlands
84
32
6
122
62
35
4
101
Belgium
219
60
26
305
185
49
29
263
Germany
70
37
22
129
65
37
24
125
Poland
58
6
3
68
61
9
4
74
Spain
22
17
9
48
12
16
8
36
Luxembourg
25
5
4
34
22
6
3
32
Rest of Europe
121
23
6
150
93
15
4
112
America
0
1
0
1
0
0
0
1
Asia
0
1
0
1
0
0
0
0
Australia
29
8
1
38
38
19
2
59
Africa
0
0
0
0
0
0
0
0
Total
628
189
78
895
538
186
78
802
Ageing analysis (past due but performing): Business lending portfolio by geographic area, outstandings (*)
in EUR million
2025
2024
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
Netherlands
586
31
9
626
929
14
943
Belgium
476
22
10
508
1,187
17
13
1,217
Germany
415
2
2
419
215
3
2
220
Poland
403
31
15
449
173
17
19
209
United Kingdom
516
531
1,046
830
8
838
France
73
73
194
194
Spain
9
9
26
26
Luxembourg
212
9
1
222
367
51
5
423
Rest of Europe
899
17
3
919
630
4
46
681
America
2,946
68
3,013
3,504
95
3,599
Asia
133
133
310
310
Australia
636
10
7
654
469
6
475
Africa
39
39
Total
7,303
720
47
8,071
8,873
215
86
9,174
Total past due but performing outstanding of business lending decreased
by \u20ac1.1. billion. The decrease was mainly witnessed in the 1\u201330 days past
due bucket (\u20ac1.6 billion) and was offset by the increase in 31-60 days
(\u20ac0.5 billion) past due bucket, fully in the United Kingdom related to
overdue fees. The largest decreases were in Belgium\u00a0 (\u20ac0.7 billion) and
America\u00a0 (\u20ac0.6 billion), while the largest increase were in Australia (\u20ac0.2
billion), Germany (\u20ac0.2 billion), Poland (\u20ac0.2 billion), and the United
Kingdom (\u20ac0.2 billion).
Forbearance (*)
Forbearance occurs when a client is unable to meet their financial
commitments due to financial difficulties they are facing or are about to
face and ING grants them concessions. Forborne assets are assets for
which forbearance measures have been granted.
Forbearance may enable clients experiencing financial difficulties to
continue repaying their debt.
For business clients, ING mainly applies forbearance measures to support
clients with fundamentally sound business models that are experiencing
temporary difficulties. The aim is to maximise the client\u2019s repayment
ability, thereby avoiding a default situation, and help the client to return to
a performing situation.
For ING Retail units, clear criteria have been established to determine
whether a client is eligible for the forbearance process. Specific approval
mandates are in place to approve the measures, as well as procedures to
manage, monitor, and report the forbearance activities.
ING reviews the performance of forborne exposures at least quarterly,
either on a case-by-case (Business) or portfolio (Retail) basis.
Both performing (risk ratings 1-19) and non-performing (risk ratings 20-22)
exposures are eligible for Forbearance measures. ING uses specific criteria
to move forborne exposures from non-performing to performing or to
remove the forbearance statuses that are consistent with the
corresponding European Banking Authority (EBA) standards. An exposure
is reported as forborne for a minimum of two years. An additional one-
year probation period is applied to forborne exposures that move from
non-performing back to performing.
Summary Forborne portfolio (*)
in EUR million
2025
2024
Business line
Outstandings
Of which: performing
Of which: non-performing
% of total portfolio(1)
Outstandings
Of which: performing
Of which: non-performing
% of total portfolio(1)
Wholesale Banking
5,910
3,194
2,716
1.7%
5,934
3,191
2,743
1.9%
Retail Banking
7,551
4,538
3,013
1.4%
6,883
3,987
2,897
1.3%
Total
13,461
7,732
5,729
1.5%
12,817
7,178
5,640
1.5%
Summary Forborne portfolio by forbearance type (*)
in EUR million
2025
2024
Forbearance type
Outstandings
Of which: performing
Of which: non-performing
% of total portfolio(1)
Outstandings
Of which: performing
Of which: non-performing
% of total portfolio(1)
Loan modification
11,883
6,581
5,302
1.3%
11,726
6,734
4,993
1.4%
Refinancing
1,578
1,151
427
0.2%
1,091
444
647
0.1%
Total
13,461
7,732
5,729
1.5%
12,817
7,178
5,640
1.5%
1% of total portfolio is based on lending and investment outstandings.
Forborne assets increased by \u20ac644 million, mainly due to the increase of
\u20ac667 million in Retail Banking, which was offset by a \u20ac24 million decrease
in Wholesale Banking. The rise in Retail Banking forborne assets was
primarily driven by residential mortgages in the Netherlands, which
contributed \u20ac608 million. This increase was largely the result of the
implementation of an updated framework, under which more clients are
classified as forborne, while outflow is only allowed after a two-year
probation period.
In terms of forbearance type, the increase is mainly witnessed in
refinancing type (\u20ac487 million) driven by a few larger files in Wholesale
Banking.
Modification of financial assets (*)
The following table shows:
\u00a7 Financial assets that were modified during the year (i.e. qualified as
forborne) while they had a loss allowance measured at an amount
equal to lifetime ECL; and
\u00a7 Financial assets that were reclassified to Stage 1 during the period
while being modified before.
Financial assets modified (*)
in EUR million
2025
2024
Financial assets modified during the period
Amortised cost before modification
1,746
1,888
Net modification results
-72
-107
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
1,027
1,506
Wholesale Banking (*)
Wholesale Banking forborne assets amounted to \u20ac5.9 billion (2024:
\u20ac5.9 billion), which represented 1.7% (2024: 1.9%) of the total Wholesale
Banking portfolio.
The net decrease in Wholesale Banking forborne assets was driven by a
\u20ac27 million reduction in non-performing forborne exposure and partially
offset by a \u20ac3 million rise in performing forborne exposures.\u00a0
Wholesale Bankings' forborne assets show an increase in Telecom due to
refinancing, which was offset by a decrease in other sectors, such as real
estate, food, beverages & personal care, chemicals, health &
pharmaceuticals and natural resources. These five sectors accounted for
69.6% of the total Wholesale Banking forborne outstandings.
Wholesale Banking: Forborne portfolio by geographical area (*)
in EUR million
2025
2024
Region
Outstandings
Of which:
performing
Of which: non-
performing
Outstandings
Of which:
performing
Of which: non-
performing
Europe
Netherlands
316
191
124
217
69
148
Belgium
3
3
172
165
7
Germany
336
29
307
372
62
310
Poland
662
305
357
630
284
346
United Kingdom
676
516
160
444
266
178
Italy
547
519
28
389
353
36
Rest of Europe
1,081
558
523
1,339
940
399
America
1,313
545
768
1,586
867
719
Asia
711
313
398
652
111
541
Australia
212
177
35
79
34
44
Africa
53
37
15
54
40
15
Total
5,910
3,194
2,716
5,934
3,191
2,743
Wholesale Banking: Forborne portfolio by economic sector (*)
in EUR million
2025
2024
Industry
Outstandings
Of which:
performing
Of which: non-
performing
Outstandings
Of which:
performing
Of which: non-
performing
Natural Resources
605
308
297
781
424
356
Real Estate
945
375
570
1,115
703
412
Transportation & Logistics
145
48
97
214
83
131
Food, Beverages & Personal Care
629
289
340
810
415
395
Services
172
149
24
211
176
34
Automotive
263
139
124
332
183
149
Utilities
497
218
279
677
301
376
General Industries
197
42
155
127
70
58
Retail
111
41
70
149
21
128
Chemicals, Health & Pharmaceuticals
619
74
545
668
136
532
Builders & Contractors
179
174
4
122
118
5
Telecom 1
1,314
1,166
148
486
383
103
Other
234
172
62
243
178
65
Total
5,910
3,194
2,716
5,934
3,191
2,743
1The presentation has been revised to separately disclose Telecom. Comparative figures have been
adjusted accordingly.
Retail Banking (*)
As of year end, Retail Banking forborne assets amounted to \u20ac7.6 billion
(2024: \u20ac6.9 billion), which represented 1.4% (2024: 1.3%) of the total Retail
Banking portfolio. Retail Banking performing forborne exposure increased
by \u20ac0.6 billion.
Retail Banking: Forborne portfolio by geographical area (*)
in EUR million
2025
2024
Region
Outstandings
Of which: performing
Of which: non-performing
Outstandings
Of which: performing
Of which: non-performing
Europe
Netherlands
2,136
1,711
424
1,548
1,134
414
Belgium
2,153
978
1,175
1,942
800
1,142
Germany
1,304
965
338
1,379
1,052
327
Poland
793
361
432
777
403
374
Spain
92
55
37
159
127
31
Italy
104
33
70
122
43
79
T\u00fcrkiye
22
16
6
13
9
4
Romania
216
106
110
173
72
101
Rest of Europe
91
32
59
102
50
52
America
5
5
22
17
6
Asia
1
1
1
Australia
635
279
357
646
279
367
Africa
Total
7,551
4,538
3,013
6,883
3,987
2,897
The main concentration of forborne assets in a single country was in
Belgium with 28.5% (2024: 28.2%) of total Retail Banking forborne assets
and 39.0% (2024: 39.4%) of the non-performing forborne assets. The other
significant single country concentration is in the Netherlands with 28.3%
(2024: 22.5%), which increased during 2025 because of the
implementation of a new framework for mortgages, and Germany having
17.3% (2024: 20.0%) 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 (non-exhaustive list):
\u00a7 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:
\u2013 The borrower (or third party) has started insolvency proceedings;
\u2013 A group company/co-borrower has NPL status;
\u2013 Indication of fraud (affecting the company\u2019s ability to service its
debt);
\u2013 There is doubt as to the borrower\u2019s ability to generate stable and
sufficient cash flows to service its debt;
\u2013 Restructuring of debt; and
\u2013 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.
\u00a7 The obligor has failed in the payment of principal, interest, or fees; the
total past due amount is above the materiality threshold, and this
remains the case for more than 90 consecutive days.
Furthermore, Wholesale Banking has an individual name approach, using
early warning indicators to signal possible future issues in debt service.
Also in Retail Banking early warning indicator frameworks have been
implemented.
The table below represents the breakdown of credit risk outstandings that
have been classified as non-performing by sector and business line.
Non-performing Loans: Outstandings by economic sector and business lines (*) 1
in EUR million
Wholesale Banking
Retail Banking
Total
Industry
2025
2024
2025
2024
2025
2024
Private Individuals
3
4
4,899
4,766
4,902
4,769
Natural Resources
945
965
115
99
1,061
1,064
Food, Beverages & Personal Care
372
452
325
357
697
809
Transportation & Logistics
251
347
227
157
478
504
Services
94
102
375
394
469
495
Real Estate
586
831
656
603
1,241
1,434
General Industries
243
236
471
451
713
687
Builders & Contractors
31
51
541
445
571
496
Retail
184
157
189
224
373
381
Utilities
336
582
26
19
362
600
Chemicals, Health & Pharmaceuticals
602
654
150
185
752
839
Telecom 2
170
151
36
12
206
163
Other
771
666
383
387
1,154
1,052
Total
4,589
5,196
8,392
8,099
12,981
13,295
1Based on lending and investment outstandings.
2The presentation has been revised to separately disclose Telecom. Comparative figures have been
adjusted accordingly.
Non-performing loans: Outstandings by economic sectors and geographical area (*)
in EUR million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United Kingdom
France
Luxembourg
Rest of Europe
America
Asia
Australia
Africa
2025
Private Individuals
697
1,481
1,113
220
357
10
8
39
574
2
2
399
1
4,902
Natural Resources
137
84
28
14
584
23
191
1,061
Food, Beverages & Personal Care
167
94
1
94
19
6
126
59
131
697
Transportation & Logistics
87
40
136
47
22
72
22
10
1
41
478
Services
68
262
75
1
3
4
16
26
13
469
Real Estate
24
419
59
115
45
47
101
8
377
48
1,241
General Industries
137
138
38
196
20
13
130
10
31
713
Builders & Contractors
89
219
7
182
8
66
571
Retail
80
79
33
56
1
4
15
105
373
Utilities
14
10
19
8
151
1
12
80
33
35
362
Chemicals, Health &
Pharmaceuticals
47
65
112
346
43
25
64
49
752
Telecom
37
4
3
15
146
2
206
Other
102
209
72
88
2
1
10
105
358
75
132
1,154
Total
1,686
3,105
1,454
1,546
470
181
108
242
1,786
1,257
488
483
175
12,981
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
In 2025, the NPL portfolio decreased to \u20ac13.0 billion (2024: \u20ac13.3 billion),
mainly driven by the decrease of \u20ac0.6 billion in Wholesale Banking. The
decrease was offset by the increase in Retail Banking (\u20ac0.3 billion) in line
with strong portfolio growth, mainly in residential mortgages.
Total net decrease was mainly seen in sectors Utilities, Real Estate and
Food, Beverage & Personal Care while the largest increase was in Private
Individuals.
Loan loss provisioning (*)
ING recognises loss allowances based on the expected credit loss (ECL)
model of IFRS 9, which is designed to be forward-looking. The IFRS 9
impairment requirements are applicable to on-balance-sheet financial
assets measured at amortised cost or fair value through other
comprehensive income (FVOCI), such as loans, debt securities, and lease
receivables, as well as off-balance-sheet items such as undrawn loan
commitments and financial- and non-financial guarantees issued.
ING distinguishes between two types of calculation methods for credit loss
allowances:
\u00a7 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; and
\u00a7 Individual lifetime ECL for credit-impaired (Stage 3) financial
instruments with exposures above \u20ac1 million.
IFRS 9 models (*)
ING\u2019s 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.
Climate and environmental risks in IFRS 9 models (*)
Climate risk drivers (physical and transition risks) can reduce the ability of
businesses and households to fulfil their obligations due, under existing
lending contracts. These climate risks are partly reflected in IFRS9 ECL
through regular credit risk transmission channels such as the
macroeconomic forecast and relevant risk parameters.
On the other hand, future physical or transition risks from climate change
are not yet fully captured within the current ECL models. In our
assessment of physical risks, it is generally expected that these risks will
only become financially significant on the long-term horizon.
Consequently, for short- and medium-term loans, such risks are not
expected to lead to significant credit deterioration over the exposure\u2019s
lifetime. For the long term, the probability and timing of physical risk
events remain highly uncertain. ING is however actively enhancing the
integration of physical and transition risks into collateral valuations,
ensuring that effects on property values are appropriately captured.
In case of risk events that have already occurred (e.g. floods, stranded
assets), the impact of such events is assessed in the calculation of Stage 3
individual provisions, collective SICR or management adjustments to ECL
models. For example, we consider whether affected assets have suffered
from a significant increase in credit risk (or are credit impaired) and
whether the ECL is appropriate.
Additionally, a management adjustment to ECL models for business
clients was introduced to specifically cover for medium- to long-term
transition risk on high greenhouse gas-emitting sectors. The management
adjustment reflects the risk of financial loss foreseen on the longer horizon
for lenders with higher transition risk in these high greenhouse gas-
emitting sectors as consequence of future carbon taxation.
ING is continuously improving on climate risk data, which will enable us to
further embed climate risks into the IFRS 9 ECL models. For more
information on ESG risk management, see \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 92.0%
(2024: 91.1%) of the total gross carrying amounts, mainly composed of
investment grade, while Stage 2 makes up 6.8% (2024: 7.6%) and Stage 3
makes up 1.2% (2024: 1.3%) of the total gross carrying amounts,
respectively.
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
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
Investment grade
1 (AAA)
79,938
79,076
2
1
126
281
80,064
79,357
2
1
2-4 (AA)
146,878
140,671
11
10
1,437
1,579
1
1
148,315
142,250
13
11
5-7 (A)
299,791
244,306
39
22
5,394
6,908
6
8
305,185
251,214
45
29
8-10 (BBB)
334,659
310,114
77
55
19,168
24,683
43
55
353,827
334,797
119
110
Non-investment
grade
11-13 (BB)
156,373
154,348
165
190
17,217
18,479
89
91
173,589
172,827
254
281
14-16 (B)
26,187
25,377
147
124
22,668
17,433
357
366
48,855
42,811
504
490
17 (CCC)
412
905
5
8
4,682
3,992
224
173
5,094
4,897
228
181
Performing
Restructuring
18 (CC)
4,349
4,059
262
233
4,349
4,060
262
233
19 (C)
2,447
2,474
198
203
2,447
2,474
198
203
Non-performing loans
20-22 (D)
13,590
13,742
4,476
4,509
13,590
13,742
4,476
4,509
Total
1,044,238
954,798
446
409
77,487
79,888
1,179
1,130
13,590
13,742
4,476
4,509
1,135,315
1,048,429
6,101
6,049
1Compared to the credit risk portfolio, the differences are due to undrawn committed amounts (\u20ac200.2 billion; 2024: \u20ac156.0 billion) and other positions (2025: nil; 2024:\u20ac6 billion) not included in credit outstandings and non-IFRS 9 eligible assets (\u20ac68.2 billion; 2024: \u20ac75.0 billion) included in credit outstandings but not
in the gross carrying amounts.
2Stage 3 lifetime credit impaired provision includes \u20ac 29 million (2024: \u20ac21 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:
\u00a7 Stage 3 gross carrying amount decreased by \u20ac0.2 billion from \u20ac13.7
billion as at 31 December 2024 to \u20ac13.6 billion as at 31 December 2025,
mainly as a result of \u20ac3.5 billion net inflow into NPL (credit impaired) in
2025, which is offset by \u20ac2.3 billion derecognitions and repayments
and \u20ac1.5 billion write-offs and disposals. Following the decrease in
carrying amount, Stage 3 provisions slightly decreased by \u20ac33 million
Stage 2 gross carrying amounts decreased by \u20ac2.4 billion from \u20ac79.9
billion as at 31 December 2024 to \u20ac77.5 billion as at 31 December 2025,
largely driven by \u20ac15.7 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 \u20ac18.0 billion due to derecognised financial assets (including
sales and repayments) and \u20ac1.2 billion exposure moving to Stage 3. Stage
2 provisions increased by \u20ac49 million to \u20ac1.2 billion as of 31 December
2025.
Changes in gross carrying amounts and loan loss provisions (*) 1, 2
in EUR million
12-month ECL\u00a0 \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
2025
2024
Opening balance
954,798
409
79,888
1,130
13,742
4,509
1,048,429
6,049
937,684
517
75,258
1,435
11,956
3,887
1,024,897
5,839
Transfer into 12-month ECL (Stage 1)
21,773
21
-21,555
-199
-218
-35
-212
20,276
22
-20,026
-195
-249
-34
0
-207
Transfer into lifetime ECL not credit impaired (Stage 2)
-37,208
-50
38,174
533
-966
-115
368
-43,155
-49
43,900
429
-745
-96
0
285
Transfer into lifetime ECL credit impaired (Stage 3)
-2,534
-14
-2,172
-138
4,705
1,259
1,108
-2,980
-18
-2,856
-235
5,836
1,802
0
1,548
Net remeasurement of loan loss provisions
7
-53
349
302
0
-180
0
-137
0
185
0
-133
New financial assets originated or purchased
263,371
189
22
2
263,393
191
212,529
192
0
0
0
0
212,529
192
Financial assets that have been derecognised
-119,098
-78
-12,295
-147
-1,422
-240
-132,814
-465
-126,858
-76
-11,840
-153
-1,450
-257
-140,148
-485
Net drawdowns and repayments
-57,441
-5,739
-853
-64,033
-41,763
0
-4,406
0
-309
0
-46,478
0
Changes in models/risk parameters
-33
71
-35
3
0
8
0
-6
0
-22
0
-20
Increase in loan loss provisions
43
68
1,185
1,296
-101
-297
1,578
1,179
Write-offs3
-937
-937
-937
-937
0
0
0
0
-1,017
-1,017
-1,017
-1,017
Disposals 3
-666
-3
-84
-3
-564
-286
-1,314
-291
-935
-1
-141
-8
-279
-215
-1,355
-225
Recoveries of amounts previously written off
58
58
0
0
0
0
0
69
0
69
Other movements
21,243
-4
1,268
-16
80
-53
22,591
-73
0
-5
0
0
0
208
0
203
Closing balance
1,044,238
446
77,487
1,179
13,590
4,476
1,135,315
6,101
954,798
409
79,888
1,130
13,742
4,509
1,048,429
6,049
1Stage 3 lifetime credit impaired provision includes \u20ac29 million (2024:\u20ac21 million) on purchased or originated credit impaired.
2The addition to the loan provision (in the consolidated statement of profit or loss) amounts to \u20ac1,304 million (2024: \u20ac1,194 million) of which \u20ac1,301 million (2024: \u20ac1,170 million) related to IFRS 9 eligible financial assets, \u20ac-5 million (2024: \u20ac9 million) to IFRS eligible commitments and \u20ac8 million (2024: \u20ac15 million) to
modification gains and losses on restructured financial assets.
Macroeconomic scenarios and sensitivity analysis of key sources
of estimation uncertainty (*)
Methodology (*)
This section outlines our methodology for adopting and generating
macroeconomic scenarios. We apply this methodology when producing
our probability-weighted ECL, incorporating alternative scenarios and
management adjustments where necessary. These adjustments are made
when management believes the consensus forecast does not fully capture
the extent of recent credit or economic events. The macroeconomic
scenarios are applicable to the whole ING portfolio in the scope of IFRS 9
ECLs.
The IFRS 9 standard, with its inherent complexities and potential impact on
the carrying amounts of our assets and liabilities, represents a key source
of estimation uncertainty. In particular, ING\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 a panels of ING experts.
Alternative scenarios and probability weights (*)
Two alternative scenarios are taken into account: an upside and a
downside scenario. The alternative scenarios have statistical
characteristics as they are based on the forecast deviations of the leading
third-party service provider.
To understand the baseline level of uncertainty around any forecast, the
leading third-party service provider keeps track of all its deviations (so-
called forecast errors) of the past 30 years. The distribution of forecast
errors for GDP, unemployment, house prices, and share prices is applied to
the baseline forecast creating a broad range of alternative outcomes. In
addition, to understand the balance of risks facing the economy in an
unbiased way, the leading third-party service provider runs a survey with
respondents from around the world and across a broad range of
industries. In this survey, respondents put forward their views of key risks.
Following the survey results, the distribution of forecast errors (that is
being used for determining the scenarios) may be skewed.
For the downside scenario, ING has chosen the 90th percentile of that
distribution because this corresponds with the way risk management
earnings-at-risk is defined within the Group. The upside scenario is
represented by the 10th percentile of the distribution. The applicable
percentiles of the distribution imply a 20 percent probability for each
alternative scenario. Consequently, the baseline scenario has a 60 percent
probability weighting. Please note that, given their technical nature, the
downside and upside scenarios are not based on an explicit specific
narrative and have not changed compared to previous year.
Macroeconomic scenarios applied (*)
The macroeconomic scenarios applied in the calculation of loan loss
provisions are based on the consensus forecasts.
Baseline assumptions (*)
The general picture that the consensus conveys is that global economic
growth is slowing compared to recent years. US growth is expected to
continue to outpace European markets, but the gap is narrowing down.
China is expected to continue a declining growth trend, but still at higher
rates than seen in advanced markets. Inflation is expected to remain near
target for most advanced economies, but a bit above for the United States.
With interest rates moderating, monetary conditions are turning more
favourable for growth. For the housing market, continued price growth is
expected for almost all main markets.
The December 2025 consensus expects global output (as measured by the
weighted average GDP growth rate of ING\u2019s 25 main markets) to remain at
a constant 2.4% from 2025-2027.
The eurozone economy has shown more resilience than expected despite
global headwinds, with sluggish but positive growth through 2025. The
coming years are expected to see modest growth rates as well. The trade
environment continues to be plagued by higher US tariffs and a stronger
euro. Expectations of a pickup in growth over the course of 2026 come
from stronger consumer spending and investment. German infrastructure
spending is expected to add to this momentum. Southern European
economies continue to benefit from European Recovery Fund investments.
Consensus expects the eurozone to have grown by 1.4% in 2025, before
slowing to 1.1% in 2026 and then recovering to 1.3% in 2027.
Elsewhere in Europe, the growth outlook is stronger. Poland\u2019s growth
momentum remains solid, growing faster than its European peers. The key
growth drivers over the near-term forecast are consumption and public
investments, such as those carried out under the National Recovery Plan
(KPO). The economy is expected to grow by 3.6% in 2025, picking up to
3.7% in 2026 and settling at 3.2% in 2027. The consensus expectation for
T\u00fcrkiye is to see stable growth of 3.5% and 3.4% in 2025 and 2026, as
domestic demand remains resilient and fixed investments and inventories
see an uptick. For 2027, a recovery to 3.7% is expected.
The American economy has held its ground despite the tariff war and
slowing employment growth. Its characterisation by a K-shaped economy
where most of the growth comes from high-income consumers and tech
investments is likely to continue in 2026. Tariffs are not feeding into
inflation as much as expected earlier in the year, and inflation
expectations remain benign, although still above the 2% target. This has
prompted the Federal Reserve to resume its rate cutting cycle. Inflation is
expected to remain around 2.8% and 2.9% in 2025 and 2026 before
steadying down at 2.4% in 2027.The US economy is expected to
experience steady growth of 2.0% in 2025-2027.
For China, economic underperformance continues as it still struggles with
the impact of the real estate correction and weak domestic demand.
However, the economy has come out resilient to the tariff war with a trade
surplus reaching record levels, making external demand the key driver of
2025. This enables the economy to reach its short-term growth target, but
medium-term consensus continues to be downbeat for the moment
because of its weak domestic economy. For 2025, consensus expects 4.9%
growth, down to 4.5% in 2026 and 4.3% in 2027.
Economic momentum in Australia is expected to be soft, as much of the
growth in 2025 came from government consumption. The economy is
lacking a clear growth engine, with the private sector struggling against
restrictive policy settings and consumers facing a tough outlook with
weaker employment growth and real wage gains moderating. Growth is
expected to come in at 1.8% in 2025, with a pick-up expected for 2026 to
2.2% and 2.3% for 2027.
When compared to the June 2025 consensus forecast, the December 2025
forecast has improved slightly because of better than expected growth in
major economies. Global GDP is expected to increase by 2.4% in both 2025
and 2026 (compared to 2.0% and 2.1% assumed before). The global
economy showed quite some resilience in 2025 despite trade and
geopolitical tensions, as GDP growth has continued despite political
disruptions. Markets, too, have adjusted to the new world of volatility.
Alternative scenarios and risks (*)
The baseline scenario assumes steady economic growth. However, further
escalation of geopolitical tensions and global trade uncertainty are seen as
key downside risks to the global economy. The balance of risks to the
baseline outlook is negative, and the alternative scenarios have a
downward skew.
The downside scenario sees a recession in 2026 and 2027 for most
countries. Unemployment increases strongly in this scenario and house
prices in most countries show outright falls. The downside scenario
captures the possible impact of geopolitical tensions, global trade policy
and heightened tariff uncertainty.
The upside scenario reflects the possibility of a better economic out-turn
resulting from the avoidance of further trade escalation, an AI-driven
productivity rebound and stronger European growth supported by defence
spending.
Management adjustments applied this reporting period (*)
In times of volatility and uncertainty where portfolio quality and the
economic environment are changing rapidly, models alone may not be
able to accurately predict losses. In these cases, management
adjustments can be applied to appropriately reflect ECL. Management
adjustments may also be applied when the impact of the updated
macroeconomic scenarios is over- or under-estimated by the IFRS 9
models, or to account for model redevelopment, recalibration, and periodic
assessment procedures that have not yet been incorporated into the IFRS9
models.
ING has an internal governance framework and controls in place to assess
the appropriateness of all management adjustments.
Management adjustments to ECL models (*)
in EUR million
2025
2024
Commercial Real Estate/ Inflation and interest rate
increases
50
Economic sector / portfolio based adjustments
9
38
Mortgage portfolio adjustments
121
112
Climate transition risk
47
29
Other Post Model Adjustments
7
-27
Total management adjustments
183
203
The management adjustment of \u20ac50 million for the Commercial Real
Estate portfolio, reported at 31 December 2024 due to prevailing risks in
this sector, is released in 2025 due to improved risk profile and partially
replaced with a management adjustment for a recent model update,
which corrects for the effects of the aforementioned risks on the model
outcome. As the model update has not been implemented in production
yet, a management adjustment of \u20ac10 million is reported under the Other
Post Model Adjustments category at 31 December 2025.
As at 31 December 2025, an economic sector / portfolio-based adjustment
is reported in the Mortgages portfolio in Australia (\u20ac9 million) to address
emerging risk from inflation, interest rate increases and overall cost of
living. The management adjustment reported at 31 December 2024 for the
increased credit risk in the Mortgages and Consumer Lending portfolios in
Spain \u2013 due to the effects of floods \u2013 has been released, as the remaining
affected performing customers are reported in Stage 2. Also the
adjustment taken in the Business Banking portfolio in Germany at 31
December 2024 to cover for the increased uncertainty in the German
economy has been released due to the agreed sale of the affected
portfolio.
As of 31 December 2025, the overall mortgage portfolio adjustment
amounts to \u20ac121 million (31 December 2024: \u20ac112 million) and fully
related to the management adjustment in Stage 2 for the risk
segmentation model that captures affordability, repayment, and
refinancing risk on performing mortgage customers with a bullet loan in
the Netherlands.
As of 31 December 2025, an adjustment of \u20ac47 million is in place to
address the impact of climate transition risk in Wholesale Banking (\u20ac31
million) and in Business Banking (\u20ac16 million). Climate transition risk is
expected to lead to a structural change in credit risk, which means specific
business activities will become structurally riskier due to environmental
policies, technological progress or changes in market sentiment and
preferences. The current IFRS 9 models do not capture this (novel) risk. The
management adjustment to ECL models for business clients was made to
specifically cover for the medium- to long-term transition risk on high
greenhouse gas-emitting sectors and is reported in Stage 2. The sectors
included in the overlay represent approximately 20% of the exposure
within Wholesale and Business Banking.
Other post-model adjustments mainly relate to the impact of model
redevelopment or recalibration and periodic model assessment
procedures that have not been incorporated in the ECL models yet. The
impact on total ECL can be positive or negative. These adjustments will be
removed once updates to the specific models have been implemented.
The change in balance compared to previous reporting date is due to i)
released negative overlays because of model updates that have been
implemented and ii) new overlays recognised for new recalibrations and
periodic model assessment procedures that have not been incorporated
yet.
Analysis on sensitivity (*)
The table below presents the analysis on the sensitivity of key forward-
looking macroeconomic inputs used in the ECL collective-assessment
modelling process and the probability weights applied to each of the three
scenarios. The countries included in the analysis are the most significant
geographic regions in ING. For Wholesale Banking, the US is the most
significant in terms of both gross contribution to reportable ECL and
sensitivity of ECL to forward-looking macroeconomics. Accordingly, ING
considers these portfolios to present the most significant risk of resulting in
a material adjustment to the carrying amount of financial assets within
the next financial year.
The purpose of the sensitivity analysis is to enable the reader to
understand the extent of the impact from the upside and downside
scenario on model-based reportable ECL.
In the table below, the real GDP is presented in percentage year-on-year
change, the unemployment in percentage of total labour force, and the
house price index (HPI) in percentage year-on-year change.
Sensitivity analysis as at December 2025\u00a0 (*)
2026
2027
2028
Unweighted
ECL (\u20ac mln)
Probability-
weighting
Reportable
ECL (\u20ac mln) 1
Netherlands
Upside scenario
Real GDP
2.6
2.9
2.3
288
20%
389
Unemployment
3.5
3.2
3.2
HPI
8.2
8.5
7.0
Baseline scenario
Real GDP
1.1
1.4
1.5
364
60%
Unemployment
4.0
3.9
4.1
HPI
4.4
3.0
2.9
Downside scenario
Real GDP
-1.2
-0.9
0.2
566
20%
Unemployment
5.5
6.5
7.4
HPI
-0.8
-5.1
-5.1
Germany
Upside scenario
Real GDP
2.8
3.0
1.8
584
20%
633
Unemployment
3.0
2.4
2.2
HPI
8.2
9.8
9.4
Baseline scenario
Real GDP
1.1
1.5
1.3
623
60%
Unemployment
3.5
3.2
3.1
HPI
5.0
6.2
6.3
Downside scenario
Real GDP
-1.7
-1.1
0.4
713
20%
Unemployment
4.7
5.3
5.6
HPI
0.9
0.4
2.7
Belgium
Upside scenario
Real GDP
2.7
2.3
1.9
544
20%
596
Unemployment
5.1
4.6
4.5
HPI
5.2
4.9
5.4
Baseline scenario
Real GDP
1.1
1.4
1.6
585
60%
Unemployment
5.9
5.6
5.5
HPI
3.7
4.2
4.4
Downside scenario
Real GDP
-1.5
0.1
1.4
682
20%
Unemployment
7.0
7.7
7.9
HPI
1.8
2.6
2.6
United States
Upside scenario
Real GDP
3.2
2.9
2.7
64
20%
105
Unemployment
3.2
2.5
2.6
HPI
4.8
9.4
10.9
Baseline scenario
Real GDP
2.0
2.0
2.0
92
60%
Unemployment
4.3
4.1
4.1
HPI
1.4
2.7
3.6
Downside scenario
Real GDP
-0.4
-0.1
0.8
184
20%
Unemployment
6.7
7.2
7.5
HPI
-5.1
-7.9
-5.5
1Excluding management adjustments.
Sensitivity analysis as at December 2024 (*)
2025
2026
2027
Unweighted
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
1Excluding management adjustments.
When compared to the sensitivity analysis of 2024, the baseline
macroeconomic inputs have become slightly more positive overall,
underpinned by the resilience of the global economy in the face of trade
and geopolitical tensions. House price growth expectations are lower for
the Netherlands, given a rise in supply from the sale of rental properties
and slowdown of wage growth. In the US, a weak labour and housing
market both signal underlying economic challenges due to policy and
trade uncertainty, and persistent affordability issues. The upside and the
downside scenarios are not directly comparable with those of 2024 due to
an update in the basis of their derivation.
On a total ING level, the unweighted ECL for all collective provisioned
clients in the upside scenario was \u20ac2,938 million, in the baseline scenario
\u20ac3,232 million and in the downside scenario \u20ac3,993 million compared to
\u20ac3,326 million reportable model ECL as at 31 December 2025 (excluding all
management adjustments). To perform the sensitivity analysis, a point in
time reportable ECL is used as input, which slightly deviates from the total
reportable collective provisions as presented below:
Reconciliation of reportable collective ECL to total ECL (*)
in EUR million
2025
2024
Total reportable collective provisions
3,168
2,975
ECL from individually assessed impairments
2,750
2,871
ECL from management adjustments
183
203
Total ECL
6,101
6,049
Criteria for identifying a significant increase in credit risk (SICR) (*)
All assets and off-balance-sheet items that are in scope of IFRS 9
impairment and which are subject to collective ECL assessment are
allocated a 12-month ECL if deemed to belong in Stage 1, or a lifetime ECL
if deemed to belong in Stages 2 or 3. An asset belongs in Stage 2 if it is
considered to have experienced a significant increase in credit risk (SICR)
since initial origination or purchase.
The main determinant of SICR is a quantitative test, whereby the lifetime
PD of an asset at each reporting date is compared against its lifetime PD
determined at the date of initial recognition. If either a threshold for
absolute change in lifetime PD or a threshold for relative change in lifetime
PD is reached, the item is considered to have experienced an SICR (for more
details on absolute and relative thresholds, see the following sections).
Furthermore, any facility which shows an increase of 200 percent between
the PD at the date of initial recognition and the lifetime PD at the reporting
date (i.e. threefold increase in PD) must be classified as Stage 2. This is
considered a backstop within the quantitative assessment of SICR.
In Wholesale Banking, a significant increase in lifetime PD is not considered
plausible for assets of obligors with a credit rating at the reporting date in
the top range of investment grade. The assets of these Wholesale Banking
obligors are excluded from the assessment of significant increase in credit
risk triggers. For these obligors the qualitative significant increases in credit
risk triggers remain applicable (see the section below on Qualitative SICR
triggers). These are, for example, the watch list and/or forbearance
triggers. Finally, the 30 days past due backstop also remains applicable for
the top range of investment grade exposures to ensure a significant
increase in credit risk recognition.
Absolute lifetime PD threshold
The absolute threshold is a fixed value calibrated per portfolio/segment
and provides a fixed threshold that, if exceeded by the difference between
lifetime PD at reporting date and lifetime PD at origination, triggers Stage 2
classification. The absolute threshold is calibrated during model
development.
Relative lifetime PD threshold
The relative threshold defines a relative increase of the lifetime PD, beyond
which a given facility is classified in Stage 2 because of a significant
increase in credit risk. The relative threshold is dependent on the individual
PD assigned to each facility at the moment of origination, and a scaling
factor calibrated in the model development phase.
Ultimately, the relative threshold provides a criterion to assess whether
the ratio (i.e. increase) between lifetime PD at reporting date and lifetime
PD at origination date is deemed a significant increase in credit risk. If the
threshold is breached, SICR is identified and Stage 2 is assigned to the
given facility.
The threshold for the relative change in lifetime PD is inversely correlated
with the PD at origination; the higher the PD at origination, the lower the
threshold. The logic behind this is to allow facilities originated in very
favourable ratings to downgrade for longer without the need of a Stage 2
classification. In fact, it is likely that such facilities will still be in favourable
ratings even after a downgrade of a few notches. On the contrary, facilities
originated in already unfavourable ratings grades are riskier and even a
single-notch downgrade might represent a significant increase in credit
risk and thus a tighter threshold will be in place. Still, the relative threshold
is relatively sensitive for investment-grade assets while the absolute
threshold primarily affects non-investment grade assets.
Average threshold ratio
The table below shows the average increase in PD at origination needed to
be classified in Stage 2 is reported, taking into account the PD at
origination of the facilities included in each combination of asset class and
rating quality. In terms of rating quality, assets are divided into
'investment grade' and 'non-investment grade' facilities. Rating 18 and 19
are not included in the table, since facilities are not originated in these
ratings and they constitute a staging trigger of their own (i.e. if a facility is
ever to reach rating 18 or 19 at reporting date, it is classified in Stage 2). In
the table, values are weighted by IFRS 9 exposure and shown for both
year-end 2024 and year-end 2025.
To represent the thresholds as a ratio (i.e. how much should the PD at
origination increase in relative terms to trigger Stage 2 classification) the
absolute threshold is recalculated as a relative threshold for disclosure
purposes. Since breaching only relative or absolute threshold triggers
Stage 2 classification, the minimum between the relative and recalculated
absolute threshold is taken as value of reference for each facility.
Quantitative SICR thresholds\u00a0 (*)
2025
2024
Average threshold ratio
Investment
grade (rating
grade 1-10)
Non-investment
grade (rating
grade 11-17)
Investment
grade (rating
grade 1-10)
Non-investment
grade (rating
grade 11-17)
Asset class category
Mortgages
2.9
2.4
2.9
2.4
Consumer lending
2.9
2.3
2.8
2.1
Business lending
2.7
2.0
2.7
2.1
Governments and financial institutions
2.9
1.8
2.9
1.9
Other Wholesale Banking
2.7
1.9
2.7
1.9
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 \u20ac1,501 million as at
31 December 2025 (31 December 2024: \u20ac1,328 million). To demonstrate
the sensitivity of the ECL to these PD threshold bands, hypothetically
solely applying the upside scenario would result in total model ECL on
performing assets of \u20ac1,159 million and a decrease in the Stage 2 ratio by
0.3%-point, while solely applying the downside scenario would result in
total model ECL on performing assets of \u20ac2,193 million and an increase in
the Stage 2 ratio by 1.6%-point.
Qualitative SICR thresholds
It should be noted that the lifetime PD thresholds are not the only drivers
of stage allocation as ING Group also relies on a number of qualitative
indicators to identify and assess SICR. An asset can also change stages as
a result of other triggers, such as having over 30 days arrears (used as a
backstop), the occurrence of an early warning indicator, collective SICR
assessment, being on a watch list, being under intensive care
management, having a substandard internal rating, or being forborne.
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:
\u00a7 Market risk in banking books;
\u00a7 Market risk in trading books; and
\u00a7 Market risk capital.
Market risk in banking books (*)
ING distinguishes between the trading and banking (non-trading) books.
Positions in banking books originate from the market risks inherent in
commercial products that are sold to clients, Group Treasury exposures, and
from the investment of our own funds (core capital). Both the commercial
products and the products used to hedge related market-risk exposures are
intended to be held until maturity, or at least for the long term.
Risk transfer (*)
Market risks in the banking book are managed via the risk transfer process.
In this process the interest rate, FX, funding, and liquidity risks are
transferred from the commercial books through matched funding or
replication to Group Treasury, where they are centrally managed. The
scheme below presents the transfer and management process of market
risks in the banking books.
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:
\u00a7 Investment of own funds;
\u00a7 Commercial business; and
\u00a7 Group Treasury exposures, including strategic interest rate positions.
Group Treasury is responsible for managing the investment of own funds
(core capital). Capital is invested for longer periods to contribute to stable
earnings within the risk appetite boundaries set by ALCO Bank.
Commercial activities can result in linear interest rate risk due to different
re-pricing properties of assets and liabilities. Also, interest rate risk can
arise from customer behaviour and/or convexity risk, depending on the
nature of the underlying product characteristics.
To determine interest rate risk in specific products (such as savings or
mortgages) certain assumptions may need to be applied. Customer
behaviour risk is defined as the potential future loss (value) arising from
deviations between actual client behaviour and the modelled behaviour
regarding embedded options within commercial products. General sources
of customer behaviour risk include, among other things, the state of the
economy, competition, changes in regulation, legislation and tax regime,
developments in the housing market, and interest rate developments.
From an interest rate risk perspective, commercial activities can typically
be divided into the following main product types: savings and current
accounts (funds entrusted), demand deposits, mortgages, and loans.
Savings and demand deposits are generally invested in such a way that
both the value is hedged and the sensitivity of the margin to market
interest rates is minimised. This is achieved by creating the investment
profile distributed from short term to long term, which dampens the
immediate impact from changes in the market rates and stabilises margin
in the longer horizon. Interest rate risk is modelled based on the stability of
deposits and the pass-through rate. This takes account of different
elements, such as pricing strategies, volume developments, and the level
and shape of the yield curve.
In determining the interest rate profile of mortgages, prepayment or other
embedded optionality can be an important risk driver. In modelling this
risk, both interest-rate-dependent prepayments and constant
prepayments are considered. Next to a dependence on interest rates,
modelled prepayments may include other effects such as loan-to-value,
seasonality, and the reset date of the loan. In addition, the interest
sensitivity of embedded offered rate options is typically considered.\u00a0
Wholesale Banking loans typically do not experience interest-rate-
dependent prepayment behaviour, as these are mostly floating rate
products. These portfolios are match-funded, taking the constant
prepayment model into account, and typically do not contain significant
convexity risk. Wholesale Banking loans can have an all-in rate floor or a
floor on a reference rate.
Customer behaviour in relation to mortgages, loans, savings, and demand
deposits is modelled based on extensive analysis of historical data.
However, the substantial fluctuations in the interest rate environment in
recent years make the analysis more challenging than before and may
increase model risk. Models are backtested and updated when deemed
necessary, at least annually. Model parameters and the resulting risk
measures are approved by (local) ALCO, and are closely monitored on a
monthly basis.
Linear risk transfers take place from commercial business books to the
treasury book (Group Treasury), if necessary, by using estimations of
customer behaviour. The originating commercial business is ultimately
responsible for estimating this customer behaviour, leaving convexity risk
and (unexpected) customer behaviour risk with the commercial business.
Risk measurement and the risk transfer process take place at least
monthly. If deemed necessary, additional risk transfers can take place.
The commercial business manages the convexity risk that is the result of
products that contain embedded options, like mortgages. Here the
convexity risk is defined as the optionality effects in the value due to
interest rate changes, excluding the first-order effects. In some cases,
convexity risk is hedged by treasury using cap/floor contracts and
swaptions.
NII at Risk (*)
The NII-at-Risk measures the impact of changing interest rates on the
forecasted net interest income (before tax) of the banking book, excluding
the impacts of credit spread sensitivity, fees, and fair value impact. Future
projected balance sheet developments (dynamic plan) are included in this
risk metric. NII-at-Risk provides insight into the sensitivity of ING\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:
\u00a7 Change in returns of (re)investments of client deposits;
\u00a7 Change in client deposit rates (mainly savings), (partially) tracking
changes in market interest rates;
\u00a7 Change in the amortisation profile of mortgages, due to an increase or
decrease in expected prepayments;
\u00a7 Higher/lower returns of (re-)investments of core capital investment;
\u00a7 Open interest rate positions, leading to changes in return because of
different market rates; and
\u00a7 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 represent a parallel, linear
interest rate shift over one year (\u2018ramped\u2019) based on the assumption that
balance sheet developments follow ING\u2019s dynamic plan within a one-year
horizon.
The NII-at-Risk is mainly influenced by the difference in the sensitivity
between client liabilities and client assets and investments to rate
changes. The primary factor of NII-at-Risk are the investments of current
accounts, while the investments of own funds have a marginal effect, as
only a relatively small portion needs to be (re)invested within a one-year
period.
NII-at-Risk banking book per currency - year one (*)
in EUR million
2025
2024
Ramped, floored
Ramped, floored
parallel \u25bc
parallel \u25b2
parallel \u25bc
parallel \u25b2
By currency
Euro
-182
205
-144
158
US dollar
1
-1
-4
5
Other
-74
94
-2
21
Total
-254
298
-151
184
EUR ramped (floored at -100bps) is at +/- 120bps in 1 year
USD ramped (floored at -100bps) is at +/- 120bps in 1 year
The change in NII under declining and upward interest rate scenarios may
not be equal. This is due to different expected reactions in prepayment
behaviour of mortgages and different pricing developments of commercial
loans and deposits products (mainly savings). This is caused by embedded
options, explicit or implicit pricing floors, and other (assumed) pricing
factors.
The metrics mentioned above are internal metrics, which therefore
deviate from the regulatory NII SOT metric. Both internal and regulatory
measures are part of the bank's risk appetite framework and are actively
managed.
Year-on-year variance analysis (*)
In 2025, ING maintained its dynamic hedging strategy, transferring
interest rate risk from business units to Group Treasury, where it was
subsequently hedged in financial markets, resulting in overall limited
sensitivity of NII at Risk (NIIaR) compared to ING\u2019s total net interest
income. Year-on-year NIIaR increase by \u20ac100 million under a parallel down
(worst case) scenario, is primarily driven by revised repricing assumptions
and positions taken by treasury.
Net present value (NPV) at Risk (*)
NPV-at-Risk measures the impact of changing interest rates on the value
of the positions in the banking book and it is defined as the outcome of an
instantaneous increase or decrease in interest rates from applying
currency-specific scenarios. The metric primarily reflects the impact of
interest rate fluctuations on the bank\u2019s strategic interest rate positions
(e.g. investments of own funds), as well as on the savings and mortgage
portfolios. While strategic positions typically adjust proportionally with
changing rates, the savings and mortgage products exhibit more complex
behavior due to embedded optionalities. Customers can prepay or
reallocate their balances, resulting in non-linear value changes. As a result,
these portfolios may incur value losses both when interest rates increase
and decrease, contributing to the asymmetric NPV-at-Risk pattern
highlighted in the annual report.
The full value impact cannot be directly linked to the financial position or
profit or loss account, as fair value movements in banking books are not
necessarily reported through the profit or loss account or through other
comprehensive income (OCI). The changes in value are expected to
materialise over time in the profit and loss account if interest rates
develop according to forward rates throughout the remaining maturity of
the portfolio. The majority of the risk comes from the investments of own
funds and from positions exhibiting negative convexity due to embedded
optionality (most notably variable rate savings and fixed rate mortgages).
The metrics mentioned above are internal metrics, which therefore
deviate from the regulatory EVE SOT metric. Both internal and regulatory
measures are part of the bank\u2019s risk appetite framework and are actively
managed.
NPV-at-Risk banking books per currency (*)
in EUR million
2025
2024
floored
floored
parallel \u25bc
parallel \u25b2
parallel \u25bc
parallel \u25b2
By currency
Euro
1,319
-2,593
7
-1,473
US dollar
273
-265
274
-266
Other
269
-267
321
-329
Total
1,862
-3,125
602
-2,068
EUR (floored at -100bps) is at +/- 120bps
USD (floored at -100bps) is at +/- 120bps
Year-on-year variance analysis (*)
The overall NPV sensitivity increased considerably compared to the
previous year. The parallel up scenario continues to represent the worst-
case outcome, and the calculation shock for the primary currencies (EUR
and USD) was maintained at 120 basis points, consistent with the level
used in 2024. Year-over-year variations are explained by the evolving
balance sheet composition, movements in interest rates, and shifting
market expectations.
The impact of the benchmark rate reform (*)
In line with the recommendations of the Financial Stability Board, a
fundamental review of important interest rates benchmarks has been
undertaken. Some interest rate benchmarks have been reformed, while
others have or will be replaced by risk-free rates and discontinued.
In 2025, the benchmark rate reform of only one reference rate, to which
ING has significant exposures as at 31 December 2025, was continuing (i.e.
WIBOR in Poland).
On 24 January 2025, the Steering Committee of the National Working
Group (NWG SC) in Poland selected POLSTR (Polish Short Term Rate) as the
ultimate interest rate benchmark to replace WIBOR. POLSTR is calculated
based on unsecured deposits of Credit and Financial Institutions and is
expected to replace WIBOR by 31 December 2027.
In April 2025, the NWG SC published the updated transition roadmap of
the replacing process of WIBOR and announced in June 2025 that the
official determination of the POLSTR has started.
During the second half of 2025, the NWG SC approved several
recommendations for products based on POLSTR, and informed that
POLSTR has been applied for the first time in the domestic financial market
on 1 September 2025. Therefore, POLSTR gained a status of a benchmark
in accordance with the requirements of the EU Benchmark Regulation.
On 30 September 2025, the benchmark administrator GPW Benchmark
S.A, published the decision to cease providing the WIBOR reference rate for
various tenors in phases, between the end of 2025 and the end of 2026.
On 21 November 2025, the Ministry of Finance (of Poland) conducted the
first pilot issuance of treasury bonds linked to the POLSTR benchmark
during a sale auction.
Other important milestones of the process are planned in subsequent
years, including the construction of a market for financial products based
on the new benchmark and achieving regulatory and operational
readiness of all market participants to offer and operate these financial
products.
Due to the discontinuation of WIBOR, ING, its customers, and in general
those market participants with exposure to this benchmark rate will be
faced with a number of risks. These risks include legal, financial,
operational, reputational, and conduct risk. The WIBOR rates are used in
several of our lending and derivative products, and hence a project team
has been established to manage the transition. The WIBOR transition is
especially important for our Polish subsidiary (ING Bank \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 exposure of ING that
has yet to transition related to WIBOR, excluding exposures expiring before
the transition date of 31 December 2027.
Non-derivative financial instruments to transition from WIBOR to POLSTR (*)
in EUR million
Financial assets
non-derivative
Financial
liabilities\u00a0 non-
derivative
Off-balance
sheet
commitments
Carrying value
Carrying value
Nominal value
31 December 2025
25,333
360
2,301
31 December 2024
19,202
134
1,544
Derivative financial instruments to transition from WIBOR to POLSTR (*)
31 December 2025
31 December 2024
in EUR million
Nominal value
Nominal value
WIBOR
196,133
110,189
See sections 1.5.4 of Note 1 \u2018Basis of preparation and material accounting
policy information\u2019 for information on the Phase 1 amendments to IFRS.
As at 31 December 2025, Phase 1 reliefs are applicable to WIBOR indexed
fair value and cash flow hedge accounting relationships as there is
uncertainty arising from the WIBOR reform with respect to the timing and
the amount of the underlying cash flows that the Group is exposed to.
Therefore, for WIBOR financial instruments designated in hedge
accounting the applicable Phase 1 reliefs will continue to apply until the
relevant contract is modified. At that point in time, the reliefs of Phase 2
amendments to IFRS will become applicable.
Following the Phase 1 reliefs that allow ING to continue applying hedge
accounting, ING has to assume that the WIBOR-based cash flows from the
hedging instrument and hedged item will remain unaffected for the
affected fair value and cash flow hedge relationships. In addition, for the
forecast transactions that are subject to cash flow hedge accounting,
under the Phase 1 reliefs ING has to assume that the WIBOR benchmark
on which the hedged cash flows are based is not altered as a result of the
reform and, therefore, the forecast transactions still meet the highly
probable requirement.
The total gross notional amounts of hedging instruments that are used in
ING\u2019s hedge accounting relationships for which the Phase 1 amendments
to IAS 39 were applied are:
Notional amounts of hedging instruments from WIBOR to POLSTR (*)
31 December 2025
31 December 2024
in EUR million
Nominal value
Nominal value
WIBOR
97,492
99,663
As at 31 December 2025, 50% (31\u00a0December 2024: 32%) of the notional
amounts have a maturity date beyond 31 December 2027. The notional
amounts of the derivative hedging instruments provide a close
approximation of the extent of the risk exposure ING manages through
these hedging relationships.
Credit spread risk in banking books (CSRBB) (*)
Credit spread risk is defined as risk driven by the changes of the market
price for credit risk, for liquidity and potentially other characteristics of
credit-risky instruments, which is not captured by another existing
prudential framework such as Interest Rate Risk in Banking Book or by
expected credit/(jump-to-) default risk. The CSRBB framework is
implemented based on EBA Guidelines. Metrics used are NPV-at-Risk, NII-
at-Risk and Market Value Changes-at Risk and view the positions across
different accounting treatments.
Credit spread risk is not part of the internal risk transfer towards Group
Treasury and therefore remains in the business unit it originated in. Group
Treasury itself is also an important driver of credit spread risk via its high-
quality liquid assets (HQLA) investment portfolio and issuance activities.
Risk appetite limits are set on a combination of metrics and accounting
scopes and are cascaded to local ALCOs depending on the type of limit
and materiality. Metrics and limits are monitored and reported monthly to
global and local risk committees, and various stakeholders.
Foreign exchange (FX) risk in banking books (*)
FX exposures in banking books result from core banking business activities
(business units doing business in currencies other than their base
currency), foreign currency investments in subsidiaries (including realised
net profit and loss), and strategic equity stakes in foreign currencies. The
policy regarding these exposures is briefly explained below.
Core banking business (*)
Every business unit hedges the FX risk resulting from core banking
business activities into its base currency to prevent volatility in profit and
loss. Consequently, assets and liabilities are matched in terms of currency,
within certain friction limits.
FX translation (*)
ING\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. Currency exposure of Return on Equity is also
considered. Hedge accounting is applied to the largest extent possible.
Taking this into account, the CET1 ratio hedge can be achieved by
deliberately taking foreign currency positions equal to certain target
positions, such that the CET1 capital and risk-weighted assets are equally
sensitive in relative terms to changing FX rates.
Risk profile \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.
Foreign currency exposures banking books (*)
in EUR million
Foreign
investments
Hedges
Net exposures
2025
2024
2025
2024
2025
2024
US Dollar 1
9,698
11,251
-4,500
-4,823
5,198
6,429
Pound Sterling
1,584
1,674
-515
-484
1,069
1,190
Polish Zloty
4,652
4,395
-2,009
-1,616
2,643
2,779
Australian Dollar
3,307
3,373
-1,933
-2,161
1,374
1,212
Turkish Lira
469
557
469
557
Chinese Yuan
2,015
2,439
1
-830
2,016
1,609
Russian Rouble
597
396
597
396
Romanian Leu
913
913
-228
-176
685
736
Thai Baht
1,307
1,266
-829
-838
478
428
Other currency
3,032
3,347
-1,995
-2,748
1,036
599
Total
27,573
29,612
-12,008
-13,675
15,565
15,936
*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.
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
\u20ac1,607 million (2024: \u20ac1,679 million) and equity securities held at fair
value through other comprehensive income (FVOCI) of \u20ac2,607 million
(2024: \u20ac2,562 million). The value of equity securities held at FVOCI is
directly linked to equity security prices with increases/decreases being
recognised in the revaluation reserve.
Investments in associates and joint ventures are measured in accordance
with the equity method of accounting, and the balance sheet value is
therefore not directly linked to equity security prices. The equity sensitivity
is expressed as the equity position.
Year-on-year variance analysis (*)
In 2025, the revaluation reserve equity securities decreased by \u20ac372
million from \u20ac1,816 million to \u20ac1,444 million due to revaluation of the
shares in Bank of Beijing with \u20ac-403 million. In 2025, the equity securities
at fair value through OCI increased by \u20ac45 million mainly due to increased
stake in Van Lanschot Kempen.
Revaluation reserve equity securities at fair value through other
comprehensive income (*)
in EUR million
2025
2024
Positive remeasurement
1,456
1,820
Negative remeasurement
-12
-4
Total
1,444
1,816
Market risk in trading books (*)
Within the trading portfolios, the positions are maintained in the financial
markets. These positions are often a result of transactions with clients and
may benefit from short-term price movements. In 2025, ING continued its
strategy of undertaking trading activities to develop its client-driven
franchise and deliver a differentiating experience by offering multiple
market and trading products.
With respect to the trading portfolios, Trading Risk Management (TRM)
focuses on the management of market risks of Wholesale Banking (mainly
Financial Markets) as this is the only business line within ING where trading
activities take place. Trading activities include facilitation of client business
and market making. TRM is responsible for the development and
implementation of trading risk policies and risk measurement
methodologies, and for reporting and monitoring risk exposures against
approved trading limits. TRM also reviews trading mandates and global
limits, and performs the gatekeeper role in the product review process
(PARP).
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 2025, there was one outlier for hypothetical P&L and
zero outliers for actual P&L. The hypothetical outlier occurred in the first
quarter of 2025, mainly driven by higher EUR rates due to anticipated
changes in German fiscal policy.
Stressed HVaR (*)
The stressed HVaR (SVaR) is intended to replicate the HVaR calculation that
would be generated on the bank\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 stressed period selection is reviewed annually. The
historical data period is chosen so that it gives the worst-scenario loss
estimates for the current portfolio. The same SVaR model is used for
management purposes and for regulatory purposes. The same SVaR model
is used for all legal entities within ING with market risk exposure in the
trading portfolio.
Incremental risk charge (*)
The incremental risk charge (IRC) for ING is an estimate of the default and
migration risks for credit products (excluding securitisations) in the trading
book, over a one-year capital horizon, with a 99.9 percent confidence level.
Trading positions (excluding securitisations) of ING, which are subject to
specific interest rate risk included in the internal model approach for market
risk regulatory capital, are in scope of the IRC model. By model choice,
equity is excluded from the model. For the calculation of IRC, ING performs a
Monte Carlo simulation based on a multi-factor t-copula. In the multi-factor
IRC model the supervisory asset correlations are no longer applicable and
the calibration of the correlations is based on historical market data. The
rating change is simulated for all issuers over the different liquidity horizons
(i.e. time required to liquidate the position or hedge all significant risks)
within one year. Movements across different rating categories and
probabilities of default are governed by a credit-rating transition matrix. An
internal transition matrix along with internal LGDs is used, to comply with
the consistency requirement. The financial impact is then determined for
the simulated migration to default, or for the simulated migration to a
different rating category, based on LGD or credit spread changes,
respectively.
The liquidity horizon has been set to the regulatory minimum of three
months for all positions in scope. ING reviews the liquidity horizons on a
yearly basis, based on a structured assessment of the time it takes to
liquidate the positions in the trading portfolio.
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 a
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
2025
2024
Foreign exchange
Foreign exchange
US Dollar
-260
US Dollar
-93
Turkish Lira
229
Turkish Lira
84
Chinese Yuan
88
Korean Won
62
Japanese Yen
-49
Japanese Yen
61
Romanian Leu
42
Chinese Yuan
-37
Most important interest rate and credit spread sensitivities at
year-end (*)
in EUR thousand
2025
2024
Interest rate (BPV) 1
Interest rate (BPV) 1
Euro
-312
Euro
-799
US Dollar
-161
US Dollar
-198
British Pound
-133
British Pound
-189
Japanese Yen
133
Korean Won
-54
Philippine Peso
-98
Philippine Peso
-54
Credit spread (CSO1) 2
Credit spread (CSO1) 2
France
178
United States
193
United Kingdom
111
Netherlands
-165
Netherlands
75
France
-113
Indonesia
-63
Poland
69
South Korea
63
Germany
49
1Basis point value (BPV) measures the impact on value of a one basis point increase in interest
rates.
2Credit 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 (*)
in EUR thousand
2025
2024
Corporate
Financial
institutions
Corporate
Financial
institutions
Credit spread (CSO1) 1
Risk classes
1 (AAA)
-2
-19
-2
-118
2\u20134 (AA)
26
-13
-44
-27
5\u20137 (A)
64
-37
49
-246
8\u201310 (BBB)
191
-54
93
-76
11\u201313 (BB)
38
-14
38
-13
14\u201316 (B)
56
8
23
-12
17\u201322 (CCC and NPL)
6
4
4
2
Total
378
-124
162
-489
1Credit spread sensitivity (CS01) measures the impact on value of a one 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:
\u00a7 Funding and liquidity risk framework;
\u00a7 Funding and liquidity risk management strategy and objectives;
\u00a7 Funding and liquidity adequacy and risk appetite;
\u00a7 Funding and liquidity risk indicators;
\u00a7 Liquidity stress testing; and
\u00a7 Contingency funding planning.
Funding and liquidity risk framework (*)
Macroeconomic and market environments 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. Exogenous factors analysed
on a regular basis include:
\u00a7 performance of global and local macroeconomic indicators, e.g. shifts
in gross domestic product, inflation rates, unemployment rates, and
public deficit/surplus;
\u00a7 developments and risks arising from geopolitical tensions and trends;
\u00a7 monetary policy with a focus on the alternative monetary measures
employed by central banks in recent years as a result of the global
energy crisis and periods of high inflation; and
\u00a7 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
to 53 percent and 22 percent of total funding, respectively. These funding
sources provide a stable funding base. The remainder of the required
funding is attracted primarily through a combination of long-term and
short-term professional funding. Group Treasury manages the professional
funding in line with the F&L risk appetite with the aim of ensuring a
sufficiently diversified and stable funding base.
