ingbank-2025-12-31-en


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	3

About this report

ING’s purpose is empowering people to stay a step

ahead in life and in business. This purpose guides

us in everything we do. In this Annual Report we

disclose our results, strategy, and management

approach in the context of external developments,

as well as emerging and existing impacts, risks

and opportunities.

In this Annual Report, unless otherwise stated or implied by context,

references to ‘ING Bank' or 'ING' refer to ING Bank N.V. The parent

company of ING Bank is ING Groep N.V. referred to as ING Group. This

Annual Report is intended to inform stakeholder groups that have an

impact on, or are affected by, our business. These include our customers,

clients, investors, society, employees and suppliers & partners.

This report covers the period of 1 January to 31 December 2025 and was

published on 26 February 2026. We published our previous Annual Report

on 6 March 2025, which covered the year 2024. This report consists of:

§ Report of the Management Board, which includes the sections

‘Strategy, business model and value creation’, ‘Our financial

performance’, ‘Our leadership and corporate governance’, ‘Capital

management’ and ‘Risk management’;

§ Consolidated financial statements;

§ Parent company financial statements; and

§ Other information and appendices

The consolidated financial statements included in this report have been

prepared in accordance with International Financial Reporting Standards

(IFRS), as adopted by the European Union (EU), and the relevant articles of

Part 9 of Book 2 of the Dutch Civil Code. The Parent company financial

statements of ING Bank N.V. are prepared in accordance with the financial

reporting requirements included in Part 9 of Book 2 of the Dutch Civil Code.

Reasonable assurance for the consolidated financial statements and the

Parent company financial statements is provided by KPMG Accountants

N.V. (KPMG).

ING Bank makes use of the exemption for subsidiary undertakings as set

out in the Omnibus I simplification amending the accounting directive

(2013/34). The sustainability information of ING Bank is reported at group

level by our parent undertaking ING Group whose registered office is

located in Amsterdam, the Netherlands. ING Group reports in accordance

with the European Sustainability Reporting Standards which - together

with the subsidiary exemption - is expected to be implemented into Dutch

law with retroactive effect.

The report of the Executive Board of ING Group including its Sustainability

statement and the related limited assurance opinion, by KPMG, is available

on ing.com. As a result ING Bank is exempt from preparing a separate

Sustainability statement.

This document is the PDF version of the 2025 Annual Report of ING made

available on ing.com. Another version of this document has been prepared

in the European single electronic reporting format (ESEF). This ESEF

reporting package is also available on ing.com. In the event of any

discrepancies between this PDF version and the ESEF reporting package,

the ESEF reporting package takes precedence.

Strategy, business model and value creation

Strategy,

business model

and value creation


Our strategy	5
Superior value for customers	6
Sustainability at the heart	9
How we are growing the difference	11


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	5

Our strategy

Our 'Growing the difference' strategy is focused

on delivering superior value to our customers and

putting sustainability at the heart of what we do.

Our ambition is to accelerate growth, increase

impact and relevance, and deliver value to

become the best European bank.

Growing the difference means expanding our scale, impact and relevance

across the markets and segments we operate in to become the most

loved, most impactful and most valued European bank. We aim to

increase our relevance by deepening customer relationships, broadening

services, and continuing to make banking easier and more seamless. Our

two main priorities are providing superior customer value and putting

sustainability at the heart of what we do, supported by four key enablers.

This strategy translates into specific business goals: in Retail, we focus on

Private Individuals, including Gen Z and affluent customers, as well as

small and medium-sized enterprises through Business Banking, and high-

net-worth and investment clients via Private Banking & Wealth

Management. Each segment has a dedicated approach aligned with our

priorities: enhancing digital engagement for younger customers, offering

personalised solutions for affluent clients, and delivering superior value

across all relationships. In Wholesale Banking, we aim to create greater

value by reinforcing our role as a strategic partner and core bank for large

corporates, multinationals, and institutional clients. Guided by our purpose

to empower people to stay a step ahead, we help individuals and

businesses realise their vision for a better future.

Providing superior value for customers

Banking relies on strong relationships, and the strongest relationships are

those where people feel valued, confident, empowered and in control. This

is how we want our customers to feel throughout their journey with us.

Growing the difference means sharpening our focus on customer value,

moving beyond one-size-fits-all services towards more tailored solutions

for each customer segment. In Retail Banking, this means making banking

simple and expertise accessible. In Wholesale Banking, this means

leveraging our network, expertise and sustainability leadership.