ING\u2019s long-term professional funding is diversified across maturities and
currencies. The main portion of long-term professional funding is euro and
US dollar denominated, which is in line with the currency composition of
customer lending.
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.\u00a0
ING assesses its F&L adequacy through three lenses \u2013 stress, economic,
and normative:
\u00a7 Through the stress lens, ING evaluates its ability to withstand periods of
prolonged F&L stress for both normative and economic requirements.
Limits under idiosyncratic, market-related, combined idiosyncratic and
market-related, and climate risk scenarios, which lead to customer
deposit outflows, deterioration of access to funding markets, and lower
liquidity value of counterbalancing capacity are evaluated.
\u00a7 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.
\u00a7 Through the normative lens, ING ascertains that the bank is in the
position to meet current and future domestic and host regulatory
requirements.
For each lens, ING has established a related set of risk appetite statements,
which define ING\u2019s risk appetite, commensurate with the principles of
liquidity adequacy.
The F&L risk appetite statements are translated into metrics with
appropriate boundaries and instruments which are used to regularly
measure and manage ING\u2019s funding and liquidity risk. The risk appetite
with respect to the stress lens aims to have sufficient counterbalancing
capacity under various internally defined stress scenarios. Regarding the
economic perspective, an internally defined stable funding to loans (SFtL)
ratio and stable funding surplus (SFS) metric (supplemented by other
metrics) is used to stimulate a diversified funding base and to prevent
overreliance on professional funding. Finally, the liquidity coverage ratio
(LCR) and the net stable funding ratio (NSFR) regulatory metrics are
monitored in terms of both ING\u2019s risk appetite and normative
requirements.\u00a0
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 Group, including all entities,
business lines as well as on- and off-balance sheet positions. The net
liquidity position (NLP) is the main stress-testing measure and is measured
at different time buckets.
The stress-testing framework considers idiosyncratic, market-wide,
combined (idiosyncratic and market-wide) and climate-stress scenarios.
The design of the framework is based on empirical evidence supplemented
by expert judgment. The framework can be extended to additional ad-hoc
scenarios. For example, it can be used as input for firm-wide stress testing
and reverse stress testing.
Outcomes of the stress tests are considered in the key aspects of ING\u2019s F&L
risk framework and F&L risk management, including:
\u00a7 Risk Appetite Framework (through risk appetite statements);
\u00a7 Risk identification and assessment;
\u00a7 Monitoring of the liquidity and funding position;
\u00a7 Business actions (if needed);
\u00a7 Contingency funding plan; and
\u00a7 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 2025, this included stress-test scenarios assessing the impact of a
shutdown of US short- and long-term funding markets and FX markets.
The internal stress scenarios and their corresponding results serve as input
in the decision on holding additional contingency measures.
Contingency funding planning (*)
ING\u2019s contingent F&L risks are addressed in its Contingency Capital and
Funding Plan (CCFP). The objectives of the CCFP include:
\u00a7 Establishment of a monitoring framework to detect approaching
contingent events as well as their impact on ING\u2019s F&L position;
\u00a7 Provision of a plan for responding to various and increasing levels of a
bank\u2019s liquidity and capital shortfall under adverse and stressed
conditions;
\u00a7 Designation of management responsibilities, crisis communication
methods and channels, and reporting requirements;
\u00a7 Identification of contingent capital and liquidity sources under
escalating adverse and stressed conditions; and
\u00a7 Description of the steps needed to ensure the bank\u2019s capital and
liquidity sources 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 on
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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "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 \u2018Financial
Instruments: Disclosures\u2019. 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, such as certain legal and regulatory
disclosures. Not all information in this section can be reconciled
back to the primary financial statements and corresponding notes,
as it has been prepared using risk data that differs from the
accounting basis of measurement. Disclosures in accordance with
Part Eight of the CRR3 and CRD VI, and as required by the
supervisory authority, are published in our \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 Accounting Standards) as adopted by the European Union (EU) and the relevant articles
of Part 9 of Book 2 of the Dutch Civil Code.
IFRS Accounting Standards as adopted by the EU are IFRS Accounting 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 more information, reference is made to paragraph 1.5.4\u00a0 Derivatives and hedge accounting
of this note and to Note 34 '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 on
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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-3": { "value": "
Credit risk
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
39
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
38
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 & counterparty risk categories (*)
In the table below, we describe the different types of credit and
counterparty risk categories and include a reconciliation with the notes in
the financial statements:
Credit risk appetite and concentration risk framework (*)
The credit risk appetite and concentration risk framework is designed to
prevent undesired high levels of credit risk and credit concentrations within
various levels of the ING portfolio. It is derived from the concepts of
boundaries and instruments as described in the ING Risk Appetite
Framework.
Credit risk appetite is the maximum level of credit risk ING is willing to
accept for growth and value creation. The credit risk appetite is linked to
the overall bank-wide framework and is expressed in quantitative and
qualitative measures.
The credit risk appetite is set at different levels and dimensions within ING.
The credit risk appetite framework specifies the scope and focus of the
credit risk ING is willing to take, as well the composition of the credit
portfolio, including the concentration and diversification objectives across
business lines, locations, sectors, and products.
The credit concentration risk framework is composed of:
\u00a7 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.
\u00a7 Single name concentration (including secondary risk): ING has an
established credit concentration risk framework to identify, measure,
and monitor single name concentration, including secondary risk. The
same concept of boundaries and instruments is applicable.
\u00a7 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:
\u00a7 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.
\u00a7 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 \u2018(ultra) low 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 =
best rating; 22 = worst 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:
\u00a7 Investment grade (risk rating 1-10);
\u00a7 Non-investment grade (risk rating 11-17);
\u00a7 Performing Restructuring (risk rating 18-19); and
\u00a7 Non-performing (risk rating 20-22).
The first three categories (1-19) are risk ratings for performing loans.
Ratings are calculated in IT systems with internally developed models,
based on manually or automatically fed data, or for part of the non-
performing loans set by the global or regional credit restructuring
department. Under certain conditions, the outcome of a manually fed
model can be challenged through a rating appeal process. For
securitisation portfolios, the external ratings of the tranche in which ING
has invested are leading indicators.
Risk ratings assigned to clients are reviewed at least annually, with the
performance of the underlying models monitored regularly. Some of these
models are global in nature, such as those for large corporates,
commercial banks, insurance companies, central governments, funds,
fund managers, project finance, and leveraged companies. Other models
are more regional or country-specific: there are PD models for small and
medium enterprises (SMEs) in the Netherlands, Belgium and Poland, as
well as residential mortgage and consumer loan models in the various
retail markets.
Rating models for Retail clients are predominantly statistically driven and
automated, such that ratings can be updated on a monthly basis. Rating
models for large corporates, institutions and banks include both statistical
characteristics and expert input, with the ratings being manually updated
at least annually. More frequent reviews (e.g. quarterly) are performed
where considered necessary.
Credit risk portfolio (*)
Within ING, credit risk exposures are classified into four sources: 1)
Consumer Lending (to private individuals), 2) Business Lending, 3)
Investment and Money Market and 4) Pre-settlement. ING\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 2025, ING\u2019s portfolio size increased by \u20ac41.1 billion (4.1%) to
\u20ac1,002.9 billion outstanding. Foreign exchange rate changes had a \u20ac22.0
billion negative impact on the portfolio size, mainly driven by the
depreciation of the US dollar which had an impact of \u20ac16.6 billion mainly
in Wholesale Banking. Following this, net growth in Wholesale Banking was
\u20ac4.4 billion. Retail Banking outstandings increased by \u20ac38.4 billion mainly
due to underlying growth in residential mortgages.
Rating distribution (*)
Overall, the rating class distribution remained stable in 2025. The share of
investment grade rating classes increased from 78.1% to 79.3%, while the
share of non-investment grade decreased from 19.9% to 18.7%.
Performing restructuring outstandings remained constant at 0.6%\u00a0 of the
total portfolio in 2025, whereas non-performing loans (calculated including
Investment and Pre-Settlement exposures) decreased from 1.4% to 1.3%.
With respect to the rating distribution within the business lines, in
Wholesale Banking, investment grade increased to 84.3% from 83.7%,
while non-investment grade exposures decreased to 13.9% from 14.6%
compared to 2024. Performing restructuring assets increased from 0.6% to
0.7% of total Wholesale Banking assets where non-performing loans for
Wholesale Banking decreased from 1.2% to 1.1%. .
For Retail Banking, investment grade increased to 75.4% from 73.3%, while
non-investment grade exposures decreased to 22.5% from 24.4% as
compared to 2024. Performing restructuring decreased to 0.6% from 0.7%
whereas NPL remained constant at 1.5% in 2025.
Industry (*)
The industry breakdown is presented in accordance with the NAICS
definition. The increase of \u20ac41.1 billion in total volume during 2025 was
mainly due to the increase in Private Individuals (\u20ac28.7 billion) and Central
Governments (\u20ac13.4 billion) which was partially offset by the decrease in
Central Banks (\u20ac21.9 billion). The share of Private Individuals increased
from 39.5% last year to 40.7%.
Portfolio analysis per business line (*)
Outstandings per line of business (*)1, 2, 3
in EUR million
Wholesale Banking
Retail Banking
Corporate line
Total
Rating class
2025
2024
2025
2024
2025
2024
2025
2024
Investment grade
1 (AAA)
43,030
53,363
34,022
29,151
27
1,790
77,079
84,304
2-4 (AA)
70,691
72,462
68,484
63,187
1
4
139,175
135,653
5-7 (A)
130,372
101,831
149,694
140,479
555
157
280,620
242,467
8-10 (BBB)
119,661
129,429
175,823
155,375
3,055
3,452
298,539
288,256
Non-investment grade
11-13 (BB)
49,980
53,757
90,916
94,753
140,896
148,510
14-16 (B)
8,900
7,396
33,663
31,165
42,563
38,561
17 (CCC)
1,224
1,037
3,147
3,345
147
170
4,518
4,552
Performing Restructuring
loans
18 (CC)
2,209
1,792
1,945
2,001
4,154
3,794
19 (C)
637
560
1,678
1,760
2,315
2,320
Non-performing loans
20-22 (D)
4,602
5,204
8,393
8,100
12,995
13,303
Total
431,305
426,832
567,764
529,317
3,784
5,572
1,002,854
961,720
Industry
Private Individuals
1,893
2,116
406,589
377,712
408,482
379,827
Central Banks
40,270
61,091
15,713
15,044
1,785
55,983
77,919
Natural Resources
39,229
39,974
1,757
1,925
40,985
41,899
Real Estate
25,024
24,643
29,665
28,738
54,689
53,381
Commercial Banks
44,604
41,027
6,351
6,662
3,638
3,619
54,593
51,308
Non-Bank Financial
Institutions
65,037
64,217
1,973
2,212
77
79
67,086
66,509
Central Governments
59,600
48,389
10,280
8,107
1
1
69,880
56,497
Transportation & Logistics
25,427
27,499
6,507
6,037
31,934
33,536
Utilities
26,378
25,517
2,431
2,196
28,809
27,713
Food, Beverages & Personal
Care
13,798
13,827
11,298
10,419
25,096
24,246
Services
9,489
8,844
13,756
13,442
19
27
23,265
22,312
General Industries
13,235
10,512
9,655
8,812
22,890
19,324
Lower Public Administration
8,904
6,959
22,529
19,598
31,433
26,557
Other
58,418
52,218
29,261
28,412
50
62
87,730
80,691
Total
431,305
426,832
567,764
529,317
3,784
5,572
1,002,854
961,720
Outstandings per line of business (*) - continued1, 2, 3
in EUR million
Wholesale Banking
Retail Banking
Corporate line
Total
Region
2025
2024
2025
2024
2025
2024
2025
2024
Europe
Netherlands
35,256
44,486
180,030
164,590
526
1,906
215,812
210,981
Belgium
25,786
26,506
99,055
95,584
0
0
124,841
122,091
Germany
29,699
27,443
136,951
128,598
22
30
166,672
156,071
Poland
23,740
21,190
34,223
30,946
3
0
57,966
52,136
United Kingdom
30,475
28,257
252
265
78
91
30,805
28,613
France
26,462
24,351
3,742
3,122
3
3
30,207
27,476
Spain
15,568
11,990
31,015
28,507
38
36
46,620
40,533
Luxembourg
28,844
26,176
4,587
5,139
0
0
33,431
31,314
Rest of Europe
70,498
72,860
26,384
23,203
37
14
96,919
96,076
America
83,269
86,402
2,304
2,402
16
22
85,590
88,827
Asia
47,881
44,136
257
215
3,060
3,464
51,198
47,815
Australia
11,673
10,887
48,938
46,723
1
8
60,613
57,618
Africa
2,154
2,148
27
22
0
0
2,181
2,170
Total
431,305
426,832
567,764
529,317
3,784
5,572
1,002,854
961,720
1Based on credit risk measurement contained in lending, pre-settlement, money market and investment activities.
2Based on the total amount of credit risk in the respective column using ING\u2019s internal credit risk measurement methodologies. Economic sectors (industry) below 2% are not shown separately but grouped in Other.
3Geographical areas are based on country of residence, except for private individuals for which the geographical areas are based on the primary country of risk.
Portfolio analysis per geographical area (*)
The portfolio analysis per geographical area re-emphasises the
international distribution of ING\u2019s credit portfolio. The Netherlands
maintains the largest portfolio share in a single country with 21.5%
(2024: 21.9%) of the total amount, followed by Germany with 16.6%
(2024: 16.2%), and Belgium with 12.4% (2024: 12.7%).
In terms of region, the majority of the portfolio balance remained in
Europe with 80.1% (2024: 80.0%), followed by the Americas with 8.5%
(2024: 9.3%) and Australia with 6.0% (2024: 6.0%).
The top five countries within Rest of Europe based on outstandings were
Italy (\u20ac25.2 billion), Romania (\u20ac14.0 billion), Switzerland (\u20ac10.9 billion),
T\u00fcrkiye (\u20ac9.7 billion), and Ireland (\u20ac5.2 billion).
The main contributors for the overall increase in outstanding are Germany
(\u20ac10.6 billion),\u00a0 Spain (\u20ac6.1 billion), Poland (\u20ac5.8 billion), and the
Netherlands (\u20ac4.8 billion).
Private Individuals remained the largest composition of portfolio balances
for the Netherlands at 61.9% (2024: 58.3%), Belgium at 37.7% (2024:
37.4%), Germany at 68.5% (2024: 68.8%), and Australia at 68.1%
(2024: 66.1%). The decrease in Central Banks is mainly attributed to the
Netherlands (\u20ac13.8 billion), Belgium (\u20ac3.6 billion) and Asia (\u20ac3.1 billion).\u00a0
In individual countries, the total share of investment grade/non-
investment grade remains substantial for the Netherlands at 98.5% (2024:
98.5%), Germany at 98.7% (2024:98.9%), and Belgium 96.8% (2024:
96.6%).
In Europe, the increase in investment grade outstandings was mainly
observed in\u00a0 Germany (\u20ac11.9 billion), Spain (\u20ac8.4 billion), Poland (\u20ac5.2
billion) and France (\u20ac3.0 billion).
The net decrease in non-investment grade outstandings was mainly
observed in Spain (\u20ac2.4 billion), America (\u20ac1.9 billion), and Germany
(\u20ac1.7\u00a0billion).
Outstandings by economic sectors and geographical area (*) 1
in EUR million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United
Kingdom
Luxembourg
France
Rest of
Europe
America
Asia
Australia
Africa
2025
Private Individuals
133,644
47,047
114,235
18,871
29,412
117
2,734
2,038
18,761
183
128
41,294
20
408,482
Central Banks
8,742
6,621
13,938
1,499
577
3,791
6,088
0
6,912
0
6,426
1,388
0
55,983
Natural Resources
2,220
1,257
869
909
156
2,848
2,254
261
10,730
8,974
8,830
1,396
281
40,985
Real Estate
17,212
14,082
1,184
2,356
1,749
679
3,257
3,055
3,805
2,591
1,409
3,309
0
54,689
Commercial Banks
1,573
504
5,605
493
754
4,917
6,808
5,228
8,205
9,182
10,762
398
164
54,593
Non-Bank Financial Institutions
3,577
1,536
5,717
2,295
880
8,040
6,819
6,255
5,738
21,109
3,451
1,659
10
67,086
Central Governments
3,297
14,525
374
11,768
6,692
31
186
5,485
11,463
14,146
935
400
580
69,880
Transportation & Logistics
4,652
2,132
1,239
1,759
698
2,384
967
839
6,048
3,665
6,196
663
692
31,934
Utilities
1,678
1,868
3,890
1,127
1,932
3,184
539
593
4,291
6,144
1,376
2,067
121
28,809
Food, Beverages & Personal Care
8,415
3,675
604
2,425
340
261
1,472
801
2,998
2,358
1,269
476
1
25,096
Services
5,322
8,420
1,906
1,639
127
1,123
306
394
1,464
1,106
873
585
1
23,265
General Industries
5,118
3,232
1,304
2,957
208
262
476
550
4,399
2,575
1,461
322
25
22,890
Lower Public Administration
2,236
7,362
10,121
815
682
0
235
3,432
520
1,462
38
4,528
0
31,433
Other
18,125
12,579
5,685
9,053
2,413
3,169
1,290
1,277
11,584
12,097
8,044
2,127
287
87,730
Total
215,812
124,841
166,672
57,966
46,620
30,805
33,431
30,207
96,919
85,590
51,198
60,613
2,181
1,002,854
Rating class
Investment grade
171,707
74,908
148,033
41,249
41,114
25,930
29,551
24,917
71,116
71,085
45,214
50,441
147
795,414
Non-investment grade
40,889
45,899
16,505
14,477
4,771
4,664
3,586
5,048
22,521
12,841
5,430
9,527
1,821
187,976
Performing Restructuring
1,528
928
680
694
265
30
53
134
1,486
406
66
162
39
6,469
Non-performing loans
1,689
3,107
1,454
1,546
470
181
242
108
1,795
1,257
488
483
175
12,995
Total
215,812
124,841
166,672
57,966
46,620
30,805
33,431
30,207
96,919
85,590
51,198
60,613
2,181
1,002,854
1Geographical areas are based on country of residence, except for private individuals for which the geographical areas are based on the primary country of risk.
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
10,913
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
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
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
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
1Geographical areas are based on country of residence, except for Private Individuals for which the geographical areas are based on the primary country of risk.
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 relying on the value of the cover.
Cover forms (*)
Within ING, there are two distinct forms of covers. First, where the asset
has been pledged to ING as collateral or security, ING has the right to
liquidate it should the customer be unable to fulfil its financial obligation.
As such, the proceeds can be applied towards full or partial compensation
of the customer's outstanding exposure. This may be tangible (such as
cash, securities, receivables, inventory, plant and machinery, and
mortgages on real estate properties) or intangible (such as patents,
trademarks, contract rights, and licences). Second, where there is a third-
party obligation, indemnification or undertaking (either by contract and/or
by law), ING has the right to claim from that third party an amount if the
customer fails in its obligations. The most common examples are
guarantees, such as parent guarantees, export credit insurances, or third-
party pledged mortgages. Insurance or reinsurance covers, including
comprehensive private risk insurance (CPRI) may be recognised as
guarantees and effectively function in an equivalent manner. ING accepts
credit risk insurance companies and export credit agencies (ECAs) as cover
providers.
Cover valuation methodology (*)
General guidelines for cover valuation are established with the objective of
ensuring consistent application within ING. These also require that the
value of the cover is monitored on a regular basis. Covers are revalued
periodically and whenever there is reason to believe that the market is
subject to significant changes in conditions. The frequency of monitoring
and revaluation depends on the type of cover.
The valuation method also depends on the type of covers. For asset
collateral, the valuation sources can be the customer\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
(market values), financial collateral (cash and securities), guarantees, and
other covers (mainly pledges). The scope of covers in this overview has
been revised due to CRR3 implementation to align with regulatory
reporting. This explains the decrease in the values of 'other covers', which
had only a limited effect on the fully covered part of the portfolio, as ING's
portfolio remains well collateralised. Collateral covering financial market
transactions is valued on a daily basis (margining), and is as such not
included in the following tables. To mitigate the credit risk arising from
financial markets transactions, the bank enters into legal agreements
governing the exchange of financial collateral (high-quality government
bonds and cash).
The cover values are presented for the total portfolio of ING, both the
performing and non-performing portfolio.
Cover values including guarantees received (*)
in EUR million
Cover type and value
Collateralisation
2025
Outstandings
Mortgages
Financial Collateral
Guarantees
Other covers
No cover
Partially covered
Fully covered
Consumer lending
407,552
905,028
5,317
37,473
842
7.8%
2.0%
90.2%
Business lending
383,443
186,276
31,834
166,953
215,177
42.1%
15.8%
42.1%
Investment and money market
151,639
\u2014
\u2014
1,506
\u2014
99.6%
\u2014%
0.4%
Total lending, investment and money market
942,634
1,091,304
37,151
205,932
216,019
36.6%
7.3%
56.1%
of which NPL
12,981
9,827
196
2,771
3,591
33.0%
18.5%
48.5%
Pre-settlement
60,220
Total Bank
1,002,854
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
\u2014
\u2014
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
The above tables gives an overview of the collateralisation of ING\u2019s total
portfolio. Excluding the pre-settlement portfolio, 56.1% (2024: 55.9%) of
ING\u2019s outstandings were fully collateralised in 2025. Since investments
traditionally do not require covers, the \u2018no covers\u2019 percentage in this
portfolio is over 99.6%.
Consumer lending portfolio (*)
The consumer lending portfolio accounts for 40.6% (2024: 39.4%) of ING\u2019s
total outstanding, primarily consisting of residential mortgage loans and
consequently most collateral consists of mortgages. Mortgage values are
collected in an internal central database and in most cases external data is
used to index the market value.
A significant part of ING\u2019s residential mortgage portfolio is in the
Netherlands (2025: 35.0%, 2024: 35.0%), Germany (2025: 27.0%,
2024: 27.3%), Belgium (including Luxembourg) (2025: 12.0%, 2024: 12.2%)
and Australia (2025: 10.9%, 2024: 10.6%).
Business lending portfolio (*)
Business lending accounts for 38.2% (2024: 38.3%) of ING\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 makes use of Early
Warning Indicators (EWIs) in daily credit risk management processes,
which relate to a change in (internal and/or external) circumstances or
outlook of the specific obligor, the sector or the portfolio. ING usually
classifies a client with a 'watch list' status (Business lending only) when
there are early warning indicators triggered that detect an increased risk
profile. Watch list status requires more than usual attention, increased
monitoring and quarterly reviews. Some clients with a watch list or EWI
status may develop into a performing restructuring status or a non-
performing status. When there is increasing doubt as to the performance
and collectability of the client\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
2025
2024
Performing not past due
879,284
823,336
Business lending performing past due
8,071
9,174
Consumer lending performing past due
895
802
Non-performing
12,981
13,295
Total lending and investment
901,232
846,607
Money market
41,402
54,145
Pre-settlement
60,220
60,968
Total
1,002,854
961,720
Past due obligations (*)
Retail Banking measures its portfolio in terms of payment arrears and
determines on a monthly basis if there are any significant changes in the
level of arrears. This methodology applies to Private Individuals as well as
Business lending. An obligation is considered \u2018past due\u2019 if it is more than
one day late, subject to materiality thresholds in line with Definition of
Default Regulation. ING aims to help its customers as soon as they are past
due by reminding them of their payment obligations. In its contact with
customers, ING aims to solve the (potential) financial difficulties by offering
a range of measures (e.g. payment arrangements, restructuring). If the
issues cannot be resolved because the customer is unable or unwilling to
pay, for example, the contract is sent to the recovery unit. The facility is
downgraded to risk rating 20 (non-performing) when the facility or obligor
\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.
The past due but performing consumer lending outstanding increased by
\u20ac93 million, due to the increase in 1-30 days (\u20ac90 million) and 31-60 days
(\u20ac3 million).
The largest single country increase was in Belgium (\u20ac42 million), followed
by the Netherlands (\u20ac22 million), mainly in the 1-30 days bucket.\u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0
The largest decrease was seen in Australia (\u20ac21 million).
Ageing analysis (past due but performing): Consumer lending portfolio by geographic area, outstandings (*)
in EUR million
2025
2024
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
Netherlands
84
32
6
122
62
35
4
101
Belgium
219
60
26
305
185
49
29
263
Germany
70
37
22
129
65
37
24
125
Poland
58
6
3
68
61
9
4
74
Spain
22
17
9
48
12
16
8
36
Luxembourg
25
5
4
34
22
6
3
32
Rest of Europe
121
23
6
150
93
15
4
112
America
0
1
0
1
0
0
0
1
Asia
0
1
0
1
0
0
0
0
Australia
29
8
1
38
38
19
2
59
Africa
0
0
0
0
0
0
0
0
Total
628
189
78
895
538
186
78
802
Ageing analysis (past due but performing): Business lending portfolio by geographic area, outstandings (*)
in EUR million
2025
2024
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
Netherlands
586
31
9
626
929
14
943
Belgium
476
22
10
508
1,187
17
13
1,217
Germany
415
2
2
419
215
3
2
220
Poland
403
31
15
449
173
17
19
209
United Kingdom
516
531
1,046
830
8
838
France
73
73
194
194
Spain
9
9
26
26
Luxembourg
212
9
1
222
367
51
5
423
Rest of Europe
899
17
3
919
630
4
46
681
America
2,946
68
3,013
3,504
95
3,599
Asia
133
133
310
310
Australia
636
10
7
654
469
6
475
Africa
39
39
Total
7,303
720
47
8,071
8,873
215
86
9,174
Total past due but performing outstanding of business lending decreased
by \u20ac1.1. billion. The decrease was mainly witnessed in the 1\u201330 days past
due bucket (\u20ac1.6 billion) and was offset by the increase in 31-60 days
(\u20ac0.5 billion) past due bucket, fully in the United Kingdom related to
overdue fees. The largest decreases were in Belgium\u00a0 (\u20ac0.7 billion) and
America\u00a0 (\u20ac0.6 billion), while the largest increase were in Australia (\u20ac0.2
billion), Germany (\u20ac0.2 billion), Poland (\u20ac0.2 billion), and the United
Kingdom (\u20ac0.2 billion).
Forbearance (*)
Forbearance occurs when a client is unable to meet their financial
commitments due to financial difficulties they are facing or are about to
face and ING grants them concessions. Forborne assets are assets for
which forbearance measures have been granted.
Forbearance may enable clients experiencing financial difficulties to
continue repaying their debt.
For business clients, ING mainly applies forbearance measures to support
clients with fundamentally sound business models that are experiencing
temporary difficulties. The aim is to maximise the client\u2019s repayment
ability, thereby avoiding a default situation, and help the client to return to
a performing situation.
For ING Retail units, clear criteria have been established to determine
whether a client is eligible for the forbearance process. Specific approval
mandates are in place to approve the measures, as well as procedures to
manage, monitor, and report the forbearance activities.
ING reviews the performance of forborne exposures at least quarterly,
either on a case-by-case (Business) or portfolio (Retail) basis.
Both performing (risk ratings 1-19) and non-performing (risk ratings 20-22)
exposures are eligible for Forbearance measures. ING uses specific criteria
to move forborne exposures from non-performing to performing or to
remove the forbearance statuses that are consistent with the
corresponding European Banking Authority (EBA) standards. An exposure
is reported as forborne for a minimum of two years. An additional one-
year probation period is applied to forborne exposures that move from
non-performing back to performing.
Summary Forborne portfolio (*)
in EUR million
2025
2024
Business line
Outstandings
Of which: performing
Of which: non-performing
% of total portfolio(1)
Outstandings
Of which: performing
Of which: non-performing
% of total portfolio(1)
Wholesale Banking
5,910
3,194
2,716
1.7%
5,934
3,191
2,743
1.9%
Retail Banking
7,551
4,538
3,013
1.4%
6,883
3,987
2,897
1.3%
Total
13,461
7,732
5,729
1.5%
12,817
7,178
5,640
1.5%
Summary Forborne portfolio by forbearance type (*)
in EUR million
2025
2024
Forbearance type
Outstandings
Of which: performing
Of which: non-performing
% of total portfolio(1)
Outstandings
Of which: performing
Of which: non-performing
% of total portfolio(1)
Loan modification
11,883
6,581
5,302
1.3%
11,726
6,734
4,993
1.4%
Refinancing
1,578
1,151
427
0.2%
1,091
444
647
0.1%
Total
13,461
7,732
5,729
1.5%
12,817
7,178
5,640
1.5%
1% of total portfolio is based on lending and investment outstandings.
Forborne assets increased by \u20ac644 million, mainly due to the increase of
\u20ac667 million in Retail Banking, which was offset by a \u20ac24 million decrease
in Wholesale Banking. The rise in Retail Banking forborne assets was
primarily driven by residential mortgages in the Netherlands, which
contributed \u20ac608 million. This increase was largely the result of the
implementation of an updated framework, under which more clients are
classified as forborne, while outflow is only allowed after a two-year
probation period.
In terms of forbearance type, the increase is mainly witnessed in
refinancing type (\u20ac487 million) driven by a few larger files in Wholesale
Banking.
Modification of financial assets (*)
The following table shows:
\u00a7 Financial assets that were modified during the year (i.e. qualified as
forborne) while they had a loss allowance measured at an amount
equal to lifetime ECL; and
\u00a7 Financial assets that were reclassified to Stage 1 during the period
while being modified before.
Financial assets modified (*)
in EUR million
2025
2024
Financial assets modified during the period
Amortised cost before modification
1,746
1,888
Net modification results
-72
-107
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
1,027
1,506
Wholesale Banking (*)
Wholesale Banking forborne assets amounted to \u20ac5.9 billion (2024:
\u20ac5.9 billion), which represented 1.7% (2024: 1.9%) of the total Wholesale
Banking portfolio.
The net decrease in Wholesale Banking forborne assets was driven by a
\u20ac27 million reduction in non-performing forborne exposure and partially
offset by a \u20ac3 million rise in performing forborne exposures.\u00a0
Wholesale Bankings' forborne assets show an increase in Telecom due to
refinancing, which was offset by a decrease in other sectors, such as real
estate, food, beverages & personal care, chemicals, health &
pharmaceuticals and natural resources. These five sectors accounted for
69.6% of the total Wholesale Banking forborne outstandings.
Wholesale Banking: Forborne portfolio by geographical area (*)
in EUR million
2025
2024
Region
Outstandings
Of which:
performing
Of which: non-
performing
Outstandings
Of which:
performing
Of which: non-
performing
Europe
Netherlands
316
191
124
217
69
148
Belgium
3
3
172
165
7
Germany
336
29
307
372
62
310
Poland
662
305
357
630
284
346
United Kingdom
676
516
160
444
266
178
Italy
547
519
28
389
353
36
Rest of Europe
1,081
558
523
1,339
940
399
America
1,313
545
768
1,586
867
719
Asia
711
313
398
652
111
541
Australia
212
177
35
79
34
44
Africa
53
37
15
54
40
15
Total
5,910
3,194
2,716
5,934
3,191
2,743
Wholesale Banking: Forborne portfolio by economic sector (*)
in EUR million
2025
2024
Industry
Outstandings
Of which:
performing
Of which: non-
performing
Outstandings
Of which:
performing
Of which: non-
performing
Natural Resources
605
308
297
781
424
356
Real Estate
945
375
570
1,115
703
412
Transportation & Logistics
145
48
97
214
83
131
Food, Beverages & Personal Care
629
289
340
810
415
395
Services
172
149
24
211
176
34
Automotive
263
139
124
332
183
149
Utilities
497
218
279
677
301
376
General Industries
197
42
155
127
70
58
Retail
111
41
70
149
21
128
Chemicals, Health & Pharmaceuticals
619
74
545
668
136
532
Builders & Contractors
179
174
4
122
118
5
Telecom 1
1,314
1,166
148
486
383
103
Other
234
172
62
243
178
65
Total
5,910
3,194
2,716
5,934
3,191
2,743
1The presentation has been revised to separately disclose Telecom. Comparative figures have been
adjusted accordingly.
Retail Banking (*)
As of year end, Retail Banking forborne assets amounted to \u20ac7.6 billion
(2024: \u20ac6.9 billion), which represented 1.4% (2024: 1.3%) of the total Retail
Banking portfolio. Retail Banking performing forborne exposure increased
by \u20ac0.6 billion.
Retail Banking: Forborne portfolio by geographical area (*)
in EUR million
2025
2024
Region
Outstandings
Of which: performing
Of which: non-performing
Outstandings
Of which: performing
Of which: non-performing
Europe
Netherlands
2,136
1,711
424
1,548
1,134
414
Belgium
2,153
978
1,175
1,942
800
1,142
Germany
1,304
965
338
1,379
1,052
327
Poland
793
361
432
777
403
374
Spain
92
55
37
159
127
31
Italy
104
33
70
122
43
79
T\u00fcrkiye
22
16
6
13
9
4
Romania
216
106
110
173
72
101
Rest of Europe
91
32
59
102
50
52
America
5
5
22
17
6
Asia
1
1
1
Australia
635
279
357
646
279
367
Africa
Total
7,551
4,538
3,013
6,883
3,987
2,897
The main concentration of forborne assets in a single country was in
Belgium with 28.5% (2024: 28.2%) of total Retail Banking forborne assets
and 39.0% (2024: 39.4%) of the non-performing forborne assets. The other
significant single country concentration is in the Netherlands with 28.3%
(2024: 22.5%), which increased during 2025 because of the
implementation of a new framework for mortgages, and Germany having
17.3% (2024: 20.0%) 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 (non-exhaustive list):
\u00a7 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:
\u2013 The borrower (or third party) has started insolvency proceedings;
\u2013 A group company/co-borrower has NPL status;
\u2013 Indication of fraud (affecting the company\u2019s ability to service its
debt);
\u2013 There is doubt as to the borrower\u2019s ability to generate stable and
sufficient cash flows to service its debt;
\u2013 Restructuring of debt; and
\u2013 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.
\u00a7 The obligor has failed in the payment of principal, interest, or fees; the
total past due amount is above the materiality threshold, and this
remains the case for more than 90 consecutive days.
Furthermore, Wholesale Banking has an individual name approach, using
early warning indicators to signal possible future issues in debt service.
Also in Retail Banking early warning indicator frameworks have been
implemented.
The table below represents the breakdown of credit risk outstandings that
have been classified as non-performing by sector and business line.
Non-performing Loans: Outstandings by economic sector and business lines (*) 1
in EUR million
Wholesale Banking
Retail Banking
Total
Industry
2025
2024
2025
2024
2025
2024
Private Individuals
3
4
4,899
4,766
4,902
4,769
Natural Resources
945
965
115
99
1,061
1,064
Food, Beverages & Personal Care
372
452
325
357
697
809
Transportation & Logistics
251
347
227
157
478
504
Services
94
102
375
394
469
495
Real Estate
586
831
656
603
1,241
1,434
General Industries
243
236
471
451
713
687
Builders & Contractors
31
51
541
445
571
496
Retail
184
157
189
224
373
381
Utilities
336
582
26
19
362
600
Chemicals, Health & Pharmaceuticals
602
654
150
185
752
839
Telecom 2
170
151
36
12
206
163
Other
771
666
383
387
1,154
1,052
Total
4,589
5,196
8,392
8,099
12,981
13,295
1Based on lending and investment outstandings.
2The presentation has been revised to separately disclose Telecom. Comparative figures have been
adjusted accordingly.
Non-performing loans: Outstandings by economic sectors and geographical area (*)
in EUR million
Region
Total
Industry
Netherlands
Belgium
Germany
Poland
Spain
United Kingdom
France
Luxembourg
Rest of Europe
America
Asia
Australia
Africa
2025
Private Individuals
697
1,481
1,113
220
357
10
8
39
574
2
2
399
1
4,902
Natural Resources
137
84
28
14
584
23
191
1,061
Food, Beverages & Personal Care
167
94
1
94
19
6
126
59
131
697
Transportation & Logistics
87
40
136
47
22
72
22
10
1
41
478
Services
68
262
75
1
3
4
16
26
13
469
Real Estate
24
419
59
115
45
47
101
8
377
48
1,241
General Industries
137
138
38
196
20
13
130
10
31
713
Builders & Contractors
89
219
7
182
8
66
571
Retail
80
79
33
56
1
4
15
105
373
Utilities
14
10
19
8
151
1
12
80
33
35
362
Chemicals, Health &
Pharmaceuticals
47
65
112
346
43
25
64
49
752
Telecom
37
4
3
15
146
2
206
Other
102
209
72
88
2
1
10
105
358
75
132
1,154
Total
1,686
3,105
1,454
1,546
470
181
108
242
1,786
1,257
488
483
175
12,981
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
In 2025, the NPL portfolio decreased to \u20ac13.0 billion (2024: \u20ac13.3 billion),
mainly driven by the decrease of \u20ac0.6 billion in Wholesale Banking. The
decrease was offset by the increase in Retail Banking (\u20ac0.3 billion) in line
with strong portfolio growth, mainly in residential mortgages.
Total net decrease was mainly seen in sectors Utilities, Real Estate and
Food, Beverage & Personal Care while the largest increase was in Private
Individuals.
Loan loss provisioning (*)
ING recognises loss allowances based on the expected credit loss (ECL)
model of IFRS 9, which is designed to be forward-looking. The IFRS 9
impairment requirements are applicable to on-balance-sheet financial
assets measured at amortised cost or fair value through other
comprehensive income (FVOCI), such as loans, debt securities, and lease
receivables, as well as off-balance-sheet items such as undrawn loan
commitments and financial- and non-financial guarantees issued.
ING distinguishes between two types of calculation methods for credit loss
allowances:
\u00a7 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; and
\u00a7 Individual lifetime ECL for credit-impaired (Stage 3) financial
instruments with exposures above \u20ac1 million.
IFRS 9 models (*)
ING\u2019s 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.
Climate and environmental risks in IFRS 9 models (*)
Climate risk drivers (physical and transition risks) can reduce the ability of
businesses and households to fulfil their obligations due, under existing
lending contracts. These climate risks are partly reflected in IFRS9 ECL
through regular credit risk transmission channels such as the
macroeconomic forecast and relevant risk parameters.
On the other hand, future physical or transition risks from climate change
are not yet fully captured within the current ECL models. In our
assessment of physical risks, it is generally expected that these risks will
only become financially significant on the long-term horizon.
Consequently, for short- and medium-term loans, such risks are not
expected to lead to significant credit deterioration over the exposure\u2019s
lifetime. For the long term, the probability and timing of physical risk
events remain highly uncertain. ING is however actively enhancing the
integration of physical and transition risks into collateral valuations,
ensuring that effects on property values are appropriately captured.
In case of risk events that have already occurred (e.g. floods, stranded
assets), the impact of such events is assessed in the calculation of Stage 3
individual provisions, collective SICR or management adjustments to ECL
models. For example, we consider whether affected assets have suffered
from a significant increase in credit risk (or are credit impaired) and
whether the ECL is appropriate.
Additionally, a management adjustment to ECL models for business
clients was introduced to specifically cover for medium- to long-term
transition risk on high greenhouse gas-emitting sectors. The management
adjustment reflects the risk of financial loss foreseen on the longer horizon
for lenders with higher transition risk in these high greenhouse gas-
emitting sectors as consequence of future carbon taxation.
ING is continuously improving on climate risk data, which will enable us to
further embed climate risks into the IFRS 9 ECL models. For more
information on ESG risk management, see \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 92.0%
(2024: 91.1%) of the total gross carrying amounts, mainly composed of
investment grade, while Stage 2 makes up 6.8% (2024: 7.6%) and Stage 3
makes up 1.2% (2024: 1.3%) of the total gross carrying amounts,
respectively.
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
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
Investment grade
1 (AAA)
79,938
79,076
2
1
126
281
80,064
79,357
2
1
2-4 (AA)
146,878
140,671
11
10
1,437
1,579
1
1
148,315
142,250
13
11
5-7 (A)
299,791
244,306
39
22
5,394
6,908
6
8
305,185
251,214
45
29
8-10 (BBB)
334,659
310,114
77
55
19,168
24,683
43
55
353,827
334,797
119
110
Non-investment
grade
11-13 (BB)
156,373
154,348
165
190
17,217
18,479
89
91
173,589
172,827
254
281
14-16 (B)
26,187
25,377
147
124
22,668
17,433
357
366
48,855
42,811
504
490
17 (CCC)
412
905
5
8
4,682
3,992
224
173
5,094
4,897
228
181
Performing
Restructuring
18 (CC)
4,349
4,059
262
233
4,349
4,060
262
233
19 (C)
2,447
2,474
198
203
2,447
2,474
198
203
Non-performing loans
20-22 (D)
13,590
13,742
4,476
4,509
13,590
13,742
4,476
4,509
Total
1,044,238
954,798
446
409
77,487
79,888
1,179
1,130
13,590
13,742
4,476
4,509
1,135,315
1,048,429
6,101
6,049
1Compared to the credit risk portfolio, the differences are due to undrawn committed amounts (\u20ac200.2 billion; 2024: \u20ac156.0 billion) and other positions (2025: nil; 2024:\u20ac6 billion) not included in credit outstandings and non-IFRS 9 eligible assets (\u20ac68.2 billion; 2024: \u20ac75.0 billion) included in credit outstandings but not
in the gross carrying amounts.
2Stage 3 lifetime credit impaired provision includes \u20ac 29 million (2024: \u20ac21 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:
\u00a7 Stage 3 gross carrying amount decreased by \u20ac0.2 billion from \u20ac13.7
billion as at 31 December 2024 to \u20ac13.6 billion as at 31 December 2025,
mainly as a result of \u20ac3.5 billion net inflow into NPL (credit impaired) in
2025, which is offset by \u20ac2.3 billion derecognitions and repayments
and \u20ac1.5 billion write-offs and disposals. Following the decrease in
carrying amount, Stage 3 provisions slightly decreased by \u20ac33 million
Stage 2 gross carrying amounts decreased by \u20ac2.4 billion from \u20ac79.9
billion as at 31 December 2024 to \u20ac77.5 billion as at 31 December 2025,
largely driven by \u20ac15.7 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 \u20ac18.0 billion due to derecognised financial assets (including
sales and repayments) and \u20ac1.2 billion exposure moving to Stage 3. Stage
2 provisions increased by \u20ac49 million to \u20ac1.2 billion as of 31 December
2025.
Changes in gross carrying amounts and loan loss provisions (*) 1, 2
in EUR million
12-month ECL\u00a0 \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
2025
2024
Opening balance
954,798
409
79,888
1,130
13,742
4,509
1,048,429
6,049
937,684
517
75,258
1,435
11,956
3,887
1,024,897
5,839
Transfer into 12-month ECL (Stage 1)
21,773
21
-21,555
-199
-218
-35
-212
20,276
22
-20,026
-195
-249
-34
0
-207
Transfer into lifetime ECL not credit impaired (Stage 2)
-37,208
-50
38,174
533
-966
-115
368
-43,155
-49
43,900
429
-745
-96
0
285
Transfer into lifetime ECL credit impaired (Stage 3)
-2,534
-14
-2,172
-138
4,705
1,259
1,108
-2,980
-18
-2,856
-235
5,836
1,802
0
1,548
Net remeasurement of loan loss provisions
7
-53
349
302
0
-180
0
-137
0
185
0
-133
New financial assets originated or purchased
263,371
189
22
2
263,393
191
212,529
192
0
0
0
0
212,529
192
Financial assets that have been derecognised
-119,098
-78
-12,295
-147
-1,422
-240
-132,814
-465
-126,858
-76
-11,840
-153
-1,450
-257
-140,148
-485
Net drawdowns and repayments
-57,441
-5,739
-853
-64,033
-41,763
0
-4,406
0
-309
0
-46,478
0
Changes in models/risk parameters
-33
71
-35
3
0
8
0
-6
0
-22
0
-20
Increase in loan loss provisions
43
68
1,185
1,296
-101
-297
1,578
1,179
Write-offs3
-937
-937
-937
-937
0
0
0
0
-1,017
-1,017
-1,017
-1,017
Disposals 3
-666
-3
-84
-3
-564
-286
-1,314
-291
-935
-1
-141
-8
-279
-215
-1,355
-225
Recoveries of amounts previously written off
58
58
0
0
0
0
0
69
0
69
Other movements
21,243
-4
1,268
-16
80
-53
22,591
-73
0
-5
0
0
0
208
0
203
Closing balance
1,044,238
446
77,487
1,179
13,590
4,476
1,135,315
6,101
954,798
409
79,888
1,130
13,742
4,509
1,048,429
6,049
1Stage 3 lifetime credit impaired provision includes \u20ac29 million (2024:\u20ac21 million) on purchased or originated credit impaired.
2The addition to the loan provision (in the consolidated statement of profit or loss) amounts to \u20ac1,304 million (2024: \u20ac1,194 million) of which \u20ac1,301 million (2024: \u20ac1,170 million) related to IFRS 9 eligible financial assets, \u20ac-5 million (2024: \u20ac9 million) to IFRS eligible commitments and \u20ac8 million (2024: \u20ac15 million) to
modification gains and losses on restructured financial assets.
Macroeconomic scenarios and sensitivity analysis of key sources
of estimation uncertainty (*)
Methodology (*)
This section outlines our methodology for adopting and generating
macroeconomic scenarios. We apply this methodology when producing
our probability-weighted ECL, incorporating alternative scenarios and
management adjustments where necessary. These adjustments are made
when management believes the consensus forecast does not fully capture
the extent of recent credit or economic events. The macroeconomic
scenarios are applicable to the whole ING portfolio in the scope of IFRS 9
ECLs.
The IFRS 9 standard, with its inherent complexities and potential impact on
the carrying amounts of our assets and liabilities, represents a key source
of estimation uncertainty. In particular, ING\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 a panels of ING experts.
Alternative scenarios and probability weights (*)
Two alternative scenarios are taken into account: an upside and a
downside scenario. The alternative scenarios have statistical
characteristics as they are based on the forecast deviations of the leading
third-party service provider.
To understand the baseline level of uncertainty around any forecast, the
leading third-party service provider keeps track of all its deviations (so-
called forecast errors) of the past 30 years. The distribution of forecast
errors for GDP, unemployment, house prices, and share prices is applied to
the baseline forecast creating a broad range of alternative outcomes. In
addition, to understand the balance of risks facing the economy in an
unbiased way, the leading third-party service provider runs a survey with
respondents from around the world and across a broad range of
industries. In this survey, respondents put forward their views of key risks.
Following the survey results, the distribution of forecast errors (that is
being used for determining the scenarios) may be skewed.
For the downside scenario, ING has chosen the 90th percentile of that
distribution because this corresponds with the way risk management
earnings-at-risk is defined within the Group. The upside scenario is
represented by the 10th percentile of the distribution. The applicable
percentiles of the distribution imply a 20 percent probability for each
alternative scenario. Consequently, the baseline scenario has a 60 percent
probability weighting. Please note that, given their technical nature, the
downside and upside scenarios are not based on an explicit specific
narrative and have not changed compared to previous year.
Macroeconomic scenarios applied (*)
The macroeconomic scenarios applied in the calculation of loan loss
provisions are based on the consensus forecasts.
Baseline assumptions (*)
The general picture that the consensus conveys is that global economic
growth is slowing compared to recent years. US growth is expected to
continue to outpace European markets, but the gap is narrowing down.
China is expected to continue a declining growth trend, but still at higher
rates than seen in advanced markets. Inflation is expected to remain near
target for most advanced economies, but a bit above for the United States.
With interest rates moderating, monetary conditions are turning more
favourable for growth. For the housing market, continued price growth is
expected for almost all main markets.
The December 2025 consensus expects global output (as measured by the
weighted average GDP growth rate of ING\u2019s 25 main markets) to remain at
a constant 2.4% from 2025-2027.
The eurozone economy has shown more resilience than expected despite
global headwinds, with sluggish but positive growth through 2025. The
coming years are expected to see modest growth rates as well. The trade
environment continues to be plagued by higher US tariffs and a stronger
euro. Expectations of a pickup in growth over the course of 2026 come
from stronger consumer spending and investment. German infrastructure
spending is expected to add to this momentum. Southern European
economies continue to benefit from European Recovery Fund investments.
Consensus expects the eurozone to have grown by 1.4% in 2025, before
slowing to 1.1% in 2026 and then recovering to 1.3% in 2027.
Elsewhere in Europe, the growth outlook is stronger. Poland\u2019s growth
momentum remains solid, growing faster than its European peers. The key
growth drivers over the near-term forecast are consumption and public
investments, such as those carried out under the National Recovery Plan
(KPO). The economy is expected to grow by 3.6% in 2025, picking up to
3.7% in 2026 and settling at 3.2% in 2027. The consensus expectation for
T\u00fcrkiye is to see stable growth of 3.5% and 3.4% in 2025 and 2026, as
domestic demand remains resilient and fixed investments and inventories
see an uptick. For 2027, a recovery to 3.7% is expected.
The American economy has held its ground despite the tariff war and
slowing employment growth. Its characterisation by a K-shaped economy
where most of the growth comes from high-income consumers and tech
investments is likely to continue in 2026. Tariffs are not feeding into
inflation as much as expected earlier in the year, and inflation
expectations remain benign, although still above the 2% target. This has
prompted the Federal Reserve to resume its rate cutting cycle. Inflation is
expected to remain around 2.8% and 2.9% in 2025 and 2026 before
steadying down at 2.4% in 2027.The US economy is expected to
experience steady growth of 2.0% in 2025-2027.
For China, economic underperformance continues as it still struggles with
the impact of the real estate correction and weak domestic demand.
However, the economy has come out resilient to the tariff war with a trade
surplus reaching record levels, making external demand the key driver of
2025. This enables the economy to reach its short-term growth target, but
medium-term consensus continues to be downbeat for the moment
because of its weak domestic economy. For 2025, consensus expects 4.9%
growth, down to 4.5% in 2026 and 4.3% in 2027.
Economic momentum in Australia is expected to be soft, as much of the
growth in 2025 came from government consumption. The economy is
lacking a clear growth engine, with the private sector struggling against
restrictive policy settings and consumers facing a tough outlook with
weaker employment growth and real wage gains moderating. Growth is
expected to come in at 1.8% in 2025, with a pick-up expected for 2026 to
2.2% and 2.3% for 2027.
When compared to the June 2025 consensus forecast, the December 2025
forecast has improved slightly because of better than expected growth in
major economies. Global GDP is expected to increase by 2.4% in both 2025
and 2026 (compared to 2.0% and 2.1% assumed before). The global
economy showed quite some resilience in 2025 despite trade and
geopolitical tensions, as GDP growth has continued despite political
disruptions. Markets, too, have adjusted to the new world of volatility.
Alternative scenarios and risks (*)
The baseline scenario assumes steady economic growth. However, further
escalation of geopolitical tensions and global trade uncertainty are seen as
key downside risks to the global economy. The balance of risks to the
baseline outlook is negative, and the alternative scenarios have a
downward skew.
The downside scenario sees a recession in 2026 and 2027 for most
countries. Unemployment increases strongly in this scenario and house
prices in most countries show outright falls. The downside scenario
captures the possible impact of geopolitical tensions, global trade policy
and heightened tariff uncertainty.
The upside scenario reflects the possibility of a better economic out-turn
resulting from the avoidance of further trade escalation, an AI-driven
productivity rebound and stronger European growth supported by defence
spending.
Management adjustments applied this reporting period (*)
In times of volatility and uncertainty where portfolio quality and the
economic environment are changing rapidly, models alone may not be
able to accurately predict losses. In these cases, management
adjustments can be applied to appropriately reflect ECL. Management
adjustments may also be applied when the impact of the updated
macroeconomic scenarios is over- or under-estimated by the IFRS 9
models, or to account for model redevelopment, recalibration, and periodic
assessment procedures that have not yet been incorporated into the IFRS9
models.
ING has an internal governance framework and controls in place to assess
the appropriateness of all management adjustments.
Management adjustments to ECL models (*)
in EUR million
2025
2024
Commercial Real Estate/ Inflation and interest rate
increases
50
Economic sector / portfolio based adjustments
9
38
Mortgage portfolio adjustments
121
112
Climate transition risk
47
29
Other Post Model Adjustments
7
-27
Total management adjustments
183
203
The management adjustment of \u20ac50 million for the Commercial Real
Estate portfolio, reported at 31 December 2024 due to prevailing risks in
this sector, is released in 2025 due to improved risk profile and partially
replaced with a management adjustment for a recent model update,
which corrects for the effects of the aforementioned risks on the model
outcome. As the model update has not been implemented in production
yet, a management adjustment of \u20ac10 million is reported under the Other
Post Model Adjustments category at 31 December 2025.
As at 31 December 2025, an economic sector / portfolio-based adjustment
is reported in the Mortgages portfolio in Australia (\u20ac9 million) to address
emerging risk from inflation, interest rate increases and overall cost of
living. The management adjustment reported at 31 December 2024 for the
increased credit risk in the Mortgages and Consumer Lending portfolios in
Spain \u2013 due to the effects of floods \u2013 has been released, as the remaining
affected performing customers are reported in Stage 2. Also the
adjustment taken in the Business Banking portfolio in Germany at 31
December 2024 to cover for the increased uncertainty in the German
economy has been released due to the agreed sale of the affected
portfolio.
As of 31 December 2025, the overall mortgage portfolio adjustment
amounts to \u20ac121 million (31 December 2024: \u20ac112 million) and fully
related to the management adjustment in Stage 2 for the risk
segmentation model that captures affordability, repayment, and
refinancing risk on performing mortgage customers with a bullet loan in
the Netherlands.
As of 31 December 2025, an adjustment of \u20ac47 million is in place to
address the impact of climate transition risk in Wholesale Banking (\u20ac31
million) and in Business Banking (\u20ac16 million). Climate transition risk is
expected to lead to a structural change in credit risk, which means specific
business activities will become structurally riskier due to environmental
policies, technological progress or changes in market sentiment and
preferences. The current IFRS 9 models do not capture this (novel) risk. The
management adjustment to ECL models for business clients was made to
specifically cover for the medium- to long-term transition risk on high
greenhouse gas-emitting sectors and is reported in Stage 2. The sectors
included in the overlay represent approximately 20% of the exposure
within Wholesale and Business Banking.
Other post-model adjustments mainly relate to the impact of model
redevelopment or recalibration and periodic model assessment
procedures that have not been incorporated in the ECL models yet. The
impact on total ECL can be positive or negative. These adjustments will be
removed once updates to the specific models have been implemented.
The change in balance compared to previous reporting date is due to i)
released negative overlays because of model updates that have been
implemented and ii) new overlays recognised for new recalibrations and
periodic model assessment procedures that have not been incorporated
yet.
Analysis on sensitivity (*)
The table below presents the analysis on the sensitivity of key forward-
looking macroeconomic inputs used in the ECL collective-assessment
modelling process and the probability weights applied to each of the three
scenarios. The countries included in the analysis are the most significant
geographic regions in ING. For Wholesale Banking, the US is the most
significant in terms of both gross contribution to reportable ECL and
sensitivity of ECL to forward-looking macroeconomics. Accordingly, ING
considers these portfolios to present the most significant risk of resulting in
a material adjustment to the carrying amount of financial assets within
the next financial year.
The purpose of the sensitivity analysis is to enable the reader to
understand the extent of the impact from the upside and downside
scenario on model-based reportable ECL.
In the table below, the real GDP is presented in percentage year-on-year
change, the unemployment in percentage of total labour force, and the
house price index (HPI) in percentage year-on-year change.
Sensitivity analysis as at December 2025\u00a0 (*)
2026
2027
2028
Unweighted
ECL (\u20ac mln)
Probability-
weighting
Reportable
ECL (\u20ac mln) 1
Netherlands
Upside scenario
Real GDP
2.6
2.9
2.3
288
20%
389
Unemployment
3.5
3.2
3.2
HPI
8.2
8.5
7.0
Baseline scenario
Real GDP
1.1
1.4
1.5
364
60%
Unemployment
4.0
3.9
4.1
HPI
4.4
3.0
2.9
Downside scenario
Real GDP
-1.2
-0.9
0.2
566
20%
Unemployment
5.5
6.5
7.4
HPI
-0.8
-5.1
-5.1
Germany
Upside scenario
Real GDP
2.8
3.0
1.8
584
20%
633
Unemployment
3.0
2.4
2.2
HPI
8.2
9.8
9.4
Baseline scenario
Real GDP
1.1
1.5
1.3
623
60%
Unemployment
3.5
3.2
3.1
HPI
5.0
6.2
6.3
Downside scenario
Real GDP
-1.7
-1.1
0.4
713
20%
Unemployment
4.7
5.3
5.6
HPI
0.9
0.4
2.7
Belgium
Upside scenario
Real GDP
2.7
2.3
1.9
544
20%
596
Unemployment
5.1
4.6
4.5
HPI
5.2
4.9
5.4
Baseline scenario
Real GDP
1.1
1.4
1.6
585
60%
Unemployment
5.9
5.6
5.5
HPI
3.7
4.2
4.4
Downside scenario
Real GDP
-1.5
0.1
1.4
682
20%
Unemployment
7.0
7.7
7.9
HPI
1.8
2.6
2.6
United States
Upside scenario
Real GDP
3.2
2.9
2.7
64
20%
105
Unemployment
3.2
2.5
2.6
HPI
4.8
9.4
10.9
Baseline scenario
Real GDP
2.0
2.0
2.0
92
60%
Unemployment
4.3
4.1
4.1
HPI
1.4
2.7
3.6
Downside scenario
Real GDP
-0.4
-0.1
0.8
184
20%
Unemployment
6.7
7.2
7.5
HPI
-5.1
-7.9
-5.5
1Excluding management adjustments.
Sensitivity analysis as at December 2024 (*)
2025
2026
2027
Unweighted
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
1Excluding management adjustments.
When compared to the sensitivity analysis of 2024, the baseline
macroeconomic inputs have become slightly more positive overall,
underpinned by the resilience of the global economy in the face of trade
and geopolitical tensions. House price growth expectations are lower for
the Netherlands, given a rise in supply from the sale of rental properties
and slowdown of wage growth. In the US, a weak labour and housing
market both signal underlying economic challenges due to policy and
trade uncertainty, and persistent affordability issues. The upside and the
downside scenarios are not directly comparable with those of 2024 due to
an update in the basis of their derivation.
On a total ING level, the unweighted ECL for all collective provisioned
clients in the upside scenario was \u20ac2,938 million, in the baseline scenario
\u20ac3,232 million and in the downside scenario \u20ac3,993 million compared to
\u20ac3,326 million reportable model ECL as at 31 December 2025 (excluding all
management adjustments). To perform the sensitivity analysis, a point in
time reportable ECL is used as input, which slightly deviates from the total
reportable collective provisions as presented below:
Reconciliation of reportable collective ECL to total ECL (*)
in EUR million
2025
2024
Total reportable collective provisions
3,168
2,975
ECL from individually assessed impairments
2,750
2,871
ECL from management adjustments
183
203
Total ECL
6,101
6,049
Criteria for identifying a significant increase in credit risk (SICR) (*)
All assets and off-balance-sheet items that are in scope of IFRS 9
impairment and which are subject to collective ECL assessment are
allocated a 12-month ECL if deemed to belong in Stage 1, or a lifetime ECL
if deemed to belong in Stages 2 or 3. An asset belongs in Stage 2 if it is
considered to have experienced a significant increase in credit risk (SICR)
since initial origination or purchase.
The main determinant of SICR is a quantitative test, whereby the lifetime
PD of an asset at each reporting date is compared against its lifetime PD
determined at the date of initial recognition. If either a threshold for
absolute change in lifetime PD or a threshold for relative change in lifetime
PD is reached, the item is considered to have experienced an SICR (for more
details on absolute and relative thresholds, see the following sections).
Furthermore, any facility which shows an increase of 200 percent between
the PD at the date of initial recognition and the lifetime PD at the reporting
date (i.e. threefold increase in PD) must be classified as Stage 2. This is
considered a backstop within the quantitative assessment of SICR.
In Wholesale Banking, a significant increase in lifetime PD is not considered
plausible for assets of obligors with a credit rating at the reporting date in
the top range of investment grade. The assets of these Wholesale Banking
obligors are excluded from the assessment of significant increase in credit
risk triggers. For these obligors the qualitative significant increases in credit
risk triggers remain applicable (see the section below on Qualitative SICR
triggers). These are, for example, the watch list and/or forbearance
triggers. Finally, the 30 days past due backstop also remains applicable for
the top range of investment grade exposures to ensure a significant
increase in credit risk recognition.
Absolute lifetime PD threshold
The absolute threshold is a fixed value calibrated per portfolio/segment
and provides a fixed threshold that, if exceeded by the difference between
lifetime PD at reporting date and lifetime PD at origination, triggers Stage 2
classification. The absolute threshold is calibrated during model
development.
Relative lifetime PD threshold
The relative threshold defines a relative increase of the lifetime PD, beyond
which a given facility is classified in Stage 2 because of a significant
increase in credit risk. The relative threshold is dependent on the individual
PD assigned to each facility at the moment of origination, and a scaling
factor calibrated in the model development phase.
Ultimately, the relative threshold provides a criterion to assess whether
the ratio (i.e. increase) between lifetime PD at reporting date and lifetime
PD at origination date is deemed a significant increase in credit risk. If the
threshold is breached, SICR is identified and Stage 2 is assigned to the
given facility.
The threshold for the relative change in lifetime PD is inversely correlated
with the PD at origination; the higher the PD at origination, the lower the
threshold. The logic behind this is to allow facilities originated in very
favourable ratings to downgrade for longer without the need of a Stage 2
classification. In fact, it is likely that such facilities will still be in favourable
ratings even after a downgrade of a few notches. On the contrary, facilities
originated in already unfavourable ratings grades are riskier and even a
single-notch downgrade might represent a significant increase in credit
risk and thus a tighter threshold will be in place. Still, the relative threshold
is relatively sensitive for investment-grade assets while the absolute
threshold primarily affects non-investment grade assets.
Average threshold ratio
The table below shows the average increase in PD at origination needed to
be classified in Stage 2 is reported, taking into account the PD at
origination of the facilities included in each combination of asset class and
rating quality. In terms of rating quality, assets are divided into
'investment grade' and 'non-investment grade' facilities. Rating 18 and 19
are not included in the table, since facilities are not originated in these
ratings and they constitute a staging trigger of their own (i.e. if a facility is
ever to reach rating 18 or 19 at reporting date, it is classified in Stage 2). In
the table, values are weighted by IFRS 9 exposure and shown for both
year-end 2024 and year-end 2025.
To represent the thresholds as a ratio (i.e. how much should the PD at
origination increase in relative terms to trigger Stage 2 classification) the
absolute threshold is recalculated as a relative threshold for disclosure
purposes. Since breaching only relative or absolute threshold triggers
Stage 2 classification, the minimum between the relative and recalculated
absolute threshold is taken as value of reference for each facility.
Quantitative SICR thresholds\u00a0 (*)
2025
2024
Average threshold ratio
Investment
grade (rating
grade 1-10)
Non-investment
grade (rating
grade 11-17)
Investment
grade (rating
grade 1-10)
Non-investment
grade (rating
grade 11-17)
Asset class category
Mortgages
2.9
2.4
2.9
2.4
Consumer lending
2.9
2.3
2.8
2.1
Business lending
2.7
2.0
2.7
2.1
Governments and financial institutions
2.9
1.8
2.9
1.9
Other Wholesale Banking
2.7
1.9
2.7
1.9
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 \u20ac1,501 million as at
31 December 2025 (31 December 2024: \u20ac1,328 million). To demonstrate
the sensitivity of the ECL to these PD threshold bands, hypothetically
solely applying the upside scenario would result in total model ECL on
performing assets of \u20ac1,159 million and a decrease in the Stage 2 ratio by
0.3%-point, while solely applying the downside scenario would result in
total model ECL on performing assets of \u20ac2,193 million and an increase in
the Stage 2 ratio by 1.6%-point.
Qualitative SICR thresholds
It should be noted that the lifetime PD thresholds are not the only drivers
of stage allocation as ING Group also relies on a number of qualitative
indicators to identify and assess SICR. An asset can also change stages as
a result of other triggers, such as having over 30 days arrears (used as a
backstop), the occurrence of an early warning indicator, collective SICR
assessment, being on a watch list, being under intensive care
management, having a substandard internal rating, or being forborne.", "dimensions": { "concept": "ifrs-full:DisclosureOfCreditRiskExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "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 and financial- and non-financial guarantees issued.
ING distinguishes between two types of calculation methods for credit loss
allowances:
\u00a7 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; and
\u00a7 Individual lifetime ECL for credit-impaired (Stage 3) financial
instruments with exposures above \u20ac1 million.
IFRS 9 models (*)
ING\u2019s 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.
Climate and environmental risks in IFRS 9 models (*)
Climate risk drivers (physical and transition risks) can reduce the ability of
businesses and households to fulfil their obligations due, under existing
lending contracts. These climate risks are partly reflected in IFRS9 ECL
through regular credit risk transmission channels such as the
macroeconomic forecast and relevant risk parameters.
On the other hand, future physical or transition risks from climate change
are not yet fully captured within the current ECL models. In our
assessment of physical risks, it is generally expected that these risks will
only become financially significant on the long-term horizon.
Consequently, for short- and medium-term loans, such risks are not
expected to lead to significant credit deterioration over the exposure\u2019s
lifetime. For the long term, the probability and timing of physical risk
events remain highly uncertain. ING is however actively enhancing the
integration of physical and transition risks into collateral valuations,
ensuring that effects on property values are appropriately captured.
In case of risk events that have already occurred (e.g. floods, stranded
assets), the impact of such events is assessed in the calculation of Stage 3
individual provisions, collective SICR or management adjustments to ECL
models. For example, we consider whether affected assets have suffered
from a significant increase in credit risk (or are credit impaired) and
whether the ECL is appropriate.
Additionally, a management adjustment to ECL models for business
clients was introduced to specifically cover for medium- to long-term
transition risk on high greenhouse gas-emitting sectors. The management
adjustment reflects the risk of financial loss foreseen on the longer horizon
for lenders with higher transition risk in these high greenhouse gas-
emitting sectors as consequence of future carbon taxation.
ING is continuously improving on climate risk data, which will enable us to
further embed climate risks into the IFRS 9 ECL models. For more
information on ESG risk management, see \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 92.0%
(2024: 91.1%) of the total gross carrying amounts, mainly composed of
investment grade, while Stage 2 makes up 6.8% (2024: 7.6%) and Stage 3
makes up 1.2% (2024: 1.3%) of the total gross carrying amounts,
respectively.
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
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
Investment grade
1 (AAA)
79,938
79,076
2
1
126
281
80,064
79,357
2
1
2-4 (AA)
146,878
140,671
11
10
1,437
1,579
1
1
148,315
142,250
13
11
5-7 (A)
299,791
244,306
39
22
5,394
6,908
6
8
305,185
251,214
45
29
8-10 (BBB)
334,659
310,114
77
55
19,168
24,683
43
55
353,827
334,797
119
110
Non-investment
grade
11-13 (BB)
156,373
154,348
165
190
17,217
18,479
89
91
173,589
172,827
254
281
14-16 (B)
26,187
25,377
147
124
22,668
17,433
357
366
48,855
42,811
504
490
17 (CCC)
412
905
5
8
4,682
3,992
224
173
5,094
4,897
228
181
Performing
Restructuring
18 (CC)
4,349
4,059
262
233
4,349
4,060
262
233
19 (C)
2,447
2,474
198
203
2,447
2,474
198
203
Non-performing loans
20-22 (D)
13,590
13,742
4,476
4,509
13,590
13,742
4,476
4,509
Total
1,044,238
954,798
446
409
77,487
79,888
1,179
1,130
13,590
13,742
4,476
4,509
1,135,315
1,048,429
6,101
6,049
1Compared to the credit risk portfolio, the differences are due to undrawn committed amounts (\u20ac200.2 billion; 2024: \u20ac156.0 billion) and other positions (2025: nil; 2024:\u20ac6 billion) not included in credit outstandings and non-IFRS 9 eligible assets (\u20ac68.2 billion; 2024: \u20ac75.0 billion) included in credit outstandings but not
in the gross carrying amounts.
2Stage 3 lifetime credit impaired provision includes \u20ac 29 million (2024: \u20ac21 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:
\u00a7 Stage 3 gross carrying amount decreased by \u20ac0.2 billion from \u20ac13.7
billion as at 31 December 2024 to \u20ac13.6 billion as at 31 December 2025,
mainly as a result of \u20ac3.5 billion net inflow into NPL (credit impaired) in
2025, which is offset by \u20ac2.3 billion derecognitions and repayments
and \u20ac1.5 billion write-offs and disposals. Following the decrease in
carrying amount, Stage 3 provisions slightly decreased by \u20ac33 million
Stage 2 gross carrying amounts decreased by \u20ac2.4 billion from \u20ac79.9
billion as at 31 December 2024 to \u20ac77.5 billion as at 31 December 2025,
largely driven by \u20ac15.7 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 \u20ac18.0 billion due to derecognised financial assets (including
sales and repayments) and \u20ac1.2 billion exposure moving to Stage 3. Stage
2 provisions increased by \u20ac49 million to \u20ac1.2 billion as of 31 December
2025.
Changes in gross carrying amounts and loan loss provisions (*) 1, 2
in EUR million
12-month ECL\u00a0 \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
2025
2024
Opening balance
954,798
409
79,888
1,130
13,742
4,509
1,048,429
6,049
937,684
517
75,258
1,435
11,956
3,887
1,024,897
5,839
Transfer into 12-month ECL (Stage 1)
21,773
21
-21,555
-199
-218
-35
-212
20,276
22
-20,026
-195
-249
-34
0
-207
Transfer into lifetime ECL not credit impaired (Stage 2)
-37,208
-50
38,174
533
-966
-115
368
-43,155
-49
43,900
429
-745
-96
0
285
Transfer into lifetime ECL credit impaired (Stage 3)
-2,534
-14
-2,172
-138
4,705
1,259
1,108
-2,980
-18
-2,856
-235
5,836
1,802
0
1,548
Net remeasurement of loan loss provisions
7
-53
349
302
0
-180
0
-137
0
185
0
-133
New financial assets originated or purchased
263,371
189
22
2
263,393
191
212,529
192
0
0
0
0
212,529
192
Financial assets that have been derecognised
-119,098
-78
-12,295
-147
-1,422
-240
-132,814
-465
-126,858
-76
-11,840
-153
-1,450
-257
-140,148
-485
Net drawdowns and repayments
-57,441
-5,739
-853
-64,033
-41,763
0
-4,406
0
-309
0
-46,478
0
Changes in models/risk parameters
-33
71
-35
3
0
8
0
-6
0
-22
0
-20
Increase in loan loss provisions
43
68
1,185
1,296
-101
-297
1,578
1,179
Write-offs3
-937
-937
-937
-937
0
0
0
0
-1,017
-1,017
-1,017
-1,017
Disposals 3
-666
-3
-84
-3
-564
-286
-1,314
-291
-935
-1
-141
-8
-279
-215
-1,355
-225
Recoveries of amounts previously written off
58
58
0
0
0
0
0
69
0
69
Other movements
21,243
-4
1,268
-16
80
-53
22,591
-73
0
-5
0
0
0
208
0
203
Closing balance
1,044,238
446
77,487
1,179
13,590
4,476
1,135,315
6,101
954,798
409
79,888
1,130
13,742
4,509
1,048,429
6,049
1Stage 3 lifetime credit impaired provision includes \u20ac29 million (2024:\u20ac21 million) on purchased or originated credit impaired.
2The addition to the loan provision (in the consolidated statement of profit or loss) amounts to \u20ac1,304 million (2024: \u20ac1,194 million) of which \u20ac1,301 million (2024: \u20ac1,170 million) related to IFRS 9 eligible financial assets, \u20ac-5 million (2024: \u20ac9 million) to IFRS eligible commitments and \u20ac8 million (2024: \u20ac15 million) to
modification gains and losses on restructured financial assets.
Macroeconomic scenarios and sensitivity analysis of key sources
of estimation uncertainty (*)
Methodology (*)
This section outlines our methodology for adopting and generating
macroeconomic scenarios. We apply this methodology when producing
our probability-weighted ECL, incorporating alternative scenarios and
management adjustments where necessary. These adjustments are made
when management believes the consensus forecast does not fully capture
the extent of recent credit or economic events. The macroeconomic
scenarios are applicable to the whole ING portfolio in the scope of IFRS 9
ECLs.
The IFRS 9 standard, with its inherent complexities and potential impact on
the carrying amounts of our assets and liabilities, represents a key source
of estimation uncertainty. In particular, ING\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 a panels of ING experts.
Alternative scenarios and probability weights (*)
Two alternative scenarios are taken into account: an upside and a
downside scenario. The alternative scenarios have statistical
characteristics as they are based on the forecast deviations of the leading
third-party service provider.
To understand the baseline level of uncertainty around any forecast, the
leading third-party service provider keeps track of all its deviations (so-
called forecast errors) of the past 30 years. The distribution of forecast
errors for GDP, unemployment, house prices, and share prices is applied to
the baseline forecast creating a broad range of alternative outcomes. In
addition, to understand the balance of risks facing the economy in an
unbiased way, the leading third-party service provider runs a survey with
respondents from around the world and across a broad range of
industries. In this survey, respondents put forward their views of key risks.
Following the survey results, the distribution of forecast errors (that is
being used for determining the scenarios) may be skewed.
For the downside scenario, ING has chosen the 90th percentile of that
distribution because this corresponds with the way risk management
earnings-at-risk is defined within the Group. The upside scenario is
represented by the 10th percentile of the distribution. The applicable
percentiles of the distribution imply a 20 percent probability for each
alternative scenario. Consequently, the baseline scenario has a 60 percent
probability weighting. Please note that, given their technical nature, the
downside and upside scenarios are not based on an explicit specific
narrative and have not changed compared to previous year.
Macroeconomic scenarios applied (*)
The macroeconomic scenarios applied in the calculation of loan loss
provisions are based on the consensus forecasts.
Baseline assumptions (*)
The general picture that the consensus conveys is that global economic
growth is slowing compared to recent years. US growth is expected to
continue to outpace European markets, but the gap is narrowing down.
China is expected to continue a declining growth trend, but still at higher
rates than seen in advanced markets. Inflation is expected to remain near
target for most advanced economies, but a bit above for the United States.
With interest rates moderating, monetary conditions are turning more
favourable for growth. For the housing market, continued price growth is
expected for almost all main markets.
The December 2025 consensus expects global output (as measured by the
weighted average GDP growth rate of ING\u2019s 25 main markets) to remain at
a constant 2.4% from 2025-2027.
The eurozone economy has shown more resilience than expected despite
global headwinds, with sluggish but positive growth through 2025. The
coming years are expected to see modest growth rates as well. The trade
environment continues to be plagued by higher US tariffs and a stronger
euro. Expectations of a pickup in growth over the course of 2026 come
from stronger consumer spending and investment. German infrastructure
spending is expected to add to this momentum. Southern European
economies continue to benefit from European Recovery Fund investments.
Consensus expects the eurozone to have grown by 1.4% in 2025, before
slowing to 1.1% in 2026 and then recovering to 1.3% in 2027.
Elsewhere in Europe, the growth outlook is stronger. Poland\u2019s growth
momentum remains solid, growing faster than its European peers. The key
growth drivers over the near-term forecast are consumption and public
investments, such as those carried out under the National Recovery Plan
(KPO). The economy is expected to grow by 3.6% in 2025, picking up to
3.7% in 2026 and settling at 3.2% in 2027. The consensus expectation for
T\u00fcrkiye is to see stable growth of 3.5% and 3.4% in 2025 and 2026, as
domestic demand remains resilient and fixed investments and inventories
see an uptick. For 2027, a recovery to 3.7% is expected.
The American economy has held its ground despite the tariff war and
slowing employment growth. Its characterisation by a K-shaped economy
where most of the growth comes from high-income consumers and tech
investments is likely to continue in 2026. Tariffs are not feeding into
inflation as much as expected earlier in the year, and inflation
expectations remain benign, although still above the 2% target. This has
prompted the Federal Reserve to resume its rate cutting cycle. Inflation is
expected to remain around 2.8% and 2.9% in 2025 and 2026 before
steadying down at 2.4% in 2027.The US economy is expected to
experience steady growth of 2.0% in 2025-2027.
For China, economic underperformance continues as it still struggles with
the impact of the real estate correction and weak domestic demand.
However, the economy has come out resilient to the tariff war with a trade
surplus reaching record levels, making external demand the key driver of
2025. This enables the economy to reach its short-term growth target, but
medium-term consensus continues to be downbeat for the moment
because of its weak domestic economy. For 2025, consensus expects 4.9%
growth, down to 4.5% in 2026 and 4.3% in 2027.
Economic momentum in Australia is expected to be soft, as much of the
growth in 2025 came from government consumption. The economy is
lacking a clear growth engine, with the private sector struggling against
restrictive policy settings and consumers facing a tough outlook with
weaker employment growth and real wage gains moderating. Growth is
expected to come in at 1.8% in 2025, with a pick-up expected for 2026 to
2.2% and 2.3% for 2027.
When compared to the June 2025 consensus forecast, the December 2025
forecast has improved slightly because of better than expected growth in
major economies. Global GDP is expected to increase by 2.4% in both 2025
and 2026 (compared to 2.0% and 2.1% assumed before). The global
economy showed quite some resilience in 2025 despite trade and
geopolitical tensions, as GDP growth has continued despite political
disruptions. Markets, too, have adjusted to the new world of volatility.
Alternative scenarios and risks (*)
The baseline scenario assumes steady economic growth. However, further
escalation of geopolitical tensions and global trade uncertainty are seen as
key downside risks to the global economy. The balance of risks to the
baseline outlook is negative, and the alternative scenarios have a
downward skew.
The downside scenario sees a recession in 2026 and 2027 for most
countries. Unemployment increases strongly in this scenario and house
prices in most countries show outright falls. The downside scenario
captures the possible impact of geopolitical tensions, global trade policy
and heightened tariff uncertainty.
The upside scenario reflects the possibility of a better economic out-turn
resulting from the avoidance of further trade escalation, an AI-driven
productivity rebound and stronger European growth supported by defence
spending.
Management adjustments applied this reporting period (*)
In times of volatility and uncertainty where portfolio quality and the
economic environment are changing rapidly, models alone may not be
able to accurately predict losses. In these cases, management
adjustments can be applied to appropriately reflect ECL. Management
adjustments may also be applied when the impact of the updated
macroeconomic scenarios is over- or under-estimated by the IFRS 9
models, or to account for model redevelopment, recalibration, and periodic
assessment procedures that have not yet been incorporated into the IFRS9
models.
ING has an internal governance framework and controls in place to assess
the appropriateness of all management adjustments.
Management adjustments to ECL models (*)
in EUR million
2025
2024
Commercial Real Estate/ Inflation and interest rate
increases
50
Economic sector / portfolio based adjustments
9
38
Mortgage portfolio adjustments
121
112
Climate transition risk
47
29
Other Post Model Adjustments
7
-27
Total management adjustments
183
203
The management adjustment of \u20ac50 million for the Commercial Real
Estate portfolio, reported at 31 December 2024 due to prevailing risks in
this sector, is released in 2025 due to improved risk profile and partially
replaced with a management adjustment for a recent model update,
which corrects for the effects of the aforementioned risks on the model
outcome. As the model update has not been implemented in production
yet, a management adjustment of \u20ac10 million is reported under the Other
Post Model Adjustments category at 31 December 2025.
As at 31 December 2025, an economic sector / portfolio-based adjustment
is reported in the Mortgages portfolio in Australia (\u20ac9 million) to address
emerging risk from inflation, interest rate increases and overall cost of
living. The management adjustment reported at 31 December 2024 for the
increased credit risk in the Mortgages and Consumer Lending portfolios in
Spain \u2013 due to the effects of floods \u2013 has been released, as the remaining
affected performing customers are reported in Stage 2. Also the
adjustment taken in the Business Banking portfolio in Germany at 31
December 2024 to cover for the increased uncertainty in the German
economy has been released due to the agreed sale of the affected
portfolio.
As of 31 December 2025, the overall mortgage portfolio adjustment
amounts to \u20ac121 million (31 December 2024: \u20ac112 million) and fully
related to the management adjustment in Stage 2 for the risk
segmentation model that captures affordability, repayment, and
refinancing risk on performing mortgage customers with a bullet loan in
the Netherlands.
As of 31 December 2025, an adjustment of \u20ac47 million is in place to
address the impact of climate transition risk in Wholesale Banking (\u20ac31
million) and in Business Banking (\u20ac16 million). Climate transition risk is
expected to lead to a structural change in credit risk, which means specific
business activities will become structurally riskier due to environmental
policies, technological progress or changes in market sentiment and
preferences. The current IFRS 9 models do not capture this (novel) risk. The
management adjustment to ECL models for business clients was made to
specifically cover for the medium- to long-term transition risk on high
greenhouse gas-emitting sectors and is reported in Stage 2. The sectors
included in the overlay represent approximately 20% of the exposure
within Wholesale and Business Banking.
Other post-model adjustments mainly relate to the impact of model
redevelopment or recalibration and periodic model assessment
procedures that have not been incorporated in the ECL models yet. The
impact on total ECL can be positive or negative. These adjustments will be
removed once updates to the specific models have been implemented.
The change in balance compared to previous reporting date is due to i)
released negative overlays because of model updates that have been
implemented and ii) new overlays recognised for new recalibrations and
periodic model assessment procedures that have not been incorporated
yet.
Analysis on sensitivity (*)
The table below presents the analysis on the sensitivity of key forward-
looking macroeconomic inputs used in the ECL collective-assessment
modelling process and the probability weights applied to each of the three
scenarios. The countries included in the analysis are the most significant
geographic regions in ING. For Wholesale Banking, the US is the most
significant in terms of both gross contribution to reportable ECL and
sensitivity of ECL to forward-looking macroeconomics. Accordingly, ING
considers these portfolios to present the most significant risk of resulting in
a material adjustment to the carrying amount of financial assets within
the next financial year.
The purpose of the sensitivity analysis is to enable the reader to
understand the extent of the impact from the upside and downside
scenario on model-based reportable ECL.
In the table below, the real GDP is presented in percentage year-on-year
change, the unemployment in percentage of total labour force, and the
house price index (HPI) in percentage year-on-year change.
Sensitivity analysis as at December 2025\u00a0 (*)
2026
2027
2028
Unweighted
ECL (\u20ac mln)
Probability-
weighting
Reportable
ECL (\u20ac mln) 1
Netherlands
Upside scenario
Real GDP
2.6
2.9
2.3
288
20%
389
Unemployment
3.5
3.2
3.2
HPI
8.2
8.5
7.0
Baseline scenario
Real GDP
1.1
1.4
1.5
364
60%
Unemployment
4.0
3.9
4.1
HPI
4.4
3.0
2.9
Downside scenario
Real GDP
-1.2
-0.9
0.2
566
20%
Unemployment
5.5
6.5
7.4
HPI
-0.8
-5.1
-5.1
Germany
Upside scenario
Real GDP
2.8
3.0
1.8
584
20%
633
Unemployment
3.0
2.4
2.2
HPI
8.2
9.8
9.4
Baseline scenario
Real GDP
1.1
1.5
1.3
623
60%
Unemployment
3.5
3.2
3.1
HPI
5.0
6.2
6.3
Downside scenario
Real GDP
-1.7
-1.1
0.4
713
20%
Unemployment
4.7
5.3
5.6
HPI
0.9
0.4
2.7
Belgium
Upside scenario
Real GDP
2.7
2.3
1.9
544
20%
596
Unemployment
5.1
4.6
4.5
HPI
5.2
4.9
5.4
Baseline scenario
Real GDP
1.1
1.4
1.6
585
60%
Unemployment
5.9
5.6
5.5
HPI
3.7
4.2
4.4
Downside scenario
Real GDP
-1.5
0.1
1.4
682
20%
Unemployment
7.0
7.7
7.9
HPI
1.8
2.6
2.6
United States
Upside scenario
Real GDP
3.2
2.9
2.7
64
20%
105
Unemployment
3.2
2.5
2.6
HPI
4.8
9.4
10.9
Baseline scenario
Real GDP
2.0
2.0
2.0
92
60%
Unemployment
4.3
4.1
4.1
HPI
1.4
2.7
3.6
Downside scenario
Real GDP
-0.4
-0.1
0.8
184
20%
Unemployment
6.7
7.2
7.5
HPI
-5.1
-7.9
-5.5
1Excluding management adjustments.
Sensitivity analysis as at December 2024 (*)
2025
2026
2027
Unweighted
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
1Excluding management adjustments.
When compared to the sensitivity analysis of 2024, the baseline
macroeconomic inputs have become slightly more positive overall,
underpinned by the resilience of the global economy in the face of trade
and geopolitical tensions. House price growth expectations are lower for
the Netherlands, given a rise in supply from the sale of rental properties
and slowdown of wage growth. In the US, a weak labour and housing
market both signal underlying economic challenges due to policy and
trade uncertainty, and persistent affordability issues. The upside and the
downside scenarios are not directly comparable with those of 2024 due to
an update in the basis of their derivation.
On a total ING level, the unweighted ECL for all collective provisioned
clients in the upside scenario was \u20ac2,938 million, in the baseline scenario
\u20ac3,232 million and in the downside scenario \u20ac3,993 million compared to
\u20ac3,326 million reportable model ECL as at 31 December 2025 (excluding all
management adjustments). To perform the sensitivity analysis, a point in
time reportable ECL is used as input, which slightly deviates from the total
reportable collective provisions as presented below:
Reconciliation of reportable collective ECL to total ECL (*)
in EUR million
2025
2024
Total reportable collective provisions
3,168
2,975
ECL from individually assessed impairments
2,750
2,871
ECL from management adjustments
183
203
Total ECL
6,101
6,049
Criteria for identifying a significant increase in credit risk (SICR) (*)
All assets and off-balance-sheet items that are in scope of IFRS 9
impairment and which are subject to collective ECL assessment are
allocated a 12-month ECL if deemed to belong in Stage 1, or a lifetime ECL
if deemed to belong in Stages 2 or 3. An asset belongs in Stage 2 if it is
considered to have experienced a significant increase in credit risk (SICR)
since initial origination or purchase.
The main determinant of SICR is a quantitative test, whereby the lifetime
PD of an asset at each reporting date is compared against its lifetime PD
determined at the date of initial recognition. If either a threshold for
absolute change in lifetime PD or a threshold for relative change in lifetime
PD is reached, the item is considered to have experienced an SICR (for more
details on absolute and relative thresholds, see the following sections).
Furthermore, any facility which shows an increase of 200 percent between
the PD at the date of initial recognition and the lifetime PD at the reporting
date (i.e. threefold increase in PD) must be classified as Stage 2. This is
considered a backstop within the quantitative assessment of SICR.
In Wholesale Banking, a significant increase in lifetime PD is not considered
plausible for assets of obligors with a credit rating at the reporting date in
the top range of investment grade. The assets of these Wholesale Banking
obligors are excluded from the assessment of significant increase in credit
risk triggers. For these obligors the qualitative significant increases in credit
risk triggers remain applicable (see the section below on Qualitative SICR
triggers). These are, for example, the watch list and/or forbearance
triggers. Finally, the 30 days past due backstop also remains applicable for
the top range of investment grade exposures to ensure a significant
increase in credit risk recognition.
Absolute lifetime PD threshold
The absolute threshold is a fixed value calibrated per portfolio/segment
and provides a fixed threshold that, if exceeded by the difference between
lifetime PD at reporting date and lifetime PD at origination, triggers Stage 2
classification. The absolute threshold is calibrated during model
development.
Relative lifetime PD threshold
The relative threshold defines a relative increase of the lifetime PD, beyond
which a given facility is classified in Stage 2 because of a significant
increase in credit risk. The relative threshold is dependent on the individual
PD assigned to each facility at the moment of origination, and a scaling
factor calibrated in the model development phase.
Ultimately, the relative threshold provides a criterion to assess whether
the ratio (i.e. increase) between lifetime PD at reporting date and lifetime
PD at origination date is deemed a significant increase in credit risk. If the
threshold is breached, SICR is identified and Stage 2 is assigned to the
given facility.
The threshold for the relative change in lifetime PD is inversely correlated
with the PD at origination; the higher the PD at origination, the lower the
threshold. The logic behind this is to allow facilities originated in very
favourable ratings to downgrade for longer without the need of a Stage 2
classification. In fact, it is likely that such facilities will still be in favourable
ratings even after a downgrade of a few notches. On the contrary, facilities
originated in already unfavourable ratings grades are riskier and even a
single-notch downgrade might represent a significant increase in credit
risk and thus a tighter threshold will be in place. Still, the relative threshold
is relatively sensitive for investment-grade assets while the absolute
threshold primarily affects non-investment grade assets.
Average threshold ratio
The table below shows the average increase in PD at origination needed to
be classified in Stage 2 is reported, taking into account the PD at
origination of the facilities included in each combination of asset class and
rating quality. In terms of rating quality, assets are divided into
'investment grade' and 'non-investment grade' facilities. Rating 18 and 19
are not included in the table, since facilities are not originated in these
ratings and they constitute a staging trigger of their own (i.e. if a facility is
ever to reach rating 18 or 19 at reporting date, it is classified in Stage 2). In
the table, values are weighted by IFRS 9 exposure and shown for both
year-end 2024 and year-end 2025.
To represent the thresholds as a ratio (i.e. how much should the PD at
origination increase in relative terms to trigger Stage 2 classification) the
absolute threshold is recalculated as a relative threshold for disclosure
purposes. Since breaching only relative or absolute threshold triggers
Stage 2 classification, the minimum between the relative and recalculated
absolute threshold is taken as value of reference for each facility.
Quantitative SICR thresholds\u00a0 (*)
2025
2024
Average threshold ratio
Investment
grade (rating
grade 1-10)
Non-investment
grade (rating
grade 11-17)
Investment
grade (rating
grade 1-10)
Non-investment
grade (rating
grade 11-17)
Asset class category
Mortgages
2.9
2.4
2.9
2.4
Consumer lending
2.9
2.3
2.8
2.1
Business lending
2.7
2.0
2.7
2.1
Governments and financial institutions
2.9
1.8
2.9
1.9
Other Wholesale Banking
2.7
1.9
2.7
1.9
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 \u20ac1,501 million as at
31 December 2025 (31 December 2024: \u20ac1,328 million). To demonstrate
the sensitivity of the ECL to these PD threshold bands, hypothetically
solely applying the upside scenario would result in total model ECL on
performing assets of \u20ac1,159 million and a decrease in the Stage 2 ratio by
0.3%-point, while solely applying the downside scenario would result in
total model ECL on performing assets of \u20ac2,193 million and an increase in
the Stage 2 ratio by 1.6%-point.
Qualitative SICR thresholds
It should be noted that the lifetime PD thresholds are not the only drivers
of stage allocation as ING Group also relies on a number of qualitative
indicators to identify and assess SICR. An asset can also change stages as
a result of other triggers, such as having over 30 days arrears (used as a
backstop), the occurrence of an early warning indicator, collective SICR
assessment, being on a watch list, being under intensive care
management, having a substandard internal rating, or being forborne.", "dimensions": { "concept": "ifrs-full:DisclosureOfAllowanceForCreditLossesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "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:
\u00a7 Market risk in banking books;
\u00a7 Market risk in trading books; and
\u00a7 Market risk capital.
Market risk in banking books (*)
ING distinguishes between the trading and banking (non-trading) books.
Positions in banking books originate from the market risks inherent in
commercial products that are sold to clients, Group Treasury exposures, and
from the investment of our own funds (core capital). Both the commercial
products and the products used to hedge related market-risk exposures are
intended to be held until maturity, or at least for the long term.
Risk transfer (*)
Market risks in the banking book are managed via the risk transfer process.
In this process the interest rate, FX, funding, and liquidity risks are
transferred from the commercial books through matched funding or
replication to Group Treasury, where they are centrally managed. The
scheme below presents the transfer and management process of market
risks in the banking books.
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:
\u00a7 Investment of own funds;
\u00a7 Commercial business; and
\u00a7 Group Treasury exposures, including strategic interest rate positions.
Group Treasury is responsible for managing the investment of own funds
(core capital). Capital is invested for longer periods to contribute to stable
earnings within the risk appetite boundaries set by ALCO Bank.
Commercial activities can result in linear interest rate risk due to different
re-pricing properties of assets and liabilities. Also, interest rate risk can
arise from customer behaviour and/or convexity risk, depending on the
nature of the underlying product characteristics.
To determine interest rate risk in specific products (such as savings or
mortgages) certain assumptions may need to be applied. Customer
behaviour risk is defined as the potential future loss (value) arising from
deviations between actual client behaviour and the modelled behaviour
regarding embedded options within commercial products. General sources
of customer behaviour risk include, among other things, the state of the
economy, competition, changes in regulation, legislation and tax regime,
developments in the housing market, and interest rate developments.
From an interest rate risk perspective, commercial activities can typically
be divided into the following main product types: savings and current
accounts (funds entrusted), demand deposits, mortgages, and loans.
Savings and demand deposits are generally invested in such a way that
both the value is hedged and the sensitivity of the margin to market
interest rates is minimised. This is achieved by creating the investment
profile distributed from short term to long term, which dampens the
immediate impact from changes in the market rates and stabilises margin
in the longer horizon. Interest rate risk is modelled based on the stability of
deposits and the pass-through rate. This takes account of different
elements, such as pricing strategies, volume developments, and the level
and shape of the yield curve.
In determining the interest rate profile of mortgages, prepayment or other
embedded optionality can be an important risk driver. In modelling this
risk, both interest-rate-dependent prepayments and constant
prepayments are considered. Next to a dependence on interest rates,
modelled prepayments may include other effects such as loan-to-value,
seasonality, and the reset date of the loan. In addition, the interest
sensitivity of embedded offered rate options is typically considered.\u00a0
Wholesale Banking loans typically do not experience interest-rate-
dependent prepayment behaviour, as these are mostly floating rate
products. These portfolios are match-funded, taking the constant
prepayment model into account, and typically do not contain significant
convexity risk. Wholesale Banking loans can have an all-in rate floor or a
floor on a reference rate.
Customer behaviour in relation to mortgages, loans, savings, and demand
deposits is modelled based on extensive analysis of historical data.
However, the substantial fluctuations in the interest rate environment in
recent years make the analysis more challenging than before and may
increase model risk. Models are backtested and updated when deemed
necessary, at least annually. Model parameters and the resulting risk
measures are approved by (local) ALCO, and are closely monitored on a
monthly basis.
Linear risk transfers take place from commercial business books to the
treasury book (Group Treasury), if necessary, by using estimations of
customer behaviour. The originating commercial business is ultimately
responsible for estimating this customer behaviour, leaving convexity risk
and (unexpected) customer behaviour risk with the commercial business.
Risk measurement and the risk transfer process take place at least
monthly. If deemed necessary, additional risk transfers can take place.
The commercial business manages the convexity risk that is the result of
products that contain embedded options, like mortgages. Here the
convexity risk is defined as the optionality effects in the value due to
interest rate changes, excluding the first-order effects. In some cases,
convexity risk is hedged by treasury using cap/floor contracts and
swaptions.
NII at Risk (*)
The NII-at-Risk measures the impact of changing interest rates on the
forecasted net interest income (before tax) of the banking book, excluding
the impacts of credit spread sensitivity, fees, and fair value impact. Future
projected balance sheet developments (dynamic plan) are included in this
risk metric. NII-at-Risk provides insight into the sensitivity of ING\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:
\u00a7 Change in returns of (re)investments of client deposits;
\u00a7 Change in client deposit rates (mainly savings), (partially) tracking
changes in market interest rates;
\u00a7 Change in the amortisation profile of mortgages, due to an increase or
decrease in expected prepayments;
\u00a7 Higher/lower returns of (re-)investments of core capital investment;
\u00a7 Open interest rate positions, leading to changes in return because of
different market rates; and
\u00a7 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 represent a parallel, linear
interest rate shift over one year (\u2018ramped\u2019) based on the assumption that
balance sheet developments follow ING\u2019s dynamic plan within a one-year
horizon.
The NII-at-Risk is mainly influenced by the difference in the sensitivity
between client liabilities and client assets and investments to rate
changes. The primary factor of NII-at-Risk are the investments of current
accounts, while the investments of own funds have a marginal effect, as
only a relatively small portion needs to be (re)invested within a one-year
period.
NII-at-Risk banking book per currency - year one (*)
in EUR million
2025
2024
Ramped, floored
Ramped, floored
parallel \u25bc
parallel \u25b2
parallel \u25bc
parallel \u25b2
By currency
Euro
-182
205
-144
158
US dollar
1
-1
-4
5
Other
-74
94
-2
21
Total
-254
298
-151
184
EUR ramped (floored at -100bps) is at +/- 120bps in 1 year
USD ramped (floored at -100bps) is at +/- 120bps in 1 year
The change in NII under declining and upward interest rate scenarios may
not be equal. This is due to different expected reactions in prepayment
behaviour of mortgages and different pricing developments of commercial
loans and deposits products (mainly savings). This is caused by embedded
options, explicit or implicit pricing floors, and other (assumed) pricing
factors.
The metrics mentioned above are internal metrics, which therefore
deviate from the regulatory NII SOT metric. Both internal and regulatory
measures are part of the bank's risk appetite framework and are actively
managed.
Year-on-year variance analysis (*)
In 2025, ING maintained its dynamic hedging strategy, transferring
interest rate risk from business units to Group Treasury, where it was
subsequently hedged in financial markets, resulting in overall limited
sensitivity of NII at Risk (NIIaR) compared to ING\u2019s total net interest
income. Year-on-year NIIaR increase by \u20ac100 million under a parallel down
(worst case) scenario, is primarily driven by revised repricing assumptions
and positions taken by treasury.
Net present value (NPV) at Risk (*)
NPV-at-Risk measures the impact of changing interest rates on the value
of the positions in the banking book and it is defined as the outcome of an
instantaneous increase or decrease in interest rates from applying
currency-specific scenarios. The metric primarily reflects the impact of
interest rate fluctuations on the bank\u2019s strategic interest rate positions
(e.g. investments of own funds), as well as on the savings and mortgage
portfolios. While strategic positions typically adjust proportionally with
changing rates, the savings and mortgage products exhibit more complex
behavior due to embedded optionalities. Customers can prepay or
reallocate their balances, resulting in non-linear value changes. As a result,
these portfolios may incur value losses both when interest rates increase
and decrease, contributing to the asymmetric NPV-at-Risk pattern
highlighted in the annual report.
The full value impact cannot be directly linked to the financial position or
profit or loss account, as fair value movements in banking books are not
necessarily reported through the profit or loss account or through other
comprehensive income (OCI). The changes in value are expected to
materialise over time in the profit and loss account if interest rates
develop according to forward rates throughout the remaining maturity of
the portfolio. The majority of the risk comes from the investments of own
funds and from positions exhibiting negative convexity due to embedded
optionality (most notably variable rate savings and fixed rate mortgages).
The metrics mentioned above are internal metrics, which therefore
deviate from the regulatory EVE SOT metric. Both internal and regulatory
measures are part of the bank\u2019s risk appetite framework and are actively
managed.
NPV-at-Risk banking books per currency (*)
in EUR million
2025
2024
floored
floored
parallel \u25bc
parallel \u25b2
parallel \u25bc
parallel \u25b2
By currency
Euro
1,319
-2,593
7
-1,473
US dollar
273
-265
274
-266
Other
269
-267
321
-329
Total
1,862
-3,125
602
-2,068
EUR (floored at -100bps) is at +/- 120bps
USD (floored at -100bps) is at +/- 120bps
Year-on-year variance analysis (*)
The overall NPV sensitivity increased considerably compared to the
previous year. The parallel up scenario continues to represent the worst-
case outcome, and the calculation shock for the primary currencies (EUR
and USD) was maintained at 120 basis points, consistent with the level
used in 2024. Year-over-year variations are explained by the evolving
balance sheet composition, movements in interest rates, and shifting
market expectations.
The impact of the benchmark rate reform (*)
In line with the recommendations of the Financial Stability Board, a
fundamental review of important interest rates benchmarks has been
undertaken. Some interest rate benchmarks have been reformed, while
others have or will be replaced by risk-free rates and discontinued.
In 2025, the benchmark rate reform of only one reference rate, to which
ING has significant exposures as at 31 December 2025, was continuing (i.e.
WIBOR in Poland).
On 24 January 2025, the Steering Committee of the National Working
Group (NWG SC) in Poland selected POLSTR (Polish Short Term Rate) as the
ultimate interest rate benchmark to replace WIBOR. POLSTR is calculated
based on unsecured deposits of Credit and Financial Institutions and is
expected to replace WIBOR by 31 December 2027.
In April 2025, the NWG SC published the updated transition roadmap of
the replacing process of WIBOR and announced in June 2025 that the
official determination of the POLSTR has started.
During the second half of 2025, the NWG SC approved several
recommendations for products based on POLSTR, and informed that
POLSTR has been applied for the first time in the domestic financial market
on 1 September 2025. Therefore, POLSTR gained a status of a benchmark
in accordance with the requirements of the EU Benchmark Regulation.
On 30 September 2025, the benchmark administrator GPW Benchmark
S.A, published the decision to cease providing the WIBOR reference rate for
various tenors in phases, between the end of 2025 and the end of 2026.
On 21 November 2025, the Ministry of Finance (of Poland) conducted the
first pilot issuance of treasury bonds linked to the POLSTR benchmark
during a sale auction.
Other important milestones of the process are planned in subsequent
years, including the construction of a market for financial products based
on the new benchmark and achieving regulatory and operational
readiness of all market participants to offer and operate these financial
products.
Due to the discontinuation of WIBOR, ING, its customers, and in general
those market participants with exposure to this benchmark rate will be
faced with a number of risks. These risks include legal, financial,
operational, reputational, and conduct risk. The WIBOR rates are used in
several of our lending and derivative products, and hence a project team
has been established to manage the transition. The WIBOR transition is
especially important for our Polish subsidiary (ING Bank \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 exposure of ING that
has yet to transition related to WIBOR, excluding exposures expiring before
the transition date of 31 December 2027.
Non-derivative financial instruments to transition from WIBOR to POLSTR (*)
in EUR million
Financial assets
non-derivative
Financial
liabilities\u00a0 non-
derivative
Off-balance
sheet
commitments
Carrying value
Carrying value
Nominal value
31 December 2025
25,333
360
2,301
31 December 2024
19,202
134
1,544
Derivative financial instruments to transition from WIBOR to POLSTR (*)
31 December 2025
31 December 2024
in EUR million
Nominal value
Nominal value
WIBOR
196,133
110,189
See sections 1.5.4 of Note 1 \u2018Basis of preparation and material accounting
policy information\u2019 for information on the Phase 1 amendments to IFRS.
As at 31 December 2025, Phase 1 reliefs are applicable to WIBOR indexed
fair value and cash flow hedge accounting relationships as there is
uncertainty arising from the WIBOR reform with respect to the timing and
the amount of the underlying cash flows that the Group is exposed to.
Therefore, for WIBOR financial instruments designated in hedge
accounting the applicable Phase 1 reliefs will continue to apply until the
relevant contract is modified. At that point in time, the reliefs of Phase 2
amendments to IFRS will become applicable.
Following the Phase 1 reliefs that allow ING to continue applying hedge
accounting, ING has to assume that the WIBOR-based cash flows from the
hedging instrument and hedged item will remain unaffected for the
affected fair value and cash flow hedge relationships. In addition, for the
forecast transactions that are subject to cash flow hedge accounting,
under the Phase 1 reliefs ING has to assume that the WIBOR benchmark
on which the hedged cash flows are based is not altered as a result of the
reform and, therefore, the forecast transactions still meet the highly
probable requirement.
The total gross notional amounts of hedging instruments that are used in
ING\u2019s hedge accounting relationships for which the Phase 1 amendments
to IAS 39 were applied are:
Notional amounts of hedging instruments from WIBOR to POLSTR (*)
31 December 2025
31 December 2024
in EUR million
Nominal value
Nominal value
WIBOR
97,492
99,663
As at 31 December 2025, 50% (31\u00a0December 2024: 32%) of the notional
amounts have a maturity date beyond 31 December 2027. The notional
amounts of the derivative hedging instruments provide a close
approximation of the extent of the risk exposure ING manages through
these hedging relationships.
Credit spread risk in banking books (CSRBB) (*)
Credit spread risk is defined as risk driven by the changes of the market
price for credit risk, for liquidity and potentially other characteristics of
credit-risky instruments, which is not captured by another existing
prudential framework such as Interest Rate Risk in Banking Book or by
expected credit/(jump-to-) default risk. The CSRBB framework is
implemented based on EBA Guidelines. Metrics used are NPV-at-Risk, NII-
at-Risk and Market Value Changes-at Risk and view the positions across
different accounting treatments.
Credit spread risk is not part of the internal risk transfer towards Group
Treasury and therefore remains in the business unit it originated in. Group
Treasury itself is also an important driver of credit spread risk via its high-
quality liquid assets (HQLA) investment portfolio and issuance activities.
Risk appetite limits are set on a combination of metrics and accounting
scopes and are cascaded to local ALCOs depending on the type of limit
and materiality. Metrics and limits are monitored and reported monthly to
global and local risk committees, and various stakeholders.
Foreign exchange (FX) risk in banking books (*)
FX exposures in banking books result from core banking business activities
(business units doing business in currencies other than their base
currency), foreign currency investments in subsidiaries (including realised
net profit and loss), and strategic equity stakes in foreign currencies. The
policy regarding these exposures is briefly explained below.
Core banking business (*)
Every business unit hedges the FX risk resulting from core banking
business activities into its base currency to prevent volatility in profit and
loss. Consequently, assets and liabilities are matched in terms of currency,
within certain friction limits.
FX translation (*)
ING\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. Currency exposure of Return on Equity is also
considered. Hedge accounting is applied to the largest extent possible.
Taking this into account, the CET1 ratio hedge can be achieved by
deliberately taking foreign currency positions equal to certain target
positions, such that the CET1 capital and risk-weighted assets are equally
sensitive in relative terms to changing FX rates.
Risk profile \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.
Foreign currency exposures banking books (*)
in EUR million
Foreign
investments
Hedges
Net exposures
2025
2024
2025
2024
2025
2024
US Dollar 1
9,698
11,251
-4,500
-4,823
5,198
6,429
Pound Sterling
1,584
1,674
-515
-484
1,069
1,190
Polish Zloty
4,652
4,395
-2,009
-1,616
2,643
2,779
Australian Dollar
3,307
3,373
-1,933
-2,161
1,374
1,212
Turkish Lira
469
557
469
557
Chinese Yuan
2,015
2,439
1
-830
2,016
1,609
Russian Rouble
597
396
597
396
Romanian Leu
913
913
-228
-176
685
736
Thai Baht
1,307
1,266
-829
-838
478
428
Other currency
3,032
3,347
-1,995
-2,748
1,036
599
Total
27,573
29,612
-12,008
-13,675
15,565
15,936
*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.
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
\u20ac1,607 million (2024: \u20ac1,679 million) and equity securities held at fair
value through other comprehensive income (FVOCI) of \u20ac2,607 million
(2024: \u20ac2,562 million). The value of equity securities held at FVOCI is
directly linked to equity security prices with increases/decreases being
recognised in the revaluation reserve.
Investments in associates and joint ventures are measured in accordance
with the equity method of accounting, and the balance sheet value is
therefore not directly linked to equity security prices. The equity sensitivity
is expressed as the equity position.
Year-on-year variance analysis (*)
In 2025, the revaluation reserve equity securities decreased by \u20ac372
million from \u20ac1,816 million to \u20ac1,444 million due to revaluation of the
shares in Bank of Beijing with \u20ac-403 million. In 2025, the equity securities
at fair value through OCI increased by \u20ac45 million mainly due to increased
stake in Van Lanschot Kempen.
Revaluation reserve equity securities at fair value through other
comprehensive income (*)
in EUR million
2025
2024
Positive remeasurement
1,456
1,820
Negative remeasurement
-12
-4
Total
1,444
1,816
Market risk in trading books (*)
Within the trading portfolios, the positions are maintained in the financial
markets. These positions are often a result of transactions with clients and
may benefit from short-term price movements. In 2025, ING continued its
strategy of undertaking trading activities to develop its client-driven
franchise and deliver a differentiating experience by offering multiple
market and trading products.
With respect to the trading portfolios, Trading Risk Management (TRM)
focuses on the management of market risks of Wholesale Banking (mainly
Financial Markets) as this is the only business line within ING where trading
activities take place. Trading activities include facilitation of client business
and market making. TRM is responsible for the development and
implementation of trading risk policies and risk measurement
methodologies, and for reporting and monitoring risk exposures against
approved trading limits. TRM also reviews trading mandates and global
limits, and performs the gatekeeper role in the product review process
(PARP).
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 2025, there was one outlier for hypothetical P&L and
zero outliers for actual P&L. The hypothetical outlier occurred in the first
quarter of 2025, mainly driven by higher EUR rates due to anticipated
changes in German fiscal policy.
Stressed HVaR (*)
The stressed HVaR (SVaR) is intended to replicate the HVaR calculation that
would be generated on the bank\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 stressed period selection is reviewed annually. The
historical data period is chosen so that it gives the worst-scenario loss
estimates for the current portfolio. The same SVaR model is used for
management purposes and for regulatory purposes. The same SVaR model
is used for all legal entities within ING with market risk exposure in the
trading portfolio.
Incremental risk charge (*)
The incremental risk charge (IRC) for ING is an estimate of the default and
migration risks for credit products (excluding securitisations) in the trading
book, over a one-year capital horizon, with a 99.9 percent confidence level.
Trading positions (excluding securitisations) of ING, which are subject to
specific interest rate risk included in the internal model approach for market
risk regulatory capital, are in scope of the IRC model. By model choice,
equity is excluded from the model. For the calculation of IRC, ING performs a
Monte Carlo simulation based on a multi-factor t-copula. In the multi-factor
IRC model the supervisory asset correlations are no longer applicable and
the calibration of the correlations is based on historical market data. The
rating change is simulated for all issuers over the different liquidity horizons
(i.e. time required to liquidate the position or hedge all significant risks)
within one year. Movements across different rating categories and
probabilities of default are governed by a credit-rating transition matrix. An
internal transition matrix along with internal LGDs is used, to comply with
the consistency requirement. The financial impact is then determined for
the simulated migration to default, or for the simulated migration to a
different rating category, based on LGD or credit spread changes,
respectively.
The liquidity horizon has been set to the regulatory minimum of three
months for all positions in scope. ING reviews the liquidity horizons on a
yearly basis, based on a structured assessment of the time it takes to
liquidate the positions in the trading portfolio.
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 a
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
2025
2024
Foreign exchange
Foreign exchange
US Dollar
-260
US Dollar
-93
Turkish Lira
229
Turkish Lira
84
Chinese Yuan
88
Korean Won
62
Japanese Yen
-49
Japanese Yen
61
Romanian Leu
42
Chinese Yuan
-37
Most important interest rate and credit spread sensitivities at
year-end (*)
in EUR thousand
2025
2024
Interest rate (BPV) 1
Interest rate (BPV) 1
Euro
-312
Euro
-799
US Dollar
-161
US Dollar
-198
British Pound
-133
British Pound
-189
Japanese Yen
133
Korean Won
-54
Philippine Peso
-98
Philippine Peso
-54
Credit spread (CSO1) 2
Credit spread (CSO1) 2
France
178
United States
193
United Kingdom
111
Netherlands
-165
Netherlands
75
France
-113
Indonesia
-63
Poland
69
South Korea
63
Germany
49
1Basis point value (BPV) measures the impact on value of a one basis point increase in interest
rates.
2Credit 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 (*)
in EUR thousand
2025
2024
Corporate
Financial
institutions
Corporate
Financial
institutions
Credit spread (CSO1) 1
Risk classes
1 (AAA)
-2
-19
-2
-118
2\u20134 (AA)
26
-13
-44
-27
5\u20137 (A)
64
-37
49
-246
8\u201310 (BBB)
191
-54
93
-76
11\u201313 (BB)
38
-14
38
-13
14\u201316 (B)
56
8
23
-12
17\u201322 (CCC and NPL)
6
4
4
2
Total
378
-124
162
-489
1Credit spread sensitivity (CS01) measures the impact on value of a one 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:
\u00a7 Funding and liquidity risk framework;
\u00a7 Funding and liquidity risk management strategy and objectives;
\u00a7 Funding and liquidity adequacy and risk appetite;
\u00a7 Funding and liquidity risk indicators;
\u00a7 Liquidity stress testing; and
\u00a7 Contingency funding planning.
Funding and liquidity risk framework (*)
Macroeconomic and market environments 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. Exogenous factors analysed
on a regular basis include:
\u00a7 performance of global and local macroeconomic indicators, e.g. shifts
in gross domestic product, inflation rates, unemployment rates, and
public deficit/surplus;
\u00a7 developments and risks arising from geopolitical tensions and trends;
\u00a7 monetary policy with a focus on the alternative monetary measures
employed by central banks in recent years as a result of the global
energy crisis and periods of high inflation; and
\u00a7 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
to 53 percent and 22 percent of total funding, respectively. These funding
sources provide a stable funding base. The remainder of the required
funding is attracted primarily through a combination of long-term and
short-term professional funding. Group Treasury manages the professional
funding in line with the F&L risk appetite with the aim of ensuring a
sufficiently diversified and stable funding base.
ING\u2019s long-term professional funding is diversified across maturities and
currencies. The main portion of long-term professional funding is euro and
US dollar denominated, which is in line with the currency composition of
customer lending.
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.\u00a0
ING assesses its F&L adequacy through three lenses \u2013 stress, economic,
and normative:
\u00a7 Through the stress lens, ING evaluates its ability to withstand periods of
prolonged F&L stress for both normative and economic requirements.
Limits under idiosyncratic, market-related, combined idiosyncratic and
market-related, and climate risk scenarios, which lead to customer
deposit outflows, deterioration of access to funding markets, and lower
liquidity value of counterbalancing capacity are evaluated.
\u00a7 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.
\u00a7 Through the normative lens, ING ascertains that the bank is in the
position to meet current and future domestic and host regulatory
requirements.
For each lens, ING has established a related set of risk appetite statements,
which define ING\u2019s risk appetite, commensurate with the principles of
liquidity adequacy.
The F&L risk appetite statements are translated into metrics with
appropriate boundaries and instruments which are used to regularly
measure and manage ING\u2019s funding and liquidity risk. The risk appetite
with respect to the stress lens aims to have sufficient counterbalancing
capacity under various internally defined stress scenarios. Regarding the
economic perspective, an internally defined stable funding to loans (SFtL)
ratio and stable funding surplus (SFS) metric (supplemented by other
metrics) is used to stimulate a diversified funding base and to prevent
overreliance on professional funding. Finally, the liquidity coverage ratio
(LCR) and the net stable funding ratio (NSFR) regulatory metrics are
monitored in terms of both ING\u2019s risk appetite and normative
requirements.
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 Group, including all entities,
business lines as well as on- and off-balance sheet positions. The net
liquidity position (NLP) is the main stress-testing measure and is measured
at different time buckets.
The stress-testing framework considers idiosyncratic, market-wide,
combined (idiosyncratic and market-wide) and climate-stress scenarios.
The design of the framework is based on empirical evidence supplemented
by expert judgment. The framework can be extended to additional ad-hoc
scenarios. For example, it can be used as input for firm-wide stress testing
and reverse stress testing.
Outcomes of the stress tests are considered in the key aspects of ING\u2019s F&L
risk framework and F&L risk management, including:
\u00a7 Risk Appetite Framework (through risk appetite statements);
\u00a7 Risk identification and assessment;
\u00a7 Monitoring of the liquidity and funding position;
\u00a7 Business actions (if needed);
\u00a7 Contingency funding plan; and
\u00a7 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 2025, this included stress-test scenarios assessing the impact of a
shutdown of US short- and long-term funding markets and FX markets.
The internal stress scenarios and their corresponding results serve as input
in the decision on holding additional contingency measures.
Contingency funding planning (*)
ING\u2019s contingent F&L risks are addressed in its Contingency Capital and
Funding Plan (CCFP). The objectives of the CCFP include:
\u00a7 Establishment of a monitoring framework to detect approaching
contingent events as well as their impact on ING\u2019s F&L position;
\u00a7 Provision of a plan for responding to various and increasing levels of a
bank\u2019s liquidity and capital shortfall under adverse and stressed
conditions;
\u00a7 Designation of management responsibilities, crisis communication
methods and channels, and reporting requirements;
\u00a7 Identification of contingent capital and liquidity sources under
escalating adverse and stressed conditions; and
\u00a7 Description of the steps needed to ensure the bank\u2019s capital and
liquidity sources 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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"value": "129996000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:RepaymentsOfBondsNotesAndDebentures", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-473": { "value": "109358000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:RepaymentsOfBondsNotesAndDebentures", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-474": { "value": "86061000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:RepaymentsOfBondsNotesAndDebentures", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00/2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-475": { "value": "3734000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:ProceedsFromIssueOfSubordinatedLiabilities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-476": { "value": "4603000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:ProceedsFromIssueOfSubordinatedLiabilities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-477": { "value": "2225000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:ProceedsFromIssueOfSubordinatedLiabilities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00/2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-478": { "value": "2808000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:RepaymentsOfSubordinatedLiabilities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-479": { "value": "2931000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:RepaymentsOfSubordinatedLiabilities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-480": { "value": "2894000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:RepaymentsOfSubordinatedLiabilities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00/2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-481": { "value": "282000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:PaymentsOfLeaseLiabilitiesClassifiedAsFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-482": { "value": "290000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:PaymentsOfLeaseLiabilitiesClassifiedAsFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-483": { "value": "291000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:PaymentsOfLeaseLiabilitiesClassifiedAsFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00/2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-484": { "value": "1324000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:DividendsPaidClassifiedAsFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-485": { "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-486": { "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-487": { "value": "13006000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashFlowsFromUsedInFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-488": { "value": "7935000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashFlowsFromUsedInFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00/2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-489": { "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-490": { "value": "-13831000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:IncreaseDecreaseInCashAndCashEquivalentsBeforeEffectOfExchangeRateChanges", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-491": { "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-492": { "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-493": { "value": "69068000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-494": { "value": "93011000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-495": { "value": "95390000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-496": { "value": "-1089000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:EffectOfExchangeRateChangesOnCashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-497": { "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-498": { "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-499": { "value": "54148000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2026-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-500": { "value": "69068000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-501": { "value": "93011000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-502": { "value": "
Cash and cash equivalents
in EUR million
2025
2024
2023
Treasury bills and other eligible bills included in securities at AC
0
37
0
Deposits from banks
-7,065
-6,303
-5,132
Loans and advances to banks
8,324
4,981
7,930
Cash and balances with central banks
52,889
70,353
90,214
Cash and cash equivalents at end of year
54,148
69,068
93,011
Cash and cash equivalents includes only deposits from banks and loans and advances to banks that are payable
on demand. Included in cash and cash equivalents are minimum mandatory reserve deposits held at various
central banks. Reference is made to Note 37 'Transfer of financial assets, assets pledged and received as collateral'
for restrictions on cash and balances with central banks.
Changes in liabilities arising from financing activities
Debt securities in issue
Subordinated Loans
Lease liabilities
Senior non-preferred
debt
in EUR million
2025
2024
2023
2025
2024
2023
2025
2024
2023
2025
2024
2023
Opening
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
Cash flows:
Additions
142,965
115,308
110,477
3,734
4,603
2,225
7,464
9,533
7,013
Redemptions /
Disposals
-129,996
-109,358
-86,061
-2,808
-2,931
-2,894
-282
-290
-291
-6,749
-3,692
-5,451
Non cash
changes:
Amortisation
560
1,062
730
21
28
34
27
27
28
42
-3
1
Other
-44
111
403
22
24
12
203
212
256
-17
1,669
102
Changes in
unrealised
revaluations
-280
594
1,279
287
188
473
325
544
1,436
Foreign
exchange
movement
-4,548
2,318
-479
-1,036
564
-236
-15
5
-4
-2,369
1,129
-694
Closing balance
103,116
94,459
84,423
18,100
17,879
15,404
1,050
1,116
1,162
48,090
49,393
40,213
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 34 'Derivatives and hedge
accounting'.
The table below presents the Interest and dividend received and paid.
in EUR million
2025
2024
2023
Interest received
51,600
57,201
51,030
Interest paid
-37,845
-41,459
-33,859
13,756
15,742
17,171
Dividend received
319
235
205
Dividends and other cash distributions paid
-1,324
-5,239
-10,272
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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-503": { "value": "
Cash and cash equivalents
in EUR million
2025
2024
2023
Treasury bills and other eligible bills included in securities at AC
0
37
0
Deposits from banks
-7,065
-6,303
-5,132
Loans and advances to banks
8,324
4,981
7,930
Cash and balances with central banks
52,889
70,353
90,214
Cash and cash equivalents at end of year
54,148
69,068
93,011
Cash and cash equivalents includes only deposits from banks and loans and advances to banks that are payable
on demand. Included in cash and cash equivalents are minimum mandatory reserve deposits held at various
central banks. Reference is made to Note 37 'Transfer of financial assets, assets pledged and received as collateral'
for restrictions on cash and balances with central banks.
", "dimensions": { "concept": "ifrs-full:DisclosureOfCashAndCashEquivalentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-504": { "value": "0.0", "decimals": -6, "dimensions": { "concept": "ingbank:TreasuryBillsAndOtherEligibleBills", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2026-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-505": { "value": "37000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:TreasuryBillsAndOtherEligibleBills", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-506": { "value": "0.0", "decimals": -6, "dimensions": { "concept": "ingbank:TreasuryBillsAndOtherEligibleBills", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-507": { "value": "7065000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:CashAndCashEquivalentsDepositsFromBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2026-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-508": { "value": "6303000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:CashAndCashEquivalentsDepositsFromBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-509": { "value": "5132000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:CashAndCashEquivalentsDepositsFromBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-510": { "value": "8324000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:CashAndCashEquivalentsLoansAndAdvancesToBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2026-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-511": { "value": "4981000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:CashAndCashEquivalentsLoansAndAdvancesToBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-512": { "value": "7930000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:CashAndCashEquivalentsLoansAndAdvancesToBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-513": { "value": "52889000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndBankBalancesAtCentralBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2026-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-514": { "value": "70353000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndBankBalancesAtCentralBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-515": { "value": "90214000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndBankBalancesAtCentralBanks", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-516": { "value": "54148000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2026-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-517": { "value": "69068000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-518": { "value": "93011000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:CashAndCashEquivalents", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2024-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-520": { "value": "
Cash and cash equivalents includes only deposits from banks and loans and advances to banks that are payable
on demand. Included in cash and cash equivalents are minimum mandatory reserve deposits held at various
central banks. Reference is made to Note 37 '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\u00a0 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 2025, 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\u00a0December 2025, were authorised
for issue in accordance with a resolution of the Management Board Banking on 23\u00a0February 2026. 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 Accounting Standards) as adopted by the European Union (EU) and the relevant articles
of Part 9 of Book 2 of the Dutch Civil Code.
IFRS Accounting Standards as adopted by the EU are IFRS Accounting 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 more information, reference is made to paragraph 1.5.4\u00a0 Derivatives and hedge accounting
of this note and to Note 34 '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 on
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.
During 2025, ING Bank has revised the presentation in Note 27\u00a0 Other operating expenses, to enhance its
relevance and improve comparability. Consequently, comparative figures for 2024 and 2023 have been updated
accordingly.