Putting sustainability at the heart of what we do

Our sustainability strategy spans climate, nature and social agendas,

recognising their interdependencies and how they affect each other, both

positively and negatively, and taking into account the legal and regulatory

frameworks in the jurisdictions in which we operate. Each of these is a

complex and dynamic matter, so our response needs to be dynamic as

well. As scientific understanding is continually advancing, our approach

will also keep evolving. Therefore, our climate action has evolved to

encompass both mitigation and a growing emphasis on adaptation.

Increasingly, we are also exploring how we can play a role in halting and

reversing nature degradation and regenerating natural systems, while

respecting human rights and working to advance financial health and

inclusion for customers and communities.

Four enabling priorities

Providing seamless digital services

We can serve our customers better if we use ‘always-on’ channels,

providing data-enabled personalised experiences and end-to-end digital

processes, with human intervention only where needed or desired.

Using scalable technology and operations

A technology and operations foundation that is modular and scalable

brings many benefits, including superior customer experience and safety.

Staying safe and secure

Trust is fundamental for all stakeholders, especially at a digital-first bank

like ING. Customers rely on us to safeguard their money and data, and

maintaining this trust is essential.

Unlocking our people’s full potential

We aim to attract, develop and retain future-ready talent and foster an

inclusive environment that enables employees to thrive, maximising their

growth and impact.

¹ Operative customers: fully onboarded, transacted once, and whose account remain open by end of 2025.


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	6

Superior value for customers

Providing superior value for customers is one of

our two overarching priorities, as we strive to

make banking easy, instant, personal and

relevant. For Retail Banking, delivering superior

customer value means making banking simple

and expertise accessible, offering the right

services, at the right time, in the right way.

For Wholesale Banking, delivering superior value

for customers means building on our network

strength, sector expertise, and sustainability

leadership.

Retail Banking

In Retail Banking, we service customers across three pillars: Private

Individuals, Business Banking, and Private Banking & Wealth Management.

Equipped with leading digital capabilities, we strive to provide a mobile-

first digital, frictionless, and relevant banking experience, shaped to

specific customer needs for all of these pillars.

Private Individuals

We serve nearly 41 million Private Individual customers 1 across 10

markets: the Netherlands, Belgium, Luxembourg, Germany, Spain, Italy,

Türkiye, Poland, Romania and Australia.

ING offers a broad range of banking products and services for private

individuals, including savings accounts, payments, credit cards,

mortgages, unsecured lending, investment solutions and insurance

products. We seek to deliver banking that is easy, instant, personal and

relevant. We focus on simplifying our services, improving our digital

capabilities, and anticipating customer needs to help people manage their

financial lives. Our progress is reflected in customers choosing us as their

primary bank and in their willingness to recommend us, as indicated by

our leading NPS score in five out of ten retail markets.

ING aims to build primary relationships with customers. In Retail Banking,

we define this as customers holding an active payment account with

recurrent income, plus at least one other active product with us. Earning

primary relationships is a key driver of sustainable, profitable growth. It

leads to deeper loyalty, significantly higher engagement, greater

customer satisfaction and ultimately higher value, as customers choose

ING for a broader set of their financial needs.

Growing the difference means focusing even more on growing value for

customers. We continue to expand our offering by developing relevant

propositions for our various customer groups and applying a personalised

approach enabled by our digital banking capabilities. Our priorities include

becoming the bank of choice for Gen Z and affluent customers, expanding

subscription-based services that provide superior customer value,

diversifying our Private Individuals lending portfolio, and partnering to offer

full-service solutions that help homeowners make their homes more

sustainable. We are also broadening our investment and savings offering

to help customers protect and grow their wealth and manage their

financial health more effectively.

We strive to provide a seamless, mobile-first digital experience, engaging

customers across their daily banking activities and offering personalised

products and services supported by advanced technology and data-driven

insights. As mobile adoption continues to grow, customer expectations for

digital services are rising. In 2025, 87 percent of customers chose mobile

as their primary channel, up from 84 percent in 2024.

This growth has led to an increase in mobile primary customers – defined

as customers with at least one mobile interaction through our app or

mobile website per quarter. In 2025, in line with our mobile-first ambition,

we expanded our mobile primary customer base by over 1 million to 15.4

million.

In 2025, customers visited our digital platforms 8.8 billion times, an

increase of 6 percent compared to 2024.

Business Banking

For Business Banking clients, growing the difference means making banking

simple, frictionless, and tailored to their needs. Our ambition is to be the first

choice for entrepreneurs and businesses to manage and grow their

operations. We define success by delivering superior customer value

through digital innovation, expert advice, and sector-specific solutions.