1.3.1\u00a0 Changes in IFRS effective in 2025
The following amendments to IFRS became effective in the current reporting period (and have been EU endorsed)
with no significant impact for ING Bank:
\u00a7 Amendments to IAS 21 'The Effects of Changes in Foreign Exchange Rates': Lack of Exchangeability (issued in
August 2023). Amendments provide guidance on determining exchange rates when a currency lacks
exchangeability, including estimation methods and disclosure requirements.
1.3.2\u00a0 Upcoming changes in IFRS after 2025
ING Bank has not early adopted any of the following Standards, interpretations or amendments that have been
issued, but are not yet effective:
Effective in 2026 (EU endorsed):
\u00a7 Amendments to IFRS 9 'Financial Instruments' and IFRS 7 'Financial Instruments: Disclosures':
Classification and Measurement of Financial Instruments (issued in May 2024). The amendments clarify that a
financial liability is derecognised on the \u2018settlement date\u2019 and introduce an accounting policy choice to
derecognise financial liabilities settled using an electronic payment system before the settlement date. Other
clarifications relate to the classification of financial assets with ESG linked features, non-recourse loans and
contractually linked instruments. Further, additional disclosure requirements introduced for equity investments
at fair value through other comprehensive income (FVOCI) and financial instruments with contingent cash flow
features.
\u00a7 Amendments to IFRS 9 'Financial Instruments' and IFRS 7 'Financial Instruments: Disclosures': Contracts
Referencing Nature-dependent Electricity (issued in December 2024). Amendments clarify accounting for
renewable electricity contracts, including own-use and hedge accounting and related disclosures.
\u00a7 Annual Improvements to IFRS Accounting Standards: Volume 11 (issued in July 2024). Amendments include
minor clarifications and corrections across a number of Standards to improve consistency and clarity.
The implementation of the above amendments is expected to have no significant impact on ING Bank's
Consolidated financial statements as they become effective.
Effective in 2027:
\u00a7 Amendments to IAS 21 'The Effects of Changes in Foreign Exchange Rates': Translation to a Hyperinflationary
Presentation Currency (issued in November 2025, not yet EU endorsed). Amendments clarify accounting when
translating from a non-hyperinflationary functional currency to a hyperinflationary presentation currency.
There is no impact expected on ING Bank's financial statements.
\u00a7 New Standard IFRS 18 'Presentation and Disclosure in Financial Statements' (issued in April 2024, EU endorsed).
IFRS 18 replaces IAS 1 'Presentation of Financial Statements', carrying forward many of the requirements in IAS
1 unchanged and complementing them with new requirements. In addition, some paragraphs from IAS 1 have
been moved to IAS 8 'Accounting Policies, Changes in Accounting Estimates and Errors' and IFRS 7.
Furthermore, the IASB has made minor amendments to IAS 7 'Statement of Cashflows' and IAS 33 'Earnings per
Share'. IFRS 18 introduces new requirements to:
\u2013 present specified categories (operating, investing, financing, income tax and discontinued operations) and
defined subtotals in the statement of profit or loss;
\u2013 provide disclosures on management-defined performance measures (MPMs) in the notes to the financial
statements; and
\u2013 improve aggregation and disaggregation.
The implementation of IFRS\u202f18 is expected to have no significant impact on ING Bank's consolidated financial
statements as it only affects the presentation and disclosure of items in the financial statements and does not
change the underlying recognition or measurement of assets, liabilities, income or expenses.
ING Bank is currently assessing the impact the amendments will have on the Consolidated financial statements. To
date, the following potential impacts have been identified:
\u00a7 IFRS 18 will not affect ING's net profit, but will reclassify income and expenses into new categories in the
statement of profit or loss and introduce a new subtotal line item 'operating profit'.
\u00a7 The line items presented in the primary financial statements might change as a result of the enhanced
principles introduced on 'aggregation and disaggregation'. ING does not expect there to be a significant change
in the information that is currently disclosed in the notes because the requirements to disclose material
information remain unchanged.
\u00a7 New disclosure requirements for management-defined performance measures (MPMs).
\u00a7 For the statement of cash flows, the starting point for calculating cash flows from operating activities will
change to 'operating profit' as noted above.
In addition, in May 2024, the IASB also issued a new accounting Standard IFRS 19 'Subsidiaries without Public
Accountability: Disclosures'. However, it is not applicable for the consolidated financial statements of ING 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:
\u00a7 Loan loss provisions (financial assets) (refer to Note 1.5.6 \u2018Impairment of financial assets');
\u00a7 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
\u00a7 Investment in associate - assessment of additional impairment losses or reversal of previous impairment losses
(refer to Note 1.10 \u2018Investment in associates and joint ventures');
\u00a7 Investment in associate - determination of significant influence over associates (refer to Note 1.10 'Investment
in associates and joint ventures'); and
\u00a7 Provisions (refer to Note 1.15 \u2018Provisions, contingent liabilities and contingent assets\u2019).
In addition, in January 2025 ING has reached an agreement on the sale of the business in Russia (ING Bank
(Eurasia) JSC), subject to several conditions, including substantive and uncertain regulatory approvals. Judgement
is required to evaluate the probability of the sale. Given the prevailing uncertainties around substantive regulatory
approvals as at 31 December 2025, no loss was recognised for the year ended 31 December 2025 and assets and
liabilities of the disposal group were not classified as held for sale. Reference is made to Note 30 'Potential sale of
ING Bank (Eurasia) JSC'.
In March 2024 ING repaid the final EUR 6 billion of its Targeted Longer-Term Refinancing Operations (TLTRO) III
participation. As a result, accounting for TLTRO is no longer an area of significant judgement in 2025 and 2024,
while it was as such in 2023.
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. ING Bank 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:
\u00a7 those to be measured subsequently at fair value (either through OCI, or through profit or loss); and
\u00a7 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:
\u00a7 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.
\u00a7 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.
\u00a7 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 repos) are presented fully within valuation result and net trading income. This also includes
interest. The interest arising on financial assets designated as at FVPL is recognised in profit or loss and
presented within Other interest income or Other interest expense in the period in which it arises. The interest
arising on a debt instrument that is part of a hedge relationship, but not subject to hedge accounting, is
recognised in profit or loss and presented within Other interest income or Other interest expense in the period in
which it arises.
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:
\u00a7 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
\u00a7 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 (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.
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.
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:
\u00a7 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
\u00a7 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
\u00a7 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.
\u00a7 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.
\u00a7 Reference is made to Note 33 '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). Interest Rate Benchmark Reform Phase 1 and Phase 2 amendments to IFRS provide
specific reliefs that allow hedge accounting relationships to continue when the benchmark rate reform is ongoing.
Phase 1 reliefs remained relevant for ING Bank as at 31 December 2025 for WIBOR hedges, and will cease to apply
once uncertainty about the timing and amount of the benchmark rate-based cash flows is resolved, or when the
hedging instrument is discontinued. ING\u2019s policy is to cease applying Phase 1 reliefs when the relevant contract
(hedging instrument or hedged item) is modified. When this occurs, Phase 2 reliefs become\u00a0 applicable still
allowing hedge accounting relationships to continue. Refer to note \u2018Risk management/Impact of the benchmark
rate reform\u2019 for further details on WIBOR transition and ING\u2019s exposures related to WIBOR that have yet to
transition.
Non-trading derivatives that do not qualify for hedge accounting
Derivative instruments that are used by ING 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 38 \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:
\u00a7 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);
\u00a7 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
\u00a7 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 initial recognition.
Write-off and debt forgiveness
Loans and debt securities are written off (either partially or in full) when there is no reasonable expectation of
recovery and/or collectability of amounts due. The following events can lead to a write-off:
\u00a7 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);
\u00a7 In a bankruptcy liquidation scenario;
\u00a7 After divestment or sale of a credit facility at a discount; and
\u00a7 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:
\u00a7 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.
\u00a7 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.
\u00a7 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 constitutes a significant judgement. Analysis of the sensitivity associated
with the assessment of a significant increase in credit risk is presented in the \u2018Risk Management\u2019 section
of the Annual Report.
\u00a7 Judgement is exercised in management\u2019s evaluation of whether there is objective evidence that
exposures are credit-impaired.
\u00a7 To reflect the risks that are not properly captured by the ECL models (including climate risk), a number of
management adjustments to the model-based ECL were necessary as at 31 December 2025, which
required significant judgement. Reference is made to the \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.
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 21 \u2018Net interest income\u2019 for the presentation
of ING Bank\u2019s participation in TLTRO programmes.
1.5.9\u00a0 Financial guarantees purchased (ING as holder)
When ING purchases a financial guarantee, it assesses whether the guarantee is integral or non\u2011integral to the
related loan.
Integral financial guarantees are not accounted for separately but included in the accounting for the loan under
IFRS 9:
\u00a7 For loans measured at amortised cost or FVOCI, the guarantee is reflected in the expected credit loss (ECL)
measurement. Premiums paid are treated as transaction costs and recognised as part of Interest income using
the effective interest rate method.
\u00a7 For loans measured at FVTPL, the guarantee is included in the fair value of the loan. Premiums paid are treated
as transaction costs and recognised within Fee and commission expense.
Non\u2011integral financial guarantees are accounted for separately, within Other assets, by analogy to
reimbursements under IAS 37 'Provisions, Contingent Liabilities and Contingent Assets':
\u00a7 For loans measured at amortised cost or FVOCI, a compensation right asset is recognised and measured based
on ECL, provided recovery is virtually certain.
\u00a7 Changes in compensation right assets are recognised as a reduction in risk costs within Addition to loan loss
provisions line in profit or loss. Premiums paid are recognised within Fee and commission expense.
\u00a7 For loans measured at FVTPL, non\u2011integral financial guarantees are designated at FVTPL, with premiums
recognised within Fee and commission expense.
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 Executive Board of ING Bank and the Management Board
Banking (together they make up the Chief Operating Decision Maker (CODM)) who decide which resources to
allocate to the segment and assess its performance.
The CODM reviews and assesses ING Bank's performance primarily by line of business. As a result, ING identified
five operating segments which are also disclosed as reportable segments.
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 then.\u00a0 IAS 29 continued to be relevant for ING\u2019s operations in
T\u00fcrkiye in 2023, 2024 and 2025. 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 2025 was 3,513.87, at 31
December 2024 was 2,684.55 and at 31 December 2023 it was 1,859.38 (movement 2025: 30.89%; 2024: 44.38%,
2023: 64.77%). The effect of such restatement for inflation in the current period of the statement of
comprehensive income and the balance sheet has been recognised in the statement of profit or loss within \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 2025. For the statement of comprehensive income this is in contrast with the usual translation
procedures where items of comprehensive income are translated at the exchange rate at the date of transaction.
Furthermore, ING 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:
\u00a7 Assets and liabilities are translated at the closing rate at the date of the statement of financial position;\u00a0
\u00a7 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
\u00a7 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:
\u00a7 Representation on the board of directors;\u00a0
\u00a7 Participation in the policymaking process; and\u00a0
\u00a7 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. In case
of an indication of potential impairment, an impairment loss is recognised when the carrying amount of the
investment exceeds its recoverable amount. Goodwill on acquisitions of interests in associates and joint ventures is
not tested separately for impairment, but is assessed as part of the carrying amount of the investment. An
impairment loss is subsequently reversed if there is indication of a reversal and there is a change in the estimates
used to determine the recoverable amount. In case of an indication of a potential reversal of impairment, an
impairment loss is reversed to the extent that the recoverable amount exceeds its carrying amount, but cannot
exceed the original impairment loss.
The reporting dates of certain associates and joint ventures can differ from the reporting date of the Group, but by
no more than three months.
Significant judgements and critical accounting estimates and assumptions:
Potential impairment and reversal assessment
Identification of impairment indicators as well as indicators of potential reversal of previous impairments of
ING 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
\u2018Investment in associates and joint ventures\u2019.
Determination of significant influence over associates
It is presumed that an entity has significant influence when it holds 20% or more of the voting power of the
investee. Conversely, it is presumed that an entity does not have significant influence when voting power is
less than 20% in the investee. Depending on the facts and circumstances, the presumption is rebutted
when ING can clearly demonstrate whether or not it has power to participate in the investee\u2019s financial and
operating policy decisions. The consideration of all relevant factors requires judgement, including, amongst
others, the investment purpose, investee\u2019s governance structure and legal regime, ability to obtain
meaningful board representation and participation in policymaking decisions. Refer to Note 5 'Financial
assets at fair value through other comprehensive income' regarding ING\u2019s accounting for its investment in
Van Lanschot Kempen.
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:
\u00a7 Fixed payments (including in-substance fixed payments), less any lease incentives receivable;
\u00a7 Variable lease payments that are based on an index or a rate;
\u00a7 Amounts expected to be payable by the lessee under residual value guarantees;
\u00a7 The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and
\u00a7 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 40 '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 in Note 39 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:
\u00a7 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
\u00a7 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:
\u00a7 Service cost which is recognised as staff costs in the statement of profit or loss;\u00a0
\u00a7 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;
\u00a7 Remeasurements which are recognised in Other comprehensive income (equity) and not recycled to the
Statement of profit or loss;
\u00a7 Any past service cost relating to a plan amendment is recognised in profit or loss in the period of the plan
amendment; and
\u00a7 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 are 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 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 2025, 2024 and 2023.
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
2025, 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
2025, 7 preference shares were issued and fully paid (2024: 7 preference shares; 2023: 7 preference shares)
amounting to EUR 8 (2024: EUR 8 and 2023: EUR 8).
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.
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 31 '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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-519": { "value": "
Cash and cash equivalents includes only deposits from banks and loans and advances to banks that are payable
on demand. Included in cash and cash equivalents are minimum mandatory reserve deposits held at various
central banks. Reference is made to Note 37 '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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-521": { "value": "Included in cash and cash equivalents are minimum mandatory reserve deposits held at various
central banks. Reference is made to Note 37 '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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-522": { "value": "
Changes in liabilities arising from financing activities
Debt securities in issue
Subordinated Loans
Lease liabilities
Senior non-preferred
debt
in EUR million
2025
2024
2023
2025
2024
2023
2025
2024
2023
2025
2024
2023
Opening
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
Cash flows:
Additions
142,965
115,308
110,477
3,734
4,603
2,225
7,464
9,533
7,013
Redemptions /
Disposals
-129,996
-109,358
-86,061
-2,808
-2,931
-2,894
-282
-290
-291
-6,749
-3,692
-5,451
Non cash
changes:
Amortisation
560
1,062
730
21
28
34
27
27
28
42
-3
1
Other
-44
111
403
22
24
12
203
212
256
-17
1,669
102
Changes in
unrealised
revaluations
-280
594
1,279
287
188
473
325
544
1,436
Foreign
exchange
movement
-4,548
2,318
-479
-1,036
564
-236
-15
5
-4
-2,369
1,129
-694
Closing balance
103,116
94,459
84,423
18,100
17,879
15,404
1,050
1,116
1,162
48,090
49,393
40,213
Lease liabilities relate to right-of-use assets. Disclosures regarding right-of-use assets are provided in Note 9
'Property and equipment'. The total cash outflow for leases in 2025 was EUR 282\u00a0million (2024: EUR 290\u00a0million).
17\u00a0 Debt securities in issue
Debt securities in issue relate to debentures and other issued debt securities with either fixed interest rates or
interest rates based on floating interest rate levels, such as certificates of deposit and accepted bills issued by ING
Bank, except for subordinated items. Debt securities in issue do not include debt securities presented as Financial
liabilities at fair value through profit or loss. ING 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
2025
2024
Fixed rate debt securities
Within 1 year
30,850
26,358
More than 1 year but less than 2 years
4,401
5,718
More than 2 years but less than 3 years
6,851
4,429
More than 3 years but less than 4 years
6,081
5,907
More than 4 years but less than 5 years
5,463
6,105
More than 5 years
12,393
12,335
Total fixed rate debt securities
66,039
60,851
Floating rate debt securities
Within 1 year
28,774
26,262
More than 1 year but less than 2 years
1,004
2,343
More than 2 years but less than 3 years
830
1,080
More than 3 years but less than 4 years
1,056
117
More than 4 years but less than 5 years
913
902
More than 5 years
4,501
2,903
Total floating rate debt securities
37,077
33,607
Total debt securities
103,116
94,459
Reference is made to the Consolidated statement of cash flows for more information on issuances, redemptions
and non-cash movements.
18\u00a0 Senior non-preferred debt
Senior non-preferred debt
In EUR million
2025
2024
Senior non-preferred debt
48,090
49,393
48,090
49,393
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
2025
2024
Subordinated loans
18,100
17,879
18,100
17,879
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 18,299 million (2024: EUR 18,403 million) have been placed with ING Bank N.V.
by ING Groep N.V.
In 2025 ING Groep N.V. issued EUR 1.25 billion 4.13% Fixed Rate Subordinated Green Tier 2 Notes in May, EUR 1.25
billion 3.88% Fixed Rate Subordinated Tier 2 Notes in August and USD 1.50 billion 7.00% Perpetual AT1 Contingent
Convertible Capital Securities in September.
In 2025 ING Groep N.V. redeemed EUR 750 million 2.00% Fixed Subordinated Tier 2 notes in March, USD 1.25 billion
6.50% Perpetual AT1 Contingent Convertible Capital Securities in April and EUR 1 billion 1.00% Fixed Subordinated
Tier 2 notes in November.
Reference is made to the Consolidated statement of cash flows for further information on issuances and
redemptions.
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"entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2023-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ingbank:DebtSecuritiesInIssueMember", "unit": "iso4217:EUR" } }, "f-526": { "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-527": { "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-528": { "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-529": { "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-530": { "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-531": { "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-532": { "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-533": { "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-534": { "value": "37806000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:LiabilitiesArisingFromFinancingActivities", "entity": 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"2025-01-01T00:00:00/2026-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-614": { "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-615": { "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-616": { "value": "37845000000.0", "decimals": -6, "dimensions": { "concept": "ifrs-full:InterestPaidClassifiedAsOperatingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-617": { "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-618": { "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-619": { "value": "-13756000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:NetInterestReceivedPaidClassifiedAsOperatingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-620": { "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-621": { "value": "-17171000000.0", "decimals": -6, "dimensions": { "concept": 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"ifrs-full:DividendsPaidClassifiedAsFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00", "unit": "iso4217:EUR" } }, "f-626": { "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-627": { "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-628": { "value": "
1.1\u00a0 Reporting entity and\u00a0 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 2025, 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\u00a0December 2025, were authorised
for issue in accordance with a resolution of the Management Board Banking on 23\u00a0February 2026. 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-629": { "value": "ING Bank N.V.", "dimensions": { "concept": "ifrs-full:NameOfReportingEntityOrOtherMeansOfIdentification", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-630": { "value": "Naamloze Vennootschap", "dimensions": { "concept": "ifrs-full:LegalFormOfEntity", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-631": { "value": "Amsterdam, the Netherlands", "dimensions": { "concept": "ifrs-full:DomicileOfEntity", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-632": { "value": "the Netherlands", "dimensions": { "concept": "ifrs-full:CountryOfIncorporation", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-633": { "value": "ING Groep N.V.", "dimensions": { "concept": "ifrs-full:NameOfParentEntity", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-634": { "value": "ING Groep N.V.", "dimensions": { "concept": "ifrs-full:NameOfUltimateParentOfGroup", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-635": { "value": "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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-636": { "value": "
The ING Bank Consolidated financial statements, as at and for the year ended 31\u00a0December 2025, were authorised
for issue in accordance with a resolution of the Management Board Banking on 23\u00a0February 2026. 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-637": { "value": "
The ING Bank Consolidated financial statements have been prepared in accordance with International Financial
Reporting Standards (IFRS Accounting Standards) as adopted by the European Union (EU) and the relevant articles
of Part 9 of Book 2 of the Dutch Civil Code.
IFRS Accounting Standards as adopted by the EU are IFRS Accounting 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-638": { "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.
During 2025, ING Bank has revised the presentation in Note 27\u00a0 Other operating expenses, to enhance its
relevance and improve comparability. Consequently, comparative figures for 2024 and 2023 have been updated
accordingly.
1.3.1\u00a0 Changes in IFRS effective in 2025
The following amendments to IFRS became effective in the current reporting period (and have been EU endorsed)
with no significant impact for ING Bank:
\u00a7 Amendments to IAS 21 'The Effects of Changes in Foreign Exchange Rates': Lack of Exchangeability (issued in
August 2023). Amendments provide guidance on determining exchange rates when a currency lacks
exchangeability, including estimation methods and disclosure requirements.
1.3.2\u00a0 Upcoming changes in IFRS after 2025
ING Bank has not early adopted any of the following Standards, interpretations or amendments that have been
issued, but are not yet effective:
Effective in 2026 (EU endorsed):
\u00a7 Amendments to IFRS 9 'Financial Instruments' and IFRS 7 'Financial Instruments: Disclosures':
Classification and Measurement of Financial Instruments (issued in May 2024). The amendments clarify that a
financial liability is derecognised on the \u2018settlement date\u2019 and introduce an accounting policy choice to
derecognise financial liabilities settled using an electronic payment system before the settlement date. Other
clarifications relate to the classification of financial assets with ESG linked features, non-recourse loans and
contractually linked instruments. Further, additional disclosure requirements introduced for equity investments
at fair value through other comprehensive income (FVOCI) and financial instruments with contingent cash flow
features.
\u00a7 Amendments to IFRS 9 'Financial Instruments' and IFRS 7 'Financial Instruments: Disclosures': Contracts
Referencing Nature-dependent Electricity (issued in December 2024). Amendments clarify accounting for
renewable electricity contracts, including own-use and hedge accounting and related disclosures.
\u00a7 Annual Improvements to IFRS Accounting Standards: Volume 11 (issued in July 2024). Amendments include
minor clarifications and corrections across a number of Standards to improve consistency and clarity.
The implementation of the above amendments is expected to have no significant impact on ING Bank's
Consolidated financial statements as they become effective.
Effective in 2027:
\u00a7 Amendments to IAS 21 'The Effects of Changes in Foreign Exchange Rates': Translation to a Hyperinflationary
Presentation Currency (issued in November 2025, not yet EU endorsed). Amendments clarify accounting when
translating from a non-hyperinflationary functional currency to a hyperinflationary presentation currency.
There is no impact expected on ING Bank's financial statements.
\u00a7 New Standard IFRS 18 'Presentation and Disclosure in Financial Statements' (issued in April 2024, EU endorsed).
IFRS 18 replaces IAS 1 'Presentation of Financial Statements', carrying forward many of the requirements in IAS
1 unchanged and complementing them with new requirements. In addition, some paragraphs from IAS 1 have
been moved to IAS 8 'Accounting Policies, Changes in Accounting Estimates and Errors' and IFRS 7.
Furthermore, the IASB has made minor amendments to IAS 7 'Statement of Cashflows' and IAS 33 'Earnings per
Share'. IFRS 18 introduces new requirements to:
\u2013 present specified categories (operating, investing, financing, income tax and discontinued operations) and
defined subtotals in the statement of profit or loss;
\u2013 provide disclosures on management-defined performance measures (MPMs) in the notes to the financial
statements; and
\u2013 improve aggregation and disaggregation.
The implementation of IFRS\u202f18 is expected to have no significant impact on ING Bank's consolidated financial
statements as it only affects the presentation and disclosure of items in the financial statements and does not
change the underlying recognition or measurement of assets, liabilities, income or expenses.
ING Bank is currently assessing the impact the amendments will have on the Consolidated financial statements. To
date, the following potential impacts have been identified:
\u00a7 IFRS 18 will not affect ING's net profit, but will reclassify income and expenses into new categories in the
statement of profit or loss and introduce a new subtotal line item 'operating profit'.
\u00a7 The line items presented in the primary financial statements might change as a result of the enhanced
principles introduced on 'aggregation and disaggregation'. ING does not expect there to be a significant change
in the information that is currently disclosed in the notes because the requirements to disclose material
information remain unchanged.
\u00a7 New disclosure requirements for management-defined performance measures (MPMs).
\u00a7 For the statement of cash flows, the starting point for calculating cash flows from operating activities will
change to 'operating profit' as noted above.
In addition, in May 2024, the IASB also issued a new accounting Standard IFRS 19 'Subsidiaries without Public
Accountability: Disclosures'. However, it is not applicable for the consolidated financial statements of ING Bank.
", "dimensions": { "concept": "ifrs-full:DisclosureOfChangesInAccountingPoliciesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-639": { "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.
During 2025, ING Bank has revised the presentation in Note 27\u00a0 Other operating expenses, to enhance its
relevance and improve comparability. Consequently, comparative figures for 2024 and 2023 have been updated
accordingly.
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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:
\u00a7 Loan loss provisions (financial assets) (refer to Note 1.5.6 \u2018Impairment of financial assets');
\u00a7 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
\u00a7 Investment in associate - assessment of additional impairment losses or reversal of previous impairment losses
(refer to Note 1.10 \u2018Investment in associates and joint ventures');
\u00a7 Investment in associate - determination of significant influence over associates (refer to Note 1.10 'Investment
in associates and joint ventures'); and
\u00a7 Provisions (refer to Note 1.15 \u2018Provisions, contingent liabilities and contingent assets\u2019).
In addition, in January 2025 ING has reached an agreement on the sale of the business in Russia (ING Bank
(Eurasia) JSC), subject to several conditions, including substantive and uncertain regulatory approvals. Judgement
is required to evaluate the probability of the sale. Given the prevailing uncertainties around substantive regulatory
approvals as at 31 December 2025, no loss was recognised for the year ended 31 December 2025 and assets and
liabilities of the disposal group were not classified as held for sale. Reference is made to Note 30 'Potential sale of
ING Bank (Eurasia) JSC'.
In March 2024 ING repaid the final EUR 6 billion of its Targeted Longer-Term Refinancing Operations (TLTRO) III
participation. As a result, accounting for TLTRO is no longer an area of significant judgement in 2025 and 2024,
while it was as such in 2023.
Significant judgements and critical accounting estimates and assumptions:
\u00a7 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
\u00a7 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
\u00a7 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.
\u00a7 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.
\u00a7 Reference is made to Note 33 '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:
\u00a7 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.
\u00a7 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.
\u00a7 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 constitutes a significant judgement. Analysis of the sensitivity associated
with the assessment of a significant increase in credit risk is presented in the \u2018Risk Management\u2019 section
of the Annual Report.
\u00a7 Judgement is exercised in management\u2019s evaluation of whether there is objective evidence that
exposures are credit-impaired.
\u00a7 To reflect the risks that are not properly captured by the ECL models (including climate risk), a number of
management adjustments to the model-based ECL were necessary as at 31 December 2025, which
required significant judgement. Reference is made to the \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:
Potential impairment and reversal assessment
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
\u2018Investment in associates and joint ventures\u2019.
Determination of significant influence over associates
It is presumed that an entity has significant influence when it holds 20% or more of the voting power of the
investee. Conversely, it is presumed that an entity does not have significant influence when voting power is
less than 20% in the investee. Depending on the facts and circumstances, the presumption is rebutted
when ING can clearly demonstrate whether or not it has power to participate in the investee\u2019s financial and
operating policy decisions. The consideration of all relevant factors requires judgement, including, amongst
others, the investment purpose, investee\u2019s governance structure and legal regime, ability to obtain
meaningful board representation and participation in policymaking decisions. Refer to Note 5 'Financial
assets at fair value through other comprehensive income' regarding ING\u2019s accounting for its investment in
Van Lanschot Kempen.
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 40 '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'.
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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. ING Bank 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:
\u00a7 those to be measured subsequently at fair value (either through OCI, or through profit or loss); and
\u00a7 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:
\u00a7 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.
\u00a7 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.
\u00a7 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 repos) are presented fully within valuation result and net trading income. This also includes
interest. The interest arising on financial assets designated as at FVPL is recognised in profit or loss and
presented within Other interest income or Other interest expense in the period in which it arises. The interest
arising on a debt instrument that is part of a hedge relationship, but not subject to hedge accounting, is
recognised in profit or loss and presented within Other interest income or Other interest expense in the period in
which it arises.
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:
\u00a7 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
\u00a7 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 (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.
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.
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:
\u00a7 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
\u00a7 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
\u00a7 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.
\u00a7 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.
\u00a7 Reference is made to Note 33 '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). Interest Rate Benchmark Reform Phase 1 and Phase 2 amendments to IFRS provide
specific reliefs that allow hedge accounting relationships to continue when the benchmark rate reform is ongoing.
Phase 1 reliefs remained relevant for ING Bank as at 31 December 2025 for WIBOR hedges, and will cease to apply
once uncertainty about the timing and amount of the benchmark rate-based cash flows is resolved, or when the
hedging instrument is discontinued. ING\u2019s policy is to cease applying Phase 1 reliefs when the relevant contract
(hedging instrument or hedged item) is modified. When this occurs, Phase 2 reliefs become\u00a0 applicable still
allowing hedge accounting relationships to continue. Refer to note \u2018Risk management/Impact of the benchmark
rate reform\u2019 for further details on WIBOR transition and ING\u2019s exposures related to WIBOR that have yet to
transition.
Non-trading derivatives that do not qualify for hedge accounting
Derivative instruments that are used by ING 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 38 \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:
\u00a7 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);
\u00a7 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
\u00a7 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 initial recognition.
Write-off and debt forgiveness
Loans and debt securities are written off (either partially or in full) when there is no reasonable expectation of
recovery and/or collectability of amounts due. The following events can lead to a write-off:
\u00a7 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);
\u00a7 In a bankruptcy liquidation scenario;
\u00a7 After divestment or sale of a credit facility at a discount; and
\u00a7 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:
\u00a7 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.
\u00a7 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.
\u00a7 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 constitutes a significant judgement. Analysis of the sensitivity associated
with the assessment of a significant increase in credit risk is presented in the \u2018Risk Management\u2019 section
of the Annual Report.
\u00a7 Judgement is exercised in management\u2019s evaluation of whether there is objective evidence that
exposures are credit-impaired.
\u00a7 To reflect the risks that are not properly captured by the ECL models (including climate risk), a number of
management adjustments to the model-based ECL were necessary as at 31 December 2025, which
required significant judgement. Reference is made to the \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.
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 21 \u2018Net interest income\u2019 for the presentation
of ING Bank\u2019s participation in TLTRO programmes.
1.5.9\u00a0 Financial guarantees purchased (ING as holder)
When ING purchases a financial guarantee, it assesses whether the guarantee is integral or non\u2011integral to the
related loan.
Integral financial guarantees are not accounted for separately but included in the accounting for the loan under
IFRS 9:
\u00a7 For loans measured at amortised cost or FVOCI, the guarantee is reflected in the expected credit loss (ECL)
measurement. Premiums paid are treated as transaction costs and recognised as part of Interest income using
the effective interest rate method.
\u00a7 For loans measured at FVTPL, the guarantee is included in the fair value of the loan. Premiums paid are treated
as transaction costs and recognised within Fee and commission expense.
Non\u2011integral financial guarantees are accounted for separately, within Other assets, by analogy to
reimbursements under IAS 37 'Provisions, Contingent Liabilities and Contingent Assets':
\u00a7 For loans measured at amortised cost or FVOCI, a compensation right asset is recognised and measured based
on ECL, provided recovery is virtually certain.
\u00a7 Changes in compensation right assets are recognised as a reduction in risk costs within Addition to loan loss
provisions line in profit or loss. Premiums paid are recognised within Fee and commission expense.
\u00a7 For loans measured at FVTPL, non\u2011integral financial guarantees are designated at FVTPL, with premiums
recognised within Fee and commission expense.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForFinancialInstrumentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-643": { "value": "
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.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForDerecognitionOfFinancialInstrumentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-642": { "value": "
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.
Financial assets
ING Bank classifies its financial assets in the following measurement categories:
\u00a7 those to be measured subsequently at fair value (either through OCI, or through profit or loss); and
\u00a7 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:
\u00a7 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.
\u00a7 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.
\u00a7 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 repos) are presented fully within valuation result and net trading income. This also includes
interest. The interest arising on financial assets designated as at FVPL is recognised in profit or loss and
presented within Other interest income or Other interest expense in the period in which it arises. The interest
arising on a debt instrument that is part of a hedge relationship, but not subject to hedge accounting, is
recognised in profit or loss and presented within Other interest income or Other interest expense in the period in
which it arises.
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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-645": { "value": "
1.5.1\u00a0 Recognition and derecognition of financial instruments
Recognition of financial liabilities
Financial liabilities are recognised on the date that the entity becomes a party to the contractual provisions of the
instrument.
Derecognition of financial liabilities
Financial liabilities are derecognised when the obligation specified in the contract is discharged, cancelled or
expired. The difference between the carrying amount of a financial liability that has been extinguished and the
consideration paid is recognised in profit or loss
Financial liabilities
Financial liabilities are classified and subsequently measured at AC, except for financial guarantee contracts,
derivatives and liabilities designated at FVPL.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:
\u00a7 Fixed payments (including in-substance fixed payments), less any lease incentives receivable;
\u00a7 Variable lease payments that are based on an index or a rate;
\u00a7 Amounts expected to be payable by the lessee under residual value guarantees;
\u00a7 The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and
\u00a7 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-644": { "value": "
1.5.1\u00a0 Recognition and derecognition of financial instruments
Recognition of financial liabilities
Financial liabilities are recognised on the date that the entity becomes a party to the contractual provisions of the
instrument.
Derecognition of financial liabilities
Financial liabilities are derecognised when the obligation specified in the contract is discharged, cancelled or
expired. The difference between the carrying amount of a financial liability that has been extinguished and the
consideration paid is recognised in profit or loss
Financial 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:
\u00a7 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
\u00a7 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-646": { "value": "
1.5.2\u00a0 Classification and measurement of financial instruments
Financial assets
ING Bank classifies its financial assets in the following measurement categories:
\u00a7 those to be measured subsequently at fair value (either through OCI, or through profit or loss); and
\u00a7 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:
\u00a7 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.
\u00a7 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.
\u00a7 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 repos) are presented fully within valuation result and net trading income. This also includes
interest. The interest arising on financial assets designated as at FVPL is recognised in profit or loss and
presented within Other interest income or Other interest expense in the period in which it arises. The interest
arising on a debt instrument that is part of a hedge relationship, but not subject to hedge accounting, is
recognised in profit or loss and presented within Other interest income or Other interest expense in the period in
which it arises.
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:
\u00a7 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
\u00a7 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.
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:
\u00a7 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
\u00a7 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
\u00a7 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.
\u00a7 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.
\u00a7 Reference is made to Note 33 '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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-647": { "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 repos) are presented fully within valuation result and net trading income. This also includes
interest. The interest arising on financial assets designated as at FVPL is recognised in profit or loss and
presented within Other interest income or Other interest expense in the period in which it arises. The interest
arising on a debt instrument that is part of a hedge relationship, but not subject to hedge accounting, is
recognised in profit or loss and presented within Other interest income or Other interest expense in the period in
which it arises.
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:
\u00a7 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
\u00a7 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-648": { "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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-649": { "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:
\u00a7 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
\u00a7 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.
1.5.9\u00a0 Financial guarantees purchased (ING as holder)
When ING purchases a financial guarantee, it assesses whether the guarantee is integral or non\u2011integral to the
related loan.
Integral financial guarantees are not accounted for separately but included in the accounting for the loan under
IFRS 9:
\u00a7 For loans measured at amortised cost or FVOCI, the guarantee is reflected in the expected credit loss (ECL)
measurement. Premiums paid are treated as transaction costs and recognised as part of Interest income using
the effective interest rate method.
\u00a7 For loans measured at FVTPL, the guarantee is included in the fair value of the loan. Premiums paid are treated
as transaction costs and recognised within Fee and commission expense.
Non\u2011integral financial guarantees are accounted for separately, within Other assets, by analogy to
reimbursements under IAS 37 'Provisions, Contingent Liabilities and Contingent Assets':
\u00a7 For loans measured at amortised cost or FVOCI, a compensation right asset is recognised and measured based
on ECL, provided recovery is virtually certain.
\u00a7 Changes in compensation right assets are recognised as a reduction in risk costs within Addition to loan loss
provisions line in profit or loss. Premiums paid are recognised within Fee and commission expense.
\u00a7 For loans measured at FVTPL, non\u2011integral financial guarantees are designated at FVTPL, with premiums
recognised within Fee and commission expense.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForFinancialGuaranteesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-650": { "value": "
Repurchase transactions and reverse repurchase transactions
Securities sold subject to repurchase agreements (repos), securities lending and similar agreements continue to be
recognised in the Consolidated statement of financial position 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.
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.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForRepurchaseAndReverseRepurchaseAgreementsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-651": { "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:
\u00a7 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
\u00a7 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
\u00a7 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.
\u00a7 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.
\u00a7 Reference is made to Note 33 '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:
\u00a7 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);
\u00a7 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
\u00a7 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 initial recognition.
Write-off and debt forgiveness
Loans and debt securities are written off (either partially or in full) when there is no reasonable expectation of
recovery and/or collectability of amounts due. The following events can lead to a write-off:
\u00a7 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);
\u00a7 In a bankruptcy liquidation scenario;
\u00a7 After divestment or sale of a credit facility at a discount; and
\u00a7 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:
\u00a7 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.
\u00a7 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.
\u00a7 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 constitutes a significant judgement. Analysis of the sensitivity associated
with the assessment of a significant increase in credit risk is presented in the \u2018Risk Management\u2019 section
of the Annual Report.
\u00a7 Judgement is exercised in management\u2019s evaluation of whether there is objective evidence that
exposures are credit-impaired.
\u00a7 To reflect the risks that are not properly captured by the ECL models (including climate risk), a number of
management adjustments to the model-based ECL were necessary as at 31 December 2025, which
required significant judgement. Reference is made to the \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.
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:
\u00a7 Representation on the board of directors;\u00a0
\u00a7 Participation in the policymaking process; and\u00a0
\u00a7 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. In case
of an indication of potential impairment, an impairment loss is recognised when the carrying amount of the
investment exceeds its recoverable amount. Goodwill on acquisitions of interests in associates and joint ventures is
not tested separately for impairment, but is assessed as part of the carrying amount of the investment. An
impairment loss is subsequently reversed if there is indication of a reversal and there is a change in the estimates
used to determine the recoverable amount. In case of an indication of a potential reversal of impairment, an
impairment loss is reversed to the extent that the recoverable amount exceeds its carrying amount, but cannot
exceed the original impairment loss.
The reporting dates of certain associates and joint ventures can differ from the reporting date of the Group, but by
no more than three months.
Significant judgements and critical accounting estimates and assumptions:
Potential impairment and reversal assessment
Identification of impairment indicators as well as indicators of potential reversal of previous impairments of
ING 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
\u2018Investment in associates and joint ventures\u2019.
Determination of significant influence over associates
It is presumed that an entity has significant influence when it holds 20% or more of the voting power of the
investee. Conversely, it is presumed that an entity does not have significant influence when voting power is
less than 20% in the investee. Depending on the facts and circumstances, the presumption is rebutted
when ING can clearly demonstrate whether or not it has power to participate in the investee\u2019s financial and
operating policy decisions. The consideration of all relevant factors requires judgement, including, amongst
others, the investment purpose, investee\u2019s governance structure and legal regime, ability to obtain
meaningful board representation and participation in policymaking decisions. Refer to Note 5 'Financial
assets at fair value through other comprehensive income' regarding ING\u2019s accounting for its investment in
Van Lanschot Kempen.
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 40 '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
2025
2024
Amounts held at central banks 1
51,133\u00a0
68,708\u00a0
Cash and bank balances
1,756\u00a0
1,645\u00a0
52,889
70,353
1Amounts held at central banks include an amount of EUR -17 million (2024: EUR -14 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
2025
2024
2025
2024
2025
2024
Loans and advances to banks1
12,362
14,343
8,841
7,426
21,204
21,769
1Loans and advances to banks include EUR -18\u00a0 million (2024: EUR -22\u00a0 million) of Loan loss provisions.
Loans and advances include balances of reverse repurchase transactions. For more information, refer to Note 4
'Financial assets at fair value through profit or loss' . Furthermore, it includes on-demand and term loans, and cash
collateral transactions. Reference is made to Note 7 'Loans and advances to customers' for information on finance
lease receivables included in Loans and advances to banks.
As at 31\u00a0December 2025 and at 31 December 2024, all loans and advances to banks are non-subordinated.
Financial assets at fair value through other comprehensive income by type
in EUR million
2025
2024
Equity securities
2,607
2,562
Debt securities 1
50,817
42,219
Loans and advances 1
3,238
1,608
56,662
46,389
1Debt securities includes an amount of EUR -15 million (2024: EUR -12 million) and Loans and advances includes EUR -6 million (2024: EUR -7 million) of
Loan loss provisions.
Debt securities by type of exposure
Debt Securities at
FVPL 1
Debt Securities at
FVOCI
Debt Securities at
AC
Total
in EUR million
2025
2024
2025
2024
2025
2024
2025
2024
Government bonds
288
289
32,578
24,757
25,297
22,734
58,163
47,780
Central bank bonds
376
444
2,541
2,900
2,917
3,344
Sub-sovereign, Supranationals
and Agencies
413
1,027
13,788
11,513
16,744
15,445
30,945
27,985
Covered bonds
3,750
4,108
5,362
5,683
9,111
9,791
Corporate bonds
89
848
109
79
50
106
248
1,033
Financial institutions' bonds
1,176
2,141
28
980
96
139
1,300
3,261
ABS portfolio
757
757
578
794
3,790
3,281
5,125
4,832
3,099
5,506
50,832
42,231
53,879
50,288
107,809
98,026
Loan loss provisions
-15
-12
-11
-15
-26
-27
Debt securities portfolio
3,099
5,506
50,817
42,219
53,867
50,273
107,783
97,999
1Debt 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
2025
2024
2025
2024
2025
2024
Loans and advances to public authorities
3,452
1,888
19,583
16,773
23,034
18,661
Residential mortgages
126,772
117,223
242,297
227,992
369,069
345,216
Other personal lending
5,033
5,007
34,690
31,789
39,723
36,797
Corporate Lending
68,866
66,987
226,981
218,473
295,847
285,459
204,122
191,105
523,551
495,027
727,673
686,132
Loan loss provisions
-836
-811
-5,058
-5,023
-5,894
-5,833
203,286
190,295
518,493
490,004
721,779
680,299
Finance lease receivables 1
in EUR million
2025
2024
Maturities of gross investment in finance lease receivables
-\u00a0 within 1 year
4,121
3,962
-\u00a0 between 1-2 years
3,040
2,961
-\u00a0 between 2-3 years
2,408
2,283
-\u00a0 between 3-4 years
1,563
1,577
-\u00a0 between 4-5 years
935
902
-\u00a0 more than 5 years
1,609
1,555
13,677
13,240
Unearned future finance income on finance leases
-1,122
-1,145
Net investment in finance leases
12,554
12,095
Included in Loans and advances to banks
3
5
Included in Loans and advances to customers
12,551
12,091
12,554
12,095
1The total loan loss provision for finance lease receivables is EUR 191 million (2024: EUR\u00a0 193 million).
8\u00a0 Investment in associates and joint ventures
Investments in associates and joint ventures
2025
2024
in EUR million
Interest
held (%)
Fair value of
listed
investments
Balance
sheet value
Interest held
(%)
Fair value of
listed
investments
Balance
sheet value
TMBThanachart Bank Public
Company Limited
23%
1,212
1,307
23%
1,164
1,266
Other investments in associates and
joint ventures
300
412
1,607
1,679
TMBThanachart Bank Public Company Limited
ING Bank has an 23% investment in TMBThanachart Bank Public Company Limited (hereafter: TTB), a bank listed on
the stock exchange of Thailand. TTB is providing products and services to wholesale, small and medium enterprise
(SME), and retail customers. TTB is accounted for as an investment in associate based on the size of ING's
shareholding and representation on the Board. The investment in TTB is reflected in the Corporate Line.
A summary of the unaudited financial information of TTB as of the end of September 2025 based on the data
available at the time the consolidated financial statements were prepared is presented below. TTB\u2019s statutory
reporting date is 31 December. For the year ending 31 December 2025, ING recognised the associate\u2019s results
using TTB\u2019s financial statements for the 12\u2011month period ending 30 September 2025.
Selected balance sheet information TMBThanachart Bank Public Company Limited
As at 30 September
in EUR million
2025
2024
Loans to customers and accrued interest receivables, net
31,009
33,878
Interbank and money market items, net
5,856
7,152
Investments, net
5,917
4,680
Other
3,158
3,436
Total assets
45,940
49,147
Deposits
34,345
36,563
Interbank and money market items
2,663
2,633
Debts issued and borrowings
462
1,139
Other
1,942
2,218
Total liabilities
39,412
42,554
Equity
6,529
6,593
Selected profit or loss information TMBThanachart Bank Public Company Limited
For the 12 months ended 30 September
in EUR million
2025
2024
Total operating income
1,795
1,991
Total expenses
1,266
1,548
Profit for the period
555
586
Total other comprehensive income for the period
170
17
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.
Significant influence for associates in which the interest held is below 20%, is based on the combination of ING\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
2025
2024
Opening balance as at 1 January
1,679
1,509
Additions
1
26
Transfers
-29
-7
Revaluations
35
0
Share of results
209
205
Dividends received
-160
-91
Disposals
-66
-16
Impairments
-9
-35
Exchange rate differences
-54
87
Closing balance
1,607
1,679
Share of results from associates and joint ventures of EUR 209 million (2024: EUR 205 million) as included in the
table above is mainly attributable to our share in the results of TTB of EUR 136\u00a0million (2024: EUR 123 million) and
a EUR 44 million gain from the sale of an associate in Belgium, while 2024 included EUR 77 million as our share in
the result of an associate in Belgium following its one-off profit.
Impairments and reversal thereof on the investment in TTB
Accumulated impairments on the investment in TTB of EUR 395\u00a0million (2024: EUR 395\u00a0million) were recognised in
previous years. There is no impairment trigger observed as per 31 December 2025. 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 the VIU did not significantly exceed the
carrying amount of the investment in TTB, no reversal of impairment was recognised.
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and VIU. Fair value less
costs of disposal is based on observable share price. The VIU calculation uses discounted cash flow projections
based on management\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:
\u00a7 The estimation of future earnings over a 5-year forecast period; and
\u00a7 The terminal value being the extrapolation of earnings into perpetuity applying a long-term growth rate. The
earnings that are used for extrapolation represent the stable long-term financial results and position of TTB, i.e.
a steady state. The terminal value comprises the majority of the total VIU.
Key assumptions used in the VIU calculation as at 31 December 2025
The VIU is determined using a valuation model which is subject to multiple management assumptions. The key
assumptions, i.e. those to which the overall result is most sensitive to, are the following:
\u00a7 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;
\u00a7 Discount rate (cost of equity): 10.17% (2024: 10.96%), based on the capital asset pricing model (CAPM)
calculated for TTB using current market data and expert judgement; and
\u00a7 Terminal growth rate: 2.41% (2024: 2.74%) consistent with current long term government bond yield in
Thailand as a proxy for a risk-free rate.
The model was evaluated for reasonably possible changes to key assumptions in the model. This reflects the
sensitivity of the VIU to each key assumption on its own and it is possible that more than one favourable and/or
unfavourable change may occur at the same time. The selected rates of reasonably possible changes to key
assumptions are based on external analysts\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:
\u00a7 A favourable change of 10% in the cash flows would result in an increase in VIU of EUR 89 million (2024: EUR 57
million), while an unfavourable change of -10% would result in a decrease in VIU of EUR -90 million (2024: EUR
-59 million);\u00a0
\u00a7 A favourable change of 1% in the discount rate would result in an increase in VIU of EUR 159 million (2024: EUR
95 million), while an unfavourable change of -1% would result in a decrease in VIU of EUR -122 million (2024:
EUR -75 million);
\u00a7 A favourable change of 1% in the terminal growth rate would result in an increase in VIU of EUR 118 million
(2024: EUR 68 million), while an unfavourable change of -1% would result in a decrease in VIU of EUR -90
million (2024: EUR -53 million).
Provisions by type
in EUR million
2025
2024
Reorganisation provisions
333
201
Litigation provisions
362
288
Other provisions
78
118
773
606
Loan loss provisions for guarantees and loan commitments
140
146
913
752
For details and changes on loan loss provisioning for guarantees and loan commitments, refer to \u2018Risk
management \u2013 Credit risk\u2019 paragraph 'Loan loss provisioning'.
Changes in provisions
Reorganisation
Litigation
Other provisions
Total
in EUR million
2025
2024
2025
2024
2025
2024
2025
2024
Opening balance as at 1 January
201
231
288
193
118
334
606
758
Additions 1
295
146
128
116
35
26
457
288
Releases 1
-6
-4
-9
-15
-13
-46
-28
-64
Utilised
-146
-163
-45
-31
-58
-196
-248
-390
Exchange rate differences
-5
1
1
-1
-1
-5
Other changes
-5
-10
-2
25
-3
-10
15
Closing balance
333
201
362
288
78
118
773
606
1Additions to provisions and unused amounts released are presented in Note 27 'Other operating expenses' in the Statement of Profit\u00a0
or Loss.
30\u00a0 Potential sale of ING Bank (Eurasia) JSC
On 28 January 2025, ING announced the proposed sale of ING Bank (Eurasia) JSC to Global Development JSC.
Completion of the transaction is subject to various regulatory approvals. This transaction will effectively end ING\u2019s
activities in the Russian market. Under the terms of the agreement, Global Development JSC will acquire all shares
of ING Bank (Eurasia) JSC, taking over all Russian onshore activities and staff. Global Development JSC intends to
continue to serve customers in Russia under a new brand. As of the date of this report and as announced in
September 2025, the buyer has not received all necessary approvals yet. We continue working towards
completing the transaction and our exit from the Russian market. In the meantime, we are in discussion with
regulators on the conflicting regulatory requirements in various jurisdictions with respect to the activities of ING
Bank (Eurasia) JSC.
ING 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. Until sales completion ING continues to direct the
relevant activities of ING Eurasia and, therefore, continues to control and to consolidate it.
Based on 31 December 2025 position, ING estimates a negative impact to the Result on disposal of Group
companies of EUR 0.8 billion post tax. This includes an estimated book loss of EUR 0.5 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. These estimates are subject to change, depending on the position at the closing date.
Given the prevailing uncertainties around substantive regulatory approvals as at 31 December 2025, no book loss
was recognised in 2025 and assets and liabilities of the disposal group were not classified as held for sale.
Furthermore, recycling of the currency translation reserve and the net investment hedge reserve through P&L will
only occur upon deal closing when ownership and control over ING Eurasia is transferred. Such recycling of the
reserves will have no impact on total equity and, hence, ING\u2019s CET1 ratio.
33\u00a0 Fair value of assets and liabilities
a) Valuation m ethods
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 the Global Valuation and Impairment Committee (GV&IC) and its
delegate, based on the valuation and valuation adjustment models approved by Trading and Counterparty Risk
Committee (TCRC), with outcomes monitored under the valuation Risk Appetite Statement established by Group
Financial Risk Committee (GFRC) and TCRC.
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 Group Financial Risk Committee (GFRC) is the highest committee
next to Management Board Banking (MBB) to discuss and approve global policies, methodologies and risk appetite
related to Financial Risk. The Trading and Counterparty Risk Committee (TCRC) 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 Banking Book Parameter Committee (BBPC) discusses the valuation topics
for non-Financial Market and non-Group Treasury Wholesale Banking portfolios. 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\u00a0defers 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. The adjustments in fair value and
the DOP reserve are 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
2025
2024
Opening balance at 1 January
-94
-90
DOP deferred on new transactions during the period
-37
-62
DOP recognised in the statement of profit or loss during the period:
\u2013 of which release
13
27
\u2013 of which amortisation and exchange differences
27
32
Closing balance at 31 December
-91
-94
The following table presents the adjustments in fair value for financial assets and liabilities.
Adjustments in fair value on financial assets and liabilities
in EUR million
2025
2024
Deferred Day One Profit or Loss
-91
-94
Own Credit Adjustments
-57
-17
Bid/Offer
-130
-130
Model Risk
-48
-33
CVA
-88
-123
DVA
43
50
CollVA
-11
-3
FVA
-82
-64
Other Valuation Adjustments
3
2
Total Valuation Adjustments
-462
-412
Own Credit Adjustment
Own issued debt and structured notes that are designated at fair value through profit or loss are adjusted for ING\u2019s
own credit risk by means of DVA.\u00a0
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:
\u00a7 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).
\u00a7 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
2025
2024
2025
2024
2025
2024
2025
2024
Financial Assets
Financial assets at fair value
through profit or loss
- Equity securities
21,395
20,798
4
15
187
141
21,586
20,954
- Debt securities
6,492
7,485
2,793
4,596
1,934
3,505
11,219
15,586
- Derivatives
52
1
25,178
31,792
773
475
26,003
32,268
- Loans and receivables
0
0
65,811
62,168
8,542
6,614
74,352
68,782
27,940
28,285
93,785
98,571
11,435
10,734
133,160
137,590
Financial assets at fair value
through other
comprehensive income
- Equity securities
2,301
2,292
0
0
307
270
2,607
2,562
- Debt securities
49,529
39,859
1,288
2,360
0
0
50,817
42,219
- Loans and receivables
0
0
3,238
1,608
0
0
3,238
1,608
51,829
42,151
4,526
3,967
307
270
56,662
46,389
Financial liabilities
Financial liabilities at fair
value through profit or loss
\u2013\u00a0 Debt securities
899
824
7,289
8,437
15
67
8,204
9,328
\u2013\u00a0 Deposits
0
0
47,751
45,648
0
0
47,751
45,648
\u2013\u00a0 Trading securities
2,534
3,631
11
12
9
10
2,554
3,653
\u2013\u00a0 Derivatives
152
45
21,090
27,528
777
694
22,019
28,267
3,585
4,501
76,142
81,625
802
770
80,529
86,896
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 for financial assets measured at fair value through
profit or loss a EUR 0.3 billion (2024: nil) transfer from Level 1 to Level 2 and a EUR 0.4 billion (2024: EUR 0.8 billion)
transfer from Level 2 to Level 1 within debt securities. For financial liabilities measured at fair value through profit or
loss, EUR 0.2 billion (2024: nil) of trading securities were transferred from Level 2 to Level 1. No other significant
transfers between Level 1 and Level 2 were recorded during the 2025 reporting period (2024: nil).
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 2025 of EUR 11.7 billion (2024: EUR
11.0 billion), an amount of EUR 10.1 billion (86.2%) (2024: EUR 9.6 billion, being 87.2%) 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 (2024: EUR 0.1 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 1.5 billion (2024: EUR 1.3 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 2025 of EUR 0.8 billion (2024: EUR
0.8 billion), an amount of EUR 0.6 billion (72.7%) (2024: EUR 0.6 billion, being 75.7%) 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 liabilities include EUR 0.1 billion (2024: EUR 0.1 billion) which relates to financial
liabilities that are part of structures that are designed to be fully neutral in terms of market risk. As explained
above, the fair value of each of the components of these structures may be sensitive to unobservable inputs, but
the overall sensitivity is by design not significant.
The remaining EUR 0.1 billion (2024: 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
2025
2024
2025
2024
2025
2024
2025
2024
At fair value through profit or loss
Debt securities
1,934
3,504
9
10
Price based
Price (%)
0%
0%
103%
120%
Price (price per share)
201
327
412
520
Present value techniques
Price (%)
n.a.
95.85%
n.a.
100%
Equity securities
187
141
Price based
Price (price per share)
0
0
5,475
5,475
Loans and advances
1,978
1,565
0
0
Price based
Price (%)
0%
0%
109%
107%
Present value techniques
Credit spread (bps)
120
576
709
629
Prepayment rate (%)
2%
2%
2%
100%
(Reverse) repos
6,563
5,050
Present value techniques
Interest rate (%)
n.a.
2%
n.a.
2%
Structured notes
15
67
Price based
Price (%)
96%
93%
103%
104%
Option pricing model
Equity volatility (%)
18%
n.a.
22%
n.a.
Equity/Equity correlation
0.7
0.7
0.8
0.7
Equity/FX correlation
-0.6
n.a.
0.2
n.a.
Dividend yield (%)
0.4%
n.a.
1.9%
n.a.
Present value techniques
Prepayment rate (%)
n.a.
99.59%
n.a.
100.09%
Derivatives
\u2013\u00a0\u00a0Rates
628
413
670
389
Option pricing model
Interest rate volatility (bps)
45
n.a.
91
n.a.
Present value techniques
Reset spread (%)
1%
2%
1%
2%
\u2013\u00a0\u00a0FX
2
6
4
8
Option pricing model
Implied volatility (%)
1.7%
2%
42%
15%
\u2013\u00a0\u00a0Credit
134
39
48
241
Present value techniques
Credit spread (bps)
10
0
88
91
Price based
Price (%)
0%
0%
100%
100%
\u2013\u00a0\u00a0Equity
7
10
46
47
Option pricing model
Equity volatility (%)
13%
7%
75%
81%
Equity/Equity correlation
0.0
0.0
1.0
1.0
Equity/FX correlation
-0.7
-0.6
0.5
0.6
Dividend yield (%)
0%
0%
51%
33%
\u2013\u00a0\u00a0Other
2
6
10
9
Option pricing model
Commodity volatility (%)
20%
13.1%
76%
61%
Com/FX correlation
-0.25
-0.40
-0.25
-0.25
Price based
Price (commodity)
66
68
66
68
At fair value through other comprehensive income
\u2013\u00a0\u00a0Equity
307
270
Present value techniques
Credit spread (bps)
5.15
5.67
5.15
5.76
Interest rate (%)
2.5%
1.5%
2.5%
3.5%
Payout ratio (%)
70%
70%
90%
90%
Price based
Price (%)
n.a.
122%
n.a.
122%
Price (price per share)
126
n.a
126
n.a
Total
11,742
11,005
802
770
1The 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
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
Opening balance as at 1 January
824
848
68
286
5,721
3,499
4,121
3,547
270
938
11,005
9,118
Realised gain/loss\u00a0 recognised in the statement of profit or loss during the period 1
247
-175
63
-38
211
294
-798
-54
-278
28
Revaluation recognised in other comprehensive income during the period 2
8
-3
8
-3
Purchase of assets
953
486
0
198
5,177
4,424
1,208
1,600
182
154
7,520
6,862
Sale of assets
-109
-111
0
-257
-1,765
-1,605
-1,160
-10
-163
-418
-3,197
-2,402
Maturity/settlement
-128
-140
0
-7
-166
-294
-763
-988
0
-20
-1,057
-1,449
Reclassifications
0
0
-1
0
18
0
0
0
10
0
28
0
Transfers into Level 3
316
370
0
0
824
615
0
30
0
0
1,139
1,014
Transfers out of Level 3
-974
-454
-9
-114
-2,389
-1,214
0
-3
0
-384
-3,372
-2,169
Exchange rate differences
-14
0
0
0
-6
5
-33
-2
0
9
-53
12
Changes in the composition of the group and other changes
0
0
0
0
0
-1
0
0
0
-5
0
-6
Closing balance
1,114
824
121
68
7,625
5,721
2,576
4,121
307
270
11,742
11,005
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 280 million (2024: EUR -41 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 2025, transfers out of Level 3 within trading assets relate mainly to securities, as their valuations were no longer
significantly influenced by unobservable inputs. In 2024, transfers out of Level 3 in trading assets primarily involved
derivative instruments, as their valuations were no longer significantly impacted by unobservable inputs.
In 2025 and 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. In 2024, the
transfer out of Level 3 in non-trading derivatives primarily involved derivative instruments, as their valuations were
no longer significantly impacted by unobservable inputs.
In 2025 and 2024, 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 out of Level 3 of financial assets at FVOCI relates to Hold-to-Collect and Sell portfolio
transferred to Level 2 resulting from change in methodology.
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
2025
2024
2025
2024
2025
2024
2025
2024
Opening balance as at 1
January
637
382
67
301
67
47
770
729
Realised gain/loss recognised
in the statement of profit or
loss during the period 1
81
-104
82
-98
-6
-5
157
-206
Additions
205
55
3
190
11
29
219
274
Redemptions
-74
-12
0
-209
0
0
-74
-222
Maturity/settlement
-160
-15
0
-7
-64
-4
-225
-26
Transfers into Level 3
19
364
0
0
19
34
38
399
Transfers out of Level 3
-72
-33
0
-111
-12
-34
-84
-179
Exchange rate differences
-1
0
0
0
0
0
-1
0
Closing balance
636
637
151
67
15
67
802
770
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 158 million
(2024: EUR -206\u00a0million) of unrealised gains and losses recognised in the statement of profit or loss.
In 2025, the transfers out of Level 3 mainly consisted of trading liabilities related to securities transferred out of
Level 3 as a result of the valuation being no longer impacted by significantly unobservable inputs.
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.
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
2025
2024
2025
2024
Equity (equity derivatives, structured notes)
20
21
-12
-20
Interest rates (Rates derivatives, FX derivatives)
1
5
0
0
Credit (Debt securities, Loans, structured notes, credit derivatives)
12
2
-14
-27
Loans and advances
0
0
0
0
33
28
-26
-47
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 value 1
Level 1
Level 2
Level 3
Total fair value
in EUR million
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
Financial Assets
Loans and advances to banks
21,204
21,769
3,053
3,194
14,722
15,614
3,366
2,957
21,141
21,766
Loans and advances to customers
721,779
680,299
18,233
18,296
12,782
18,626
678,392
630,493
709,408
667,415
Securities at amortised cost
53,867
50,273
47,722
42,871
2,381
2,908
2,692
2,523
52,796
48,303
796,850
752,341
21,286
21,490
47,723
42,871
29,885
37,149
684,450
635,973
783,344
737,483
Financial liabilities
Deposits from banks
18,521
16,722
5,401
4,347
9,162
8,208
3,745
3,943
18,308
16,498
Customer deposits
724,707
699,725
621,172
582,511
85,801
69,790
17,433
46,984
724,406
699,285
Debt securities in issue
103,116
94,459
36,782
33,019
62,567
59,141
3,857
2,000
103,207
94,161
Senior non-preferred debt
48,090
49,393
49,155
50,230
49,155
50,230
Subordinated loans
18,100
17,879
18,722
18,357
18,722
18,357
912,534
878,178
626,573
586,857
36,782
33,019
225,408
205,726
25,035
52,927
913,798
878,530
1In 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, excluding the negative macro fair value hedge adjustment.
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.
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
There is an embedded value in our on-demand deposits. However, for the purpose of this disclosure, and in
accordance with IFRS, the fair value of deposits with an immediate on demand feature approximates the carrying
amount, excluding the negative macro fair value hedge adjustment.
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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-652": { "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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-653": { "value": "Significant judgements and critical accounting estimates and assumptions: \u00a7 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 \u00a7 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 \u00a7 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. \u00a7 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. \u00a7 Reference is made to Note 33 '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:\u00a7 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. \u00a7 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. \u00a7 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 constitutes a significant judgement. Analysis of the sensitivity associated with the assessment of a significant increase in credit risk is presented in the \u2018Risk Management\u2019 section of the Annual Report. \u00a7 Judgement is exercised in management\u2019s evaluation of whether there is objective evidence that exposures are credit-impaired. \u00a7 To reflect the risks that are not properly captured by the ECL models (including climate risk), a number of management adjustments to the model-based ECL were necessary as at 31 December 2025, which required significant judgement. Reference is made to the \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:Potential impairment and reversal assessmentIdentification 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 \u2018Investment in associates and joint ventures\u2019. Determination of significant influence over associatesIt is presumed that an entity has significant influence when it holds 20% or more of the voting power of the investee. Conversely, it is presumed that an entity does not have significant influence when voting power is less than 20% in the investee. Depending on the facts and circumstances, the presumption is rebutted when ING can clearly demonstrate whether or not it has power to participate in the investee\u2019s financial and operating policy decisions. The consideration of all relevant factors requires judgement, including, amongst others, the investment purpose, investee\u2019s governance structure and legal regime, ability to obtain meaningful board representation and participation in policymaking decisions. Refer to Note 5 'Financial assets at fair value through other comprehensive income' regarding ING\u2019s accounting for its investment in Van Lanschot Kempen.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 40 '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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-655": { "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). Interest Rate Benchmark Reform Phase 1 and Phase 2 amendments to IFRS provide
specific reliefs that allow hedge accounting relationships to continue when the benchmark rate reform is ongoing.
Phase 1 reliefs remained relevant for ING Bank as at 31 December 2025 for WIBOR hedges, and will cease to apply
once uncertainty about the timing and amount of the benchmark rate-based cash flows is resolved, or when the
hedging instrument is discontinued. ING\u2019s policy is to cease applying Phase 1 reliefs when the relevant contract
(hedging instrument or hedged item) is modified. When this occurs, Phase 2 reliefs become\u00a0 applicable still
allowing hedge accounting relationships to continue. Refer to note \u2018Risk management/Impact of the benchmark
rate reform\u2019 for further details on WIBOR transition and ING\u2019s exposures related to WIBOR that have yet to
transition.
Non-trading derivatives that do not qualify for hedge accounting
Derivative instruments that are used by ING 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-654": { "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). Interest Rate Benchmark Reform Phase 1 and Phase 2 amendments to IFRS provide
specific reliefs that allow hedge accounting relationships to continue when the benchmark rate reform is ongoing.
Phase 1 reliefs remained relevant for ING Bank as at 31 December 2025 for WIBOR hedges, and will cease to apply
once uncertainty about the timing and amount of the benchmark rate-based cash flows is resolved, or when the
hedging instrument is discontinued. ING\u2019s policy is to cease applying Phase 1 reliefs when the relevant contract
(hedging instrument or hedged item) is modified. When this occurs, Phase 2 reliefs become\u00a0 applicable still
allowing hedge accounting relationships to continue. Refer to note \u2018Risk management/Impact of the benchmark
rate reform\u2019 for further details on WIBOR transition and ING\u2019s exposures related to WIBOR that have yet to
transition.
Non-trading derivatives that do not qualify for hedge accounting
Derivative instruments that are used by ING 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-656": { "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). Interest Rate Benchmark Reform Phase 1 and Phase 2 amendments to IFRS provide
specific reliefs that allow hedge accounting relationships to continue when the benchmark rate reform is ongoing.
Phase 1 reliefs remained relevant for ING Bank as at 31 December 2025 for WIBOR hedges, and will cease to apply
once uncertainty about the timing and amount of the benchmark rate-based cash flows is resolved, or when the
hedging instrument is discontinued. ING\u2019s policy is to cease applying Phase 1 reliefs when the relevant contract
(hedging instrument or hedged item) is modified. When this occurs, Phase 2 reliefs become\u00a0 applicable still
allowing hedge accounting relationships to continue. Refer to note \u2018Risk management/Impact of the benchmark
rate reform\u2019 for further details on WIBOR transition and ING\u2019s exposures related to WIBOR that have yet to
transition.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForHedgingExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-657": { "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 38 \u2018Offsetting financial assets and liabilities\u2019.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForOffsettingOfFinancialInstrumentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-658": { "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:
\u00a7 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);
\u00a7 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
\u00a7 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 initial recognition.
Write-off and debt forgiveness
Loans and debt securities are written off (either partially or in full) when there is no reasonable expectation of
recovery and/or collectability of amounts due. The following events can lead to a write-off:
\u00a7 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);
\u00a7 In a bankruptcy liquidation scenario;
\u00a7 After divestment or sale of a credit facility at a discount; and
\u00a7 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:
\u00a7 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.
\u00a7 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.
\u00a7 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 constitutes a significant judgement. Analysis of the sensitivity associated
with the assessment of a significant increase in credit risk is presented in the \u2018Risk Management\u2019 section
of the Annual Report.
\u00a7 Judgement is exercised in management\u2019s evaluation of whether there is objective evidence that
exposures are credit-impaired.
\u00a7 To reflect the risks that are not properly captured by the ECL models (including climate risk), a number of
management adjustments to the model-based ECL were necessary as at 31 December 2025, which
required significant judgement. Reference is made to the \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. In case
of an indication of potential impairment, an impairment loss is recognised when the carrying amount of the
investment exceeds its recoverable amount. Goodwill on acquisitions of interests in associates and joint ventures is
not tested separately for impairment, but is assessed as part of the carrying amount of the investment. An
impairment loss is subsequently reversed if there is indication of a reversal and there is a change in the estimates
used to determine the recoverable amount. In case of an indication of a potential reversal of impairment, an
impairment loss is reversed to the extent that the recoverable amount exceeds its carrying amount, but cannot
exceed the original impairment loss.
Significant judgements and critical accounting estimates and assumptions:
Potential impairment and reversal assessment
Identification of impairment indicators as well as indicators of potential reversal of previous impairments of
ING 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
\u2018Investment in associates and joint ventures\u2019.
Determination of significant influence over associates
It is presumed that an entity has significant influence when it holds 20% or more of the voting power of the
investee. Conversely, it is presumed that an entity does not have significant influence when voting power is
less than 20% in the investee. Depending on the facts and circumstances, the presumption is rebutted
when ING can clearly demonstrate whether or not it has power to participate in the investee\u2019s financial and
operating policy decisions. The consideration of all relevant factors requires judgement, including, amongst
others, the investment purpose, investee\u2019s governance structure and legal regime, ability to obtain
meaningful board representation and participation in policymaking decisions. Refer to Note 5 'Financial
assets at fair value through other comprehensive income' regarding ING\u2019s accounting for its investment in
Van Lanschot Kempen.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForImpairmentOfFinancialAssetsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-659": { "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 in Note 39 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-661": { "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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-660": { "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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-662": { "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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-663": { "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 Executive Board of ING Bank and the Management Board
Banking (together they make up the Chief Operating Decision Maker (CODM)) who decide which resources to
allocate to the segment and assess its performance.
The CODM reviews and assesses ING Bank's performance primarily by line of business. As a result, ING identified
five operating segments which are also disclosed as reportable segments.
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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-664": { "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 then.\u00a0 IAS 29 continued to be relevant for ING\u2019s operations in
T\u00fcrkiye in 2023, 2024 and 2025. 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 2025 was 3,513.87, at 31
December 2024 was 2,684.55 and at 31 December 2023 it was 1,859.38 (movement 2025: 30.89%; 2024: 44.38%,
2023: 64.77%). The effect of such restatement for inflation in the current period of the statement of
comprehensive income and the balance sheet has been recognised in the statement of profit or loss within \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 2025. For the statement of comprehensive income this is in contrast with the usual translation
procedures where items of comprehensive income are translated at the exchange rate at the date of transaction.
Furthermore, ING 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-665": { "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:
\u00a7 Assets and liabilities are translated at the closing rate at the date of the statement of financial position;\u00a0
\u00a7 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
\u00a7 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-666": { "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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-669": { "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:
\u00a7 Representation on the board of directors;\u00a0
\u00a7 Participation in the policymaking process; and\u00a0
\u00a7 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. In case
of an indication of potential impairment, an impairment loss is recognised when the carrying amount of the
investment exceeds its recoverable amount. Goodwill on acquisitions of interests in associates and joint ventures is
not tested separately for impairment, but is assessed as part of the carrying amount of the investment. An
impairment loss is subsequently reversed if there is indication of a reversal and there is a change in the estimates
used to determine the recoverable amount. In case of an indication of a potential reversal of impairment, an
impairment loss is reversed to the extent that the recoverable amount exceeds its carrying amount, but cannot
exceed the original impairment loss.
The reporting dates of certain associates and joint ventures can differ from the reporting date of the Group, but by
no more than three months.
Significant judgements and critical accounting estimates and assumptions:
Potential impairment and reversal assessment
Identification of impairment indicators as well as indicators of potential reversal of previous impairments of
ING 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
\u2018Investment in associates and joint ventures\u2019.
Determination of significant influence over associates
It is presumed that an entity has significant influence when it holds 20% or more of the voting power of the
investee. Conversely, it is presumed that an entity does not have significant influence when voting power is
less than 20% in the investee. Depending on the facts and circumstances, the presumption is rebutted
when ING can clearly demonstrate whether or not it has power to participate in the investee\u2019s financial and
operating policy decisions. The consideration of all relevant factors requires judgement, including, amongst
others, the investment purpose, investee\u2019s governance structure and legal regime, ability to obtain
meaningful board representation and participation in policymaking decisions. Refer to Note 5 'Financial
assets at fair value through other comprehensive income' regarding ING\u2019s accounting for its investment in
Van Lanschot Kempen.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForInvestmentInAssociatesAndJointVenturesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-668": { "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:
\u00a7 Representation on the board of directors;\u00a0
\u00a7 Participation in the policymaking process; and\u00a0
\u00a7 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. In case
of an indication of potential impairment, an impairment loss is recognised when the carrying amount of the
investment exceeds its recoverable amount. Goodwill on acquisitions of interests in associates and joint ventures is
not tested separately for impairment, but is assessed as part of the carrying amount of the investment. An
impairment loss is subsequently reversed if there is indication of a reversal and there is a change in the estimates
used to determine the recoverable amount. In case of an indication of a potential reversal of impairment, an
impairment loss is reversed to the extent that the recoverable amount exceeds its carrying amount, but cannot
exceed the original impairment loss.
The reporting dates of certain associates and joint ventures can differ from the reporting date of the Group, but by
no more than three months.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForInvestmentsInJointVentures", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-667": { "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:
\u00a7 Representation on the board of directors;\u00a0
\u00a7 Participation in the policymaking process; and\u00a0
\u00a7 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. In case
of an indication of potential impairment, an impairment loss is recognised when the carrying amount of the
investment exceeds its recoverable amount. Goodwill on acquisitions of interests in associates and joint ventures is
not tested separately for impairment, but is assessed as part of the carrying amount of the investment. An
impairment loss is subsequently reversed if there is indication of a reversal and there is a change in the estimates
used to determine the recoverable amount. In case of an indication of a potential reversal of impairment, an
impairment loss is reversed to the extent that the recoverable amount exceeds its carrying amount, but cannot
exceed the original impairment loss.
The reporting dates of certain associates and joint ventures can differ from the reporting date of the Group, but by
no more than three months.
Significant judgements and critical accounting estimates and assumptions:
Potential impairment and reversal assessment
Identification of impairment indicators as well as indicators of potential reversal of previous impairments of
ING 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
\u2018Investment in associates and joint ventures\u2019.
Determination of significant influence over associates
It is presumed that an entity has significant influence when it holds 20% or more of the voting power of the
investee. Conversely, it is presumed that an entity does not have significant influence when voting power is
less than 20% in the investee. Depending on the facts and circumstances, the presumption is rebutted
when ING can clearly demonstrate whether or not it has power to participate in the investee\u2019s financial and
operating policy decisions. The consideration of all relevant factors requires judgement, including, amongst
others, the investment purpose, investee\u2019s governance structure and legal regime, ability to obtain
meaningful board representation and participation in policymaking decisions. Refer to Note 5 'Financial
assets at fair value through other comprehensive income' regarding ING\u2019s accounting for its investment in
Van Lanschot Kempen.
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForInvestmentInAssociates", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-670": { "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. In case
of an indication of potential impairment, an impairment loss is recognised when the carrying amount of the
investment exceeds its recoverable amount. Goodwill on acquisitions of interests in associates and joint ventures is
not tested separately for impairment, but is assessed as part of the carrying amount of the investment. An
impairment loss is subsequently reversed if there is indication of a reversal and there is a change in the estimates
used to determine the recoverable amount. In case of an indication of a potential reversal of impairment, an
impairment loss is reversed to the extent that the recoverable amount exceeds its carrying amount, but cannot
exceed the original impairment loss.
Significant judgements and critical accounting estimates and assumptions:
Potential impairment and reversal assessment
Identification of impairment indicators as well as indicators of potential reversal of previous impairments of
ING 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
\u2018Investment in associates and joint ventures\u2019.
Determination of significant influence over associates
It is presumed that an entity has significant influence when it holds 20% or more of the voting power of the
investee. Conversely, it is presumed that an entity does not have significant influence when voting power is
less than 20% in the investee. Depending on the facts and circumstances, the presumption is rebutted
when ING can clearly demonstrate whether or not it has power to participate in the investee\u2019s financial and
operating policy decisions. The consideration of all relevant factors requires judgement, including, amongst
others, the investment purpose, investee\u2019s governance structure and legal regime, ability to obtain
meaningful board representation and participation in policymaking decisions. Refer to Note 5 'Financial
assets at fair value through other comprehensive income' regarding ING\u2019s accounting for its investment in
Van Lanschot Kempen.
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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-672": { "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:
\u00a7 Fixed payments (including in-substance fixed payments), less any lease incentives receivable;
\u00a7 Variable lease payments that are based on an index or a rate;
\u00a7 Amounts expected to be payable by the lessee under residual value guarantees;
\u00a7 The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and
\u00a7 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-671": { "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:
\u00a7 Fixed payments (including in-substance fixed payments), less any lease incentives receivable;
\u00a7 Variable lease payments that are based on an index or a rate;
\u00a7 Amounts expected to be payable by the lessee under residual value guarantees;
\u00a7 The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and
\u00a7 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-673": { "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:
\u00a7 Fixed payments (including in-substance fixed payments), less any lease incentives receivable;
\u00a7 Variable lease payments that are based on an index or a rate;
\u00a7 Amounts expected to be payable by the lessee under residual value guarantees;
\u00a7 The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and
\u00a7 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-674": { "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.
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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-676": { "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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-675": { "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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-677": { "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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-679": { "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, 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 2025 amounts to EUR 5.8 million (2024: EUR 9.5 million).
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForIncomeTaxExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-678": { "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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-680": { "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 40 '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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-681": { "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.", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForContingentLiabilitiesAndContingentAssetsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-682": { "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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-683": { "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:
\u00a7 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
\u00a7 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:
\u00a7 Service cost which is recognised as staff costs in the statement of profit or loss;\u00a0
\u00a7 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;
\u00a7 Remeasurements which are recognised in Other comprehensive income (equity) and not recycled to the
Statement of profit or loss;
\u00a7 Any past service cost relating to a plan amendment is recognised in profit or loss in the period of the plan
amendment; and
\u00a7 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-684": { "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 are 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-685": { "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 are 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-686": { "value": "
Interest results on instruments classified at Amortised Cost, assets measured at FVOCI and derivatives in a formal
hedge accounting relationship are 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-687": { "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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-688": { "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 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-689": { "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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-690": { "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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-692": { "value": "
2\u00a0 Cash and balances with central banks
Cash and balances with central banks
in EUR million
2025
2024
Amounts held at central banks 1
51,133\u00a0
68,708\u00a0
Cash and bank balances
1,756\u00a0
1,645\u00a0
52,889
70,353
1Amounts held at central banks include an amount of EUR -17 million (2024: EUR -14 million) of Loan loss provisions.
Amounts held at central banks reflect on-demand balances. The movement reflects ING\u2019s active liquidity
management.
Reference is made to Note 37 '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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-691": { "value": "
2\u00a0 Cash and balances with central banks
Cash and balances with central banks
in EUR million
2025
2024
Amounts held at central banks 1
51,133\u00a0
68,708\u00a0
Cash and bank balances
1,756\u00a0
1,645\u00a0
52,889
70,353
1Amounts held at central banks include an amount of EUR -17 million (2024: EUR -14 million) of Loan loss provisions.
Amounts held at central banks reflect on-demand balances. The movement reflects ING\u2019s active liquidity
management.
Reference is made to Note 37 '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
2025
2024
2025
2024
2025
2024
Loans and advances to banks1
12,362
14,343
8,841
7,426
21,204
21,769
1Loans and advances to banks include EUR -18\u00a0 million (2024: EUR -22\u00a0 million) of Loan loss provisions.
Loans and advances include balances of reverse repurchase transactions. For more information, refer to Note 4
'Financial assets at fair value through profit or loss' . Furthermore, it includes on-demand and term loans, and cash
collateral transactions. Reference is made to Note 7 'Loans and advances to customers' for information on finance
lease receivables included in Loans and advances to banks.
As at 31\u00a0December 2025 and at 31 December 2024, 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
2025
2024
Trading assets
55,734
72,906
Non-trading derivatives
1,657
2,463
Designated at fair value through profit or loss
3,448
5,740
Mandatorily measured at fair value through profit or loss
72,322
56,481
133,160
137,590
(Reverse) repurchase transactions
Financial assets at fair value through profit or loss include securities lending and sales and repurchase transactions
with securities. At ING, these types of transactions are recognised in several lines in the statement of financial
position depending on business model assessment and counterparty. Netting is applicable to repurchase
agreements that are governed by an established Global Master Repurchase Agreement (GMRA) when ING has the
intention to settle net. This netting is restricted to transactions involving the same currency and maturity date,
and must occur within the same legal entity. Reference is made to Note 38 '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. 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.\u00a0
Reference is made to Note 37 '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
2025
2024
Reverse repurchase transactions
Loans and advances to banks
6,836
10,777
Loans and advances to customers
3,866
3,471
Trading assets, loans and receivables
1,574
12,033
Loans and receivables mandatorily measured at fair value through profit or loss
68,469
53,393
80,746
79,675
Repurchase transactions
Deposits from banks
330
33
Customer deposits
182
1
Trading liabilities, funds on deposit
31
5,269
Funds entrusted designated and measured at fair value through profit or loss
46,211
38,420
46,755
43,723
Trading assets
Trading assets by type
in EUR million
2025
2024
Equity securities
21,276
20,726
Debt securities
8,120
10,080
Derivatives
24,346
29,805
Loans and receivables
1,991
12,295
55,734
72,906
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
2025
2024
Derivatives used in
-\u00a0 fair value hedges
578
617
-\u00a0 cash flow hedges
459
158
-\u00a0 hedges of net investments in foreign operations
68
82
Other non-trading derivatives
550
1,606
1,657
2,463
Reference is made to Note 34 'Derivatives and hedge accounting' for information on derivatives designated in
hedge accounting.
Other non-trading derivatives mainly includes interest-rate swaps, foreign exchange swaps, and cross currency
swaps for which no hedge accounting is applied.
Designated at fair value through profit or loss
Designated at fair value through profit or loss by type
in EUR million
2025
2024
Debt securities
2,330
4,718
Loans and receivables
1,118
1,022
3,448
5,740
\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 3,448 million (2024: EUR 5,740 million). In 2025, the change in fair value of these loans
and debt securities amounts to EUR -177\u00a0million (2024: EUR 5\u00a0million).
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
2,454 million (2024: EUR 3,797 million). The cumulative change in fair value attributable to changes in credit risk for
the financial asset economically hedged is EUR 85 million (2024: EUR 173 million) and the change for the current
year is EUR -88\u00a0million (2024: EUR 24\u00a0million). The cumulative change in fair value attributable to changes in credit
risk for the financial assets non-economically hedged with credit derivatives is EUR 513\u00a0million (2024: EUR
489\u00a0million) and the change for the current year is EUR 23\u00a0million.
The notional value of the related credit derivatives is EUR 2,486 million (2024: EUR 3,807 million). The cumulative
change in fair value of the credit derivatives since the financial assets were first designated, amounts to EUR
-85\u00a0million (2024: EUR -214\u00a0million) and the change for the current year is EUR 128\u00a0million (2024: EUR -95\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
2025
2024
Equity securities
310
228
Debt securities
769
789
Loans and receivables
71,243
55,464
72,322
56,481
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
2025
2024
Equity securities
2,607
2,562
Debt securities 1
50,817
42,219
Loans and advances 1
3,238
1,608
56,662
46,389
1Debt securities includes an amount of EUR -15 million (2024: EUR -12 million) and Loans and advances includes EUR -6 million (2024: EUR -7 million) of
Loan loss provisions.
Exposure to equity securities
Equity securities designated as at fair value through other comprehensive income
Carrying
value
Carrying
value 1
Dividend
income
Dividend
income 1
in EUR million
2025
2024
2025
2024
Investment in Bank of Beijing
1,838
2,241
98
101
Investment in Van Lanschot Kempen
462
51
12
2
Other Investments
307
270
6
14
2,607
2,562
116
117
The table has been updated to present the increased stake in Van Lanschot Kempen separately from other investments.
As at 31\u00a0December 2025 ING holds 13% (2024: 13%) of the shares of Bank of Beijing, a bank listed on the Shanghai
Stock Exchange. The stake in Bank of Beijing is part of the Corporate Line. As per regulatory requirements set by
the China Banking and Insurance Regulatory Commission, ING, as a shareholder holding more than 5% of the
shares, is required to supply additional capital when necessary. No request for additional capital was received in
2025 (2024: nil).
In 2025 ING increased its ownership in Van Lanschot Kempen by acquiring an additional 17.6% stake, raising its
total interest based on the issued share capital from 2.7% to 20.3%. Despite ING holding over 20% voting rights in
VLK (a presumption of significant influence in IFRS), this presumption is rebutted given that ING holds rights similar
to other ordinary shareholders where voting does not include financial and operating policy decisions and ING
does not have the rights or ability to obtain board representation. Therefore, the increased investment in VLK is
designated at fair value through other comprehensive income consistent with ING\u2019s passive investment purpose.
The stake is part of the Corporate Line.
Changes in fair value through other comprehensive income
The following table presents changes in financial assets at fair value through other comprehensive income:
Changes in fair value through other comprehensive income financial assets
FVOCI equity
securities
FVOCI debt
instruments 1
Total
in EUR million
2025
2024
2025
2024
2025
2024
Opening balance as at 1 January
2,562
1,885
43,827
39,231
46,389
41,116
Additions
395
11
42,899
21,080
43,294
21,091
Amortisation
75
77
75
77
Transfers
10
1
10
1
Changes in unrealised revaluations 2
-156
605
322
-96
166
509
Impairments
-10
2
-10
2
Reversals of impairments
7
-7
7
-7
Disposals and redemptions
-7
-1
-33,124
-16,906
-33,131
-16,907
Exchange rate differences
-178
62
-1,088
443
-1,267
506
Other changes
-19
1,148
1,128
Closing balance
2,607
2,562
54,055
43,827
56,662
46,389
1Fair value through other comprehensive income debt instruments includes both debt securities and loans and advances.
2Changes in unrealised revaluations of FVOCI debt instruments include changes on hedged items which are recognised in the statement of profit or loss.
Reference is made to Note 20 'Equity' for details on the changes in the revaluation reserve.
FVOCI equity securities
Exchange rate differences of EUR -178\u00a0million (31 December 2024: EUR 62\u00a0million) are mainly related to the stake
in Bank of Beijing following the depreciation of CNY versus EUR. In 2025, changes in unrealised revaluations of
equity securities are mainly related to a revaluation of the stake in Bank of Beijing of EUR -225\u00a0million (31
December 2024: EUR 590\u00a0million) following a change in the share price.
FVOCI debt instruments
In 2025, changes in interest rates and portfolio composition resulted in changes in unrealised revaluations of debt
securities of EUR 322\u00a0million (31 December 2024: EUR -96\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
2025
2024
Debt securities at fair value through other comprehensive income
50,817
42,219
Debt securities at amortised cost
53,867
50,273
Total debt securities at fair value through other comprehensive income and amortised cost
104,684
92,493
Trading assets
8,120
10,080
Debt securities designated and measured at fair value through profit or loss
2,330
4,718
Debt securities mandatorily measured at fair value through profit or loss
769
789
Total debt securities at fair value through profit or loss
11,219
15,586
115,903
108,078
ING Bank\u2019s total exposure to debt securities (excluding debt securities held in the trading portfolio) of EUR 107,783
million ( 31\u00a0December 2024: EUR 97,999 million ) is specified as follows:
Debt securities by type of exposure
Debt Securities at
FVPL 1
Debt Securities at
FVOCI
Debt Securities at
AC
Total
in EUR million
2025
2024
2025
2024
2025
2024
2025
2024
Government bonds
288
289
32,578
24,757
25,297
22,734
58,163
47,780
Central bank bonds
376
444
2,541
2,900
2,917
3,344
Sub-sovereign, Supranationals
and Agencies
413
1,027
13,788
11,513
16,744
15,445
30,945
27,985
Covered bonds
3,750
4,108
5,362
5,683
9,111
9,791
Corporate bonds
89
848
109
79
50
106
248
1,033
Financial institutions' bonds
1,176
2,141
28
980
96
139
1,300
3,261
ABS portfolio
757
757
578
794
3,790
3,281
5,125
4,832
3,099
5,506
50,832
42,231
53,879
50,288
107,809
98,026
Loan loss provisions
-15
-12
-11
-15
-26
-27
Debt securities portfolio
3,099
5,506
50,817
42,219
53,867
50,273
107,783
97,999
1Debt 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
2025
2024
2025
2024
2025
2024
Loans and advances to public authorities
3,452
1,888
19,583
16,773
23,034
18,661
Residential mortgages
126,772
117,223
242,297
227,992
369,069
345,216
Other personal lending
5,033
5,007
34,690
31,789
39,723
36,797
Corporate Lending
68,866
66,987
226,981
218,473
295,847
285,459
204,122
191,105
523,551
495,027
727,673
686,132
Loan loss provisions
-836
-811
-5,058
-5,023
-5,894
-5,833
203,286
190,295
518,493
490,004
721,779
680,299
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 2025 EUR 721,543 million (2024 : EUR 680,085 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
2025
2024
Maturities of gross investment in finance lease receivables
-\u00a0 within 1 year
4,121
3,962
-\u00a0 between 1-2 years
3,040
2,961
-\u00a0 between 2-3 years
2,408
2,283
-\u00a0 between 3-4 years
1,563
1,577
-\u00a0 between 4-5 years
935
902
-\u00a0 more than 5 years
1,609
1,555
13,677
13,240
Unearned future finance income on finance leases
-1,122
-1,145
Net investment in finance leases
12,554
12,095
Included in Loans and advances to banks
3
5
Included in Loans and advances to customers
12,551
12,091
12,554
12,095
1The total loan loss provision for finance lease receivables is EUR 191 million (2024: EUR\u00a0 193 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 2025 on finance lease receivables
amounts to EUR 513 million (2024: EUR 522 million).
12\u00a0 Deposits from banks
Deposits from banks by type
Netherlands
Rest of the world
Total
in EUR million
2025
2024
2025
2024
2025
2024
Non-interest bearing
2
4
115
166
117
170
Interest bearing
6,443
5,845
11,962
10,707
18,404
16,553
6,444
5,849
12,077
10,873
18,521
16,722
Deposits from banks includes non-subordinated deposits and, to a lesser extent, repurchase transactions. For more
information on reverse repurchase transactions, refer to Note 4 'Financial assets at fair value through profit or loss' .
13\u00a0 Customer deposits
Customer deposits
in EUR million
2025
2024
Current accounts / Overnight deposits
239,106
227,951
Savings accounts
382,066
354,560
Time deposits
101,767
115,636
Other
1,768
1,579
724,707
699,725
Current accounts / Overnight deposits, Savings accounts and Time deposits include balances with individuals,
respectively EUR 113,580\u00a0million (2024: EUR 107,068\u00a0million ), EUR 347,234\u00a0million (2024: EUR 324,134\u00a0million) and
EUR 50,033\u00a0million (2024: EUR 56,599\u00a0million ).
Customer deposits by type
Netherlands
Rest of the world
Total
in EUR million
2025
2024
2025
2024
2025
2024
Non-interest bearing
3
26
30,036
27,142
30,039
27,168
Interest bearing 1
249,480
245,375
445,187
427,182
694,667
672,557
249,484
245,401
475,223
454,324
724,707
699,725
1Interest bearing includes current accounts which are not remunerated. However, ING holds the contractual right to revise the rates.
\u00a0 \u00a0 \u00a0
14\u00a0 Financial liabilities at fair value through profit or loss
Financial liabilities at fair value through profit or loss
in EUR million
2025
2024
Trading liabilities
23,427
35,255
Non-trading derivatives
1,338
2,101
Designated at fair value through profit or loss
55,764
49,539
80,529
86,896
Trading liabilities
Trading liabilities by type
in EUR million
2025
2024
Equity securities
682
467
Debt securities
1,872
3,185
Funds on deposit
191
5,437
Derivatives
20,681
26,166
23,427
35,255
Non-trading derivatives
Non-trading derivatives by type
in EUR million
2025
2024
Derivatives used in:
-\u00a0 fair value hedges
54
79
-\u00a0 cash flow hedges
254
573
-\u00a0 hedges of net investments in foreign operations
74
117
Other non-trading derivatives
957
1,332
1,338
2,101
Reference is made to Note 34 '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
2025
2024
Debt securities
8,202
9,326
Funds entrusted
47,431
40,092
Subordinated liabilities
131
122
55,764
49,539
As at 31\u00a0December 2025, the change in the fair value of financial liabilities designated at fair value through profit
or loss attributable to changes in credit risk is EUR 57 million on a cumulative basis (2024: EUR\u00a0 17 million ). This
change has been determined as the amount of change in fair value of the financial liability that is not attributable
to changes in market conditions that gave rise to market risk (i.e. mainly interest-rate risk based on yield curves).
The amount that ING 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
9,574 million ( 2024: EUR\u00a011,376 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 relate to debentures and other issued debt securities with either fixed interest rates or
interest rates based on floating interest rate levels, such as certificates of deposit and accepted bills issued by ING
Bank, except for subordinated items. Debt securities in issue do not include debt securities presented as Financial
liabilities at fair value through profit or loss. ING 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
2025
2024
Fixed rate debt securities
Within 1 year
30,850
26,358
More than 1 year but less than 2 years
4,401
5,718
More than 2 years but less than 3 years
6,851
4,429
More than 3 years but less than 4 years
6,081
5,907
More than 4 years but less than 5 years
5,463
6,105
More than 5 years
12,393
12,335
Total fixed rate debt securities
66,039
60,851
Floating rate debt securities
Within 1 year
28,774
26,262
More than 1 year but less than 2 years
1,004
2,343
More than 2 years but less than 3 years
830
1,080
More than 3 years but less than 4 years
1,056
117
More than 4 years but less than 5 years
913
902
More than 5 years
4,501
2,903
Total floating rate debt securities
37,077
33,607
Total debt securities
103,116
94,459
Reference is made to the Consolidated statement of cash flows for more information on issuances, redemptions
and non-cash movements.
18\u00a0 Senior non-preferred debt
Senior non-preferred debt
In EUR million
2025
2024
Senior non-preferred debt
48,090
49,393
48,090
49,393
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
2025
2024
Subordinated loans
18,100
17,879
18,100
17,879
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 18,299 million (2024: EUR 18,403 million) have been placed with ING Bank N.V.
by ING Groep N.V.
In 2025 ING Groep N.V. issued EUR 1.25 billion 4.13% Fixed Rate Subordinated Green Tier 2 Notes in May, EUR 1.25
billion 3.88% Fixed Rate Subordinated Tier 2 Notes in August and USD 1.50 billion 7.00% Perpetual AT1 Contingent
Convertible Capital Securities in September.
In 2025 ING Groep N.V. redeemed EUR 750 million 2.00% Fixed Subordinated Tier 2 notes in March, USD 1.25 billion
6.50% Perpetual AT1 Contingent Convertible Capital Securities in April and EUR 1 billion 1.00% Fixed Subordinated
Tier 2 notes in November.
Reference is made to the Consolidated statement of cash flows for further information on issuances and
redemptions.
33\u00a0 Fair value of assets and liabilities
a) Valuation m ethods
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 the Global Valuation and Impairment Committee (GV&IC) and its
delegate, based on the valuation and valuation adjustment models approved by Trading and Counterparty Risk
Committee (TCRC), with outcomes monitored under the valuation Risk Appetite Statement established by Group
Financial Risk Committee (GFRC) and TCRC.
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 Group Financial Risk Committee (GFRC) is the highest committee
next to Management Board Banking (MBB) to discuss and approve global policies, methodologies and risk appetite
related to Financial Risk. The Trading and Counterparty Risk Committee (TCRC) 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 Banking Book Parameter Committee (BBPC) discusses the valuation topics
for non-Financial Market and non-Group Treasury Wholesale Banking portfolios. 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\u00a0defers 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. The adjustments in fair value and
the DOP reserve are 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
2025
2024
Opening balance at 1 January
-94
-90
DOP deferred on new transactions during the period
-37
-62
DOP recognised in the statement of profit or loss during the period:
\u2013 of which release
13
27
\u2013 of which amortisation and exchange differences
27
32
Closing balance at 31 December
-91
-94
The following table presents the adjustments in fair value for financial assets and liabilities.
Adjustments in fair value on financial assets and liabilities
in EUR million
2025
2024
Deferred Day One Profit or Loss
-91
-94
Own Credit Adjustments
-57
-17
Bid/Offer
-130
-130
Model Risk
-48
-33
CVA
-88
-123
DVA
43
50
CollVA
-11
-3
FVA
-82
-64
Other Valuation Adjustments
3
2
Total Valuation Adjustments
-462
-412
Own Credit Adjustment
Own issued debt and structured notes that are designated at fair value through profit or loss are adjusted for ING\u2019s
own credit risk by means of DVA.\u00a0
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:
\u00a7 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).
\u00a7 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
2025
2024
2025
2024
2025
2024
2025
2024
Financial Assets
Financial assets at fair value
through profit or loss
- Equity securities
21,395
20,798
4
15
187
141
21,586
20,954
- Debt securities
6,492
7,485
2,793
4,596
1,934
3,505
11,219
15,586
- Derivatives
52
1
25,178
31,792
773
475
26,003
32,268
- Loans and receivables
0
0
65,811
62,168
8,542
6,614
74,352
68,782
27,940
28,285
93,785
98,571
11,435
10,734
133,160
137,590
Financial assets at fair value
through other
comprehensive income
- Equity securities
2,301
2,292
0
0
307
270
2,607
2,562
- Debt securities
49,529
39,859
1,288
2,360
0
0
50,817
42,219
- Loans and receivables
0
0
3,238
1,608
0
0
3,238
1,608
51,829
42,151
4,526
3,967
307
270
56,662
46,389
Financial liabilities
Financial liabilities at fair
value through profit or loss
\u2013\u00a0 Debt securities
899
824
7,289
8,437
15
67
8,204
9,328
\u2013\u00a0 Deposits
0
0
47,751
45,648
0
0
47,751
45,648
\u2013\u00a0 Trading securities
2,534
3,631
11
12
9
10
2,554
3,653
\u2013\u00a0 Derivatives
152
45
21,090
27,528
777
694
22,019
28,267
3,585
4,501
76,142
81,625
802
770
80,529
86,896
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 for financial assets measured at fair value through
profit or loss a EUR 0.3 billion (2024: nil) transfer from Level 1 to Level 2 and a EUR 0.4 billion (2024: EUR 0.8 billion)
transfer from Level 2 to Level 1 within debt securities. For financial liabilities measured at fair value through profit or
loss, EUR 0.2 billion (2024: nil) of trading securities were transferred from Level 2 to Level 1. No other significant
transfers between Level 1 and Level 2 were recorded during the 2025 reporting period (2024: nil).
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 2025 of EUR 11.7 billion (2024: EUR
11.0 billion), an amount of EUR 10.1 billion (86.2%) (2024: EUR 9.6 billion, being 87.2%) 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 (2024: EUR 0.1 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 1.5 billion (2024: EUR 1.3 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 2025 of EUR 0.8 billion (2024: EUR
0.8 billion), an amount of EUR 0.6 billion (72.7%) (2024: EUR 0.6 billion, being 75.7%) 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 liabilities include EUR 0.1 billion (2024: EUR 0.1 billion) which relates to financial
liabilities that are part of structures that are designed to be fully neutral in terms of market risk. As explained
above, the fair value of each of the components of these structures may be sensitive to unobservable inputs, but
the overall sensitivity is by design not significant.
The remaining EUR 0.1 billion (2024: 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
2025
2024
2025
2024
2025
2024
2025
2024
At fair value through profit or loss
Debt securities
1,934
3,504
9
10
Price based
Price (%)
0%
0%
103%
120%
Price (price per share)
201
327
412
520
Present value techniques
Price (%)
n.a.
95.85%
n.a.
100%
Equity securities
187
141
Price based
Price (price per share)
0
0
5,475
5,475
Loans and advances
1,978
1,565
0
0
Price based
Price (%)
0%
0%
109%
107%
Present value techniques
Credit spread (bps)
120
576
709
629
Prepayment rate (%)
2%
2%
2%
100%
(Reverse) repos
6,563
5,050
Present value techniques
Interest rate (%)
n.a.
2%
n.a.
2%
Structured notes
15
67
Price based
Price (%)
96%
93%
103%
104%
Option pricing model
Equity volatility (%)
18%
n.a.
22%
n.a.
Equity/Equity correlation
0.7
0.7
0.8
0.7
Equity/FX correlation
-0.6
n.a.
0.2
n.a.
Dividend yield (%)
0.4%
n.a.
1.9%
n.a.
Present value techniques
Prepayment rate (%)
n.a.
99.59%
n.a.
100.09%
Derivatives
\u2013\u00a0\u00a0Rates
628
413
670
389
Option pricing model
Interest rate volatility (bps)
45
n.a.
91
n.a.
Present value techniques
Reset spread (%)
1%
2%
1%
2%
\u2013\u00a0\u00a0FX
2
6
4
8
Option pricing model
Implied volatility (%)
1.7%
2%
42%
15%
\u2013\u00a0\u00a0Credit
134
39
48
241
Present value techniques
Credit spread (bps)
10
0
88
91
Price based
Price (%)
0%
0%
100%
100%
\u2013\u00a0\u00a0Equity
7
10
46
47
Option pricing model
Equity volatility (%)
13%
7%
75%
81%
Equity/Equity correlation
0.0
0.0
1.0
1.0
Equity/FX correlation
-0.7
-0.6
0.5
0.6
Dividend yield (%)
0%
0%
51%
33%
\u2013\u00a0\u00a0Other
2
6
10
9
Option pricing model
Commodity volatility (%)
20%
13.1%
76%
61%
Com/FX correlation
-0.25
-0.40
-0.25
-0.25
Price based
Price (commodity)
66
68
66
68
At fair value through other comprehensive income
\u2013\u00a0\u00a0Equity
307
270
Present value techniques
Credit spread (bps)
5.15
5.67
5.15
5.76
Interest rate (%)
2.5%
1.5%
2.5%
3.5%
Payout ratio (%)
70%
70%
90%
90%
Price based
Price (%)
n.a.
122%
n.a.
122%
Price (price per share)
126
n.a
126
n.a
Total
11,742
11,005
802
770
1The 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
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
Opening balance as at 1 January
824
848
68
286
5,721
3,499
4,121
3,547
270
938
11,005
9,118
Realised gain/loss\u00a0 recognised in the statement of profit or loss during the period 1
247
-175
63
-38
211
294
-798
-54
-278
28
Revaluation recognised in other comprehensive income during the period 2
8
-3
8
-3
Purchase of assets
953
486
0
198
5,177
4,424
1,208
1,600
182
154
7,520
6,862
Sale of assets
-109
-111
0
-257
-1,765
-1,605
-1,160
-10
-163
-418
-3,197
-2,402
Maturity/settlement
-128
-140
0
-7
-166
-294
-763
-988
0
-20
-1,057
-1,449
Reclassifications
0
0
-1
0
18
0
0
0
10
0
28
0
Transfers into Level 3
316
370
0
0
824
615
0
30
0
0
1,139
1,014
Transfers out of Level 3
-974
-454
-9
-114
-2,389
-1,214
0
-3
0
-384
-3,372
-2,169
Exchange rate differences
-14
0
0
0
-6
5
-33
-2
0
9
-53
12
Changes in the composition of the group and other changes
0
0
0
0
0
-1
0
0
0
-5
0
-6
Closing balance
1,114
824
121
68
7,625
5,721
2,576
4,121
307
270
11,742
11,005
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 280 million (2024: EUR -41 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 2025, transfers out of Level 3 within trading assets relate mainly to securities, as their valuations were no longer
significantly influenced by unobservable inputs. In 2024, transfers out of Level 3 in trading assets primarily involved
derivative instruments, as their valuations were no longer significantly impacted by unobservable inputs.
In 2025 and 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. In 2024, the
transfer out of Level 3 in non-trading derivatives primarily involved derivative instruments, as their valuations were
no longer significantly impacted by unobservable inputs.
In 2025 and 2024, 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 out of Level 3 of financial assets at FVOCI relates to Hold-to-Collect and Sell portfolio
transferred to Level 2 resulting from change in methodology.
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
2025
2024
2025
2024
2025
2024
2025
2024
Opening balance as at 1
January
637
382
67
301
67
47
770
729
Realised gain/loss recognised
in the statement of profit or
loss during the period 1
81
-104
82
-98
-6
-5
157
-206
Additions
205
55
3
190
11
29
219
274
Redemptions
-74
-12
0
-209
0
0
-74
-222
Maturity/settlement
-160
-15
0
-7
-64
-4
-225
-26
Transfers into Level 3
19
364
0
0
19
34
38
399
Transfers out of Level 3
-72
-33
0
-111
-12
-34
-84
-179
Exchange rate differences
-1
0
0
0
0
0
-1
0
Closing balance
636
637
151
67
15
67
802
770
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 158 million
(2024: EUR -206\u00a0million) of unrealised gains and losses recognised in the statement of profit or loss.
In 2025, the transfers out of Level 3 mainly consisted of trading liabilities related to securities transferred out of
Level 3 as a result of the valuation being no longer impacted by significantly unobservable inputs.
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.
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
2025
2024
2025
2024
Equity (equity derivatives, structured notes)
20
21
-12
-20
Interest rates (Rates derivatives, FX derivatives)
1
5
0
0
Credit (Debt securities, Loans, structured notes, credit derivatives)
12
2
-14
-27
Loans and advances
0
0
0
0
33
28
-26
-47
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 value 1
Level 1
Level 2
Level 3
Total fair value
in EUR million
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
Financial Assets
Loans and advances to banks
21,204
21,769
3,053
3,194
14,722
15,614
3,366
2,957
21,141
21,766
Loans and advances to customers
721,779
680,299
18,233
18,296
12,782
18,626
678,392
630,493
709,408
667,415
Securities at amortised cost
53,867
50,273
47,722
42,871
2,381
2,908
2,692
2,523
52,796
48,303
796,850
752,341
21,286
21,490
47,723
42,871
29,885
37,149
684,450
635,973
783,344
737,483
Financial liabilities
Deposits from banks
18,521
16,722
5,401
4,347
9,162
8,208
3,745
3,943
18,308
16,498
Customer deposits
724,707
699,725
621,172
582,511
85,801
69,790
17,433
46,984
724,406
699,285
Debt securities in issue
103,116
94,459
36,782
33,019
62,567
59,141
3,857
2,000
103,207
94,161
Senior non-preferred debt
48,090
49,393
49,155
50,230
49,155
50,230
Subordinated loans
18,100
17,879
18,722
18,357
18,722
18,357
912,534
878,178
626,573
586,857
36,782
33,019
225,408
205,726
25,035
52,927
913,798
878,530
1In 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, excluding the negative macro fair value hedge adjustment.
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.
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
There is an embedded value in our on-demand deposits. However, for the purpose of this disclosure, and in
accordance with IFRS, the fair value of deposits with an immediate on demand feature approximates the carrying
amount, excluding the negative macro fair value hedge adjustment.
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.
34\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 hedges of interest rate risk, 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
2025
Liabilities
2025
Assets
2024
Liabilities
2024
As at 31 December
Hedging instrument on interest rate risk
\u2013 Interest rate swaps
26,279
19,625
26,963
24,107
\u2013 Other interest derivatives
213
13
207
23
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 578 million (2024: EUR 617
million) respectively \u2018Financial liabilities at fair value through profit or loss \u2013 Non-trading derivatives\u2019 EUR 54 million
(2024: EUR 79 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
1.85% (2024: 1.69%) for EUR and 4.43% (2024: 4.22%) 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
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
As at 31 December 2025
Hedging instrument on
interest rate risk
\u2013 Interest rate swaps
4,133
304
17,551
-373
10,494
2,859
-2,524
-52,863
-20,419
\u2013 Other interest derivatives
-3
93
229
131
-303
184
212
260
803
As at 31 December 2024
Hedging instrument on
interest rate risk
- 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
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 2025
Interest rate risk and FX rate risk
\u2013 Debt securities at fair value through other comprehensive income
44,165
n/a
-480
\u2013 Loans at FVOCI
n/a
\u2013 Loans and advances to customers
71,093
-7,441
-2,352
\u2013 Debt instruments at amortised cost
20,695
-438
-284
\u2013 Debt securities in issue
40,839
-1,193
280
\u2013 Senior non-preferred debt
46,566
-934
-325
\u2013 Subordinated loans
18,058
-327
-287
\u2013 Customer deposits and other funds on deposit
10,040
-9
3
\u2013 Discontinued hedges
1,444
Total
135,953
115,502
-6,435
-2,463
-3,445
3,481
36
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
During 2025, 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 2025. Refer to Note 23 'Valuation results and net trading income'.
In addition, the net increase in hedged items is mainly due to higher volumes in debt securities as well as the
extension of the macro fair value hedge on core deposits in 2025. 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:
\u00a7 differences in maturities of the hedged item(s) and hedging instrument(s);
\u00a7 different interest rate curves applied to discount the hedged item(s) and hedging instrument(s);
\u00a7 differences in timing of cash flows of the hedged item(s) and hedging instrument(s).
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
2025
2025
2024
2024
As at 31\u00a0December
Hedging instrument on interest rate risk
\u2013 Interest rate swaps
9,414
10,066
10,635
12,814
Hedging instrument on FX rate risk
\u2013 Cross currency swaps
1,042
139
472
339
Hedging instrument on combined interest and FX rate risk
\u2013 Cross currency interest rate swaps
63
10
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 459 million (2024: EUR 158
million) respectively \u2018Financial liabilities at fair value through profit or loss \u2013 Non-trading derivatives\u2019 EUR 254
million (2024: EUR 573 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
1.81% (2024: 1.79%) for EUR, 4.27% (2024: 4.37%) for PLN, 3.85% (2024: 3.99%) for USD and 3.38% (2024: 3.29%)
for AUD. The average currency exchange rates for cross currency interest rate swaps used in cash flow hedge
accounting is for EUR/USD 0.97 (2024: 1.03) and for EUR/AUD 1.56 (2024: 1.52).
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
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
As at 31 December 2025
Hedging instrument on interest
rate risk
\u2013 Interest rate swaps
-2,023
-3,542
-6,217
-15,357
-14,152
-4,549
-4,381
-11,676
-61,897
Hedging instrument on FX rate
risk
\u2013 Cross currency swaps
456
964
654
-1,271
-446
607
-601
-1,572
-1,210
Hedging instrument on combined
interest and FX rate risk
\u2013 Cross currency interest rate
swaps
-1,246
-1,518
-2,765
As at 31 December 2024
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
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
ineffectiveness
for the period
Carrying
amount cash
flow hedge
reserve at the
end of the
reporting
period 1
Amount
reclassified
from CFH
reserve to
profit or loss 2
Change in
value of
hedging
instrument
recognised in
OCI for the
period
Hedge
ineffectiveness
recognised in
the statement
of profit or
loss, gain (+) /
loss (-)
As at 31 December 2025
Interest rate risk on:
\u2013 Floating rate lending
-1,265
-1,157
536
\u2013 Floating rate borrowing
289
-141
-146
\u2013 Other
\u2013 Discontinued hedges
-323
7
Total interest rate risk
-977
-1,619
397
602
7
FX rate risk on:
\u2013 Floating rate lending
-15
-58
-171
\u2013 Floating rate borrowing
34
-4
-38
\u2013 Other
\u2013 Discontinued hedges
-1
Total FX risk
20
-62
-209
195
3
Combined interest and FX rate risk on:
\u2013 Floating rate lending
37
47
-39
\u2013 Floating rate borrowing
\u2013 Other
\u2013 Discontinued hedges
Total combined interest and FX risk
37
47
-39
2
1
Total cash flow hedge
-920
-1,635
149
799
10
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
ineffectiveness
for the period
Carrying
amount cash
flow hedge
reserve at the
end of the
reporting
period 1
Amount
reclassified
from CFH
reserve to
profit or loss 2
Change in
value of
hedging
instrument
recognised in
OCI for the
period
Hedge
ineffectiveness
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
1The carrying amount is the gross amount, excluding tax adjustments.
2The amounts are reclassified to Net interest income - interest income and/or expense on non-trading derivatives (hedge accounting).
In 2025, EUR -1 million was reclassified from CFH reserve to profit or loss for cash flows that are no longer expected
to occur (2024: nil).
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 2025.
The main sources of ineffectiveness for cash flow hedges are:
\u00a7 Differences in timing of cash flows of the hedged item(s) and hedging instrument(s); and
\u00a7 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
2025
2024
Opening balance
-1,693
-2,058
Value changes recognised in OCI
799
743
Amounts recycled to profit or loss
149
-209
Income tax
-175
-140
Exchange rate and other changes
-12
-14
Adjustment for non controlling interest
-163
-14
Movement for the year
597
365
Ending balance
-1,096
-1,693
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 of. 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
2025
2025
2024
2024
As at 31 December
\u2013 FX forwards and Cross currency swaps
68
74
82
117
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 68 million (2024: EUR 82
million) respectively \u2018Financial liabilities at fair value through profit or loss \u2013 Non trading derivatives\u2019 EUR 74 million
(2024: EUR 117 million).
For ING\u2019s main currencies the average exchange rates used in net investment hedge accounting for 2025 are EUR/USD
1.12 (2024: 1.08), EUR/PLN 4.24 (2024: 4.31), EUR/AUD 1.75 (2024: 1.64) and EUR/THB 36.98 (2024: 38.00).
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
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
As at 31 December 2025
\u2013 FX forwards and cross
currency swaps
-6,683
-4,298
-86
-11,066
As at 31 December 2024
\u2013 FX forwards and Cross
currency swaps
-8,681
-4,158
-76
-12,916
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
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(-)
As at 31 December 2025
Investment in foreign operations
-816
488
816
Discontinued hedges
535
As at 31 December 2024
Investment in foreign operations
295
-95
-295
Discontinued hedges
302
1The carrying amount is the gross amount, excluding tax adjustments.
35\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
2025
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
52,889
52,889
Loans and advances to banks
12,910
1,581
3,735
2,258
720
21,204
Financial assets at fair value through profit or loss
\u2013\u00a0 Trading assets
20,958
3,508
7,988
11,974
11,305
55,734
\u2013\u00a0 Non-trading derivatives
160
62
185
517
732
1,657
\u2013\u00a0 Mandatorily at fair value through profit or loss
31,075
14,907
14,182
9,967
1,881
310
72,322
\u2013\u00a0 Designated as at fair value through profit or loss
14
233
383
1,698
1,120
3,448
Financial assets at fair value through other comprehensive income
\u2013\u00a0 Equity securities
2,607
2,607
\u2013\u00a0 Debt securities
135
628
1,136
23,026
25,892
50,817
\u2013\u00a0 Loans and advances
321
569
654
1,056
639
3,238
Securities at amortised cost
1,714
1,932
5,629
24,150
20,442
53,867
Loans and advances to customers
61,978
23,768
62,643
235,586
337,804
721,779
Other assets 2
5,581
363
1,454
1,155
1,331
5,060
14,946
Total assets
187,735
47,551
97,989
311,386
401,867
7,977
1,054,507
2024
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
1Includes assets on demand.
2Includes 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.
36\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:
\u00a7 Perpetual liabilities are included in the column \u2018Maturity not applicable\u2019.
\u00a7 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.
\u00a7 Undiscounted future coupon interest on financial liabilities payable is included in a separate line and in the
relevant maturity bucket.
\u00a7 Non-financial liabilities are included based on a breakdown of the amounts per statement of financial position,
per expected maturity.
\u00a7 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
2025
Less than 1 month 1
1\u20133 months
3\u201312 months
1\u20135 years
Over 5 years
Maturity not applicable
Adjustment\u00a0 2
Total
Deposits from banks
10,307\u00a0
2,433\u00a0
2,392\u00a0
1,737\u00a0
1,617\u00a0
34\u00a0
18,521\u00a0
Customer deposits
649,957\u00a0
26,346\u00a0
37,769\u00a0
6,769\u00a0
2,049\u00a0
1,816\u00a0
724,707\u00a0
Financial liabilities at fair value
through profit or loss
\u2013\u00a0 Other trading liabilities
704\u00a0
48\u00a0
110\u00a0
1,028\u00a0
610\u00a0
247\u00a0
2,745\u00a0
\u2013\u00a0 Trading derivatives
2,509\u00a0
2,290\u00a0
4,604\u00a0
7,508\u00a0
2,459\u00a0
1,311\u00a0
20,681\u00a0
\u2013\u00a0 Non-trading derivatives
170\u00a0
199\u00a0
229\u00a0
304\u00a0
128\u00a0
309\u00a0
1,338\u00a0
\u2013\u00a0 Designated at fair value through
profit or loss
39,279\u00a0
6,980\u00a0
937\u00a0
4,110\u00a0
4,558\u00a0
36\u00a0
-137\u00a0
55,764\u00a0
Debt securities in issue
1,268\u00a0
17,674\u00a0
40,682\u00a0
26,598\u00a0
17,731\u00a0
-838\u00a0
103,116\u00a0
Senior non preferred debt
2,032\u00a0
1,139\u00a0
\u00a0
28,600\u00a0
16,791\u00a0
-473\u00a0
48,090\u00a0
Subordinated loans
\u00a0
\u00a0
\u00a0
\u00a0
10,612\u00a0
7,627\u00a0
-139\u00a0
18,100\u00a0
Lease liabilities
15\u00a0
34\u00a0
172\u00a0
574\u00a0
304\u00a0
-50\u00a0
1,050\u00a0
Financial liabilities
706,242\u00a0
57,144\u00a0
86,894\u00a0
77,227\u00a0
56,860\u00a0
7,663\u00a0
2,081\u00a0
994,112\u00a0
Other liabilities 3
7,289\u00a0
843\u00a0
2,221\u00a0
490\u00a0
553\u00a0
11,395\u00a0
Total liabilities
713,531\u00a0
57,986\u00a0
89,115\u00a0
77,717\u00a0
57,413\u00a0
7,663\u00a0
2,081\u00a0
1,005,507\u00a0
Coupon interest due on financial
liabilities
1,913\u00a0
1,331\u00a0
4,661\u00a0
11,837\u00a0
8,866\u00a0
476\u00a0
29,086\u00a0
Commitments:
\u2013\u00a0 Guarantees
28,690\u00a0
\u00a0
\u00a0
552\u00a0
\u00a0
29,242\u00a0
\u2013\u00a0 Irrevocable letters of credit
15,230\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
15,230\u00a0
Irrevocable facilities
200,000\u00a0
39\u00a0
6\u00a0
77\u00a0
76\u00a0
200,198\u00a0
243,920
39
6
629
76
244,670
1Includes liabilities on demand.
2This 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.
Liabilities and off-balance sheet commitments by maturity
in EUR million
2024
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
9,104
1,367
2,085
1,637
2,484
46
16,722
Customer deposits
610,590
23,479
50,034
11,141
2,081
2,399
699,725
Financial liabilities at fair value
through profit or loss
\u2013\u00a0 Other trading liabilities
5,790
230
313
1,325
1,465
-34
9,089
\u2013\u00a0 Trading derivatives
2,631
2,367
3,730
7,641
5,499
4,298
26,166
\u2013\u00a0 Non-trading derivatives
419
57
-36
711
149
801
2,101
\u2013\u00a0 Designated at fair value through
profit or loss
32,644
5,842
1,798
5,095
4,365
34
-239
49,539
Debt securities in issue
1,949
17,635
33,037
26,600
15,704
-466
94,459
Senior non preferred debt
975
30,121
19,153
-856
49,393
Subordinated loans
9,962
8,415
-498
17,879
Lease liabilities
20
44
162
607
328
-45
1,116
Financial liabilities
663,148
51,995
91,125
84,879
61,190
8,448
5,405
966,190
Other liabilities 3
7,294
456
2,073
502
470
10,795
Total liabilities
670,442
52,451
93,198
85,381
61,660
8,448
5,405
976,986
Coupon interest due on financial
liabilities
2,278
1,600
5,981
10,388
8,065
516
28,829
Commitments:
\u2013\u00a0 Guarantees
26,355
3
550
26,908
\u2013\u00a0 Irrevocable letters of credit
16,388
16,388
Irrevocable facilities
175,000
9
15
143
56
175,222
217,743
9
15
146
606
218,518
1Includes liabilities on demand.
2This 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.
37\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
2025
2024
Banks
\u2013\u00a0 Cash and balances with central banks
499
397
\u2013\u00a0 Loans and advances to banks
2,672
2,211
Financial assets at fair value through profit or loss
20,561
28,905
Financial assets at fair value through OCI
1,519
3,037
Securities at amortised cost
3,339
3,184
Loans and advances to customers
71,321
67,706
Other assets
479
503
100,392
105,944
In some jurisdictions ING Bank N.V. has an obligation to maintain a reserve with central banks. As at 31 December
2025, the minimum mandatory reserve deposits with various central banks amount to EUR 11,925 million (2024 :
EUR 11,648 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
2025
2024
Total received collateral available for sale or repledge at fair value
\u2013\u00a0 equity securities
21,494
22,815
\u2013\u00a0 debt securities
144,257
140,285
of which sold or repledged at fair value
\u2013\u00a0 equity securities
16,018
12,024
\u2013\u00a0 debt securities
98,422
90,708
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. These transferred financial
assets remain recognized on the balance sheet as ING retains substantially all the risk and rewards of ownership
and remains exposed to the changes in the fair value of the assets.
Transfer of financial assets not qualifying for derecognition
Securities lending
Sale and repurchase
Equity
Debt
Equity
Debt
in EUR million
2025
2024
2025
2024
2025
2024
2025
2024
Transferred assets at carrying
amount
Financial assets at fair value through
profit or loss
4,163
4,141
3
3
5,929
7,273
9,687
16,929
Financial assets at fair value through
other comprehensive income
314
603
886
1,956
Securities at amortised cost
399
635
989
819
Associated liabilities at carrying
amount1
Financial liabilities at fair value
through profit or loss
n/a
n/a
n/a
n/a
5,398
7,005
6,684
11,901
1The 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'.
38\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:
\u00a7 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
\u00a7 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 section \u2018Credit risk mitigation'.
Financial assets subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million
2025
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
4,964
-77
4,886
4,859
27
1,949
6,836
4,964
-77
4,886
4,859
27
1,949
6,836
Financial assets at fair value through
profit or loss
Trading and Non-trading
Reverse repurchase, securities
borrowing and similar agreements
102,179
-48,514
53,665
26
53,507
132
16,378
70,044
Derivatives 3
81,453
-59,208
22,245
10,755
3,068
8,421
3,758
26,003
183,632
-107,722
75,910
10,782
56,575
8,553
20,136
96,047
Loans and advances to customers 4
Reverse repurchase, securities
borrowing and similar agreements
3,247
-32
3,215
3,205
9
652
3,866
Cash pools
211,791
-209,568
2,222
37
1,847
338
2,222
215,038
-209,601
5,437
37
5,052
347
652
6,089
Other items where offsetting is applied in
the statement of financial position 5
742
-657
85
45
39
85
Total financial assets
404,375
-318,057
86,318
10,864
66,487
8,967
22,738
109,056
1\u2018The statement of financial position total\u2019 is the sum of \u2018Net amounts of financial assets presented in the statement of financial position\u2019 and \u2019Amounts not subject to enforceable master netting arrangements\u2019.
2At 31 December 2025, the total amount of \u2018Loans and advances to banks\u2019 excluding repurchase agreements is EUR 14,368 million which is not subject to offsetting.
3Derivative assets and derivative liabilities include certain exchange traded future and option positions with the same underlying.
4At 31 December 2025, the total amount of \u2018Loans and advances to customers\u2019 excluding repurchase agreements is EUR 717,912 million of which the net cash pool position of EUR 2,222 million is subject to offsetting.
5Other items include amounts to be settled with Central Clearing Counterparties regarding derivatives transactions and is included in \u2018Other Assets \u2013 Amounts to be settled\u2019 for EUR 4,074 million in the statement of financial position of which EUR 85 million is subject to offsetting as at 31 December 2025.
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
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 3
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 4
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.
2At 31 December 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.
3Derivative assets and derivative liabilities include certain exchange traded future and option positions with the same underlying.
4At 31 December 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.
5Other 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 3,550 million in the statement of financial position of which EUR 382 million is subject to offsetting as at 31 December
2024.
Financial liabilities subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million
2025
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
79
-77
1
1
329
330
Other
287
-287
366
-365
1
1
329
330
Customer deposits 4
Repurchase, securities lending
and similar agreements
32
-32
182
182
Cash pools
228,013
-209,568
18,445
8
18,437
18,445
228,045
-209,601
18,445
8
18,437
182
18,627
Financial liabilities at fair value through profit or
loss
Trading and Non-trading
Repurchase, securities lending
and similar agreements
84,997
-48,514
36,483
26
36,520
-63
9,760
46,243
Derivatives 3
71,427
-53,882
17,545
10,783
3,409
3,353
4,474
22,019
156,424
-102,395
54,028
10,809
39,929
3,291
14,234
68,262
Other items where offsetting is applied in the
statement of financial position 5
5,742
-5,697
45
45
45
Total financial liabilities
390,577
-318,057
72,520
10,862
39,929
21,729
14,745
87,265
1\u2018The statement of financial position total\u2019 is the sum of \u2018Net amounts of financial liabilities presented in the statement of financial position\u2019 and \u2019Amounts not subject to enforceable master netting arrangements\u2019.
2At 31 December 2025, the total amount of \u2018Deposits from banks\u2019 excluding repurchase agreements is EUR 18,190 million of which EUR 0 million is subject to offsetting.
3Derivative assets and derivative liabilities include certain exchange traded future and option positions with the same underlying.
4At 31 December 2025, the total amount of \u2018Customers deposits\u2019 excluding repurchase agreements is EUR 724,525 million of which the net cash pool position of EUR 18,445 million is subject to offsetting.
5Other items include amounts to be settled with Central Clearing Counterparties regarding derivatives transactions and is included in \u2018Other Liabilities \u2013 Amounts to be settled\u2019 for EUR 4,188 million in the statement of financial position of which EUR 45 million is subject to offsetting as at 31 December 2025.
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 3
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
11,671
43,689
Derivatives
89,386
-67,731
21,655
17,639
2,745
1,272
6,612
28,267
170,769
-117,095
53,674
17,859
34,414
1,402
18,283
71,956
Other items where offsetting is applied in the
statement of financial position 4
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.
2At 31 December 2024, the total amount of \u2018Deposits from banks\u2019 excluding repurchase agreements is EUR 16,690 million of which EUR 0 million is subject to offsetting.
3Derivative assets and derivative liabilities include certain exchange traded future and option positions with the same underlying.
4At 31 December 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.
5Other 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 December
2024.
39\u00a0 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.
Commitments
in EUR million
2025
2024
\u2013\u00a0 Guarantees
29,242
26,908
\u2013\u00a0 Irrevocable letters of credit
15,230
16,388
44,472
43,296
Irrevocable facilities
200,198
175,222
244,670
218,518
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\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, irrevocable facilities includes certain revocable facilities where the
ability to withdraw such facilities is constrained in practice, and cancellation typically occurs only after a significant
increase in credit risk, these commitments are treated as \u201cin substance irrevocable\u201d and are therefore included
within the scope of the IFRS 9 impairment requirements.
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 2025 (31 December 2024:
EUR 346 million). No IPCs were provided to the SRF during 2025 (2024: nil). No IPCs were called by the SRF in 2025
(2024: 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. IPCs amount to EUR
322 million as at 31 December 2025 (31 December 2024: EUR 309 million). Of these, EUR 13 million of IPCs were
provided to the DGS during 2025 (2024: EUR 35 million). No IPCs were called by the DGS in 2025 (2024: nil). ING
posted government bonds as collateral for the total nominal amount of EUR 336 million as at 31 December 2025
(31 December 2024: EUR 336 million).
In addition to the items included in commitments, 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", "dimensions": { "concept": "ifrs-full:DisclosureOfFinancialInstrumentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-693": { "value": "
3\u00a0 Loans and advances to banks
Loans and advances to banks
Netherlands
Rest of the world
Total
in EUR million
2025
2024
2025
2024
2025
2024
Loans and advances to banks1
12,362
14,343
8,841
7,426
21,204
21,769
1Loans and advances to banks include EUR -18\u00a0 million (2024: EUR -22\u00a0 million) of Loan loss provisions.
Loans and advances include balances of reverse repurchase transactions. For more information, refer to Note 4
'Financial assets at fair value through profit or loss' . Furthermore, it includes on-demand and term loans, and cash
collateral transactions. Reference is made to Note 7 'Loans and advances to customers' for information on finance
lease receivables included in Loans and advances to banks.
As at 31\u00a0December 2025 and at 31 December 2024, all loans and advances to banks are non-subordinated.", "dimensions": { "concept": "ifrs-full:DisclosureOfLoansAndAdvancesToBanksExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-695": { "value": "
4\u00a0 Financial assets at fair value through profit or loss
Financial assets at fair value through profit or loss
in EUR million
2025
2024
Trading assets
55,734
72,906
Non-trading derivatives
1,657
2,463
Designated at fair value through profit or loss
3,448
5,740
Mandatorily measured at fair value through profit or loss
72,322
56,481
133,160
137,590
(Reverse) repurchase transactions
Financial assets at fair value through profit or loss include securities lending and sales and repurchase transactions
with securities. At ING, these types of transactions are recognised in several lines in the statement of financial
position depending on business model assessment and counterparty. Netting is applicable to repurchase
agreements that are governed by an established Global Master Repurchase Agreement (GMRA) when ING has the
intention to settle net. This netting is restricted to transactions involving the same currency and maturity date,
and must occur within the same legal entity. Reference is made to Note 38 '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. 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.\u00a0
Reference is made to Note 37 '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
2025
2024
Reverse repurchase transactions
Loans and advances to banks
6,836
10,777
Loans and advances to customers
3,866
3,471
Trading assets, loans and receivables
1,574
12,033
Loans and receivables mandatorily measured at fair value through profit or loss
68,469
53,393
80,746
79,675
Repurchase transactions
Deposits from banks
330
33
Customer deposits
182
1
Trading liabilities, funds on deposit
31
5,269
Funds entrusted designated and measured at fair value through profit or loss
46,211
38,420
46,755
43,723
Trading assets
Trading assets by type
in EUR million
2025
2024
Equity securities
21,276
20,726
Debt securities
8,120
10,080
Derivatives
24,346
29,805
Loans and receivables
1,991
12,295
55,734
72,906
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
2025
2024
Derivatives used in
-\u00a0 fair value hedges
578
617
-\u00a0 cash flow hedges
459
158
-\u00a0 hedges of net investments in foreign operations
68
82
Other non-trading derivatives
550
1,606
1,657
2,463
Reference is made to Note 34 'Derivatives and hedge accounting' for information on derivatives designated in
hedge accounting.
Other non-trading derivatives mainly includes interest-rate swaps, foreign exchange swaps, and cross currency
swaps for which no hedge accounting is applied.
Designated at fair value through profit or loss
Designated at fair value through profit or loss by type
in EUR million
2025
2024
Debt securities
2,330
4,718
Loans and receivables
1,118
1,022
3,448
5,740
\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 3,448 million (2024: EUR 5,740 million). In 2025, the change in fair value of these loans
and debt securities amounts to EUR -177\u00a0million (2024: EUR 5\u00a0million).
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
2,454 million (2024: EUR 3,797 million). The cumulative change in fair value attributable to changes in credit risk for
the financial asset economically hedged is EUR 85 million (2024: EUR 173 million) and the change for the current
year is EUR -88\u00a0million (2024: EUR 24\u00a0million). The cumulative change in fair value attributable to changes in credit
risk for the financial assets non-economically hedged with credit derivatives is EUR 513\u00a0million (2024: EUR
489\u00a0million) and the change for the current year is EUR 23\u00a0million.
The notional value of the related credit derivatives is EUR 2,486 million (2024: EUR 3,807 million). The cumulative
change in fair value of the credit derivatives since the financial assets were first designated, amounts to EUR
-85\u00a0million (2024: EUR -214\u00a0million) and the change for the current year is EUR 128\u00a0million (2024: EUR -95\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
2025
2024
Equity securities
310
228
Debt securities
769
789
Loans and receivables
71,243
55,464
72,322
56,481
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
2025
2024
Trading liabilities
23,427
35,255
Non-trading derivatives
1,338
2,101
Designated at fair value through profit or loss
55,764
49,539
80,529
86,896
Trading liabilities
Trading liabilities by type
in EUR million
2025
2024
Equity securities
682
467
Debt securities
1,872
3,185
Funds on deposit
191
5,437
Derivatives
20,681
26,166
23,427
35,255
Non-trading derivatives
Non-trading derivatives by type
in EUR million
2025
2024
Derivatives used in:
-\u00a0 fair value hedges
54
79
-\u00a0 cash flow hedges
254
573
-\u00a0 hedges of net investments in foreign operations
74
117
Other non-trading derivatives
957
1,332
1,338
2,101
Reference is made to Note 34 '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
2025
2024
Debt securities
8,202
9,326
Funds entrusted
47,431
40,092
Subordinated liabilities
131
122
55,764
49,539
As at 31\u00a0December 2025, the change in the fair value of financial liabilities designated at fair value through profit
or loss attributable to changes in credit risk is EUR 57 million on a cumulative basis (2024: EUR\u00a0 17 million ). This
change has been determined as the amount of change in fair value of the financial liability that is not attributable
to changes in market conditions that gave rise to market risk (i.e. mainly interest-rate risk based on yield curves).
The amount that ING 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
9,574 million ( 2024: EUR\u00a011,376 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-694": { "value": "
4\u00a0 Financial assets at fair value through profit or loss
Financial assets at fair value through profit or loss
in EUR million
2025
2024
Trading assets
55,734
72,906
Non-trading derivatives
1,657
2,463
Designated at fair value through profit or loss
3,448
5,740
Mandatorily measured at fair value through profit or loss
72,322
56,481
133,160
137,590
(Reverse) repurchase transactions
Financial assets at fair value through profit or loss include securities lending and sales and repurchase transactions
with securities. At ING, these types of transactions are recognised in several lines in the statement of financial
position depending on business model assessment and counterparty. Netting is applicable to repurchase
agreements that are governed by an established Global Master Repurchase Agreement (GMRA) when ING has the
intention to settle net. This netting is restricted to transactions involving the same currency and maturity date,
and must occur within the same legal entity. Reference is made to Note 38 '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. 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.\u00a0
Reference is made to Note 37 '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
2025
2024
Reverse repurchase transactions
Loans and advances to banks
6,836
10,777
Loans and advances to customers
3,866
3,471
Trading assets, loans and receivables
1,574
12,033
Loans and receivables mandatorily measured at fair value through profit or loss
68,469
53,393
80,746
79,675
Repurchase transactions
Deposits from banks
330
33
Customer deposits
182
1
Trading liabilities, funds on deposit
31
5,269
Funds entrusted designated and measured at fair value through profit or loss
46,211
38,420
46,755
43,723
Trading assets
Trading assets by type
in EUR million
2025
2024
Equity securities
21,276
20,726
Debt securities
8,120
10,080
Derivatives
24,346
29,805
Loans and receivables
1,991
12,295
55,734
72,906
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
2025
2024
Derivatives used in
-\u00a0 fair value hedges
578
617
-\u00a0 cash flow hedges
459
158
-\u00a0 hedges of net investments in foreign operations
68
82
Other non-trading derivatives
550
1,606
1,657
2,463
Reference is made to Note 34 'Derivatives and hedge accounting' for information on derivatives designated in
hedge accounting.
Other non-trading derivatives mainly includes interest-rate swaps, foreign exchange swaps, and cross currency
swaps for which no hedge accounting is applied.
Designated at fair value through profit or loss
Designated at fair value through profit or loss by type
in EUR million
2025
2024
Debt securities
2,330
4,718
Loans and receivables
1,118
1,022
3,448
5,740
\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 3,448 million (2024: EUR 5,740 million). In 2025, the change in fair value of these loans
and debt securities amounts to EUR -177\u00a0million (2024: EUR 5\u00a0million).
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
2,454 million (2024: EUR 3,797 million). The cumulative change in fair value attributable to changes in credit risk for
the financial asset economically hedged is EUR 85 million (2024: EUR 173 million) and the change for the current
year is EUR -88\u00a0million (2024: EUR 24\u00a0million). The cumulative change in fair value attributable to changes in credit
risk for the financial assets non-economically hedged with credit derivatives is EUR 513\u00a0million (2024: EUR
489\u00a0million) and the change for the current year is EUR 23\u00a0million.
The notional value of the related credit derivatives is EUR 2,486 million (2024: EUR 3,807 million). The cumulative
change in fair value of the credit derivatives since the financial assets were first designated, amounts to EUR
-85\u00a0million (2024: EUR -214\u00a0million) and the change for the current year is EUR 128\u00a0million (2024: EUR -95\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
2025
2024
Equity securities
310
228
Debt securities
769
789
Loans and receivables
71,243
55,464
72,322
56,481
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
2025
2024
Equity securities
2,607
2,562
Debt securities 1
50,817
42,219
Loans and advances 1
3,238
1,608
56,662
46,389
1Debt securities includes an amount of EUR -15 million (2024: EUR -12 million) and Loans and advances includes EUR -6 million (2024: EUR -7 million) of
Loan loss provisions.
Exposure to equity securities
Equity securities designated as at fair value through other comprehensive income
Carrying
value
Carrying
value 1
Dividend
income
Dividend
income 1
in EUR million
2025
2024
2025
2024
Investment in Bank of Beijing
1,838
2,241
98
101
Investment in Van Lanschot Kempen
462
51
12
2
Other Investments
307
270
6
14
2,607
2,562
116
117
The table has been updated to present the increased stake in Van Lanschot Kempen separately from other investments.
As at 31\u00a0December 2025 ING holds 13% (2024: 13%) of the shares of Bank of Beijing, a bank listed on the Shanghai
Stock Exchange. The stake in Bank of Beijing is part of the Corporate Line. As per regulatory requirements set by
the China Banking and Insurance Regulatory Commission, ING, as a shareholder holding more than 5% of the
shares, is required to supply additional capital when necessary. No request for additional capital was received in
2025 (2024: nil).
In 2025 ING increased its ownership in Van Lanschot Kempen by acquiring an additional 17.6% stake, raising its
total interest based on the issued share capital from 2.7% to 20.3%. Despite ING holding over 20% voting rights in
VLK (a presumption of significant influence in IFRS), this presumption is rebutted given that ING holds rights similar
to other ordinary shareholders where voting does not include financial and operating policy decisions and ING
does not have the rights or ability to obtain board representation. Therefore, the increased investment in VLK is
designated at fair value through other comprehensive income consistent with ING\u2019s passive investment purpose.
The stake is part of the Corporate Line.
Changes in fair value through other comprehensive income
The following table presents changes in financial assets at fair value through other comprehensive income:
Changes in fair value through other comprehensive income financial assets
FVOCI equity
securities
FVOCI debt
instruments 1
Total
in EUR million
2025
2024
2025
2024
2025
2024
Opening balance as at 1 January
2,562
1,885
43,827
39,231
46,389
41,116
Additions
395
11
42,899
21,080
43,294
21,091
Amortisation
75
77
75
77
Transfers
10
1
10
1
Changes in unrealised revaluations 2
-156
605
322
-96
166
509
Impairments
-10
2
-10
2
Reversals of impairments
7
-7
7
-7
Disposals and redemptions
-7
-1
-33,124
-16,906
-33,131
-16,907
Exchange rate differences
-178
62
-1,088
443
-1,267
506
Other changes
-19
1,148
1,128
Closing balance
2,607
2,562
54,055
43,827
56,662
46,389
1Fair value through other comprehensive income debt instruments includes both debt securities and loans and advances.
2Changes in unrealised revaluations of FVOCI debt instruments include changes on hedged items which are recognised in the statement of profit or loss.
Reference is made to Note 20 'Equity' for details on the changes in the revaluation reserve.
FVOCI equity securities
Exchange rate differences of EUR -178\u00a0million (31 December 2024: EUR 62\u00a0million) are mainly related to the stake
in Bank of Beijing following the depreciation of CNY versus EUR. In 2025, changes in unrealised revaluations of
equity securities are mainly related to a revaluation of the stake in Bank of Beijing of EUR -225\u00a0million (31
December 2024: EUR 590\u00a0million) following a change in the share price.
FVOCI debt instruments
In 2025, changes in interest rates and portfolio composition resulted in changes in unrealised revaluations of debt
securities of EUR 322\u00a0million (31 December 2024: EUR -96\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
2025
2024
Trading liabilities
23,427
35,255
Non-trading derivatives
1,338
2,101
Designated at fair value through profit or loss
55,764
49,539
80,529
86,896
Trading liabilities
Trading liabilities by type
in EUR million
2025
2024
Equity securities
682
467
Debt securities
1,872
3,185
Funds on deposit
191
5,437
Derivatives
20,681
26,166
23,427
35,255
Non-trading derivatives
Non-trading derivatives by type
in EUR million
2025
2024
Derivatives used in:
-\u00a0 fair value hedges
54
79
-\u00a0 cash flow hedges
254
573
-\u00a0 hedges of net investments in foreign operations
74
117
Other non-trading derivatives
957
1,332
1,338
2,101
Reference is made to Note 34 '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
2025
2024
Debt securities
8,202
9,326
Funds entrusted
47,431
40,092
Subordinated liabilities
131
122
55,764
49,539
As at 31\u00a0December 2025, the change in the fair value of financial liabilities designated at fair value through profit
or loss attributable to changes in credit risk is EUR 57 million on a cumulative basis (2024: EUR\u00a0 17 million ). This
change has been determined as the amount of change in fair value of the financial liability that is not attributable
to changes in market conditions that gave rise to market risk (i.e. mainly interest-rate risk based on yield curves).
The amount that ING 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
9,574 million ( 2024: EUR\u00a011,376 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
2025
2024
2023
Securities trading results
4,801
996
873
Derivatives trading results
-3,053
207
116
Other trading results
263
336
273
Change in fair value of derivatives relating to
\u2013\u00a0 fair value hedges
3,481
-766
-3,028
\u2013\u00a0 cash flow hedges (ineffective portion)
10
35
48
\u2013\u00a0 other non-trading derivatives
-819
1,923
563
Change in fair value of assets and liabilities (hedged items)
-3,445
750
2,962
Valuation results on assets and liabilities designated at FVPL (excluding trading)
8
31
-127
Foreign exchange transactions results
2,176
-105
1,230
3,422
3,407
2,910
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 whose results may neutralise
one another. A significant part of the derivatives in the trading portfolio are related to servicing corporate clients in
their risk management to hedge for example currency or interest rate exposures. From a risk perspective, the
gross amount of trading assets must be considered together with the gross amount of trading liabilities, which are
presented separately on the statement of financial position. However, IFRS does not always allow the netting of
these positions in the statement of financial position. Reference is made to Note 4 'Financial assets at fair value
through profit or loss' and Note 14 'Financial liabilities at fair value through profit or loss' for information on trading
assets and trading liabilities respectively.
Securities trading results include the results of market making in instruments such as government securities,
equity securities, corporate debt securities, and money-market instruments. The majority of the risks involved in
security and currency trading are economically hedged with derivatives. The securities trading results are partly
offset by results on these derivatives. Derivatives trading results include the results of derivatives such as interest
rate swaps, options, futures, and forward contracts. Trading gains and losses relating to trading securities still held
as at 31\u00a0December 2025 amount to EUR 1,219 million (2024: EUR 20 million; 2023: EUR\u00a0160 million).
Other trading results include the results of trading loans and funds entrusted.
Foreign-exchange transactions results include gains and losses from spot, options, futures, and translated foreign
currency assets and liabilities. The result on currency trading is included in foreign exchange transactions results.
Valuation results and net trading income include the fair value movements on derivatives (used for both hedge
accounting and economically hedging exposures) as well as the changes in the fair value of assets and liabilities
included in hedging relationships as hedged items. In 2025, fluctuations in interest rate had a significant impact on
the fair value changes of both the derivatives and the hedged items designated in fair value hedges. Reference is
made to Note 34 '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 33 'Fair value of assets and liabilities' for information on these valuation adjustments.
33\u00a0 Fair value of assets and liabilities
a) Valuation m ethods
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 the Global Valuation and Impairment Committee (GV&IC) and its
delegate, based on the valuation and valuation adjustment models approved by Trading and Counterparty Risk
Committee (TCRC), with outcomes monitored under the valuation Risk Appetite Statement established by Group
Financial Risk Committee (GFRC) and TCRC.
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 Group Financial Risk Committee (GFRC) is the highest committee
next to Management Board Banking (MBB) to discuss and approve global policies, methodologies and risk appetite
related to Financial Risk. The Trading and Counterparty Risk Committee (TCRC) 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 Banking Book Parameter Committee (BBPC) discusses the valuation topics
for non-Financial Market and non-Group Treasury Wholesale Banking portfolios. 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\u00a0defers 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. The adjustments in fair value and
the DOP reserve are 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
2025
2024
Opening balance at 1 January
-94
-90
DOP deferred on new transactions during the period
-37
-62
DOP recognised in the statement of profit or loss during the period:
\u2013 of which release
13
27
\u2013 of which amortisation and exchange differences
27
32
Closing balance at 31 December
-91
-94
The following table presents the adjustments in fair value for financial assets and liabilities.
Adjustments in fair value on financial assets and liabilities
in EUR million
2025
2024
Deferred Day One Profit or Loss
-91
-94
Own Credit Adjustments
-57
-17
Bid/Offer
-130
-130
Model Risk
-48
-33
CVA
-88
-123
DVA
43
50
CollVA
-11
-3
FVA
-82
-64
Other Valuation Adjustments
3
2
Total Valuation Adjustments
-462
-412
Own Credit Adjustment
Own issued debt and structured notes that are designated at fair value through profit or loss are adjusted for ING\u2019s
own credit risk by means of DVA.\u00a0
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:
\u00a7 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).
\u00a7 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
2025
2024
2025
2024
2025
2024
2025
2024
Financial Assets
Financial assets at fair value
through profit or loss
- Equity securities
21,395
20,798
4
15
187
141
21,586
20,954
- Debt securities
6,492
7,485
2,793
4,596
1,934
3,505
11,219
15,586
- Derivatives
52
1
25,178
31,792
773
475
26,003
32,268
- Loans and receivables
0
0
65,811
62,168
8,542
6,614
74,352
68,782
27,940
28,285
93,785
98,571
11,435
10,734
133,160
137,590
Financial assets at fair value
through other
comprehensive income
- Equity securities
2,301
2,292
0
0
307
270
2,607
2,562
- Debt securities
49,529
39,859
1,288
2,360
0
0
50,817
42,219
- Loans and receivables
0
0
3,238
1,608
0
0
3,238
1,608
51,829
42,151
4,526
3,967
307
270
56,662
46,389
Financial liabilities
Financial liabilities at fair
value through profit or loss
\u2013\u00a0 Debt securities
899
824
7,289
8,437
15
67
8,204
9,328
\u2013\u00a0 Deposits
0
0
47,751
45,648
0
0
47,751
45,648
\u2013\u00a0 Trading securities
2,534
3,631
11
12
9
10
2,554
3,653
\u2013\u00a0 Derivatives
152
45
21,090
27,528
777
694
22,019
28,267
3,585
4,501
76,142
81,625
802
770
80,529
86,896
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 for financial assets measured at fair value through
profit or loss a EUR 0.3 billion (2024: nil) transfer from Level 1 to Level 2 and a EUR 0.4 billion (2024: EUR 0.8 billion)
transfer from Level 2 to Level 1 within debt securities. For financial liabilities measured at fair value through profit or
loss, EUR 0.2 billion (2024: nil) of trading securities were transferred from Level 2 to Level 1. No other significant
transfers between Level 1 and Level 2 were recorded during the 2025 reporting period (2024: nil).
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 2025 of EUR 11.7 billion (2024: EUR
11.0 billion), an amount of EUR 10.1 billion (86.2%) (2024: EUR 9.6 billion, being 87.2%) 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 (2024: EUR 0.1 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 1.5 billion (2024: EUR 1.3 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 2025 of EUR 0.8 billion (2024: EUR
0.8 billion), an amount of EUR 0.6 billion (72.7%) (2024: EUR 0.6 billion, being 75.7%) 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 liabilities include EUR 0.1 billion (2024: EUR 0.1 billion) which relates to financial
liabilities that are part of structures that are designed to be fully neutral in terms of market risk. As explained
above, the fair value of each of the components of these structures may be sensitive to unobservable inputs, but
the overall sensitivity is by design not significant.
The remaining EUR 0.1 billion (2024: 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
2025
2024
2025
2024
2025
2024
2025
2024
At fair value through profit or loss
Debt securities
1,934
3,504
9
10
Price based
Price (%)
0%
0%
103%
120%
Price (price per share)
201
327
412
520
Present value techniques
Price (%)
n.a.
95.85%
n.a.
100%
Equity securities
187
141
Price based
Price (price per share)
0
0
5,475
5,475
Loans and advances
1,978
1,565
0
0
Price based
Price (%)
0%
0%
109%
107%
Present value techniques
Credit spread (bps)
120
576
709
629
Prepayment rate (%)
2%
2%
2%
100%
(Reverse) repos
6,563
5,050
Present value techniques
Interest rate (%)
n.a.
2%
n.a.
2%
Structured notes
15
67
Price based
Price (%)
96%
93%
103%
104%
Option pricing model
Equity volatility (%)
18%
n.a.
22%
n.a.
Equity/Equity correlation
0.7
0.7
0.8
0.7
Equity/FX correlation
-0.6
n.a.
0.2
n.a.
Dividend yield (%)
0.4%
n.a.
1.9%
n.a.
Present value techniques
Prepayment rate (%)
n.a.
99.59%
n.a.
100.09%
Derivatives
\u2013\u00a0\u00a0Rates
628
413
670
389
Option pricing model
Interest rate volatility (bps)
45
n.a.
91
n.a.
Present value techniques
Reset spread (%)
1%
2%
1%
2%
\u2013\u00a0\u00a0FX
2
6
4
8
Option pricing model
Implied volatility (%)
1.7%
2%
42%
15%
\u2013\u00a0\u00a0Credit
134
39
48
241
Present value techniques
Credit spread (bps)
10
0
88
91
Price based
Price (%)
0%
0%
100%
100%
\u2013\u00a0\u00a0Equity
7
10
46
47
Option pricing model
Equity volatility (%)
13%
7%
75%
81%
Equity/Equity correlation
0.0
0.0
1.0
1.0
Equity/FX correlation
-0.7
-0.6
0.5
0.6
Dividend yield (%)
0%
0%
51%
33%
\u2013\u00a0\u00a0Other
2
6
10
9
Option pricing model
Commodity volatility (%)
20%
13.1%
76%
61%
Com/FX correlation
-0.25
-0.40
-0.25
-0.25
Price based
Price (commodity)
66
68
66
68
At fair value through other comprehensive income
\u2013\u00a0\u00a0Equity
307
270
Present value techniques
Credit spread (bps)
5.15
5.67
5.15
5.76
Interest rate (%)
2.5%
1.5%
2.5%
3.5%
Payout ratio (%)
70%
70%
90%
90%
Price based
Price (%)
n.a.
122%
n.a.
122%
Price (price per share)
126
n.a
126
n.a
Total
11,742
11,005
802
770
1The 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
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
Opening balance as at 1 January
824
848
68
286
5,721
3,499
4,121
3,547
270
938
11,005
9,118
Realised gain/loss\u00a0 recognised in the statement of profit or loss during the period 1
247
-175
63
-38
211
294
-798
-54
-278
28
Revaluation recognised in other comprehensive income during the period 2
8
-3
8
-3
Purchase of assets
953
486
0
198
5,177
4,424
1,208
1,600
182
154
7,520
6,862
Sale of assets
-109
-111
0
-257
-1,765
-1,605
-1,160
-10
-163
-418
-3,197
-2,402
Maturity/settlement
-128
-140
0
-7
-166
-294
-763
-988
0
-20
-1,057
-1,449
Reclassifications
0
0
-1
0
18
0
0
0
10
0
28
0
Transfers into Level 3
316
370
0
0
824
615
0
30
0
0
1,139
1,014
Transfers out of Level 3
-974
-454
-9
-114
-2,389
-1,214
0
-3
0
-384
-3,372
-2,169
Exchange rate differences
-14
0
0
0
-6
5
-33
-2
0
9
-53
12
Changes in the composition of the group and other changes
0
0
0
0
0
-1
0
0
0
-5
0
-6
Closing balance
1,114
824
121
68
7,625
5,721
2,576
4,121
307
270
11,742
11,005
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 280 million (2024: EUR -41 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 2025, transfers out of Level 3 within trading assets relate mainly to securities, as their valuations were no longer
significantly influenced by unobservable inputs. In 2024, transfers out of Level 3 in trading assets primarily involved
derivative instruments, as their valuations were no longer significantly impacted by unobservable inputs.
In 2025 and 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. In 2024, the
transfer out of Level 3 in non-trading derivatives primarily involved derivative instruments, as their valuations were
no longer significantly impacted by unobservable inputs.
In 2025 and 2024, 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 out of Level 3 of financial assets at FVOCI relates to Hold-to-Collect and Sell portfolio
transferred to Level 2 resulting from change in methodology.
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
2025
2024
2025
2024
2025
2024
2025
2024
Opening balance as at 1
January
637
382
67
301
67
47
770
729
Realised gain/loss recognised
in the statement of profit or
loss during the period 1
81
-104
82
-98
-6
-5
157
-206
Additions
205
55
3
190
11
29
219
274
Redemptions
-74
-12
0
-209
0
0
-74
-222
Maturity/settlement
-160
-15
0
-7
-64
-4
-225
-26
Transfers into Level 3
19
364
0
0
19
34
38
399
Transfers out of Level 3
-72
-33
0
-111
-12
-34
-84
-179
Exchange rate differences
-1
0
0
0
0
0
-1
0
Closing balance
636
637
151
67
15
67
802
770
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 158 million
(2024: EUR -206\u00a0million) of unrealised gains and losses recognised in the statement of profit or loss.
In 2025, the transfers out of Level 3 mainly consisted of trading liabilities related to securities transferred out of
Level 3 as a result of the valuation being no longer impacted by significantly unobservable inputs.
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.
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
2025
2024
2025
2024
Equity (equity derivatives, structured notes)
20
21
-12
-20
Interest rates (Rates derivatives, FX derivatives)
1
5
0
0
Credit (Debt securities, Loans, structured notes, credit derivatives)
12
2
-14
-27
Loans and advances
0
0
0
0
33
28
-26
-47
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 value 1
Level 1
Level 2
Level 3
Total fair value
in EUR million
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
Financial Assets
Loans and advances to banks
21,204
21,769
3,053
3,194
14,722
15,614
3,366
2,957
21,141
21,766
Loans and advances to customers
721,779
680,299
18,233
18,296
12,782
18,626
678,392
630,493
709,408
667,415
Securities at amortised cost
53,867
50,273
47,722
42,871
2,381
2,908
2,692
2,523
52,796
48,303
796,850
752,341
21,286
21,490
47,723
42,871
29,885
37,149
684,450
635,973
783,344
737,483
Financial liabilities
Deposits from banks
18,521
16,722
5,401
4,347
9,162
8,208
3,745
3,943
18,308
16,498
Customer deposits
724,707
699,725
621,172
582,511
85,801
69,790
17,433
46,984
724,406
699,285
Debt securities in issue
103,116
94,459
36,782
33,019
62,567
59,141
3,857
2,000
103,207
94,161
Senior non-preferred debt
48,090
49,393
49,155
50,230
49,155
50,230
Subordinated loans
18,100
17,879
18,722
18,357
18,722
18,357
912,534
878,178
626,573
586,857
36,782
33,019
225,408
205,726
25,035
52,927
913,798
878,530
1In 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, excluding the negative macro fair value hedge adjustment.
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.
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
There is an embedded value in our on-demand deposits. However, for the purpose of this disclosure, and in
accordance with IFRS, the fair value of deposits with an immediate on demand feature approximates the carrying
amount, excluding the negative macro fair value hedge adjustment.
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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-696": { "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. Netting is applicable to repurchase
agreements that are governed by an established Global Master Repurchase Agreement (GMRA) when ING has the
intention to settle net. This netting is restricted to transactions involving the same currency and maturity date,
and must occur within the same legal entity. Reference is made to Note 38 '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. 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.\u00a0
Reference is made to Note 37 '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
2025
2024
Reverse repurchase transactions
Loans and advances to banks
6,836
10,777
Loans and advances to customers
3,866
3,471
Trading assets, loans and receivables
1,574
12,033
Loans and receivables mandatorily measured at fair value through profit or loss
68,469
53,393
80,746
79,675
Repurchase transactions
Deposits from banks
330
33
Customer deposits
182
1
Trading liabilities, funds on deposit
31
5,269
Funds entrusted designated and measured at fair value through profit or loss
46,211
38,420
46,755
43,723
", "dimensions": { "concept": "ifrs-full:DisclosureOfRepurchaseAndReverseRepurchaseAgreementsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-698": { "value": "
Trading assets
Trading assets by type
in EUR million
2025
2024
Equity securities
21,276
20,726
Debt securities
8,120
10,080
Derivatives
24,346
29,805
Loans and receivables
1,991
12,295
55,734
72,906
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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-697": { "value": "
Trading assets
Trading assets by type
in EUR million
2025
2024
Equity securities
21,276
20,726
Debt securities
8,120
10,080
Derivatives
24,346
29,805
Loans and receivables
1,991
12,295
55,734
72,906
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
2025
2024
Equity securities
682
467
Debt securities
1,872
3,185
Funds on deposit
191
5,437
Derivatives
20,681
26,166
23,427
35,255
", "dimensions": { "concept": "ifrs-full:DisclosureOfFinancialInstrumentsHeldForTradingExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-699": { "value": "
Non-trading derivatives
Non-trading derivatives by type
in EUR million
2025
2024
Derivatives used in
-\u00a0 fair value hedges
578
617
-\u00a0 cash flow hedges
459
158
-\u00a0 hedges of net investments in foreign operations
68
82
Other non-trading derivatives
550
1,606
1,657
2,463
Reference is made to Note 34 '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
2025
2024
Derivatives used in:
-\u00a0 fair value hedges
54
79
-\u00a0 cash flow hedges
254
573
-\u00a0 hedges of net investments in foreign operations
74
117
Other non-trading derivatives
957
1,332
1,338
2,101
Reference is made to Note 34 '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.
34\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 hedges of interest rate risk, 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
2025
Liabilities
2025
Assets
2024
Liabilities
2024
As at 31 December
Hedging instrument on interest rate risk
\u2013 Interest rate swaps
26,279
19,625
26,963
24,107
\u2013 Other interest derivatives
213
13
207
23
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 578 million (2024: EUR 617
million) respectively \u2018Financial liabilities at fair value through profit or loss \u2013 Non-trading derivatives\u2019 EUR 54 million
(2024: EUR 79 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
1.85% (2024: 1.69%) for EUR and 4.43% (2024: 4.22%) 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
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
As at 31 December 2025
Hedging instrument on
interest rate risk
\u2013 Interest rate swaps
4,133
304
17,551
-373
10,494
2,859
-2,524
-52,863
-20,419
\u2013 Other interest derivatives
-3
93
229
131
-303
184
212
260
803
As at 31 December 2024
Hedging instrument on
interest rate risk
- 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
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 2025
Interest rate risk and FX rate risk
\u2013 Debt securities at fair value through other comprehensive income
44,165
n/a
-480
\u2013 Loans at FVOCI
n/a
\u2013 Loans and advances to customers
71,093
-7,441
-2,352
\u2013 Debt instruments at amortised cost
20,695
-438
-284
\u2013 Debt securities in issue
40,839
-1,193
280
\u2013 Senior non-preferred debt
46,566
-934
-325
\u2013 Subordinated loans
18,058
-327
-287
\u2013 Customer deposits and other funds on deposit
10,040
-9
3
\u2013 Discontinued hedges
1,444
Total
135,953
115,502
-6,435
-2,463
-3,445
3,481
36
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
During 2025, 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 2025. Refer to Note 23 'Valuation results and net trading income'.
In addition, the net increase in hedged items is mainly due to higher volumes in debt securities as well as the
extension of the macro fair value hedge on core deposits in 2025. 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:
\u00a7 differences in maturities of the hedged item(s) and hedging instrument(s);
\u00a7 different interest rate curves applied to discount the hedged item(s) and hedging instrument(s);
\u00a7 differences in timing of cash flows of the hedged item(s) and hedging instrument(s).
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
2025
2025
2024
2024
As at 31\u00a0December
Hedging instrument on interest rate risk
\u2013 Interest rate swaps
9,414
10,066
10,635
12,814
Hedging instrument on FX rate risk
\u2013 Cross currency swaps
1,042
139
472
339
Hedging instrument on combined interest and FX rate risk
\u2013 Cross currency interest rate swaps
63
10
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 459 million (2024: EUR 158
million) respectively \u2018Financial liabilities at fair value through profit or loss \u2013 Non-trading derivatives\u2019 EUR 254
million (2024: EUR 573 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
1.81% (2024: 1.79%) for EUR, 4.27% (2024: 4.37%) for PLN, 3.85% (2024: 3.99%) for USD and 3.38% (2024: 3.29%)
for AUD. The average currency exchange rates for cross currency interest rate swaps used in cash flow hedge
accounting is for EUR/USD 0.97 (2024: 1.03) and for EUR/AUD 1.56 (2024: 1.52).
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
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
As at 31 December 2025
Hedging instrument on interest
rate risk
\u2013 Interest rate swaps
-2,023
-3,542
-6,217
-15,357
-14,152
-4,549
-4,381
-11,676
-61,897
Hedging instrument on FX rate
risk
\u2013 Cross currency swaps
456
964
654
-1,271
-446
607
-601
-1,572
-1,210
Hedging instrument on combined
interest and FX rate risk
\u2013 Cross currency interest rate
swaps
-1,246
-1,518
-2,765
As at 31 December 2024
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
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
ineffectiveness
for the period
Carrying
amount cash
flow hedge
reserve at the
end of the
reporting
period 1
Amount
reclassified
from CFH
reserve to
profit or loss 2
Change in
value of
hedging
instrument
recognised in
OCI for the
period
Hedge
ineffectiveness
recognised in
the statement
of profit or
loss, gain (+) /
loss (-)
As at 31 December 2025
Interest rate risk on:
\u2013 Floating rate lending
-1,265
-1,157
536
\u2013 Floating rate borrowing
289
-141
-146
\u2013 Other
\u2013 Discontinued hedges
-323
7
Total interest rate risk
-977
-1,619
397
602
7
FX rate risk on:
\u2013 Floating rate lending
-15
-58
-171
\u2013 Floating rate borrowing
34
-4
-38
\u2013 Other
\u2013 Discontinued hedges
-1
Total FX risk
20
-62
-209
195
3
Combined interest and FX rate risk on:
\u2013 Floating rate lending
37
47
-39
\u2013 Floating rate borrowing
\u2013 Other
\u2013 Discontinued hedges
Total combined interest and FX risk
37
47
-39
2
1
Total cash flow hedge
-920
-1,635
149
799
10
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
ineffectiveness
for the period
Carrying
amount cash
flow hedge
reserve at the
end of the
reporting
period 1
Amount
reclassified
from CFH
reserve to
profit or loss 2
Change in
value of
hedging
instrument
recognised in
OCI for the
period
Hedge
ineffectiveness
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
1The carrying amount is the gross amount, excluding tax adjustments.
2The amounts are reclassified to Net interest income - interest income and/or expense on non-trading derivatives (hedge accounting).
In 2025, EUR -1 million was reclassified from CFH reserve to profit or loss for cash flows that are no longer expected
to occur (2024: nil).
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 2025.
The main sources of ineffectiveness for cash flow hedges are:
\u00a7 Differences in timing of cash flows of the hedged item(s) and hedging instrument(s); and
\u00a7 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
2025
2024
Opening balance
-1,693
-2,058
Value changes recognised in OCI
799
743
Amounts recycled to profit or loss
149
-209
Income tax
-175
-140
Exchange rate and other changes
-12
-14
Adjustment for non controlling interest
-163
-14
Movement for the year
597
365
Ending balance
-1,096
-1,693
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 of. 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
2025
2025
2024
2024
As at 31 December
\u2013 FX forwards and Cross currency swaps
68
74
82
117
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 68 million (2024: EUR 82
million) respectively \u2018Financial liabilities at fair value through profit or loss \u2013 Non trading derivatives\u2019 EUR 74 million
(2024: EUR 117 million).
For ING\u2019s main currencies the average exchange rates used in net investment hedge accounting for 2025 are EUR/USD
1.12 (2024: 1.08), EUR/PLN 4.24 (2024: 4.31), EUR/AUD 1.75 (2024: 1.64) and EUR/THB 36.98 (2024: 38.00).
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
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
As at 31 December 2025
\u2013 FX forwards and cross
currency swaps
-6,683
-4,298
-86
-11,066
As at 31 December 2024
\u2013 FX forwards and Cross
currency swaps
-8,681
-4,158
-76
-12,916
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
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(-)
As at 31 December 2025
Investment in foreign operations
-816
488
816
Discontinued hedges
535
As at 31 December 2024
Investment in foreign operations
295
-95
-295
Discontinued hedges
302
1The carrying amount is the gross amount, excluding tax adjustments.
", "dimensions": { "concept": "ifrs-full:DisclosureOfDerivativeFinancialInstrumentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-700": { "value": "
Designated at fair value through profit or loss
Designated at fair value through profit or loss by type
in EUR million
2025
2024
Debt securities
2,330
4,718
Loans and receivables
1,118
1,022
3,448
5,740
\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 3,448 million (2024: EUR 5,740 million). In 2025, the change in fair value of these loans
and debt securities amounts to EUR -177\u00a0million (2024: EUR 5\u00a0million).
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
2,454 million (2024: EUR 3,797 million). The cumulative change in fair value attributable to changes in credit risk for
the financial asset economically hedged is EUR 85 million (2024: EUR 173 million) and the change for the current
year is EUR -88\u00a0million (2024: EUR 24\u00a0million). The cumulative change in fair value attributable to changes in credit
risk for the financial assets non-economically hedged with credit derivatives is EUR 513\u00a0million (2024: EUR
489\u00a0million) and the change for the current year is EUR 23\u00a0million.
The notional value of the related credit derivatives is EUR 2,486 million (2024: EUR 3,807 million). The cumulative
change in fair value of the credit derivatives since the financial assets were first designated, amounts to EUR
-85\u00a0million (2024: EUR -214\u00a0million) and the change for the current year is EUR 128\u00a0million (2024: EUR -95\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
2025
2024
Debt securities
8,202
9,326
Funds entrusted
47,431
40,092
Subordinated liabilities
131
122
55,764
49,539
As at 31\u00a0December 2025, the change in the fair value of financial liabilities designated at fair value through profit
or loss attributable to changes in credit risk is EUR 57 million on a cumulative basis (2024: EUR\u00a0 17 million ). This
change has been determined as the amount of change in fair value of the financial liability that is not attributable
to changes in market conditions that gave rise to market risk (i.e. mainly interest-rate risk based on yield curves).
The amount that ING 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
9,574 million ( 2024: EUR\u00a011,376 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-701": { "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
2025
2024
Debt securities at fair value through other comprehensive income
50,817
42,219
Debt securities at amortised cost
53,867
50,273
Total debt securities at fair value through other comprehensive income and amortised cost
104,684
92,493
Trading assets
8,120
10,080
Debt securities designated and measured at fair value through profit or loss
2,330
4,718
Debt securities mandatorily measured at fair value through profit or loss
769
789
Total debt securities at fair value through profit or loss
11,219
15,586
115,903
108,078
ING Bank\u2019s total exposure to debt securities (excluding debt securities held in the trading portfolio) of EUR 107,783
million ( 31\u00a0December 2024: EUR 97,999 million ) is specified as follows:
Debt securities by type of exposure
Debt Securities at
FVPL 1
Debt Securities at
FVOCI
Debt Securities at
AC
Total
in EUR million
2025
2024
2025
2024
2025
2024
2025
2024
Government bonds
288
289
32,578
24,757
25,297
22,734
58,163
47,780
Central bank bonds
376
444
2,541
2,900
2,917
3,344
Sub-sovereign, Supranationals
and Agencies
413
1,027
13,788
11,513
16,744
15,445
30,945
27,985
Covered bonds
3,750
4,108
5,362
5,683
9,111
9,791
Corporate bonds
89
848
109
79
50
106
248
1,033
Financial institutions' bonds
1,176
2,141
28
980
96
139
1,300
3,261
ABS portfolio
757
757
578
794
3,790
3,281
5,125
4,832
3,099
5,506
50,832
42,231
53,879
50,288
107,809
98,026
Loan loss provisions
-15
-12
-11
-15
-26
-27
Debt securities portfolio
3,099
5,506
50,817
42,219
53,867
50,273
107,783
97,999
1Debt 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 relate to debentures and other issued debt securities with either fixed interest rates or
interest rates based on floating interest rate levels, such as certificates of deposit and accepted bills issued by ING
Bank, except for subordinated items. Debt securities in issue do not include debt securities presented as Financial
liabilities at fair value through profit or loss. ING 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
2025
2024
Fixed rate debt securities
Within 1 year
30,850
26,358
More than 1 year but less than 2 years
4,401
5,718
More than 2 years but less than 3 years
6,851
4,429
More than 3 years but less than 4 years
6,081
5,907
More than 4 years but less than 5 years
5,463
6,105
More than 5 years
12,393
12,335
Total fixed rate debt securities
66,039
60,851
Floating rate debt securities
Within 1 year
28,774
26,262
More than 1 year but less than 2 years
1,004
2,343
More than 2 years but less than 3 years
830
1,080
More than 3 years but less than 4 years
1,056
117
More than 4 years but less than 5 years
913
902
More than 5 years
4,501
2,903
Total floating rate debt securities
37,077
33,607
Total debt securities
103,116
94,459
Reference is made to the Consolidated statement of cash flows for more information on issuances, redemptions
and non-cash movements.
18\u00a0 Senior non-preferred debt
Senior non-preferred debt
In EUR million
2025
2024
Senior non-preferred debt
48,090
49,393
48,090
49,393
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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-702": { "value": "
7\u00a0 Loans and advances to customers
Loans and advances to customers by type
Netherlands
Rest of the world
Total
in EUR million
2025
2024
2025
2024
2025
2024
Loans and advances to public authorities
3,452
1,888
19,583
16,773
23,034
18,661
Residential mortgages
126,772
117,223
242,297
227,992
369,069
345,216
Other personal lending
5,033
5,007
34,690
31,789
39,723
36,797
Corporate Lending
68,866
66,987
226,981
218,473
295,847
285,459
204,122
191,105
523,551
495,027
727,673
686,132
Loan loss provisions
-836
-811
-5,058
-5,023
-5,894
-5,833
203,286
190,295
518,493
490,004
721,779
680,299
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 2025 EUR 721,543 million (2024 : EUR 680,085 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
2025
2024
Maturities of gross investment in finance lease receivables
-\u00a0 within 1 year
4,121
3,962
-\u00a0 between 1-2 years
3,040
2,961
-\u00a0 between 2-3 years
2,408
2,283
-\u00a0 between 3-4 years
1,563
1,577
-\u00a0 between 4-5 years
935
902
-\u00a0 more than 5 years
1,609
1,555
13,677
13,240
Unearned future finance income on finance leases
-1,122
-1,145
Net investment in finance leases
12,554
12,095
Included in Loans and advances to banks
3
5
Included in Loans and advances to customers
12,551
12,091
12,554
12,095
1The total loan loss provision for finance lease receivables is EUR 191 million (2024: EUR\u00a0 193 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 2025 on finance lease receivables
amounts to EUR 513 million (2024: EUR 522 million).
", "dimensions": { "concept": "ifrs-full:DisclosureOfLoansAndAdvancesToCustomersExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-703": { "value": "
Finance lease receivables 1
in EUR million
2025
2024
Maturities of gross investment in finance lease receivables
-\u00a0 within 1 year
4,121
3,962
-\u00a0 between 1-2 years
3,040
2,961
-\u00a0 between 2-3 years
2,408
2,283
-\u00a0 between 3-4 years
1,563
1,577
-\u00a0 between 4-5 years
935
902
-\u00a0 more than 5 years
1,609
1,555
13,677
13,240
Unearned future finance income on finance leases
-1,122
-1,145
Net investment in finance leases
12,554
12,095
Included in Loans and advances to banks
3
5
Included in Loans and advances to customers
12,551
12,091
12,554
12,095
1The total loan loss provision for finance lease receivables is EUR 191 million (2024: EUR\u00a0 193 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 2025 on finance lease receivables
amounts to EUR 513 million (2024: EUR 522 million).
9\u00a0 Property and equipment
Property and equipment by type
in EUR million
2025
2024
Property in own use
863
758
Equipment:
- Data processing equipment
197
218
- Other equipment
447
426
Right- of- use assets:
- ROU property
837
895
- ROU cars
123
124
- ROU other leases
12
13
2,478
2,434
Changes in property and equipment
Property in own use
Equipment
Right-of-use assets
Total
in EUR million
2025
2024
2025
2024
2025
2024
2025
2024
Opening balance as at 1 January
758
616
643
705
1,033
1,078
2,434
2,399
Additions
147
92
203
240
160
141
510
473
Transfers
-15
83
11
-78
-4
-3
1
Depreciation
-11
-11
-194
-204
-237
-242
-442
-457
Impairments1
-8
-9
-6
-10
-3
-4
-16
-23
Reversals of impairments 1
6
5
7
5
Remeasurements
15
5
40
75
56
80
Disposals
-28
-36
-11
-14
-10
-18
-48
-68
Exchange rate differences
-3
13
-3
5
-12
8
-18
25
Closing balance
863
758
644
643
972
1,033
2,478
2,434
Cost price
994
871
2,827
3,027
1,982
1,933
5,803
5,831
Accumulated depreciation
-299
-298
-2,176
-2,376
-1,237
-1,098
-3,712
-3,772
Accumulated impairments
-95
-97
-7
-8
-31
-31
-134
-136
Accumulated revaluation surplus
264
282
264
282
Accumulated remeasurement
258
229
258
229
Net carrying value
863
758
644
643
972
1,033
2,478
2,434
1Impairments and reversals of impairments of property and equipment are presented as Other operating expenses in the statement of Profit or Loss.
ING considers valuations from third-party experts in determining the fair values of property in own use. The vast
majority of the land and buildings were appraised during 2025. Property in own use purchase costs amounted to
EUR 994 million (2024: EUR\u00a0871 million ). Cost or the purchase price less accumulated depreciation and
impairments would have been EUR 599 million ( 2024: EUR 476 million) had property in own use been valued at
cost instead of at fair value.
16\u00a0 Other liabilities
Other liabilities by type
In EUR million
2025
2024
Net defined benefit liability
141
152
Other post-employment benefits
42
38
Other staff-related liabilities
798
784
Other taxation and social security contributions
837
899
Rents received in advance
15
14
Costs payable
2,021
1,763
Amounts to be settled
4,188
4,290
Lease liabilities
1,050
1,116
Other
1,665
1,538
10,755
10,596
Disclosures in respect of Net defined benefit liabilities are provided in Note 30 'Pensions and other post-
employment benefits'. Other staff-related liabilities comprise provisions for vacation leave, jubilee, disability and
illness, as well as liabilities for variable compensations.
Lease liabilities relate to right-of-use assets. Disclosures regarding right-of-use assets are provided in Note 9
'Property and equipment'. The total cash outflow for leases in 2025 was EUR 282\u00a0million (2024: EUR 290\u00a0million).
", "dimensions": { "concept": "ifrs-full:DisclosureOfLeasesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-706": { "value": "
8\u00a0 Investment in associates and joint ventures
Investments in associates and joint ventures
2025
2024
in EUR million
Interest
held (%)
Fair value of
listed
investments
Balance
sheet value
Interest held
(%)
Fair value of
listed
investments
Balance
sheet value
TMBThanachart Bank Public
Company Limited
23%
1,212
1,307
23%
1,164
1,266
Other investments in associates and
joint ventures
300
412
1,607
1,679
TMBThanachart Bank Public Company Limited
ING Bank has an 23% investment in TMBThanachart Bank Public Company Limited (hereafter: TTB), a bank listed on
the stock exchange of Thailand. TTB is providing products and services to wholesale, small and medium enterprise
(SME), and retail customers. TTB is accounted for as an investment in associate based on the size of ING's
shareholding and representation on the Board. The investment in TTB is reflected in the Corporate Line.
A summary of the unaudited financial information of TTB as of the end of September 2025 based on the data
available at the time the consolidated financial statements were prepared is presented below. TTB\u2019s statutory
reporting date is 31 December. For the year ending 31 December 2025, ING recognised the associate\u2019s results
using TTB\u2019s financial statements for the 12\u2011month period ending 30 September 2025.
Selected balance sheet information TMBThanachart Bank Public Company Limited
As at 30 September
in EUR million
2025
2024
Loans to customers and accrued interest receivables, net
31,009
33,878
Interbank and money market items, net
5,856
7,152
Investments, net
5,917
4,680
Other
3,158
3,436
Total assets
45,940
49,147
Deposits
34,345
36,563
Interbank and money market items
2,663
2,633
Debts issued and borrowings
462
1,139
Other
1,942
2,218
Total liabilities
39,412
42,554
Equity
6,529
6,593
Selected profit or loss information TMBThanachart Bank Public Company Limited
For the 12 months ended 30 September
in EUR million
2025
2024
Total operating income
1,795
1,991
Total expenses
1,266
1,548
Profit for the period
555
586
Total other comprehensive income for the period
170
17
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.
Significant influence for associates in which the interest held is below 20%, is based on the combination of ING\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
2025
2024
Opening balance as at 1 January
1,679
1,509
Additions
1
26
Transfers
-29
-7
Revaluations
35
0
Share of results
209
205
Dividends received
-160
-91
Disposals
-66
-16
Impairments
-9
-35
Exchange rate differences
-54
87
Closing balance
1,607
1,679
Share of results from associates and joint ventures of EUR 209 million (2024: EUR 205 million) as included in the
table above is mainly attributable to our share in the results of TTB of EUR 136\u00a0million (2024: EUR 123 million) and
a EUR 44 million gain from the sale of an associate in Belgium, while 2024 included EUR 77 million as our share in
the result of an associate in Belgium following its one-off profit.
Impairments and reversal thereof on the investment in TTB
Accumulated impairments on the investment in TTB of EUR 395\u00a0million (2024: EUR 395\u00a0million) were recognised in
previous years. There is no impairment trigger observed as per 31 December 2025. 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 the VIU did not significantly exceed the
carrying amount of the investment in TTB, no reversal of impairment was recognised.
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and VIU. Fair value less
costs of disposal is based on observable share price. The VIU calculation uses discounted cash flow projections
based on management\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:
\u00a7 The estimation of future earnings over a 5-year forecast period; and
\u00a7 The terminal value being the extrapolation of earnings into perpetuity applying a long-term growth rate. The
earnings that are used for extrapolation represent the stable long-term financial results and position of TTB, i.e.
a steady state. The terminal value comprises the majority of the total VIU.
Key assumptions used in the VIU calculation as at 31 December 2025
The VIU is determined using a valuation model which is subject to multiple management assumptions. The key
assumptions, i.e. those to which the overall result is most sensitive to, are the following:
\u00a7 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;
\u00a7 Discount rate (cost of equity): 10.17% (2024: 10.96%), based on the capital asset pricing model (CAPM)
calculated for TTB using current market data and expert judgement; and
\u00a7 Terminal growth rate: 2.41% (2024: 2.74%) consistent with current long term government bond yield in
Thailand as a proxy for a risk-free rate.
The model was evaluated for reasonably possible changes to key assumptions in the model. This reflects the
sensitivity of the VIU to each key assumption on its own and it is possible that more than one favourable and/or
unfavourable change may occur at the same time. The selected rates of reasonably possible changes to key
assumptions are based on external analysts\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:
\u00a7 A favourable change of 10% in the cash flows would result in an increase in VIU of EUR 89 million (2024: EUR 57
million), while an unfavourable change of -10% would result in a decrease in VIU of EUR -90 million (2024: EUR
-59 million);\u00a0
\u00a7 A favourable change of 1% in the discount rate would result in an increase in VIU of EUR 159 million (2024: EUR
95 million), while an unfavourable change of -1% would result in a decrease in VIU of EUR -122 million (2024:
EUR -75 million);
\u00a7 A favourable change of 1% in the terminal growth rate would result in an increase in VIU of EUR 118 million
(2024: EUR 68 million), while an unfavourable change of -1% would result in a decrease in VIU of EUR -90
million (2024: EUR -53 million).", "dimensions": { "concept": "ifrs-full:DisclosureOfInvestmentsAccountedForUsingEquityMethodExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-705": { "value": "
8\u00a0 Investment in associates and joint ventures
Investments in associates and joint ventures
2025
2024
in EUR million
Interest
held (%)
Fair value of
listed
investments
Balance
sheet value
Interest held
(%)
Fair value of
listed
investments
Balance
sheet value
TMBThanachart Bank Public
Company Limited
23%
1,212
1,307
23%
1,164
1,266
Other investments in associates and
joint ventures
300
412
1,607
1,679
TMBThanachart Bank Public Company Limited
ING Bank has an 23% investment in TMBThanachart Bank Public Company Limited (hereafter: TTB), a bank listed on
the stock exchange of Thailand. TTB is providing products and services to wholesale, small and medium enterprise
(SME), and retail customers. TTB is accounted for as an investment in associate based on the size of ING's
shareholding and representation on the Board. The investment in TTB is reflected in the Corporate Line.
A summary of the unaudited financial information of TTB as of the end of September 2025 based on the data
available at the time the consolidated financial statements were prepared is presented below. TTB\u2019s statutory
reporting date is 31 December. For the year ending 31 December 2025, ING recognised the associate\u2019s results
using TTB\u2019s financial statements for the 12\u2011month period ending 30 September 2025.
Selected balance sheet information TMBThanachart Bank Public Company Limited
As at 30 September
in EUR million
2025
2024
Loans to customers and accrued interest receivables, net
31,009
33,878
Interbank and money market items, net
5,856
7,152
Investments, net
5,917
4,680
Other
3,158
3,436
Total assets
45,940
49,147
Deposits
34,345
36,563
Interbank and money market items
2,663
2,633
Debts issued and borrowings
462
1,139
Other
1,942
2,218
Total liabilities
39,412
42,554
Equity
6,529
6,593
Selected profit or loss information TMBThanachart Bank Public Company Limited
For the 12 months ended 30 September
in EUR million
2025
2024
Total operating income
1,795
1,991
Total expenses
1,266
1,548
Profit for the period
555
586
Total other comprehensive income for the period
170
17
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.
Significant influence for associates in which the interest held is below 20%, is based on the combination of ING\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
2025
2024
Opening balance as at 1 January
1,679
1,509
Additions
1
26
Transfers
-29
-7
Revaluations
35
0
Share of results
209
205
Dividends received
-160
-91
Disposals
-66
-16
Impairments
-9
-35
Exchange rate differences
-54
87
Closing balance
1,607
1,679
Share of results from associates and joint ventures of EUR 209 million (2024: EUR 205 million) as included in the
table above is mainly attributable to our share in the results of TTB of EUR 136\u00a0million (2024: EUR 123 million) and
a EUR 44 million gain from the sale of an associate in Belgium, while 2024 included EUR 77 million as our share in
the result of an associate in Belgium following its one-off profit.
Impairments and reversal thereof on the investment in TTB
Accumulated impairments on the investment in TTB of EUR 395\u00a0million (2024: EUR 395\u00a0million) were recognised in
previous years. There is no impairment trigger observed as per 31 December 2025. 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 the VIU did not significantly exceed the
carrying amount of the investment in TTB, no reversal of impairment was recognised.
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and VIU. Fair value less
costs of disposal is based on observable share price. The VIU calculation uses discounted cash flow projections
based on management\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:
\u00a7 The estimation of future earnings over a 5-year forecast period; and
\u00a7 The terminal value being the extrapolation of earnings into perpetuity applying a long-term growth rate. The
earnings that are used for extrapolation represent the stable long-term financial results and position of TTB, i.e.
a steady state. The terminal value comprises the majority of the total VIU.
Key assumptions used in the VIU calculation as at 31 December 2025
The VIU is determined using a valuation model which is subject to multiple management assumptions. The key
assumptions, i.e. those to which the overall result is most sensitive to, are the following:
\u00a7 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;
\u00a7 Discount rate (cost of equity): 10.17% (2024: 10.96%), based on the capital asset pricing model (CAPM)
calculated for TTB using current market data and expert judgement; and
\u00a7 Terminal growth rate: 2.41% (2024: 2.74%) consistent with current long term government bond yield in
Thailand as a proxy for a risk-free rate.
The model was evaluated for reasonably possible changes to key assumptions in the model. This reflects the
sensitivity of the VIU to each key assumption on its own and it is possible that more than one favourable and/or
unfavourable change may occur at the same time. The selected rates of reasonably possible changes to key
assumptions are based on external analysts\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:
\u00a7 A favourable change of 10% in the cash flows would result in an increase in VIU of EUR 89 million (2024: EUR 57
million), while an unfavourable change of -10% would result in a decrease in VIU of EUR -90 million (2024: EUR
-59 million);\u00a0
\u00a7 A favourable change of 1% in the discount rate would result in an increase in VIU of EUR 159 million (2024: EUR
95 million), while an unfavourable change of -1% would result in a decrease in VIU of EUR -122 million (2024:
EUR -75 million);
\u00a7 A favourable change of 1% in the terminal growth rate would result in an increase in VIU of EUR 118 million
(2024: EUR 68 million), while an unfavourable change of -1% would result in a decrease in VIU of EUR -90
million (2024: EUR -53 million).", "dimensions": { "concept": "ifrs-full:DisclosureOfSignificantInvestmentsInAssociatesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-704": { "value": "
8\u00a0 Investment in associates and joint ventures
Investments in associates and joint ventures
2025
2024
in EUR million
Interest
held (%)
Fair value of
listed
investments
Balance
sheet value
Interest held
(%)
Fair value of
listed
investments
Balance
sheet value
TMBThanachart Bank Public
Company Limited
23%
1,212
1,307
23%
1,164
1,266
Other investments in associates and
joint ventures
300
412
1,607
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.
Significant influence for associates in which the interest held is below 20%, is based on the combination of ING\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
2025
2024
Opening balance as at 1 January
1,679
1,509
Additions
1
26
Transfers
-29
-7
Revaluations
35
0
Share of results
209
205
Dividends received
-160
-91
Disposals
-66
-16
Impairments
-9
-35
Exchange rate differences
-54
87
Closing balance
1,607
1,679
Share of results from associates and joint ventures of EUR 209 million (2024: EUR 205 million) as included in the
table above is mainly attributable to our share in the results of TTB of EUR 136\u00a0million (2024: EUR 123 million) and
a EUR 44 million gain from the sale of an associate in Belgium, while 2024 included EUR 77 million as our share in
the result of an associate in Belgium following its one-off profit.
", "dimensions": { "concept": "ifrs-full:DisclosureOfJointVenturesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-707": { "value": "
Impairments and reversal thereof on the investment in TTB
Accumulated impairments on the investment in TTB of EUR 395\u00a0million (2024: EUR 395\u00a0million) were recognised in
previous years. There is no impairment trigger observed as per 31 December 2025. 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 the VIU did not significantly exceed the
carrying amount of the investment in TTB, no reversal of impairment was recognised.
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and VIU. Fair value less
costs of disposal is based on observable share price. The VIU calculation uses discounted cash flow projections
based on management\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:
\u00a7 The estimation of future earnings over a 5-year forecast period; and
\u00a7 The terminal value being the extrapolation of earnings into perpetuity applying a long-term growth rate. The
earnings that are used for extrapolation represent the stable long-term financial results and position of TTB, i.e.
a steady state. The terminal value comprises the majority of the total VIU.
Key assumptions used in the VIU calculation as at 31 December 2025
The VIU is determined using a valuation model which is subject to multiple management assumptions. The key
assumptions, i.e. those to which the overall result is most sensitive to, are the following:
\u00a7 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;
\u00a7 Discount rate (cost of equity): 10.17% (2024: 10.96%), based on the capital asset pricing model (CAPM)
calculated for TTB using current market data and expert judgement; and
\u00a7 Terminal growth rate: 2.41% (2024: 2.74%) consistent with current long term government bond yield in
Thailand as a proxy for a risk-free rate.
The model was evaluated for reasonably possible changes to key assumptions in the model. This reflects the
sensitivity of the VIU to each key assumption on its own and it is possible that more than one favourable and/or
unfavourable change may occur at the same time. The selected rates of reasonably possible changes to key
assumptions are based on external analysts\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:
\u00a7 A favourable change of 10% in the cash flows would result in an increase in VIU of EUR 89 million (2024: EUR 57
million), while an unfavourable change of -10% would result in a decrease in VIU of EUR -90 million (2024: EUR
-59 million);\u00a0
\u00a7 A favourable change of 1% in the discount rate would result in an increase in VIU of EUR 159 million (2024: EUR
95 million), while an unfavourable change of -1% would result in a decrease in VIU of EUR -122 million (2024:
EUR -75 million);
\u00a7 A favourable change of 1% in the terminal growth rate would result in an increase in VIU of EUR 118 million
(2024: EUR 68 million), while an unfavourable change of -1% would result in a decrease in VIU of EUR -90
million (2024: EUR -53 million).
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 2025, no triggering events were identified.\u00a0
At the annual impairment test in the fourth quarter, the recoverable amount exceeds the carrying value of the
CGUs as at 31 December 2025 and therefore no impairment is required (31 December 2024: nil).
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and Value in Use (VIU).
The VIU calculation is based on a Dividend Discount model using three-year management-approved plans,
updated for expected changes in the macroeconomic environment. When estimating the VIU of a CGU, local
conditions and requirements determine the capital requirements, discount rates, and terminal growth rates. These
local conditions and requirements determine the ability to upstream excess capital and profits to ING 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.
", "dimensions": { "concept": "ifrs-full:DisclosureOfImpairmentOfAssetsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-708": { "value": "
9\u00a0 Property and equipment
Property and equipment by type
in EUR million
2025
2024
Property in own use
863
758
Equipment:
- Data processing equipment
197
218
- Other equipment
447
426
Right- of- use assets:
- ROU property
837
895
- ROU cars
123
124
- ROU other leases
12
13
2,478
2,434
Changes in property and equipment
Property in own use
Equipment
Right-of-use assets
Total
in EUR million
2025
2024
2025
2024
2025
2024
2025
2024
Opening balance as at 1 January
758
616
643
705
1,033
1,078
2,434
2,399
Additions
147
92
203
240
160
141
510
473
Transfers
-15
83
11
-78
-4
-3
1
Depreciation
-11
-11
-194
-204
-237
-242
-442
-457
Impairments1
-8
-9
-6
-10
-3
-4
-16
-23
Reversals of impairments 1
6
5
7
5
Remeasurements
15
5
40
75
56
80
Disposals
-28
-36
-11
-14
-10
-18
-48
-68
Exchange rate differences
-3
13
-3
5
-12
8
-18
25
Closing balance
863
758
644
643
972
1,033
2,478
2,434
Cost price
994
871
2,827
3,027
1,982
1,933
5,803
5,831
Accumulated depreciation
-299
-298
-2,176
-2,376
-1,237
-1,098
-3,712
-3,772
Accumulated impairments
-95
-97
-7
-8
-31
-31
-134
-136
Accumulated revaluation surplus
264
282
264
282
Accumulated remeasurement
258
229
258
229
Net carrying value
863
758
644
643
972
1,033
2,478
2,434
1Impairments and reversals of impairments of property and equipment are presented as Other operating expenses in the statement of Profit or Loss.
ING considers valuations from third-party experts in determining the fair values of property in own use. The vast
majority of the land and buildings were appraised during 2025. Property in own use purchase costs amounted to
EUR 994 million (2024: EUR\u00a0871 million ). Cost or the purchase price less accumulated depreciation and
impairments would have been EUR 599 million ( 2024: EUR 476 million) had property in own use been valued at
cost instead of at fair value.
", "dimensions": { "concept": "ifrs-full:DisclosureOfPropertyPlantAndEquipmentExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-711": { "value": "
10\u00a0 Intangible assets
Changes in intangible assets
Goodwill
Software
Other
Total
in EUR million
2025
2024
2025
2024
2025
2024
2025
2024
Opening balance as at 1 January
476
469
855
727
3
2
1,334
1,198
Additions
6
35
43
1
35
50
Capitalised expenses
380
324
380
324
Amortisation
-223
-215
-223
-216
Impairments 1
-7
-12
-7
-12
Exchange rate differences
1
1
-10
8
-9
9
Disposals
-2
-9
-2
-9
Other changes
2
-10
1
2
-10
Closing balance
477
476
1,030
855
3
3
1,510
1,334
Gross carrying amount
477
476
3,281
2,986
9
8
3,767
3,471
Accumulated amortisation
-2,197
-2,079
-4
-4
-2,201
-2,084
Accumulated impairments
-53
-52
-1
-2
-55
-53
Net carrying value
477
476
1,030
855
3
3
1,510
1,334
1Impairments 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
Group of CGUs
2025
2024
2025
2024
2025
2024
Retail Netherlands
Value in use
7.20%
7.81%
2.00%
2.00%
30
30
Retail Germany
Value in use
7.20%
7.77%
2.20%
2.00%
356
356
Retail Poland
Value in use
8.76%
9.30%
2.50%
2.50%
77
76
Retail Romania
Value in use
10.86%
11.45%
2.60%
3.00%
14
15
477
476
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 2025, no triggering events were identified.\u00a0
At the annual impairment test in the fourth quarter, the recoverable amount exceeds the carrying value of the
CGUs as at 31 December 2025 and therefore no impairment is required (31 December 2024: nil).
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and Value in Use (VIU).
The VIU calculation is based on a Dividend Discount model using three-year management-approved plans,
updated for expected changes in the macroeconomic environment. When estimating the VIU of a CGU, local
conditions and requirements determine the capital requirements, discount rates, and terminal growth rates. These
local conditions and requirements determine the ability to upstream excess capital and profits to ING 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 956 million (2024: EUR 768 million). Software
capitalisation amounts increased in 2025 following the significant IT-platform investments in our Retail business.
Software is reviewed for indicators of impairment. Irrespective of whether there is an indication of impairment,
software under development is tested annually for impairment.
", "dimensions": { "concept": "ifrs-full:DisclosureOfIntangibleAssetsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-710": { "value": "
10\u00a0 Intangible assets
Changes in intangible assets
Goodwill
Software
Other
Total
in EUR million
2025
2024
2025
2024
2025
2024
2025
2024
Opening balance as at 1 January
476
469
855
727
3
2
1,334
1,198
Additions
6
35
43
1
35
50
Capitalised expenses
380
324
380
324
Amortisation
-223
-215
-223
-216
Impairments 1
-7
-12
-7
-12
Exchange rate differences
1
1
-10
8
-9
9
Disposals
-2
-9
-2
-9
Other changes
2
-10
1
2
-10
Closing balance
477
476
1,030
855
3
3
1,510
1,334
Gross carrying amount
477
476
3,281
2,986
9
8
3,767
3,471
Accumulated amortisation
-2,197
-2,079
-4
-4
-2,201
-2,084
Accumulated impairments
-53
-52
-1
-2
-55
-53
Net carrying value
477
476
1,030
855
3
3
1,510
1,334
1Impairments 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
Group of CGUs
2025
2024
2025
2024
2025
2024
Retail Netherlands
Value in use
7.20%
7.81%
2.00%
2.00%
30
30
Retail Germany
Value in use
7.20%
7.77%
2.20%
2.00%
356
356
Retail Poland
Value in use
8.76%
9.30%
2.50%
2.50%
77
76
Retail Romania
Value in use
10.86%
11.45%
2.60%
3.00%
14
15
477
476
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 2025, no triggering events were identified.\u00a0
At the annual impairment test in the fourth quarter, the recoverable amount exceeds the carrying value of the
CGUs as at 31 December 2025 and therefore no impairment is required (31 December 2024: nil).
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and Value in Use (VIU).
The VIU calculation is based on a Dividend Discount model using three-year management-approved plans,
updated for expected changes in the macroeconomic environment. When estimating the VIU of a CGU, local
conditions and requirements determine the capital requirements, discount rates, and terminal growth rates. These
local conditions and requirements determine the ability to upstream excess capital and profits to ING 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-709": { "value": "
10\u00a0 Intangible assets
Changes in intangible assets
Goodwill
Software
Other
Total
in EUR million
2025
2024
2025
2024
2025
2024
2025
2024
Opening balance as at 1 January
476
469
855
727
3
2
1,334
1,198
Additions
6
35
43
1
35
50
Capitalised expenses
380
324
380
324
Amortisation
-223
-215
-223
-216
Impairments 1
-7
-12
-7
-12
Exchange rate differences
1
1
-10
8
-9
9
Disposals
-2
-9
-2
-9
Other changes
2
-10
1
2
-10
Closing balance
477
476
1,030
855
3
3
1,510
1,334
Gross carrying amount
477
476
3,281
2,986
9
8
3,767
3,471
Accumulated amortisation
-2,197
-2,079
-4
-4
-2,201
-2,084
Accumulated impairments
-53
-52
-1
-2
-55
-53
Net carrying value
477
476
1,030
855
3
3
1,510
1,334
1Impairments 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
Group of CGUs
2025
2024
2025
2024
2025
2024
Retail Netherlands
Value in use
7.20%
7.81%
2.00%
2.00%
30
30
Retail Germany
Value in use
7.20%
7.77%
2.20%
2.00%
356
356
Retail Poland
Value in use
8.76%
9.30%
2.50%
2.50%
77
76
Retail Romania
Value in use
10.86%
11.45%
2.60%
3.00%
14
15
477
476
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 2025, no triggering events were identified.\u00a0
At the annual impairment test in the fourth quarter, the recoverable amount exceeds the carrying value of the
CGUs as at 31 December 2025 and therefore no impairment is required (31 December 2024: nil).
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and Value in Use (VIU).
The VIU calculation is based on a Dividend Discount model using three-year management-approved plans,
updated for expected changes in the macroeconomic environment. When estimating the VIU of a CGU, local
conditions and requirements determine the capital requirements, discount rates, and terminal growth rates. These
local conditions and requirements determine the ability to upstream excess capital and profits to ING 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 956 million (2024: EUR 768 million). Software
capitalisation amounts increased in 2025 following the significant IT-platform investments in our Retail business.
Software is reviewed for indicators of impairment. Irrespective of whether there is an indication of impairment,
software under development is tested annually for impairment.
", "dimensions": { "concept": "ifrs-full:DisclosureOfIntangibleAssetsAndGoodwillExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-712": { "value": "
11\u00a0 Other assets
Other assets by type
in EUR million
2025
2024
Assets held for sale
164
0
Net defined benefit assets
528
568
Investment properties
27
19
Property development and obtained from foreclosures
17
18
Prepayments
827
412
Accrued assets
477
496
Amounts to be settled
4,074
3,548
Other
1,850
1,875
7,965
6,935
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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-713": { "value": "
12\u00a0 Deposits from banks
Deposits from banks by type
Netherlands
Rest of the world
Total
in EUR million
2025
2024
2025
2024
2025
2024
Non-interest bearing
2
4
115
166
117
170
Interest bearing
6,443
5,845
11,962
10,707
18,404
16,553
6,444
5,849
12,077
10,873
18,521
16,722
Deposits from banks includes non-subordinated deposits and, to a lesser extent, repurchase transactions. For more
information on reverse repurchase transactions, refer to Note 4 'Financial assets at fair value through profit or loss' .
", "dimensions": { "concept": "ifrs-full:DisclosureOfDepositsFromBanksExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-714": { "value": "
13\u00a0 Customer deposits
Customer deposits
in EUR million
2025
2024
Current accounts / Overnight deposits
239,106
227,951
Savings accounts
382,066
354,560
Time deposits
101,767
115,636
Other
1,768
1,579
724,707
699,725
Current accounts / Overnight deposits, Savings accounts and Time deposits include balances with individuals,
respectively EUR 113,580\u00a0million (2024: EUR 107,068\u00a0million ), EUR 347,234\u00a0million (2024: EUR 324,134\u00a0million) and
EUR 50,033\u00a0million (2024: EUR 56,599\u00a0million ).
Customer deposits by type
Netherlands
Rest of the world
Total
in EUR million
2025
2024
2025
2024
2025
2024
Non-interest bearing
3
26
30,036
27,142
30,039
27,168
Interest bearing 1
249,480
245,375
445,187
427,182
694,667
672,557
249,484
245,401
475,223
454,324
724,707
699,725
1Interest bearing includes current accounts which are not remunerated. However, ING holds the contractual right to revise the rates.
\u00a0 \u00a0 \u00a0
In 2025, Customer deposits includes EUR 3,340 million (31 December 2024: EUR 8,064 million) from ING Group in
time deposits and current accounts.", "dimensions": { "concept": "ifrs-full:DisclosureOfDepositsFromCustomersExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-715": { "value": "
Trading liabilities
Trading liabilities by type
in EUR million
2025
2024
Equity securities
682
467
Debt securities
1,872
3,185
Funds on deposit
191
5,437
Derivatives
20,681
26,166
23,427
35,255
", "dimensions": { "concept": "ifrs-full:DisclosureOfFinancialLiabilitiesHeldForTradingExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-716": { "value": "
15\u00a0 Provisions
Provisions by type
in EUR million
2025
2024
Reorganisation provisions
333
201
Litigation provisions
362
288
Other provisions
78
118
773
606
Loan loss provisions for guarantees and loan commitments
140
146
913
752
For details and changes on loan loss provisioning for guarantees and loan commitments, refer to \u2018Risk
management \u2013 Credit risk\u2019 paragraph 'Loan loss provisioning'.
Changes in provisions
Reorganisation
Litigation
Other provisions
Total
in EUR million
2025
2024
2025
2024
2025
2024
2025
2024
Opening balance as at 1 January
201
231
288
193
118
334
606
758
Additions 1
295
146
128
116
35
26
457
288
Releases 1
-6
-4
-9
-15
-13
-46
-28
-64
Utilised
-146
-163
-45
-31
-58
-196
-248
-390
Exchange rate differences
-5
1
1
-1
-1
-5
Other changes
-5
-10
-2
25
-3
-10
15
Closing balance
333
201
362
288
78
118
773
606
1Additions 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 2025 , amounts expected to be settled within 12 months in provisions amount to EUR 666
million (2024: EUR 552 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
Reorganisation initiatives are implemented over a period of several years and the estimate of the reorganisation
provisions is inherently uncertain.
Litigation provisions
Furthermore, we refer to Note 40 'Legal proceedings' for any contingent liabilities in respect of legal proceedings.
Other provisions
In 2024, the utilisations in the Other provisions mainly relate to the provision for the compensation of Dutch retail
customers for past interest charges that did not sufficiently track market rates.
", "dimensions": { "concept": "ifrs-full:DisclosureOfProvisionsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-718": { "value": "
16\u00a0 Other liabilities
Other liabilities by type
In EUR million
2025
2024
Net defined benefit liability
141
152
Other post-employment benefits
42
38
Other staff-related liabilities
798
784
Other taxation and social security contributions
837
899
Rents received in advance
15
14
Costs payable
2,021
1,763
Amounts to be settled
4,188
4,290
Lease liabilities
1,050
1,116
Other
1,665
1,538
10,755
10,596
Disclosures in respect of Net defined benefit liabilities are provided in Note 30 'Pensions and other post-
employment benefits'. Other staff-related liabilities comprise provisions for vacation leave, jubilee, disability and
illness, as well as liabilities for variable compensations.
Lease liabilities relate to right-of-use assets. Disclosures regarding right-of-use assets are provided in Note 9
'Property and equipment'. The total cash outflow for leases in 2025 was EUR 282\u00a0million (2024: EUR 290\u00a0million).
Amounts to be settled include primarily transactions not settled at the balance sheet date. The nature of these
transactions is short term and have settled after the closing date of the balance sheet. The line Other relates
mainly to amounts payable to suppliers.
", "dimensions": { "concept": "ifrs-full:DisclosureOfAccruedExpensesAndOtherLiabilitiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-717": { "value": "
16\u00a0 Other liabilities
Other liabilities by type
In EUR million
2025
2024
Net defined benefit liability
141
152
Other post-employment benefits
42
38
Other staff-related liabilities
798
784
Other taxation and social security contributions
837
899
Rents received in advance
15
14
Costs payable
2,021
1,763
Amounts to be settled
4,188
4,290
Lease liabilities
1,050
1,116
Other
1,665
1,538
10,755
10,596
Disclosures in respect of Net defined benefit liabilities are provided in Note 30 'Pensions and other post-
employment benefits'. Other staff-related liabilities comprise provisions for vacation leave, jubilee, disability and
illness, as well as liabilities for variable compensations.
Lease liabilities relate to right-of-use assets. Disclosures regarding right-of-use assets are provided in Note 9
'Property and equipment'. The total cash outflow for leases in 2025 was EUR 282\u00a0million (2024: EUR 290\u00a0million).
Amounts to be settled include primarily transactions not settled at the balance sheet date. The nature of these
transactions is short term and have settled after the closing date of the balance sheet. The line Other relates
mainly to amounts payable to suppliers.
", "dimensions": { "concept": "ifrs-full:DisclosureOfOtherLiabilitiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-719": { "value": "-282000000.0", "decimals": -6, "dimensions": { "concept": "ingbank:IncreaseDecreaseThroughRedemptionsOrDisposalsLiabilitiesArisingFromFinancingActivities", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00", "ifrs-full:LiabilitiesArisingFromFinancingActivitiesAxis": "ifrs-full:LeaseLiabilitiesMember", "unit": "iso4217:EUR" } }, "f-720": { "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-721": { "value": "
19\u00a0 Subordinated loans
Subordinated loans
In EUR million
2025
2024
Subordinated loans
18,100
17,879
18,100
17,879
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 18,299 million (2024: EUR 18,403 million) have been placed with ING Bank N.V.
by ING Groep N.V.
In 2025 ING Groep N.V. issued EUR 1.25 billion 4.13% Fixed Rate Subordinated Green Tier 2 Notes in May, EUR 1.25
billion 3.88% Fixed Rate Subordinated Tier 2 Notes in August and USD 1.50 billion 7.00% Perpetual AT1 Contingent
Convertible Capital Securities in September.
In 2025 ING Groep N.V. redeemed EUR 750 million 2.00% Fixed Subordinated Tier 2 notes in March, USD 1.25 billion
6.50% Perpetual AT1 Contingent Convertible Capital Securities in April and EUR 1 billion 1.00% Fixed Subordinated
Tier 2 notes in November.
Reference is made to the Consolidated statement of cash flows for further information on issuances and
redemptions.
", "dimensions": { "concept": "ifrs-full:DisclosureOfSubordinatedLiabilitiesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-722": { "value": "
20\u00a0 Equity
Total equity
In EUR million
2025
2024
2023
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
1,444
1,816
1,152
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Revaluation reserve: Debt instruments at FVOCI
-41
-479
-277
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Revaluation reserve: Cash flow hedge
-1,096
-1,693
-2,058
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Revaluation reserve: Credit liability
-49
-15
31
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Revaluation reserve: Property in own use
156
161
178
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Net defined benefit asset/liability remeasurement reserve
-345
-333
-317
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Currency translation reserve
-2,774
-1,986
-2,527
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0-\u00a0\u00a0Share of associates and joint ventures and other reserves
2,032
2,607
3,048
-675
78
-769
Retained earnings
31,352
25,598
23,893
Shareholders\u2019 equity (parent)
47,744
42,743
40,191
Non-controlling interests
1,255
995
944
Total equity
48,999
43,738
41,135
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 34 million (2024: EUR 50 million; 2023: EUR 54 million) of which EUR 123 million (2024: EUR 202 million;
2023: EUR 284 million) in the currency translation reserve, EUR 0 million ( 2024: EUR 4 million; 2023: EUR 3 million)
in revaluation reserves and EUR -89 million (2024: EUR -156\u00a0million; 2023: EUR -234 million) in profit or loss.
Share capital and share premium
Share capital
Ordinary shares (par value EUR\u00a01.13)
Number x 1,000
Amount
2025
2024
2023
2025
2024
2023
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 2025, 2024 and 2023.
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
2025, 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
2025, 7 preference shares were issued and fully paid (2024: 7 preference shares; 2023: 7 preference shares)
amounting to EUR 8 (2024: EUR 8 and 2023: EUR 8).
Revaluation reserves
Changes in revaluation reserve: Equity securities and Debt instruments at FVOCI
Equity securities at FVOCI
Debt instruments at FVOCI
In EUR million
2025
2024
2023
2025
2024
2023
Opening balance
1,816
1,152
1,187
-479
-277
-339
Unrealised revaluations
-366
664
-35
459
-265
53
Realised gains/losses transferred to the statement
of profit or loss
-21
62
9
Realised revaluations transferred to retained
earnings
-6
0
1
Closing balance
1,444
1,816
1,152
-41
-479
-277
Equity securities at FVOCI
In 2025, the unrealised revaluation of EUR -366\u00a0million (2024: EUR 664 million; 2023: EUR -35 million) includes
revaluation of shares in Bank of Beijing for EUR -403 million (2024: EUR 652 million; 2023: EUR -24 million).
Changes in cash flow hedge and credit liability reserve
Cash flow hedge
Credit liability
In EUR million
2025
2024
2023
2025
2024
2023
Opening balance
-1,693
-2,058
-3,055
-15
31
70
Changes in credit liability reserve
-34
-46
-39
Unrealised revaluations
597
365
997
Closing balance
-1,096
-1,693
-2,058
-49
-15
31
Cash flow hedge
The increase in the cash flow hedge reserve, primarily related to floating rate lending with interest rate swaps, in
2025 (EUR 597 million) reflects the impact of changes in interest rates, pull-to-par effect and amortisation of de-
designated hedges. Reference is made to Note 34 'Derivatives and hedge accounting'.
Changes in Property in own use reserve
In EUR million
2025
2024
2023
Opening balance
161
178
176
Unrealised revaluations
7
3
10
Realised revaluations transferred to retained earnings
-12
-20
-8
Closing balance
156
161
178
Net defined benefit asset/liability remeasurement reserve
Reference is made to Note 31 'Pensions and other post-employment benefits'.
Currency translation reserve
Changes in currency translation reserve
In EUR million
2025
2024
2023
Opening balance
-1,986
-2,527
-2,395
Unrealised revaluations
637
-222
183
Realised gains/losses transferred to the statement of profit or loss
1
Exchange rate differences
-1,425
763
-316
Closing balance
-2,774
-1,986
-2,527
Unrealised revaluations relates to changes in the value of hedging instruments that are designated as net
investment hedges. The hedging strategy is to protect the CET1 ratio against adverse impact from exchange rate
fluctuations. The net decrease of unrealised revaluations and Exchange rate differences of EUR -788 million is
related to several currencies including USD (EUR -664 million), TRY (EUR -21 million including EUR 123 million IAS 29
indexation effect), GBP (EUR -64 million), PLN (EUR 29\u00a0 million), UAH (EUR -16 million), AUD (EUR -69 million), RUB
(EUR 87 million), THB (EUR -19 million), RON (EUR -13 million) and other currencies (EUR -39 million).
Share of associates and joint ventures and other reserves
Changes in share of associates, joint ventures and other reserves
In EUR million
2025
2024
2023
Opening balance
2,607
3,048
3,604
Result for the year
14
125
336
Transfer to/from retained earnings
-590
-565
-892
Closing balance
2,032
2,607
3,048
The Share of associates, joint ventures and other reserves includes non-distributable profits from associates and
joint ventures of EUR 963 million (2024: EUR 940 million; 2023: EUR 815 million). Other reserves includes a
statutory reserve of EUR 108 million (2024: EUR 897 million; 2023: EUR 1,602 million) related to the former
Stichting Regio Bank and the former Stichting Vakbondsspaarbank SPN and a legal reserve of EUR 956 million
(2024: EUR 768 million; 2023: EUR 628 million) related to internally developed software. The transfer to retained
earnings of EUR -590 million includes the release of the Regio bank and Vakbondsspaarbank SPN reserve of EUR
-802 million (2024: EUR -830 million; 2023: EUR -998 million) against regulatory expenses which are recognised in
the statement of profit or loss.
Retained earnings
Changes in retained earnings
In EUR million
2025
2024
2023
Opening balance
25,598
23,893
26,462
Impact on opening balance 1
-45
Transfer to/from other reserves
616
585
899
Result for the year
6,212
6,062
6,821
Dividend and other cash distributions
-1,129
-4,986
-10,269
Employee share plans
52
45
30
Changes in composition of the group and other changes
3
-1
-5
Closing balance
31,352
25,598
23,893
12023: Changes in policy following the adoption of IFRS 17 and change in policy for non-financial guarantees.
Restrictions with respect to dividend and repayment of capital
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.
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.
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 6,225
million (2024: EUR 5,672 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.
Changes in the net defined benefit assets/liability remeasurement reserve
in EUR million
2025
2024
Opening balance as at 1 January
-333
-317
Remeasurement of plan assets
-37
-118
Actuarial gains and losses arising from changes in demographic assumptions
-6
3
Actuarial gains and losses arising from changes in financial assumptions
32
94
Taxation and Exchange rate differences
5
Total Other comprehensive income movement for the year
-12
-16
Closing balance
-345
-333
Movement cash flow hedge reserve
in EUR million
2025
2024
Opening balance
-1,693
-2,058
Value changes recognised in OCI
799
743
Amounts recycled to profit or loss
149
-209
Income tax
-175
-140
Exchange rate and other changes
-12
-14
Adjustment for non controlling interest
-163
-14
Movement for the year
597
365
Ending balance
-1,096
-1,693
", "dimensions": { "concept": "ifrs-full:DisclosureOfShareCapitalReservesAndOtherEquityInterestExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-723": { "value": "
Share capital
Ordinary shares (par value EUR\u00a01.13)
Number x 1,000
Amount
2025
2024
2023
2025
2024
2023
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 2025, 2024 and 2023.
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
2025, 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
2025, 7 preference shares were issued and fully paid (2024: 7 preference shares; 2023: 7 preference shares)
amounting to EUR 8 (2024: EUR 8 and 2023: EUR 8).
", "dimensions": { "concept": "ifrs-full:DisclosureOfIssuedCapitalExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-724": { "value": "
No change occurred in the issued share capital and share premium in 2025, 2024 and 2023.
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
2025, 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
2025, 7 preference shares were issued and fully paid (2024: 7 preference shares; 2023: 7 preference shares)
amounting to EUR 8 (2024: EUR 8 and 2023: EUR 8).
", "dimensions": { "concept": "ifrs-full:DescriptionOfAccountingPolicyForIssuedCapitalExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-725": { "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
2025
2024
2023
2025
2024
2023
Opening balance
1,816
1,152
1,187
-479
-277
-339
Unrealised revaluations
-366
664
-35
459
-265
53
Realised gains/losses transferred to the statement
of profit or loss
-21
62
9
Realised revaluations transferred to retained
earnings
-6
0
1
Closing balance
1,444
1,816
1,152
-41
-479
-277
Equity securities at FVOCI
In 2025, the unrealised revaluation of EUR -366\u00a0million (2024: EUR 664 million; 2023: EUR -35 million) includes
revaluation of shares in Bank of Beijing for EUR -403 million (2024: EUR 652 million; 2023: EUR -24 million).
Changes in cash flow hedge and credit liability reserve
Cash flow hedge
Credit liability
In EUR million
2025
2024
2023
2025
2024
2023
Opening balance
-1,693
-2,058
-3,055
-15
31
70
Changes in credit liability reserve
-34
-46
-39
Unrealised revaluations
597
365
997
Closing balance
-1,096
-1,693
-2,058
-49
-15
31
Cash flow hedge
The increase in the cash flow hedge reserve, primarily related to floating rate lending with interest rate swaps, in
2025 (EUR 597 million) reflects the impact of changes in interest rates, pull-to-par effect and amortisation of de-
designated hedges. Reference is made to Note 34 'Derivatives and hedge accounting'.
Changes in Property in own use reserve
In EUR million
2025
2024
2023
Opening balance
161
178
176
Unrealised revaluations
7
3
10
Realised revaluations transferred to retained earnings
-12
-20
-8
Closing balance
156
161
178
Net defined benefit asset/liability remeasurement reserve
Reference is made to Note 31 'Pensions and other post-employment benefits'.
Currency translation reserve
Changes in currency translation reserve
In EUR million
2025
2024
2023
Opening balance
-1,986
-2,527
-2,395
Unrealised revaluations
637
-222
183
Realised gains/losses transferred to the statement of profit or loss
1
Exchange rate differences
-1,425
763
-316
Closing balance
-2,774
-1,986
-2,527
Unrealised revaluations relates to changes in the value of hedging instruments that are designated as net
investment hedges. The hedging strategy is to protect the CET1 ratio against adverse impact from exchange rate
fluctuations. The net decrease of unrealised revaluations and Exchange rate differences of EUR -788 million is
related to several currencies including USD (EUR -664 million), TRY (EUR -21 million including EUR 123 million IAS 29
indexation effect), GBP (EUR -64 million), PLN (EUR 29\u00a0 million), UAH (EUR -16 million), AUD (EUR -69 million), RUB
(EUR 87 million), THB (EUR -19 million), RON (EUR -13 million) and other currencies (EUR -39 million).
Share of associates and joint ventures and other reserves
Changes in share of associates, joint ventures and other reserves
In EUR million
2025
2024
2023
Opening balance
2,607
3,048
3,604
Result for the year
14
125
336
Transfer to/from retained earnings
-590
-565
-892
Closing balance
2,032
2,607
3,048
The Share of associates, joint ventures and other reserves includes non-distributable profits from associates and
joint ventures of EUR 963 million (2024: EUR 940 million; 2023: EUR 815 million). Other reserves includes a
statutory reserve of EUR 108 million (2024: EUR 897 million; 2023: EUR 1,602 million) related to the former
Stichting Regio Bank and the former Stichting Vakbondsspaarbank SPN and a legal reserve of EUR 956 million
(2024: EUR 768 million; 2023: EUR 628 million) related to internally developed software. The transfer to retained
earnings of EUR -590 million includes the release of the Regio bank and Vakbondsspaarbank SPN reserve of EUR
-802 million (2024: EUR -830 million; 2023: EUR -998 million) against regulatory expenses which are recognised in
the statement of profit or loss.
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 6,225
million (2024: EUR 5,672 million).
Changes in the net defined benefit assets/liability remeasurement reserve
in EUR million
2025
2024
Opening balance as at 1 January
-333
-317
Remeasurement of plan assets
-37
-118
Actuarial gains and losses arising from changes in demographic assumptions
-6
3
Actuarial gains and losses arising from changes in financial assumptions
32
94
Taxation and Exchange rate differences
5
Total Other comprehensive income movement for the year
-12
-16
Closing balance
-345
-333
Movement cash flow hedge reserve
in EUR million
2025
2024
Opening balance
-1,693
-2,058
Value changes recognised in OCI
799
743
Amounts recycled to profit or loss
149
-209
Income tax
-175
-140
Exchange rate and other changes
-12
-14
Adjustment for non controlling interest
-163
-14
Movement for the year
597
365
Ending balance
-1,096
-1,693
", "dimensions": { "concept": "ifrs-full:DisclosureOfReservesAndOtherEquityInterestExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-726": { "value": "
Currency translation reserve
Changes in currency translation reserve
In EUR million
2025
2024
2023
Opening balance
-1,986
-2,527
-2,395
Unrealised revaluations
637
-222
183
Realised gains/losses transferred to the statement of profit or loss
1
Exchange rate differences
-1,425
763
-316
Closing balance
-2,774
-1,986
-2,527
Unrealised revaluations relates to changes in the value of hedging instruments that are designated as net
investment hedges. The hedging strategy is to protect the CET1 ratio against adverse impact from exchange rate
fluctuations. The net decrease of unrealised revaluations and Exchange rate differences of EUR -788 million is
related to several currencies including USD (EUR -664 million), TRY (EUR -21 million including EUR 123 million IAS 29
indexation effect), GBP (EUR -64 million), PLN (EUR 29\u00a0 million), UAH (EUR -16 million), AUD (EUR -69 million), RUB
(EUR 87 million), THB (EUR -19 million), RON (EUR -13 million) and other currencies (EUR -39 million).", "dimensions": { "concept": "ifrs-full:DisclosureOfEffectOfChangesInForeignExchangeRatesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-727": { "value": "
Changes in retained earnings
In EUR million
2025
2024
2023
Opening balance
25,598
23,893
26,462
Impact on opening balance 1
-45
Transfer to/from other reserves
616
585
899
Result for the year
6,212
6,062
6,821
Dividend and other cash distributions
-1,129
-4,986
-10,269
Employee share plans
52
45
30
Changes in composition of the group and other changes
3
-1
-5
Closing balance
31,352
25,598
23,893
12023: Changes in policy following the adoption of IFRS 17 and change in policy for non-financial guarantees.
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.
", "dimensions": { "concept": "ifrs-full:DisclosureOfDividendsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-731": { "value": "
21\u00a0 Net interest income
Net interest income
in EUR million
2025
2024
2023
2025
2024
2023
Interest income on loans1
30,683
33,892
31,850
Interest expense on deposits2
14,658
16,849
13,282
Interest income on debt securities at amortised cost
1,333
1,204
877
Interest expense on debt securities in issue
3,427
3,796
2,856
Interest income on financial assets at fair value through OCI
1,790
1,481
1,078
Interest expense on subordinated loans
813
752
707
Interest income on non-trading derivatives (hedge accounting)
9,676
12,644
10,682
Interest expense on non-trading derivatives (hedge accounting)
10,957
13,767
11,849
Total interest income using effective interest rate method
43,481
49,221
44,486
Total interest expense using effective interest rate method
29,855
35,164
28,693
Interest income on financial assets at fair value through profit or loss
5,401
6,343
4,934
Interest expense on financial liabilities at fair value through profit or loss
4,419
5,479
4,410
Interest income on non-trading derivatives (no hedge accounting)
2,044
3,168
2,637
Interest expense on non-trading derivatives (no hedge accounting)
2,059
3,308
3,131
Interest income other
123
173
171
Interest expense on lease liabilities
27
27
28
Total other interest income
7,568
9,685
7,741
Interest expense other
147
178
157
Total other interest expense
6,652
8,993
7,726
Total interest income
51,049
58,905
52,228
Total interest expense
36,507
44,157
36,419
Net interest income
14,542
14,749
15,809
1Includes interest income on loans to customers and banks, cash balances as well as negative interest on liabilities. Negative interest on liabilities amounted to EUR 11 million (2024: EUR 8 million; 2023: EUR 19 million).
2Includes interest paid on deposits from customers and banks, senior non-preferred debt and negative interest on assets. Negative interest on assets amounted to EUR 12 million (2024: EUR 1 million; 2023: nil).
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.
22\u00a0 Net fee and commission income
Net fee and commission income
in EUR million
2025
2024
2023
Fee and commission income
Payment Services
2,478
2,219
2,062
Securities business
922
734
584
Insurance and other broking
650
594
529
Portfolio management
796
699
625
Lending business
727
650
602
Financial guarantees and other commitments
461
454
459
Other fee and commission income
259
249
239
Total fee and commission income
6,292
5,598
5,100
Fee and commission expenses
Payment Services
858
756
704
Securities business
170
147
129
Distribution of products
457
475
480
Other fee and commission expenses
210
218
202
Total fee and commission expenses
1,695
1,596
1,514
Net fee and commission income
4,597
4,002
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
Management Board Banking, disaggregated by segment.
23\u00a0 Valuation results and net trading income
Valuation results and net trading income
in EUR million
2025
2024
2023
Securities trading results
4,801
996
873
Derivatives trading results
-3,053
207
116
Other trading results
263
336
273
Change in fair value of derivatives relating to
\u2013\u00a0 fair value hedges
3,481
-766
-3,028
\u2013\u00a0 cash flow hedges (ineffective portion)
10
35
48
\u2013\u00a0 other non-trading derivatives
-819
1,923
563
Change in fair value of assets and liabilities (hedged items)
-3,445
750
2,962
Valuation results on assets and liabilities designated at FVPL (excluding trading)
8
31
-127
Foreign exchange transactions results
2,176
-105
1,230
3,422
3,407
2,910
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 whose results may neutralise
one another. A significant part of the derivatives in the trading portfolio are related to servicing corporate clients in
their risk management to hedge for example currency or interest rate exposures. From a risk perspective, the
gross amount of trading assets must be considered together with the gross amount of trading liabilities, which are
presented separately on the statement of financial position. However, IFRS does not always allow the netting of
these positions in the statement of financial position. Reference is made to Note 4 'Financial assets at fair value
through profit or loss' and Note 14 'Financial liabilities at fair value through profit or loss' for information on trading
assets and trading liabilities respectively.
Securities trading results include the results of market making in instruments such as government securities,
equity securities, corporate debt securities, and money-market instruments. The majority of the risks involved in
security and currency trading are economically hedged with derivatives. The securities trading results are partly
offset by results on these derivatives. Derivatives trading results include the results of derivatives such as interest
rate swaps, options, futures, and forward contracts. Trading gains and losses relating to trading securities still held
as at 31\u00a0December 2025 amount to EUR 1,219 million (2024: EUR 20 million; 2023: EUR\u00a0160 million).
Other trading results include the results of trading loans and funds entrusted.
Foreign-exchange transactions results include gains and losses from spot, options, futures, and translated foreign
currency assets and liabilities. The result on currency trading is included in foreign exchange transactions results.
Valuation results and net trading income include the fair value movements on derivatives (used for both hedge
accounting and economically hedging exposures) as well as the changes in the fair value of assets and liabilities
included in hedging relationships as hedged items. In 2025, fluctuations in interest rate had a significant impact on
the fair value changes of both the derivatives and the hedged items designated in fair value hedges. Reference is
made to Note 34 '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 33 'Fair value of assets and liabilities' for information on these valuation adjustments.
24\u00a0 Investment income
Investment income
in EUR million
2025
2024
2023
Dividend income
116
117
105
Realised gains/losses on disposal of debt instruments measured at FVOCI
28
-104
-11
Other investment income
-15
129
13
95
Dividend income mainly consists of dividend received from ING\u2019s equity stake in Bank of Beijing.
25\u00a0 Other net income
Other net income
in EUR million
2025
2024
2023
Net monetary loss reflecting IAS 29 hyperinflation impact
-84
-159
-244
Income related to a prior insolvency of a financial institution in the Netherlands
16
53
Sale of the remaining NNHB mortgages
21
Other
71
82
98
3
-3
-146
The net monetary loss, reflecting the IAS 29 hyperinflation impact, is fully related to the indexation of ING T\u00fcrkiye's
statement of financial position and statement of profit or loss with an offsetting effect in the currency translation
reserve.
", "dimensions": { "concept": "ifrs-full:DisclosureOfRevenueExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-730": { "value": "
21\u00a0 Net interest income
Net interest income
in EUR million
2025
2024
2023
2025
2024
2023
Interest income on loans1
30,683
33,892
31,850
Interest expense on deposits2
14,658
16,849
13,282
Interest income on debt securities at amortised cost
1,333
1,204
877
Interest expense on debt securities in issue
3,427
3,796
2,856
Interest income on financial assets at fair value through OCI
1,790
1,481
1,078
Interest expense on subordinated loans
813
752
707
Interest income on non-trading derivatives (hedge accounting)
9,676
12,644
10,682
Interest expense on non-trading derivatives (hedge accounting)
10,957
13,767
11,849
Total interest income using effective interest rate method
43,481
49,221
44,486
Total interest expense using effective interest rate method
29,855
35,164
28,693
Interest income on financial assets at fair value through profit or loss
5,401
6,343
4,934
Interest expense on financial liabilities at fair value through profit or loss
4,419
5,479
4,410
Interest income on non-trading derivatives (no hedge accounting)
2,044
3,168
2,637
Interest expense on non-trading derivatives (no hedge accounting)
2,059
3,308
3,131
Interest income other
123
173
171
Interest expense on lease liabilities
27
27
28
Total other interest income
7,568
9,685
7,741
Interest expense other
147
178
157
Total other interest expense
6,652
8,993
7,726
Total interest income
51,049
58,905
52,228
Total interest expense
36,507
44,157
36,419
Net interest income
14,542
14,749
15,809
1Includes interest income on loans to customers and banks, cash balances as well as negative interest on liabilities. Negative interest on liabilities amounted to EUR 11 million (2024: EUR 8 million; 2023: EUR 19 million).
2Includes interest paid on deposits from customers and banks, senior non-preferred debt and negative interest on assets. Negative interest on assets amounted to EUR 12 million (2024: EUR 1 million; 2023: nil).
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.
", "dimensions": { "concept": "ifrs-full:DisclosureOfInterestIncomeExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-729": { "value": "
21\u00a0 Net interest income
Net interest income
in EUR million
2025
2024
2023
2025
2024
2023
Interest income on loans1
30,683
33,892
31,850
Interest expense on deposits2
14,658
16,849
13,282
Interest income on debt securities at amortised cost
1,333
1,204
877
Interest expense on debt securities in issue
3,427
3,796
2,856
Interest income on financial assets at fair value through OCI
1,790
1,481
1,078
Interest expense on subordinated loans
813
752
707
Interest income on non-trading derivatives (hedge accounting)
9,676
12,644
10,682
Interest expense on non-trading derivatives (hedge accounting)
10,957
13,767
11,849
Total interest income using effective interest rate method
43,481
49,221
44,486
Total interest expense using effective interest rate method
29,855
35,164
28,693
Interest income on financial assets at fair value through profit or loss
5,401
6,343
4,934
Interest expense on financial liabilities at fair value through profit or loss
4,419
5,479
4,410
Interest income on non-trading derivatives (no hedge accounting)
2,044
3,168
2,637
Interest expense on non-trading derivatives (no hedge accounting)
2,059
3,308
3,131
Interest income other
123
173
171
Interest expense on lease liabilities
27
27
28
Total other interest income
7,568
9,685
7,741
Interest expense other
147
178
157
Total other interest expense
6,652
8,993
7,726
Total interest income
51,049
58,905
52,228
Total interest expense
36,507
44,157
36,419
Net interest income
14,542
14,749
15,809
1Includes interest income on loans to customers and banks, cash balances as well as negative interest on liabilities. Negative interest on liabilities amounted to EUR 11 million (2024: EUR 8 million; 2023: EUR 19 million).
2Includes interest paid on deposits from customers and banks, senior non-preferred debt and negative interest on assets. Negative interest on assets amounted to EUR 12 million (2024: EUR 1 million; 2023: nil).
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.
", "dimensions": { "concept": "ifrs-full:DisclosureOfInterestExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-728": { "value": "
21\u00a0 Net interest income
Net interest income
in EUR million
2025
2024
2023
2025
2024
2023
Interest income on loans1
30,683
33,892
31,850
Interest expense on deposits2
14,658
16,849
13,282
Interest income on debt securities at amortised cost
1,333
1,204
877
Interest expense on debt securities in issue
3,427
3,796
2,856
Interest income on financial assets at fair value through OCI
1,790
1,481
1,078
Interest expense on subordinated loans
813
752
707
Interest income on non-trading derivatives (hedge accounting)
9,676
12,644
10,682
Interest expense on non-trading derivatives (hedge accounting)
10,957
13,767
11,849
Total interest income using effective interest rate method
43,481
49,221
44,486
Total interest expense using effective interest rate method
29,855
35,164
28,693
Interest income on financial assets at fair value through profit or loss
5,401
6,343
4,934
Interest expense on financial liabilities at fair value through profit or loss
4,419
5,479
4,410
Interest income on non-trading derivatives (no hedge accounting)
2,044
3,168
2,637
Interest expense on non-trading derivatives (no hedge accounting)
2,059
3,308
3,131
Interest income other
123
173
171
Interest expense on lease liabilities
27
27
28
Total other interest income
7,568
9,685
7,741
Interest expense other
147
178
157
Total other interest expense
6,652
8,993
7,726
Total interest income
51,049
58,905
52,228
Total interest expense
36,507
44,157
36,419
Net interest income
14,542
14,749
15,809
1Includes interest income on loans to customers and banks, cash balances as well as negative interest on liabilities. Negative interest on liabilities amounted to EUR 11 million (2024: EUR 8 million; 2023: EUR 19 million).
2Includes interest paid on deposits from customers and banks, senior non-preferred debt and negative interest on assets. Negative interest on assets amounted to EUR 12 million (2024: EUR 1 million; 2023: nil).
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.
", "dimensions": { "concept": "ifrs-full:DisclosureOfInterestIncomeExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-733": { "value": "
22\u00a0 Net fee and commission income
Net fee and commission income
in EUR million
2025
2024
2023
Fee and commission income
Payment Services
2,478
2,219
2,062
Securities business
922
734
584
Insurance and other broking
650
594
529
Portfolio management
796
699
625
Lending business
727
650
602
Financial guarantees and other commitments
461
454
459
Other fee and commission income
259
249
239
Total fee and commission income
6,292
5,598
5,100
Fee and commission expenses
Payment Services
858
756
704
Securities business
170
147
129
Distribution of products
457
475
480
Other fee and commission expenses
210
218
202
Total fee and commission expenses
1,695
1,596
1,514
Net fee and commission income
4,597
4,002
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
Management Board Banking, disaggregated by segment.
", "dimensions": { "concept": "ifrs-full:DisclosureOfRevenueFromContractsWithCustomersExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-732": { "value": "
22\u00a0 Net fee and commission income
Net fee and commission income
in EUR million
2025
2024
2023
Fee and commission income
Payment Services
2,478
2,219
2,062
Securities business
922
734
584
Insurance and other broking
650
594
529
Portfolio management
796
699
625
Lending business
727
650
602
Financial guarantees and other commitments
461
454
459
Other fee and commission income
259
249
239
Total fee and commission income
6,292
5,598
5,100
Fee and commission expenses
Payment Services
858
756
704
Securities business
170
147
129
Distribution of products
457
475
480
Other fee and commission expenses
210
218
202
Total fee and commission expenses
1,695
1,596
1,514
Net fee and commission income
4,597
4,002
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
Management Board Banking, disaggregated by segment.
", "dimensions": { "concept": "ifrs-full:DisclosureOfFeeAndCommissionIncomeExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-734": { "value": "
23\u00a0 Valuation results and net trading income
Valuation results and net trading income
in EUR million
2025
2024
2023
Securities trading results
4,801
996
873
Derivatives trading results
-3,053
207
116
Other trading results
263
336
273
Change in fair value of derivatives relating to
\u2013\u00a0 fair value hedges
3,481
-766
-3,028
\u2013\u00a0 cash flow hedges (ineffective portion)
10
35
48
\u2013\u00a0 other non-trading derivatives
-819
1,923
563
Change in fair value of assets and liabilities (hedged items)
-3,445
750
2,962
Valuation results on assets and liabilities designated at FVPL (excluding trading)
8
31
-127
Foreign exchange transactions results
2,176
-105
1,230
3,422
3,407
2,910
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 whose results may neutralise
one another. A significant part of the derivatives in the trading portfolio are related to servicing corporate clients in
their risk management to hedge for example currency or interest rate exposures. From a risk perspective, the
gross amount of trading assets must be considered together with the gross amount of trading liabilities, which are
presented separately on the statement of financial position. However, IFRS does not always allow the netting of
these positions in the statement of financial position. Reference is made to Note 4 'Financial assets at fair value
through profit or loss' and Note 14 'Financial liabilities at fair value through profit or loss' for information on trading
assets and trading liabilities respectively.
Securities trading results include the results of market making in instruments such as government securities,
equity securities, corporate debt securities, and money-market instruments. The majority of the risks involved in
security and currency trading are economically hedged with derivatives. The securities trading results are partly
offset by results on these derivatives. Derivatives trading results include the results of derivatives such as interest
rate swaps, options, futures, and forward contracts. Trading gains and losses relating to trading securities still held
as at 31\u00a0December 2025 amount to EUR 1,219 million (2024: EUR 20 million; 2023: EUR\u00a0160 million).
Other trading results include the results of trading loans and funds entrusted.
Foreign-exchange transactions results include gains and losses from spot, options, futures, and translated foreign
currency assets and liabilities. The result on currency trading is included in foreign exchange transactions results.
Valuation results and net trading income include the fair value movements on derivatives (used for both hedge
accounting and economically hedging exposures) as well as the changes in the fair value of assets and liabilities
included in hedging relationships as hedged items. In 2025, fluctuations in interest rate had a significant impact on
the fair value changes of both the derivatives and the hedged items designated in fair value hedges. Reference is
made to Note 34 '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 33 'Fair value of assets and liabilities' for information on these valuation adjustments.", "dimensions": { "concept": "ifrs-full:DisclosureOfTradingIncomeExpenseExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-736": { "value": "
26\u00a0 Staff expenses
Staff expenses
in EUR million
2025
2024
2023
Salaries
5,277
4,906
4,559
Pension costs and other staff-related benefit costs
488
455
418
Social security costs
752
690
635
Share-based compensation arrangements
52
45
30
External employees
662
720
776
Education
56
49
50
Other staff costs
313
319
256
7,600
7,184
6,725
Share-based compensation arrangements include EUR 52\u00a0million (2024: EUR 45 million; 2023: EUR 30 million)
relating to equity-settled share-based payment arrangements.\u00a0
Number of employees
Netherlands
Rest of the world
Total
2025
2024
2023
2025
2024
2023
2025
2024
2023
Total average number of
internal employees at full time
equivalent basis
15,280
14,821
14,449
47,490
46,301
44,985
62,770
61,121
59,434
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 2025 relate to the performance year 2024. In 2025, 145,472 share awards (2024:
180,994; 2023: 224,796) were granted to the members of the Management Board Banking. To senior management
and other employees 3,876,388 share awards (2024: 4,248,400; 2023: 3,244,951) were granted.
Changes in share awards
Share awards (in numbers)
Weighted average grant date fair values
(in euros)
2025
2024
2023
2025
2024
2023
Opening balance as at 1 January
4,853,529
3,895,787
3,697,542
10.88
8.81
7.97
Granted
4,021,860
4,429,394
3,469,747
17.57
13.75
9.71
Vested
-3,448,317
-3,343,429
-3,113,115
14.67
12.29
8.83
Forfeited
-138,970
-128,223
-158,387
13.99
10.73
8.54
Closing balance
5,288,102
4,853,529
3,895,787
13.44
10.88
8.81
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 2025, total unrecognised compensation costs related to share awards amount to EUR 33
million (2024: EUR 25 million; 2023: EUR 15 million). These costs are expected to be recognised over a weighted
average period of 2.0 years ( 2024: 2.0 years; 2023: 2.0 years).
27\u00a0 Other operating expenses
Other operating expenses
in EUR million
2025
2024 1
2023 1
Promotional and clients acquisition costs
443
441
369
IT related expenses (excluding outsourcing and subcontracting)
768
694
653
Outsourcing and subcontracting
697
664
579
Facilities
271
277
289
Market data services
153
136
120
Advisory fees
292
315
294
Audit and supervisory fees
142
142
123
Indirect taxes
208
235
107
Regulatory costs
866
882
1,042
Depreciation and impairment of property and equipment 9
451
475
493
Amortisation and impairment of intangible assets 10
230
228
218
Additions and releases of provisions 15
322
219
243
Other
132
224
308
4,976
4,931
4,838
1ING changed the presentation of Other operating expenses as of 2025. The comparative figures for 2024 and 2023 have been updated accordingly. The
reclassifications do not affect the total amount of Other operating expenses.
Reference is made to Note 9 'Property and equipment' for (reversals of) impairments of property and equipment
and Note 10 'Intangible assets' for (reversals of) impairments of intangible assets. For more information on
addition to (unused amounts reversed of) provision for reorganisations refer to Note 15 'Provisions' and for more
information on addition to (unused amounts reversed of) other provisions refer to Note 15 'Provisions' and Note 40
'Legal proceedings'.
Regulatory costs
Regulatory costs represent contributions to the Deposit Guarantee Schemes (DGS), the Single Resolution Fund
(SRF), local bank taxes and local resolution funds. Included in Regulatory costs for 2025 , are contributions to DGS of
EUR 167 million (2024 : EUR 230 million; 2023: EUR 320 million) mainly related to Belgium, Poland, Germany and
the Netherlands and contributions to the SRF and local resolution funds of EUR 41 million (2024: EUR 35 million;
2023: EUR 251 million). In 2025 local bank taxes increased by EUR 41 million from EUR 617 million in 2024 to EUR
657 million (2023 : EUR 472 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-735": { "value": "
26\u00a0 Staff expenses
Staff expenses
in EUR million
2025
2024
2023
Salaries
5,277
4,906
4,559
Pension costs and other staff-related benefit costs
488
455
418
Social security costs
752
690
635
Share-based compensation arrangements
52
45
30
External employees
662
720
776
Education
56
49
50
Other staff costs
313
319
256
7,600
7,184
6,725
Share-based compensation arrangements include EUR 52\u00a0million (2024: EUR 45 million; 2023: EUR 30 million)
relating to equity-settled share-based payment arrangements.\u00a0
Number of employees
Netherlands
Rest of the world
Total
2025
2024
2023
2025
2024
2023
2025
2024
2023
Total average number of
internal employees at full time
equivalent basis
15,280
14,821
14,449
47,490
46,301
44,985
62,770
61,121
59,434
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 2025 relate to the performance year 2024. In 2025, 145,472 share awards (2024:
180,994; 2023: 224,796) were granted to the members of the Management Board Banking. To senior management
and other employees 3,876,388 share awards (2024: 4,248,400; 2023: 3,244,951) were granted.
Changes in share awards
Share awards (in numbers)
Weighted average grant date fair values
(in euros)
2025
2024
2023
2025
2024
2023
Opening balance as at 1 January
4,853,529
3,895,787
3,697,542
10.88
8.81
7.97
Granted
4,021,860
4,429,394
3,469,747
17.57
13.75
9.71
Vested
-3,448,317
-3,343,429
-3,113,115
14.67
12.29
8.83
Forfeited
-138,970
-128,223
-158,387
13.99
10.73
8.54
Closing balance
5,288,102
4,853,529
3,895,787
13.44
10.88
8.81
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 2025, total unrecognised compensation costs related to share awards amount to EUR 33
million (2024: EUR 25 million; 2023: EUR 15 million). These costs are expected to be recognised over a weighted
average period of 2.0 years ( 2024: 2.0 years; 2023: 2.0 years).
31\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 2025 to EUR 460 million (2024: EUR 423 million and 2023: EUR 391 million).
Transition Plan on the New Dutch Pension Plan Legislation
In 2024, ING and unions agreed on a transition plan for a new pension plan, based on the new Dutch pension
legislation. This new plan will replace the current pension plan and will remain to be classified as a Defined
Contribution Plan and will continue to be executed by the ING CDC Pension fund.
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
2025
2024
2025
2024
2025
2024
The Netherlands
302
325
381
415
-79
-90
United States
226
250
224
235
1
15
United Kingdom
1,129
1,206
706
751
423
455
Belgium
514
513
441
450
72
63
Other countries
327
341
358
368
-31
-26
Funded status (Net defined benefit asset/liability)
2,497
2,636
2,110
2,219
387
416
Presented as:
- Other assets
528
568
- Other liabilities
-141
-152
387
416
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 2025. 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
2025
2024
Opening balance as at 1 January
2,636
2,678
Interest income
108
106
Remeasurements: Return on plan assets excluding amounts included in interest income
-37
-118
Employer's contribution
13
23
Participants contributions
4
4
Benefits paid
-121
-128
Effect of curtailment or settlement
-12
-8
Exchange rate differences
-93
79
Closing balance
2,497
2,636
Actual return on the plan assets
70
-12
As at 31\u00a0December 2025 the defined benefit plans did not hold any direct investments in ING Groep N.V. (2024: nil).
During 2025 and 2024 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 2026.
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
2025
2024
2025
2024
Opening balance as at 1 January
2,219
2,288
38
30
Current service cost
28
28
1
1
Interest cost
86
87
3
3
Remeasurements: Actuarial gains and losses arising from changes in
demographic assumptions
6
-3
Remeasurements: Actuarial gains and losses arising from changes in
financial assumptions
-32
-94
6
5
Participants\u2019 contributions
4
3
Benefits paid
-127
-132
-1
-1
Past service cost
1
1
Effect of curtailment or settlement
-12
-9
Exchange rate differences and other changes
-65
51
-5
1
Closing balance
2,110
2,219
42
38
Amounts recognised directly in Other comprehensive income were as follows:
Changes in the net defined benefit assets/liability remeasurement reserve
in EUR million
2025
2024
Opening balance as at 1 January
-333
-317
Remeasurement of plan assets
-37
-118
Actuarial gains and losses arising from changes in demographic assumptions
-6
3
Actuarial gains and losses arising from changes in financial assumptions
32
94
Taxation and Exchange rate differences
5
Total Other comprehensive income movement for the year
-12
-16
Closing balance
-345
-333
In 2025, the EUR -37\u00a0 million (2024: EUR -118\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 32\u00a0 million (2024: EUR 94\u00a0
million) of actuarial gains arising from changes in financial assumptions in the calculation of the defined benefit
obligation is mainly due to changes in discount rates.
The accumulated amount of remeasurements recognised directly in Other comprehensive income is EUR
-433\u00a0million(EUR -345\u00a0million after tax) as at 31\u00a0December 2025 (2024: EUR -447\u00a0 million; EUR -333\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
2025
2024
2023
2025
2024
2023
2025
2024
2023
Current service cost
28
28
27
1
1
1
29
29
28
Past service cost
1
1
1
1
1
1
Net Interest cost
-21
-19
-23
3
3
2
-19
-16
-21
Effect of curtailment or settlement
-1
-1
Defined benefit plans
7
9
5
3
4
3
11
13
8
Defined contribution plans
460
423
391
Pension and other post employment
benefits
471
435
399
Other staff related benefits
16
20
19
Pension and other staff-related benefits
488
455
418
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 2025 was
4.2% (2024: 4.4%) 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 2025 was
5.4% (2024: 5.7%).
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 200 million (increase) and EUR 228 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 2026,
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 2026-2030 are estimated to be between EUR 159 million and EUR 174 million per year. From 2030 to
2034, the total payments made by the plan are expected to be EUR 790 million.
", "dimensions": { "concept": "ifrs-full:DisclosureOfEmployeeBenefitsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-737": { "value": "
Number of employees
Netherlands
Rest of the world
Total
2025
2024
2023
2025
2024
2023
2025
2024
2023
Total average number of
internal employees at full time
equivalent basis
15,280
14,821
14,449
47,490
46,301
44,985
62,770
61,121
59,434
", "dimensions": { "concept": "ifrs-full:DisclosureOfInformationAboutEmployeesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-738": { "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 2025 relate to the performance year 2024. In 2025, 145,472 share awards (2024:
180,994; 2023: 224,796) were granted to the members of the Management Board Banking. To senior management
and other employees 3,876,388 share awards (2024: 4,248,400; 2023: 3,244,951) were granted.
Changes in share awards
Share awards (in numbers)
Weighted average grant date fair values
(in euros)
2025
2024
2023
2025
2024
2023
Opening balance as at 1 January
4,853,529
3,895,787
3,697,542
10.88
8.81
7.97
Granted
4,021,860
4,429,394
3,469,747
17.57
13.75
9.71
Vested
-3,448,317
-3,343,429
-3,113,115
14.67
12.29
8.83
Forfeited
-138,970
-128,223
-158,387
13.99
10.73
8.54
Closing balance
5,288,102
4,853,529
3,895,787
13.44
10.88
8.81
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 2025, total unrecognised compensation costs related to share awards amount to EUR 33
million (2024: EUR 25 million; 2023: EUR 15 million). These costs are expected to be recognised over a weighted
average period of 2.0 years ( 2024: 2.0 years; 2023: 2.0 years).", "dimensions": { "concept": "ifrs-full:DisclosureOfSharebasedPaymentArrangementsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-740": { "value": "
27\u00a0 Other operating expenses
Other operating expenses
in EUR million
2025
2024 1
2023 1
Promotional and clients acquisition costs
443
441
369
IT related expenses (excluding outsourcing and subcontracting)
768
694
653
Outsourcing and subcontracting
697
664
579
Facilities
271
277
289
Market data services
153
136
120
Advisory fees
292
315
294
Audit and supervisory fees
142
142
123
Indirect taxes
208
235
107
Regulatory costs
866
882
1,042
Depreciation and impairment of property and equipment 9
451
475
493
Amortisation and impairment of intangible assets 10
230
228
218
Additions and releases of provisions 15
322
219
243
Other
132
224
308
4,976
4,931
4,838
1ING changed the presentation of Other operating expenses as of 2025. The comparative figures for 2024 and 2023 have been updated accordingly. The
reclassifications do not affect the total amount of Other operating expenses.
Reference is made to Note 9 'Property and equipment' for (reversals of) impairments of property and equipment
and Note 10 'Intangible assets' for (reversals of) impairments of intangible assets. For more information on
addition to (unused amounts reversed of) provision for reorganisations refer to Note 15 'Provisions' and for more
information on addition to (unused amounts reversed of) other provisions refer to Note 15 'Provisions' and Note 40
'Legal proceedings'.
Regulatory costs
Regulatory costs represent contributions to the Deposit Guarantee Schemes (DGS), the Single Resolution Fund
(SRF), local bank taxes and local resolution funds. Included in Regulatory costs for 2025 , are contributions to DGS of
EUR 167 million (2024 : EUR 230 million; 2023: EUR 320 million) mainly related to Belgium, Poland, Germany and
the Netherlands and contributions to the SRF and local resolution funds of EUR 41 million (2024: EUR 35 million;
2023: EUR 251 million). In 2025 local bank taxes increased by EUR 41 million from EUR 617 million in 2024 to EUR
657 million (2023 : EUR 472 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-739": { "value": "
27\u00a0 Other operating expenses
Other operating expenses
in EUR million
2025
2024 1
2023 1
Promotional and clients acquisition costs
443
441
369
IT related expenses (excluding outsourcing and subcontracting)
768
694
653
Outsourcing and subcontracting
697
664
579
Facilities
271
277
289
Market data services
153
136
120
Advisory fees
292
315
294
Audit and supervisory fees
142
142
123
Indirect taxes
208
235
107
Regulatory costs
866
882
1,042
Depreciation and impairment of property and equipment 9
451
475
493
Amortisation and impairment of intangible assets 10
230
228
218
Additions and releases of provisions 15
322
219
243
Other
132
224
308
4,976
4,931
4,838
1ING changed the presentation of Other operating expenses as of 2025. The comparative figures for 2024 and 2023 have been updated accordingly. The
reclassifications do not affect the total amount of Other operating expenses.
Reference is made to Note 9 'Property and equipment' for (reversals of) impairments of property and equipment
and Note 10 'Intangible assets' for (reversals of) impairments of intangible assets. For more information on
addition to (unused amounts reversed of) provision for reorganisations refer to Note 15 'Provisions' and for more
information on addition to (unused amounts reversed of) other provisions refer to Note 15 'Provisions' and Note 40
'Legal proceedings'.
Regulatory costs
Regulatory costs represent contributions to the Deposit Guarantee Schemes (DGS), the Single Resolution Fund
(SRF), local bank taxes and local resolution funds. Included in Regulatory costs for 2025 , are contributions to DGS of
EUR 167 million (2024 : EUR 230 million; 2023: EUR 320 million) mainly related to Belgium, Poland, Germany and
the Netherlands and contributions to the SRF and local resolution funds of EUR 41 million (2024: EUR 35 million;
2023: EUR 251 million). In 2025 local bank taxes increased by EUR 41 million from EUR 617 million in 2024 to EUR
657 million (2023 : EUR 472 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-741": { "value": "
Other operating expenses
in EUR million
2025
2024 1
2023 1
Promotional and clients acquisition costs
443
441
369
IT related expenses (excluding outsourcing and subcontracting)
768
694
653
Outsourcing and subcontracting
697
664
579
Facilities
271
277
289
Market data services
153
136
120
Advisory fees
292
315
294
Audit and supervisory fees
142
142
123
Indirect taxes
208
235
107
Regulatory costs
866
882
1,042
Depreciation and impairment of property and equipment 9
451
475
493
Amortisation and impairment of intangible assets 10
230
228
218
Additions and releases of provisions 15
322
219
243
Other
132
224
308
4,976
4,931
4,838
1ING changed the presentation of Other operating expenses as of 2025. The comparative figures for 2024 and 2023 have been updated accordingly. The
reclassifications do not affect the total amount of Other operating expenses.
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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-742": { "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
Australia, Italy, Spain and Portugal
Growth Markets
Poland, Romania and T\u00fcrkiye
Wholesale Banking Rest of World
Other countries in Europe & Middle East, Americas, Asia
Other
Corporate Line
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 also includes certain other income and expenses that are not allocated to the banking businesses,
such as our investments in Bank of Beijing and TMBThanachart Bank (Asian stakes) as well as our stake in Van
Lanschot Kempen (which in 2025 was increased to 20.3%). Furthermore, as from 2022, results in the Corporate
Line have been impacted by the application of hyperinflation accounting in the consolidation of our subsidiary in
T\u00fcrkiye (IAS 29).
Total income within the Corporate Line increased to EUR 340 million, up from EUR 97 million in the previous year.
This growth was driven by higher income from foreign currency ratio hedging (up EUR 70 million year-on-year),
increased results from our financial stakes (EUR +49 million, including a favourable revaluation of the derivative
related to the forward purchase of a stake in Van Lanschot Kempen), and a diminished impact from IAS 29
(reflecting lower inflation in T\u00fcrkiye). In both years, results also included a receivable related to the prior insolvency
of a financial institution in the Netherlands: EUR 16 million in 2025 and EUR 53 million in 2024.
Operating expenses for the Corporate Line decreased to EUR 505 million, compared with EUR 528 million in 2024.
The 2025 figure comprised a hyperinflation impact of EUR 12 million and EUR 73 million in restructuring costs. In
2024, expenses included a EUR 35 million hyperinflation impact, EUR 25 million in restructuring costs, a EUR 22
million one-off CLA-related payment to staff in the Netherlands, and a EUR 21 million litigation provision. Expenses
excluding the aforementioned items declined year-on-year due to a higher VAT refund.
The information presented in this note is in line with the information presented to the 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.
Segments
12 month period
2025
2024
2023
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
Wholesale
Banking
Corporate
Line
Total
Income
Net interest income
3,115
1,786
2,457
3,892
2,997
295
14,542
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
Net fee and
commission income
1,128
692
632
717
1,433
-4
4,597
1,049
603
433
609
1,317
-9
4,002
959
502
357
519
1,259
-10
3,586
Total investment and
other income
726
197
-98
299
2,579
49
3,752
835
189
-173
263
2,405
65
3,584
945
117
-67
277
1,771
-37
3,006
\u2013 of which share of
result from associates
and joint ventures
-8
119
11
-56
133
200
81
8
-36
118
170
7
31
107
144
\u2013 of which
revaluations and
trading income
689
118
-112
257
2,571
-102
3,422
810
81
-160
253
2,478
-55
3,407
898
61
-57
264
1,730
13
2,910
Total income
4,968
2,674
2,991
4,908
7,009
340
22,891
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
Expenditure
Operating expenses
2,089
1,878
1,362
2,905
3,837
505
12,576
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
\u2013 of which Regulatory
costs
67
261
32
287
219
866
114
206
88
261
212
1
882
212
211
96
252
271
0
1,042
Addition to loan loss
provisions
107
153
171
323
549
1
1,304
-8
134
149
291
627
1
1,194
5
169
119
313
-92
5
520
Total expenses
2,196
2,031
1,533
3,228
4,386
506
13,879
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
Result before taxation
2,773
644
1,457
1,680
2,624
-166
9,012
2,793
807
1,455
1,605
2,796
-431
9,025
2,861
661
1,790
1,441
3,836
-270
10,318
Taxation
733
178
472
398
673
57
2,510
723
210
505
381
693
67
2,580
740
182
631
359
900
114
2,926
Non-controlling
interests
0
2
225
48
275
0
1
221
35
258
0
174
61
235
Net result1
2,040
466
983
1,058
1,902
-222
6,226
2,070
597
949
1,002
2,068
-499
6,187
2,121
479
1,159
908
2,875
-385
7,157
1Net result in the table above reflects the net result attributable to shareholders of the parent.
Geographical split of the segments
12 month period
2025
2024
2023
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
Growth
markets
Wholesale
Banking
Rest of
World
Other
Total
Income
Net interest income
2,925
2,277
2,936
2,099
2,526
1,487
292
14,542
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
Net fee and
commission income
1,387
948
698
397
513
660
-6
4,597
1,329
832
484
337
445
585
-9
4,002
1,239
715
400
285
384
573
-10
3,586
Total investment and
other income
2,079
198
-112
37
455
1,040
56
3,752
1,889
207
-188
27
408
1,167
73
3,584
1,627
145
-81
21
487
829
-24
3,006
\u2013 of which share of
result from
associates and joint
ventures
1
54
11
133
200
-45
87
8
120
170
31
7
107
144
\u2013 of which
revaluations and
trading income
2,072
137
-147
3
409
1,074
-127
3,422
1,916
119
-191
2
403
1,217
-59
3,407
1,568
95
-83
4
479
841
6
2,910
Total income
6,392
3,422
3,522
2,533
3,493
3,186
343
22,891
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
Expenditure
Operating expenses
3,067
2,260
1,587
1,468
1,922
1,766
507
12,576
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
\u2013 of which Regulatory
costs
112
285
33
36
320
80
866
159
228
90
61
260
83
1
882
296
243
103
92
207
101
0
1,042
Addition to loan loss
provisions
168
298
259
134
239
205
1
1,304
42
148
222
188
214
378
1
1,194
-111
139
35
166
189
96
5
520
Total expenses
3,235
2,558
1,846
1,602
2,161
1,970
508
13,879
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
Result before taxation
3,157
865
1,676
931
1,333
1,216
-165
9,012
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
Retail Banking
2,773
644
1,457
593
1,087
6,554
2,793
807
1,455
534
1,071
6,660
2,861
661
1,790
649
792
0
6,753
Wholesale Banking
384
221
219
338
246
1,216
2,624
420
391
289
319
218
1,153
7
2,796
824
577
432
292
357
1,345
8
3,836
Corporate Line
-166
-166
-431
-431
-270
-270
Result before taxation
3,157
865
1,676
931
1,333
1,216
-165
9,012
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
Taxation
833
236
543
292
263
287
57
2,510
847
308
563
272
256
267
66
2,580
909
349
723
282
225
335
104
2,926
Non-controlling
interests
0
2
273
275
0
1
256
258
0
234
235
Net result1
2,324
629
1,131
639
796
929
-222
6,226
2,367
889
1,179
581
777
886
-491
6,187
2,776
889
1,499
659
690
1,011
-367
7,157
1Net result in the table above reflects the net result attributable to shareholders of the parent.
", "dimensions": { "concept": "ifrs-full:DisclosureOfEntitysReportableSegmentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-743": { "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, 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 2025 amounts to EUR 5.8 million (2024: EUR 9.5 million).
Overview Top up tax to be paid per jurisdiction (EUR million)
Country
2025
2024
Singapore
3.0
6.5
Ireland
2.2
2.1
Bulgaria
0.3
0.6
Switzerland
0.3
0.3
5.8
9.5
32\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
2025
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
126
-155
5
2
-22
Financial assets and liabilities at FVPL
-19
-47
-13
-79
Depreciation
-22
18
6
2
Cash flow hedges
363
-43
2
322
Pension and post-employment
benefits
-32
4
-1
1
-28
Other provisions
62
-1
61
Loans and advances
427
1
-42
-9
376
Unused tax losses carried forward
85
-47
-4
35
Other
-208
57
21
-8
-139
Total
781
-137
-93
-23
528
Presented in the statement of
financial position as:
\u2013\u00a0 Deferred tax liabilities
-287
-365
\u2013\u00a0 Deferred tax assets
1,069
893
781
528
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 164 million (2024: EUR 178
million and 2023: EUR 195 million ) and a deferred tax amount for lease liabilities of EUR 181 million (2024: EUR 197
million and 2023: EUR 217 million).
The deferred tax on cash flow hedges relate to floating rate lending with interest rate swaps. Due to interest rate
developments in 2025 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 43 million compared to the decline in deferred
tax assets in 2024 by EUR 138 million due to the decline in the interest yield curve. The deferred tax asset in cash
flow hedges decreased from EUR 363 million in 2024 to EUR 322 million in 2025.
The deferred tax on Loans and advances changes through net result in 2025 EUR -42 million (2024: EUR -49\u00a0
million) relates mainly to differences in valuation between accounting (carrying) value and tax value caused by for
example collectively assessed expected credit losses and fee amortisation in Germany.
The deferred tax changes through equity - Other in 2025 of EUR 57 million (2024: EUR -41 million)is due to FX
developments following the USD depreciation and the application of IAS 29 Hyperinflation in T\u00fcrkiye.
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
Deferred tax in connection with unused tax losses carried forward
in EUR million
2025
2024
Total unused tax losses carried forward
860
1,345
Unused tax losses carried forward not recognised as a deferred tax asset
640
951
Unused tax losses carried forward recognised as a deferred tax asset
220
394
Average tax rate
15.7%
21.6%
Deferred tax asset
35
85
Total unused tax losses carried forward analysed by expiry terms
No deferred tax\u00a0
asset recognised
Deferred tax asset
recognised
in EUR million
2025
2024
2025
2024
Within 1 year
More than 1 year but less than 5 years
55
135
152
14
More than 5 years but less than 10 years
9
30
66
More than 10 years but less than 20 years
Unlimited
585
808
38
313
640
951
220
394
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
2025
2024
Australia
14
1
Czech Republic
1
China
8
9
Hong Kong
5
Singapore
2
Taiwan
10
T\u00fcrkiye
30
40
United States of America
1
55
66
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.
At 31 December 2025 and 2024, 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
2025
2024
2023
2025
2024
2023
2025
2024
2023
Current taxation
476
384
558
1,942
1,977
2,120
2,418
2,361
2,677
Deferred taxation
-1
-13
-45
93
232
293
93
219
249
475
371
513
2,036
2,209
2,413
2,510
2,580
2,926
Reconciliation of the weighted average statutory income tax rate to ING Bank\u2019s effective income tax rate
in EUR million
2025
2024
2023
Result before tax from continuing operations
9,012
9,025
10,318
Weighted average statutory tax rate
25.2%
25.1%
25.5%
Weighted average statutory tax amount
2,267
2,263
2,634
Permanent differences affecting current tax
Participation exemption
-69
-87
-43
Other income not subject to tax
-123
-64
-68
Expenses not deductible for tax purposes
476
424
398
Current tax from previously unrecognised amounts
0
-1
1
State and local taxes
56
77
99
Adjustments to prior periods
-92
-34
-72
Differences affecting deferred tax
Impact on deferred tax from change in tax rates
-6
-1
2
Deferred tax benefit from previously unrecognised amounts
-1
-30
Write-off/reversal of deferred tax assets
1
4
4
Effective tax amount
2,510
2,580
2,926
Effective tax rate
27.9%
28.6%
28.4%
The weighted average statutory tax rate in 2025 (25.2%) increased compared to that of 2024 (25.1%).
The effective tax rate of 27.9% in 2025 is higher than the weighted average statutory tax rate. This is mainly
caused by the impact in 2025 of the following non-deductible items for income tax purposes: interest expenses
based on Dutch thin capitalisation rules for banks, bank taxes, and other non-deductible expenses in various
countries. State and local taxes mainly relate to taxes in the United States of America.
The weighted average statutory tax rate in 2024 (25.1%) was lower than the rate of 25.5% in 2023.
The effective tax rate of 28.6% in 2024 was 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. State and local taxes
mainly relate to Base Erosion and anti-Abuse Tax (BEAT) in the United States of America and top-up Tax based on
Global Anti-Base Erosion Model Rules (Pillar Two).
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 for income tax purposes: hyperinflation
accounting loss in T\u00fcrkiye,\u00a0 interest expenses, and bank- and local taxes in various countries. Adjustments to prior
periods mainly relate to a tax refund in Spain.
Equity \u2013 Other comprehensive income
Income tax related to components of other comprehensive income
in EUR million
2025
2024
2023
Unrealised revaluations of financial assets at fair value through other comprehensive
income and other revaluations
-162
100
-7
Realised gains/losses transferred to the statement of profit or loss (reclassifications
from equity to profit or loss)
7
-29
-3
Changes in cash flow hedge reserve
-43
-138
-251
Remeasurement of the net defined benefit asset/liability
4
6
31
Changes in fair value of own credit risk of financial liabilities at fair value through profit
or loss
6
5
2
Exchange rate differences and other
51
-46
19
Total income tax related to components of other comprehensive income
-137
-102
-209
", "dimensions": { "concept": "ifrs-full:DisclosureOfIncomeTaxExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-744": { "value": "
30\u00a0 Potential sale of ING Bank (Eurasia) JSC
On 28 January 2025, ING announced the proposed sale of ING Bank (Eurasia) JSC to Global Development JSC.
Completion of the transaction is subject to various regulatory approvals. This transaction will effectively end ING\u2019s
activities in the Russian market. Under the terms of the agreement, Global Development JSC will acquire all shares
of ING Bank (Eurasia) JSC, taking over all Russian onshore activities and staff. Global Development JSC intends to
continue to serve customers in Russia under a new brand. As of the date of this report and as announced in
September 2025, the buyer has not received all necessary approvals yet. We continue working towards
completing the transaction and our exit from the Russian market. In the meantime, we are in discussion with
regulators on the conflicting regulatory requirements in various jurisdictions with respect to the activities of ING
Bank (Eurasia) JSC.
ING 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. Until sales completion ING continues to direct the
relevant activities of ING Eurasia and, therefore, continues to control and to consolidate it.
Based on 31 December 2025 position, ING estimates a negative impact to the Result on disposal of Group
companies of EUR 0.8 billion post tax. This includes an estimated book loss of EUR 0.5 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. These estimates are subject to change, depending on the position at the closing date.
Given the prevailing uncertainties around substantive regulatory approvals as at 31 December 2025, no book loss
was recognised in 2025 and assets and liabilities of the disposal group were not classified as held for sale.
Furthermore, recycling of the currency translation reserve and the net investment hedge reserve through P&L will
only occur upon deal closing when ownership and control over ING Eurasia is transferred. Such recycling of the
reserves will have no impact on total equity and, hence, ING\u2019s CET1 ratio.
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:
\u00a7 Representation on the board of directors;
\u00a7 Participation in the policymaking process; and
\u00a7 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
2025
2024
Subsidiary
Statutory place of
Incorporation
Country of operation
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%
Investments in associates and joint
ventures
TMBThanachart Bank Public Company
Ltd2
Bangkok
Thailand
23%
23%
1The 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'
2Reference is made to Note 8 'Investment in associates and joint ventures'.
", "dimensions": { "concept": "ifrs-full:DisclosureOfSignificantInvestmentsInSubsidiariesExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-745": { "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
2025
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
126
-155
5
2
-22
Financial assets and liabilities at FVPL
-19
-47
-13
-79
Depreciation
-22
18
6
2
Cash flow hedges
363
-43
2
322
Pension and post-employment
benefits
-32
4
-1
1
-28
Other provisions
62
-1
61
Loans and advances
427
1
-42
-9
376
Unused tax losses carried forward
85
-47
-4
35
Other
-208
57
21
-8
-139
Total
781
-137
-93
-23
528
Presented in the statement of
financial position as:
\u2013\u00a0 Deferred tax liabilities
-287
-365
\u2013\u00a0 Deferred tax assets
1,069
893
781
528
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 164 million (2024: EUR 178
million and 2023: EUR 195 million ) and a deferred tax amount for lease liabilities of EUR 181 million (2024: EUR 197
million and 2023: EUR 217 million).
The deferred tax on cash flow hedges relate to floating rate lending with interest rate swaps. Due to interest rate
developments in 2025 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 43 million compared to the decline in deferred
tax assets in 2024 by EUR 138 million due to the decline in the interest yield curve. The deferred tax asset in cash
flow hedges decreased from EUR 363 million in 2024 to EUR 322 million in 2025.
The deferred tax on Loans and advances changes through net result in 2025 EUR -42 million (2024: EUR -49\u00a0
million) relates mainly to differences in valuation between accounting (carrying) value and tax value caused by for
example collectively assessed expected credit losses and fee amortisation in Germany.
The deferred tax changes through equity - Other in 2025 of EUR 57 million (2024: EUR -41 million)is due to FX
developments following the USD depreciation and the application of IAS 29 Hyperinflation in T\u00fcrkiye.
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
Deferred tax in connection with unused tax losses carried forward
in EUR million
2025
2024
Total unused tax losses carried forward
860
1,345
Unused tax losses carried forward not recognised as a deferred tax asset
640
951
Unused tax losses carried forward recognised as a deferred tax asset
220
394
Average tax rate
15.7%
21.6%
Deferred tax asset
35
85
Total unused tax losses carried forward analysed by expiry terms
No deferred tax\u00a0
asset recognised
Deferred tax asset
recognised
in EUR million
2025
2024
2025
2024
Within 1 year
More than 1 year but less than 5 years
55
135
152
14
More than 5 years but less than 10 years
9
30
66
More than 10 years but less than 20 years
Unlimited
585
808
38
313
640
951
220
394
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
2025
2024
Australia
14
1
Czech Republic
1
China
8
9
Hong Kong
5
Singapore
2
Taiwan
10
T\u00fcrkiye
30
40
United States of America
1
55
66
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.
At 31 December 2025 and 2024, 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-746": { "value": "
33\u00a0 Fair value of assets and liabilities
a) Valuation m ethods
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 the Global Valuation and Impairment Committee (GV&IC) and its
delegate, based on the valuation and valuation adjustment models approved by Trading and Counterparty Risk
Committee (TCRC), with outcomes monitored under the valuation Risk Appetite Statement established by Group
Financial Risk Committee (GFRC) and TCRC.
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 Group Financial Risk Committee (GFRC) is the highest committee
next to Management Board Banking (MBB) to discuss and approve global policies, methodologies and risk appetite
related to Financial Risk. The Trading and Counterparty Risk Committee (TCRC) 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 Banking Book Parameter Committee (BBPC) discusses the valuation topics
for non-Financial Market and non-Group Treasury Wholesale Banking portfolios. 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\u00a0defers 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. The adjustments in fair value and
the DOP reserve are 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
2025
2024
Opening balance at 1 January
-94
-90
DOP deferred on new transactions during the period
-37
-62
DOP recognised in the statement of profit or loss during the period:
\u2013 of which release
13
27
\u2013 of which amortisation and exchange differences
27
32
Closing balance at 31 December
-91
-94
The following table presents the adjustments in fair value for financial assets and liabilities.
Adjustments in fair value on financial assets and liabilities
in EUR million
2025
2024
Deferred Day One Profit or Loss
-91
-94
Own Credit Adjustments
-57
-17
Bid/Offer
-130
-130
Model Risk
-48
-33
CVA
-88
-123
DVA
43
50
CollVA
-11
-3
FVA
-82
-64
Other Valuation Adjustments
3
2
Total Valuation Adjustments
-462
-412
Own Credit Adjustment
Own issued debt and structured notes that are designated at fair value through profit or loss are adjusted for ING\u2019s
own credit risk by means of DVA.\u00a0
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:
\u00a7 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).
\u00a7 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
2025
2024
2025
2024
2025
2024
2025
2024
Financial Assets
Financial assets at fair value
through profit or loss
- Equity securities
21,395
20,798
4
15
187
141
21,586
20,954
- Debt securities
6,492
7,485
2,793
4,596
1,934
3,505
11,219
15,586
- Derivatives
52
1
25,178
31,792
773
475
26,003
32,268
- Loans and receivables
0
0
65,811
62,168
8,542
6,614
74,352
68,782
27,940
28,285
93,785
98,571
11,435
10,734
133,160
137,590
Financial assets at fair value
through other
comprehensive income
- Equity securities
2,301
2,292
0
0
307
270
2,607
2,562
- Debt securities
49,529
39,859
1,288
2,360
0
0
50,817
42,219
- Loans and receivables
0
0
3,238
1,608
0
0
3,238
1,608
51,829
42,151
4,526
3,967
307
270
56,662
46,389
Financial liabilities
Financial liabilities at fair
value through profit or loss
\u2013\u00a0 Debt securities
899
824
7,289
8,437
15
67
8,204
9,328
\u2013\u00a0 Deposits
0
0
47,751
45,648
0
0
47,751
45,648
\u2013\u00a0 Trading securities
2,534
3,631
11
12
9
10
2,554
3,653
\u2013\u00a0 Derivatives
152
45
21,090
27,528
777
694
22,019
28,267
3,585
4,501
76,142
81,625
802
770
80,529
86,896
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 for financial assets measured at fair value through
profit or loss a EUR 0.3 billion (2024: nil) transfer from Level 1 to Level 2 and a EUR 0.4 billion (2024: EUR 0.8 billion)
transfer from Level 2 to Level 1 within debt securities. For financial liabilities measured at fair value through profit or
loss, EUR 0.2 billion (2024: nil) of trading securities were transferred from Level 2 to Level 1. No other significant
transfers between Level 1 and Level 2 were recorded during the 2025 reporting period (2024: nil).
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 2025 of EUR 11.7 billion (2024: EUR
11.0 billion), an amount of EUR 10.1 billion (86.2%) (2024: EUR 9.6 billion, being 87.2%) 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 (2024: EUR 0.1 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 1.5 billion (2024: EUR 1.3 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 2025 of EUR 0.8 billion (2024: EUR
0.8 billion), an amount of EUR 0.6 billion (72.7%) (2024: EUR 0.6 billion, being 75.7%) 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 liabilities include EUR 0.1 billion (2024: EUR 0.1 billion) which relates to financial
liabilities that are part of structures that are designed to be fully neutral in terms of market risk. As explained
above, the fair value of each of the components of these structures may be sensitive to unobservable inputs, but
the overall sensitivity is by design not significant.
The remaining EUR 0.1 billion (2024: 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
2025
2024
2025
2024
2025
2024
2025
2024
At fair value through profit or loss
Debt securities
1,934
3,504
9
10
Price based
Price (%)
0%
0%
103%
120%
Price (price per share)
201
327
412
520
Present value techniques
Price (%)
n.a.
95.85%
n.a.
100%
Equity securities
187
141
Price based
Price (price per share)
0
0
5,475
5,475
Loans and advances
1,978
1,565
0
0
Price based
Price (%)
0%
0%
109%
107%
Present value techniques
Credit spread (bps)
120
576
709
629
Prepayment rate (%)
2%
2%
2%
100%
(Reverse) repos
6,563
5,050
Present value techniques
Interest rate (%)
n.a.
2%
n.a.
2%
Structured notes
15
67
Price based
Price (%)
96%
93%
103%
104%
Option pricing model
Equity volatility (%)
18%
n.a.
22%
n.a.
Equity/Equity correlation
0.7
0.7
0.8
0.7
Equity/FX correlation
-0.6
n.a.
0.2
n.a.
Dividend yield (%)
0.4%
n.a.
1.9%
n.a.
Present value techniques
Prepayment rate (%)
n.a.
99.59%
n.a.
100.09%
Derivatives
\u2013\u00a0\u00a0Rates
628
413
670
389
Option pricing model
Interest rate volatility (bps)
45
n.a.
91
n.a.
Present value techniques
Reset spread (%)
1%
2%
1%
2%
\u2013\u00a0\u00a0FX
2
6
4
8
Option pricing model
Implied volatility (%)
1.7%
2%
42%
15%
\u2013\u00a0\u00a0Credit
134
39
48
241
Present value techniques
Credit spread (bps)
10
0
88
91
Price based
Price (%)
0%
0%
100%
100%
\u2013\u00a0\u00a0Equity
7
10
46
47
Option pricing model
Equity volatility (%)
13%
7%
75%
81%
Equity/Equity correlation
0.0
0.0
1.0
1.0
Equity/FX correlation
-0.7
-0.6
0.5
0.6
Dividend yield (%)
0%
0%
51%
33%
\u2013\u00a0\u00a0Other
2
6
10
9
Option pricing model
Commodity volatility (%)
20%
13.1%
76%
61%
Com/FX correlation
-0.25
-0.40
-0.25
-0.25
Price based
Price (commodity)
66
68
66
68
At fair value through other comprehensive income
\u2013\u00a0\u00a0Equity
307
270
Present value techniques
Credit spread (bps)
5.15
5.67
5.15
5.76
Interest rate (%)
2.5%
1.5%
2.5%
3.5%
Payout ratio (%)
70%
70%
90%
90%
Price based
Price (%)
n.a.
122%
n.a.
122%
Price (price per share)
126
n.a
126
n.a
Total
11,742
11,005
802
770
1The 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
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
Opening balance as at 1 January
824
848
68
286
5,721
3,499
4,121
3,547
270
938
11,005
9,118
Realised gain/loss\u00a0 recognised in the statement of profit or loss during the period 1
247
-175
63
-38
211
294
-798
-54
-278
28
Revaluation recognised in other comprehensive income during the period 2
8
-3
8
-3
Purchase of assets
953
486
0
198
5,177
4,424
1,208
1,600
182
154
7,520
6,862
Sale of assets
-109
-111
0
-257
-1,765
-1,605
-1,160
-10
-163
-418
-3,197
-2,402
Maturity/settlement
-128
-140
0
-7
-166
-294
-763
-988
0
-20
-1,057
-1,449
Reclassifications
0
0
-1
0
18
0
0
0
10
0
28
0
Transfers into Level 3
316
370
0
0
824
615
0
30
0
0
1,139
1,014
Transfers out of Level 3
-974
-454
-9
-114
-2,389
-1,214
0
-3
0
-384
-3,372
-2,169
Exchange rate differences
-14
0
0
0
-6
5
-33
-2
0
9
-53
12
Changes in the composition of the group and other changes
0
0
0
0
0
-1
0
0
0
-5
0
-6
Closing balance
1,114
824
121
68
7,625
5,721
2,576
4,121
307
270
11,742
11,005
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 280 million (2024: EUR -41 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 2025, transfers out of Level 3 within trading assets relate mainly to securities, as their valuations were no longer
significantly influenced by unobservable inputs. In 2024, transfers out of Level 3 in trading assets primarily involved
derivative instruments, as their valuations were no longer significantly impacted by unobservable inputs.
In 2025 and 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. In 2024, the
transfer out of Level 3 in non-trading derivatives primarily involved derivative instruments, as their valuations were
no longer significantly impacted by unobservable inputs.
In 2025 and 2024, 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 out of Level 3 of financial assets at FVOCI relates to Hold-to-Collect and Sell portfolio
transferred to Level 2 resulting from change in methodology.
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
2025
2024
2025
2024
2025
2024
2025
2024
Opening balance as at 1
January
637
382
67
301
67
47
770
729
Realised gain/loss recognised
in the statement of profit or
loss during the period 1
81
-104
82
-98
-6
-5
157
-206
Additions
205
55
3
190
11
29
219
274
Redemptions
-74
-12
0
-209
0
0
-74
-222
Maturity/settlement
-160
-15
0
-7
-64
-4
-225
-26
Transfers into Level 3
19
364
0
0
19
34
38
399
Transfers out of Level 3
-72
-33
0
-111
-12
-34
-84
-179
Exchange rate differences
-1
0
0
0
0
0
-1
0
Closing balance
636
637
151
67
15
67
802
770
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 158 million
(2024: EUR -206\u00a0million) of unrealised gains and losses recognised in the statement of profit or loss.
In 2025, the transfers out of Level 3 mainly consisted of trading liabilities related to securities transferred out of
Level 3 as a result of the valuation being no longer impacted by significantly unobservable inputs.
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.
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
2025
2024
2025
2024
Equity (equity derivatives, structured notes)
20
21
-12
-20
Interest rates (Rates derivatives, FX derivatives)
1
5
0
0
Credit (Debt securities, Loans, structured notes, credit derivatives)
12
2
-14
-27
Loans and advances
0
0
0
0
33
28
-26
-47
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 value 1
Level 1
Level 2
Level 3
Total fair value
in EUR million
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
2025
2024
Financial Assets
Loans and advances to banks
21,204
21,769
3,053
3,194
14,722
15,614
3,366
2,957
21,141
21,766
Loans and advances to customers
721,779
680,299
18,233
18,296
12,782
18,626
678,392
630,493
709,408
667,415
Securities at amortised cost
53,867
50,273
47,722
42,871
2,381
2,908
2,692
2,523
52,796
48,303
796,850
752,341
21,286
21,490
47,723
42,871
29,885
37,149
684,450
635,973
783,344
737,483
Financial liabilities
Deposits from banks
18,521
16,722
5,401
4,347
9,162
8,208
3,745
3,943
18,308
16,498
Customer deposits
724,707
699,725
621,172
582,511
85,801
69,790
17,433
46,984
724,406
699,285
Debt securities in issue
103,116
94,459
36,782
33,019
62,567
59,141
3,857
2,000
103,207
94,161
Senior non-preferred debt
48,090
49,393
49,155
50,230
49,155
50,230
Subordinated loans
18,100
17,879
18,722
18,357
18,722
18,357
912,534
878,178
626,573
586,857
36,782
33,019
225,408
205,726
25,035
52,927
913,798
878,530
1In 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, excluding the negative macro fair value hedge adjustment.
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.
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
There is an embedded value in our on-demand deposits. However, for the purpose of this disclosure, and in
accordance with IFRS, the fair value of deposits with an immediate on demand feature approximates the carrying
amount, excluding the negative macro fair value hedge adjustment.
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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-747": { "value": "
36\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:
\u00a7 Perpetual liabilities are included in the column \u2018Maturity not applicable\u2019.
\u00a7 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.
\u00a7 Undiscounted future coupon interest on financial liabilities payable is included in a separate line and in the
relevant maturity bucket.
\u00a7 Non-financial liabilities are included based on a breakdown of the amounts per statement of financial position,
per expected maturity.
\u00a7 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
2025
Less than 1 month 1
1\u20133 months
3\u201312 months
1\u20135 years
Over 5 years
Maturity not applicable
Adjustment\u00a0 2
Total
Deposits from banks
10,307\u00a0
2,433\u00a0
2,392\u00a0
1,737\u00a0
1,617\u00a0
34\u00a0
18,521\u00a0
Customer deposits
649,957\u00a0
26,346\u00a0
37,769\u00a0
6,769\u00a0
2,049\u00a0
1,816\u00a0
724,707\u00a0
Financial liabilities at fair value
through profit or loss
\u2013\u00a0 Other trading liabilities
704\u00a0
48\u00a0
110\u00a0
1,028\u00a0
610\u00a0
247\u00a0
2,745\u00a0
\u2013\u00a0 Trading derivatives
2,509\u00a0
2,290\u00a0
4,604\u00a0
7,508\u00a0
2,459\u00a0
1,311\u00a0
20,681\u00a0
\u2013\u00a0 Non-trading derivatives
170\u00a0
199\u00a0
229\u00a0
304\u00a0
128\u00a0
309\u00a0
1,338\u00a0
\u2013\u00a0 Designated at fair value through
profit or loss
39,279\u00a0
6,980\u00a0
937\u00a0
4,110\u00a0
4,558\u00a0
36\u00a0
-137\u00a0
55,764\u00a0
Debt securities in issue
1,268\u00a0
17,674\u00a0
40,682\u00a0
26,598\u00a0
17,731\u00a0
-838\u00a0
103,116\u00a0
Senior non preferred debt
2,032\u00a0
1,139\u00a0
\u00a0
28,600\u00a0
16,791\u00a0
-473\u00a0
48,090\u00a0
Subordinated loans
\u00a0
\u00a0
\u00a0
\u00a0
10,612\u00a0
7,627\u00a0
-139\u00a0
18,100\u00a0
Lease liabilities
15\u00a0
34\u00a0
172\u00a0
574\u00a0
304\u00a0
-50\u00a0
1,050\u00a0
Financial liabilities
706,242\u00a0
57,144\u00a0
86,894\u00a0
77,227\u00a0
56,860\u00a0
7,663\u00a0
2,081\u00a0
994,112\u00a0
Other liabilities 3
7,289\u00a0
843\u00a0
2,221\u00a0
490\u00a0
553\u00a0
11,395\u00a0
Total liabilities
713,531\u00a0
57,986\u00a0
89,115\u00a0
77,717\u00a0
57,413\u00a0
7,663\u00a0
2,081\u00a0
1,005,507\u00a0
Coupon interest due on financial
liabilities
1,913\u00a0
1,331\u00a0
4,661\u00a0
11,837\u00a0
8,866\u00a0
476\u00a0
29,086\u00a0
Commitments:
\u2013\u00a0 Guarantees
28,690\u00a0
\u00a0
\u00a0
552\u00a0
\u00a0
29,242\u00a0
\u2013\u00a0 Irrevocable letters of credit
15,230\u00a0
\u00a0
\u00a0
\u00a0
\u00a0
15,230\u00a0
Irrevocable facilities
200,000\u00a0
39\u00a0
6\u00a0
77\u00a0
76\u00a0
200,198\u00a0
243,920
39
6
629
76
244,670
1Includes liabilities on demand.
2This 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.
Liabilities and off-balance sheet commitments by maturity
in EUR million
2024
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
9,104
1,367
2,085
1,637
2,484
46
16,722
Customer deposits
610,590
23,479
50,034
11,141
2,081
2,399
699,725
Financial liabilities at fair value
through profit or loss
\u2013\u00a0 Other trading liabilities
5,790
230
313
1,325
1,465
-34
9,089
\u2013\u00a0 Trading derivatives
2,631
2,367
3,730
7,641
5,499
4,298
26,166
\u2013\u00a0 Non-trading derivatives
419
57
-36
711
149
801
2,101
\u2013\u00a0 Designated at fair value through
profit or loss
32,644
5,842
1,798
5,095
4,365
34
-239
49,539
Debt securities in issue
1,949
17,635
33,037
26,600
15,704
-466
94,459
Senior non preferred debt
975
30,121
19,153
-856
49,393
Subordinated loans
9,962
8,415
-498
17,879
Lease liabilities
20
44
162
607
328
-45
1,116
Financial liabilities
663,148
51,995
91,125
84,879
61,190
8,448
5,405
966,190
Other liabilities 3
7,294
456
2,073
502
470
10,795
Total liabilities
670,442
52,451
93,198
85,381
61,660
8,448
5,405
976,986
Coupon interest due on financial
liabilities
2,278
1,600
5,981
10,388
8,065
516
28,829
Commitments:
\u2013\u00a0 Guarantees
26,355
3
550
26,908
\u2013\u00a0 Irrevocable letters of credit
16,388
16,388
Irrevocable facilities
175,000
9
15
143
56
175,222
217,743
9
15
146
606
218,518
1Includes liabilities on demand.
2This 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.
39\u00a0 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.
Commitments
in EUR million
2025
2024
\u2013\u00a0 Guarantees
29,242
26,908
\u2013\u00a0 Irrevocable letters of credit
15,230
16,388
44,472
43,296
Irrevocable facilities
200,198
175,222
244,670
218,518
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\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, irrevocable facilities includes certain revocable facilities where the
ability to withdraw such facilities is constrained in practice, and cancellation typically occurs only after a significant
increase in credit risk, these commitments are treated as \u201cin substance irrevocable\u201d and are therefore included
within the scope of the IFRS 9 impairment requirements.
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 2025 (31 December 2024:
EUR 346 million). No IPCs were provided to the SRF during 2025 (2024: nil). No IPCs were called by the SRF in 2025
(2024: 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. IPCs amount to EUR
322 million as at 31 December 2025 (31 December 2024: EUR 309 million). Of these, EUR 13 million of IPCs were
provided to the DGS during 2025 (2024: EUR 35 million). No IPCs were called by the DGS in 2025 (2024: nil). ING
posted government bonds as collateral for the total nominal amount of EUR 336 million as at 31 December 2025
(31 December 2024: EUR 336 million).
In addition to the items included in commitments, 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", "dimensions": { "concept": "ifrs-full:DisclosureOfCommitmentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-748": { "value": "
37\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
2025
2024
Banks
\u2013\u00a0 Cash and balances with central banks
499
397
\u2013\u00a0 Loans and advances to banks
2,672
2,211
Financial assets at fair value through profit or loss
20,561
28,905
Financial assets at fair value through OCI
1,519
3,037
Securities at amortised cost
3,339
3,184
Loans and advances to customers
71,321
67,706
Other assets
479
503
100,392
105,944
In some jurisdictions ING Bank N.V. has an obligation to maintain a reserve with central banks. As at 31 December
2025, the minimum mandatory reserve deposits with various central banks amount to EUR 11,925 million (2024 :
EUR 11,648 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
2025
2024
Total received collateral available for sale or repledge at fair value
\u2013\u00a0 equity securities
21,494
22,815
\u2013\u00a0 debt securities
144,257
140,285
of which sold or repledged at fair value
\u2013\u00a0 equity securities
16,018
12,024
\u2013\u00a0 debt securities
98,422
90,708
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. These transferred financial
assets remain recognized on the balance sheet as ING retains substantially all the risk and rewards of ownership
and remains exposed to the changes in the fair value of the assets.
Transfer of financial assets not qualifying for derecognition
Securities lending
Sale and repurchase
Equity
Debt
Equity
Debt
in EUR million
2025
2024
2025
2024
2025
2024
2025
2024
Transferred assets at carrying
amount
Financial assets at fair value through
profit or loss
4,163
4,141
3
3
5,929
7,273
9,687
16,929
Financial assets at fair value through
other comprehensive income
314
603
886
1,956
Securities at amortised cost
399
635
989
819
Associated liabilities at carrying
amount1
Financial liabilities at fair value
through profit or loss
n/a
n/a
n/a
n/a
5,398
7,005
6,684
11,901
1The 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 2025 (31 December 2024:
EUR 346 million). No IPCs were provided to the SRF during 2025 (2024: nil). No IPCs were called by the SRF in 2025
(2024: 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. IPCs amount to EUR
322 million as at 31 December 2025 (31 December 2024: EUR 309 million). Of these, EUR 13 million of IPCs were
provided to the DGS during 2025 (2024: EUR 35 million). No IPCs were called by the DGS in 2025 (2024: nil). ING
posted government bonds as collateral for the total nominal amount of EUR 336 million as at 31 December 2025
(31 December 2024: EUR 336 million).
", "dimensions": { "concept": "ifrs-full:DisclosureOfCollateralExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-749": { "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
2025
2024
Banks
\u2013\u00a0 Cash and balances with central banks
499
397
\u2013\u00a0 Loans and advances to banks
2,672
2,211
Financial assets at fair value through profit or loss
20,561
28,905
Financial assets at fair value through OCI
1,519
3,037
Securities at amortised cost
3,339
3,184
Loans and advances to customers
71,321
67,706
Other assets
479
503
100,392
105,944
In some jurisdictions ING Bank N.V. has an obligation to maintain a reserve with central banks. As at 31 December
2025, the minimum mandatory reserve deposits with various central banks amount to EUR 11,925 million (2024 :
EUR 11,648 million ).
", "dimensions": { "concept": "ifrs-full:DisclosureOfRestrictedCashAndCashEquivalentsExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-750": { "value": "
40\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 ING and/or 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 2025, the Court decided that ING\u2019s former CEO does not have to be
prosecuted. This case is now closed.
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. ING does not agree with the allegations and will defend itself against these and the claimed
damages of EUR 587\u00a0million. In February 2025, ING and the (former) board members filed their statement of
defence against the allegations and in November 2025, the court rejected all claims by the investors. In February
2026, the investors filed an appeal against this decision of the court. 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. The court issued a decision on the request in May 2025 where it
rejected the entirety of the request made by these investors. These investors may decide to pursue further legal
action. ING follows 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, a Luxembourg 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. In December 2025, the Court of Appeal upheld the first decision without making any
substantive changes, as a result of which the case can now be heard before the Tribunal Correctionnel. It is
currently not possible to determine how this matter will be resolved or the timing of any such resolution, ING does
not expect the outcome of this matter to have a material financial effect.
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.
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.
Additionally, ING Bank T\u00fcrkiye has initiated enforcement proceedings against SDIF regarding accumulated
receivables that SDIF has either partially or completely failed to pay.
As of February 2026, four lawsuits have been finalized in favour of ING Bank T\u00fcrkiye with the Turkish Supreme
Court's verdict, which are likely to be precedent decisions for the other files. 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.
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 has adapted its strategy to 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.
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 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 interest 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 installments 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.
In June 2025, the CJEU issued a judgement in one of the Polish cases concerning banks' capital recovery after
invalidation of the mortgage Swiss franc loan agreement. The verdict was passed in the case brought by a bank.
The CJEU questioned the compliance with European Union law of the so-called two-claims theory, which has so far
been widely used in Polish jurisprudence. It was based on the assumption that each party of the invalidated
contract has its own claim. A consumer is entitled to ask for all the installments paid to the bank, and a bank is
entitled to ask for the capital (in two separate civil proceedings). CJEU said that this approach is against EU law.
Both claims should be taken into consideration in one proceeding. A bank is entitled to ask only for the result of
subtraction of its claim and a claim of a consumer (the balance theory). Despite this CJEU ruling, the majority of
Polish courts continues issuing judgments in accordance with two-claims theory.
Since September 2025, ING Poland has seen an increase in the number of settlements.
In January 2026, the CJEU issued a judgement confirming that it is permissible to settle both parties\u2019 claims in a
Swiss franc dispute within a single proceeding by way of set off. The CJEU found that banks may raise the defence
of set-off even if the invalidity of the contract is disputed. The CJEU pointed out that if the bank were deprived of
the possibility of raising a set-off defence against the consumer, his right to effective judicial protection would be
disproportionately infringed. Although the judgment is generally favorable to banks, certain theses contained in
the judgment may result in an approach to calculating interest that is unfavorable for banks. At this point,
however, it is unclear how the courts will approach the application of this ruling. This requires observation.
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. ING substantially finalized the compensation
process in the first half of 2025, with a spill-over to the third quarter of 2025 for after-care in individual cases. ING
has reached out to its customers with respect to the Kifid ruling, to also compensate amounts under EUR 50. Kifid
confirmed ING's calculation methodology in relation to older consumer credits, where there is no relevant data
available to determine the start delta and in relation to the interest-on-interest effect. The compensation process
is still ongoing and may take until Q2 2026.
Climate litigation: In January 2024, Friends of the Earth Netherlands (Milieudefensie) announced that it holds ING
liable for alleged contribution to climate change and threatened to initiate legal proceedings against ING. In March
2025, Milieudefensie started legal proceedings at the Court in Amsterdam against ING by serving the writ of
summons. ING will defend its science-based climate approach in court and submitted its statement of defence in
February 2026.
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. ING does
not agree with these claims, as they do not comply with the underlying contracts or applicable laws, including
sanctions. ING follows 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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-751": { "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:
\u00a7 Representation on the board of directors;
\u00a7 Participation in the policymaking process; and
\u00a7 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
2025
2024
Subsidiary
Statutory place of
Incorporation
Country of operation
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%
Investments in associates and joint
ventures
TMBThanachart Bank Public Company
Ltd2
Bangkok
Thailand
23%
23%
1The 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'
2Reference is made to Note 8 'Investment in associates and joint ventures'.
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 December 2025, these consisted of EUR 76 billion (2024: EUR
74 billion) of senior and subordinated notes, of which EUR 4 billion (2024: EUR 4 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 2025 , 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 presented in table
below. In order for these entities to fulfil their guarantee, ING legally transfers mainly 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
2025
2024
Dutch Covered Bond programmes
29,131
27,172
Diba Mortgage Pfandbriefe
18,811
15,050
ING Belgium Residential Pandbrieven Programme
8,986
9,024
IBAL Covered Bond
3,492
3,676
ING Bank Hipoteczny CBP
820
602
61,240
55,524
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 in the ABCP markets.
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.
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 4,800 million (2024: EUR 3,119 million). The drawn liquidity
amount is nil as at 31 December 2025 (2024: 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 programmes
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. Service fee income recognised, for the role as administrative agent, in
the statement of profit or loss in 2025 amounted to EUR 1 million (2024: EUR 1 million). The cumulative income
recognised in profit or loss since derecognition amounts to EUR 21 million (2024: EUR 20 million).
In 2025, ING established two SPVs, which are Designated Activity Companies incorporated in Ireland, for the
purpose of significant risk transfer securitizations. ING transferred the credit risk on the selected diversified
portfolios of corporate loans without transferring the assets to the SPVs. Each SPV has issued a series of credit
linked notes varying in seniority of the referenced loans to the investors. Subsequently, SPVs provide a financial
guarantee to ING in respect of the referenced loans and, in return for a fee, are liable to make protection
payments to ING upon the occurrence of a credit event in relation to any of the referenced loans.As of 31
December 2025, credit linked notes held by third parties amounted to EUR 676 million (2024: nil) and funds raised
by the sale of the credit linked notes are deposited within ING as collateral for the credit protection. The associated
corporate loans were EUR 10 billion (2024: nil). The SPVs are not consolidated by ING because the third-party
investors have the exposure, or rights to all variability of returns of the entities. No assets are transferred to, or
income received from these entities and the credit linked notes are fully cash collateralized.
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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-752": { "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 31 '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
2025
2024
Assets
83
72
Liabilities
71,222
77,739
Income received
0
0
Expenses paid
2,656
2,507
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
2025
2024
2025
2024
Assets
117
142
Liabilities
242
263
7
10
Off-balance sheet commitments
18
23
Income received
21
16
Expenses paid
2
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 2025, 2024 and 2023, 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)
2025
in EUR thousands
Executive Board of
ING Groep N.V.
Management Board
Banking 1
Total
Fixed Compensation
\u2013\u00a0 Base salary
4,615
4,306
8,921
\u2013\u00a0 Collective fixed allowances 2
1,094
984
2,078
\u2013\u00a0 Pension costs
83
111
194
\u2013\u00a0 Severance benefits 3
1,347
444
1,791
Variable compensation
\u2013\u00a0 Upfront cash
745
745
\u2013\u00a0 Upfront shares
330
745
1,075
\u2013\u00a0 Deferred cash
1,118
1,118
\u2013\u00a0 Deferred shares
494
1,118
1,613
\u2013\u00a0 Other emoluments 4
340
468
808
Total compensation
8,302
10,041
18,343
1Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.
2The collective fixed allowances consist of two savings allowances applicable to employees in the Netherlands; an individual savings allowance of 3.5%
and a collective savings allowance to compensate for the\u00a0 loss of pension benefits with respect to salary in excess of EUR 137,800.
3In accordance with the Executive Board remuneration policy and with due observance of applicable legal requirements, a severance payment equal to
one year's base salary has been granted.
4 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)
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
609
609
\u2013\u00a0 Upfront shares
302
609
911
\u2013\u00a0 Deferred cash
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
1Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.
2The collective fixed allowances consist of two savings allowances applicable to employees in the Netherlands; an individual savings allowance of 3.5%
and a collective savings allowance to compensate for the 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; 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)
2023
Executive Board of
ING Groep N.V.
Management Board
Banking 1
Total
in EUR thousands
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
1Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.
2The collective fixed allowances consist of two savings allowances applicable to employees in the Netherlands; an individual savings allowance of 3.5%
and a collective savings allowance to compensate for loss of pension benefits with respect to salary in excess of EUR 128,810.
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 2025 relating to the fixed expenses of 2025 and the vesting of variable remuneration of earlier
performance years, is EUR 16 million (2024: EUR 12 million; 2023: EUR 14 million).\u00a0
The table below shows the total of fixed remuneration, expense allowances and attendance fees for the
Supervisory Board in 2025, 2024 and 2023.
Key management personnel compensation (Supervisory Board)
in EUR thousands
2025
2024
2023
Total compensation
1,434
1,191
1,152
Loans and advances to key management personnel
As at 31 December 2025 Loans and advances outstanding to key management personnel amounted to EUR 1.1
million (2024: EUR 1.1 million) with an average interest rate of 1.7% (2024: 2.1%) and loan commitments to key
management personnel amounted to EUR 162 thousand (2024: EUR 145\u00a0thousand). Total interest received in 2025
on these loans and advances amounted to EUR 17 thousand (2024: EUR 28 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 and bonds invested in by key management personnel
As at 31 December 2025 Deposits outstanding from key management personnel amounted to EUR 12.9 million
(2024: EUR 15.8 million) and bonds invested in by key management personnel amounted to EUR 226 thousand
(2024: nil). Total interest paid in 2025 on these deposits amounted to EUR 1.1\u00a0million (2024: EUR 324 thousand)
and total interest paid in 2025 on these bonds amounted to EUR 3 thousand (2024: nil). These transactions are
entered into under the same commercial and market terms, including interest rates, that apply to non-related
parties.
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
2025
2024
Executive Board members
178,187
152,652
Management Board Banking
415,008
343,055
Supervisory Board members
9,395
5,295
", "dimensions": { "concept": "ifrs-full:DisclosureOfRelatedPartyExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-753": { "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 31 '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": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-754": { "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 2025, 2024 and 2023, 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)
2025
in EUR thousands
Executive Board of
ING Groep N.V.
Management Board
Banking 1
Total
Fixed Compensation
\u2013\u00a0 Base salary
4,615
4,306
8,921
\u2013\u00a0 Collective fixed allowances 2
1,094
984
2,078
\u2013\u00a0 Pension costs
83
111
194
\u2013\u00a0 Severance benefits 3
1,347
444
1,791
Variable compensation
\u2013\u00a0 Upfront cash
745
745
\u2013\u00a0 Upfront shares
330
745
1,075
\u2013\u00a0 Deferred cash
1,118
1,118
\u2013\u00a0 Deferred shares
494
1,118
1,613
\u2013\u00a0 Other emoluments 4
340
468
808
Total compensation
8,302
10,041
18,343
1Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.
2The collective fixed allowances consist of two savings allowances applicable to employees in the Netherlands; an individual savings allowance of 3.5%
and a collective savings allowance to compensate for the\u00a0 loss of pension benefits with respect to salary in excess of EUR 137,800.
3In accordance with the Executive Board remuneration policy and with due observance of applicable legal requirements, a severance payment equal to
one year's base salary has been granted.
4 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)
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
609
609
\u2013\u00a0 Upfront shares
302
609
911
\u2013\u00a0 Deferred cash
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
1Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.
2The collective fixed allowances consist of two savings allowances applicable to employees in the Netherlands; an individual savings allowance of 3.5%
and a collective savings allowance to compensate for the 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; 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)
2023
Executive Board of
ING Groep N.V.
Management Board
Banking 1
Total
in EUR thousands
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
1Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.
2The collective fixed allowances consist of two savings allowances applicable to employees in the Netherlands; an individual savings allowance of 3.5%
and a collective savings allowance to compensate for loss of pension benefits with respect to salary in excess of EUR 128,810.
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 2025 relating to the fixed expenses of 2025 and the vesting of variable remuneration of earlier
performance years, is EUR 16 million (2024: EUR 12 million; 2023: EUR 14 million).\u00a0
The table below shows the total of fixed remuneration, expense allowances and attendance fees for the
Supervisory Board in 2025, 2024 and 2023.
Key management personnel compensation (Supervisory Board)
in EUR thousands
2025
2024
2023
Total compensation
1,434
1,191
1,152
Loans and advances to key management personnel
As at 31 December 2025 Loans and advances outstanding to key management personnel amounted to EUR 1.1
million (2024: EUR 1.1 million) with an average interest rate of 1.7% (2024: 2.1%) and loan commitments to key
management personnel amounted to EUR 162 thousand (2024: EUR 145\u00a0thousand). Total interest received in 2025
on these loans and advances amounted to EUR 17 thousand (2024: EUR 28 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 and bonds invested in by key management personnel
As at 31 December 2025 Deposits outstanding from key management personnel amounted to EUR 12.9 million
(2024: EUR 15.8 million) and bonds invested in by key management personnel amounted to EUR 226 thousand
(2024: nil). Total interest paid in 2025 on these deposits amounted to EUR 1.1\u00a0million (2024: EUR 324 thousand)
and total interest paid in 2025 on these bonds amounted to EUR 3 thousand (2024: nil). These transactions are
entered into under the same commercial and market terms, including interest rates, that apply to non-related
parties.
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
2025
2024
Executive Board members
178,187
152,652
Management Board Banking
415,008
343,055
Supervisory Board members
9,395
5,295
", "dimensions": { "concept": "ifrs-full:DisclosureOfInformationAboutKeyManagementPersonnelExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-755": { "value": "
44\u00a0 Capital management
Capital management strategy
Group Treasury (GT) is responsible for maintaining adequate capitalisation across ING Group and its banking
entities to support the management of risks associated with ING\u2019s business activities. This includes capital
planning, allocation, and management within the Group, as well as the execution of capital market, term capital
funding, and risk management transactions. ING employs an integrated approach to assessing capital adequacy,
whereby GT considers regulatory and internal economic capital metrics alongside the interests of key
stakeholders, including customers, shareholders, and rating agencies.
ING applies the following main capital definitions:
\u00a7 Common Equity Tier 1 (CET1) capital consists of shareholders\u2019 equity after the correction for applicable
regulatory adjustments. The CET1 ratio is calculated as CET1 capital divided by risk-weighted assets (RWAs).
\u00a7 Tier 1 capital is defined as CET1 capital plus Additional Tier 1 (AT1) securities and other regulatory adjustments.
The Tier 1 capital ratio is defined as Tier 1 capital divided by RWAs.
\u00a7 Total capital consists of Tier 1 capital plus Tier 2 subordinated liabilities, after regulatory adjustments. The Total
capital ratio is calculated as Total capital divided by RWAs.
\u00a7 ING\u2019s CET1 ratio target is built on the CET1 requirements specified for ING, potential increase in the regulatory
requirements, the potential impact of a standardised and predetermined stress scenario and available
mitigating actions, and general uncertainties in its baseline planning.
\u00a7 Leverage ratio (LR) is defined as Tier 1 capital divided by the leverage exposure.
\u00a7 Minimum Required Eligible Liabilities (MREL)/ Total Loss Absorbing Capacity (TLAC) is Total capital plus senior
unsecured bonds and amortisations. Related MREL and TLAC ratios are expressed relative to both risk-weighted
assets and leverage exposure.\u00a0
Capital position as per 31 December 2025
ING Bank capital position according to CRR III / CRD V
in EUR million
2025
2024
Shareholders\u2019 equity 1
47,744
42,743
- Interim profits not included in CET 1 capital
-699
0
- Other adjustments
-2,580
-2,146
Regulatory adjustments
-3,279
-2,146
Available common equity Tier 1 capital
44,465
40,597
Additional Tier 1 securities
7,460
7,967
Regulatory adjustments additional Tier 1
112
106
Available Tier 1 capital
52,037
48,671
Supplementary capital Tier 2 bonds
10,609
9,853
Regulatory adjustments Tier 2
98
81
Available Total capital
62,744
58,604
Risk weighted assets
340,186
334,770
Common equity Tier 1 ratio
13.1%
12.1%
Tier 1 ratio
15.3%
14.5%
Total capital ratio
18.4%
17.5%
1Shareholders' equity is determined in accordance with IFRS-EU.
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 regulatory capital requirements are based on the standards issued by the Basel Committee
on Banking Supervision (the Basel Committee) and implemented in the European Union Directives through the
Capital Requirements Regulation (CRR) and Capital Requirements Directive (CRD), as implemented by De
Nederlandsche Bank (DNB) and the European Central Bank (ECB). Under the CRR, the minimum Pillar 1 capital
requirements applicable to ING 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\u2011weighted assets.
The overall SREP CET1 requirement (including buffer requirements) for ING Bank N.V. at a consolidated level was
11.03% at the end of 2025 (2024: 9.83%). This requirement is the sum of a 4.5% Pillar 1 requirement, a 0.93% Pillar
2 requirement, a 2.5% capital conservation buffer (CCB), a 0.93% countercyclical buffer (CCyB), 0.16% Sectoral
Systemic Risk buffer (s-SyRB) and a 2.0% Other Systemically Important Institutions (O-SII) buffer that is set
separately for Dutch systemic banks by DNB. This requirement excludes the Pillar 2 guidance, which is not
disclosed. ING met the externally imposed regulatory capital requirements in 2025.
", "dimensions": { "concept": "ifrs-full:DisclosureOfObjectivesPoliciesAndProcessesForManagingCapitalExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-756": { "value": "
45\u00a0 Subsequent events
There are no subsequent events to report.", "dimensions": { "concept": "ifrs-full:DisclosureOfEventsAfterReportingPeriodExplanatory", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-757": { "value": "Naamloze Vennootschap", "dimensions": { "concept": "ifrs-full:LegalFormOfEntity", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-758": { "value": "Bijlmerdreef 106, 1102 CT Amsterdam, the Netherlands", "dimensions": { "concept": "ifrs-full:PrincipalPlaceOfBusiness", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } }, "f-759": { "value": "Bijlmerdreef 106, 1102 CT Amsterdam, the Netherlands", "dimensions": { "concept": "ifrs-full:AddressOfRegisteredOfficeOfEntity", "language": "en", "entity": "scheme:3TK20IVIUJ8J3ZU0QE75", "period": "2025-01-01T00:00:00/2026-01-01T00:00:00" } } } }