Business Banking serves clients in nine markets: the Netherlands, Belgium,

Luxembourg, Germany, Türkiye, Poland, Romania, Australia, and most

recently Italy, where we began offering Business Banking services to a select

group of customers at the end of 2025 ahead of the wider commercial

launch in January 2026.


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	7

Our service model addresses both basic and complex needs, offering

solutions through a mix of self-service digital platforms and remote or in-

person advisory. Through this approach, we aim to strengthen client

engagement and incorporate sector-specific expertise to support informed

decision-making.

Across all three segments – Self-Employed & Micro, SME, and Mid-Corps –

we focus on making banking effortless and accessible. As of 2025, we offer

digital onboarding journeys, and instant and fast-track lending across six

markets: the Netherlands, Belgium, Poland, Romania, Türkiye and Germany.

We aim to combine digital convenience with human expertise, making

sure every client, regardless of size, receives the support they need.

Private Banking & Wealth Management

Private Banking, Wealth Management & Investments combines our Private

Banking & Wealth Management activities with our total Retail investments

business across Private Individuals, Private Banking and Business Banking

clients. We do this through a scalable investments platform that we are

implementing across our Retail markets, designed to meet diverse client

needs.

Our Private Banking & Wealth Management offering provides tailored

banking solutions to ultra-high-net worth individuals and high-net-worth

individuals and their entities in the Netherlands, Belgium, Luxembourg,

and Poland. We provide clients with investment solutions focused on

managing, preserving, and growing their wealth. Beyond investments, we

offer solutions to meet specific client needs, including financial planning,

estate planning, real estate financing, and securities-based lending.

Our strategy builds on our strong Business Banking position to serve

entrepreneurs and their wealth needs. We continue to invest in digital

capabilities to enhance client engagement and provide actionable insights

through advanced analytics, while maintaining human expertise through

relationship managers supported by product specialists and portfolio

managers.

Our investments offering spans all Retail Banking countries, serving mass,

affluent, high-net-worth individuals and ultra-high-net worth individuals

through a differentiated approach. For Private Individual clients, we aim to

provide a fully digital experience with simple onboarding, intuitive tools,

and innovative features for first-time investors. For affluent clients, we

offer a hybrid model that combines digital convenience with personalised

support.

In line with our ambition to make investing personal and accessible

throughout Europe, total assets under management and e-brokerage

reached €278 billion in 2025, representing a 16 percent increase from

2024.

Wholesale Banking

Growing the difference for our clients means we strive to be the best – and

in this case, the best European wholesale bank. We define ‘best’ as

achieving a high NPS, ranking in the industry’s top quartile, leading in

sustainability, digital services and employer attractiveness, while delivering

sustainable returns. Our work starts with providing corporate clients and

financial institutions with the financial solutions they need across their

value chains. Underpinning this is the ‘ING difference’, encompassing three

major characteristics that offer value to clients:

1. Our global reach, with local experts: no matter where clients are, our

network of experts offers them a seamless local experience with a

global view.

2. We’re sector experts: clients trust us to provide tailored solutions to

meet their needs.

3. We’re sustainability pioneers: we work hand-in-hand with clients to

address some of the most pressing issues in the world today.

ING’s Wholesale Banking network serves clients around the world and

operates from 36 countries across three regions: EMEA, APAC and the

Americas. Clients benefit from our knowledge in eight areas, including:

commodities, food & agriculture; corporate sector coverage; energy;

financial institutions; infrastructure & real estate; sustainable value chains;

technology, media, telecom & healthcare; and transport & logistics. By

making use of our target sector research capabilities and our client

segmentation model, we aim to help clients navigate the highs and lows of

economic cycles. We provide them with relevant advice, data-driven

insights and customised, integrated solutions that support their business

ambitions.

As a large wholesale bank, with billions of euros flowing through our

balance sheet, ING aims to play an important role in supporting our clients’

transitions to net zero by 2050. We aim to be a leader in sustainable

finance, but our leadership goes beyond financial support and incentives.

We also help and advise clients by putting our climate-action experience

and other sustainability-related insights to work for them.

Given the significant level of sustainable finance needed for the energy

transition, banks have an opportunity to increase the available level of

finance. ING has achieved €166 billion sustainable volume mobilised by

year-end 2025, versus €130 billion in 2024.

In 2025, our Wholesale Banking team was recognised by Global Finance as

Best Bank for Payments in Western and Central & Eastern Europe, and the

Most Innovative Bank for Trade Finance globally. Treasury Management

International named ING as the 2025 Best Bank for Trade & Supply Chain

Finance in Europe, and Global Capital recognised ING as the 2025 Most

Impressive Investment Bank for Corporate ESG Capital Markets and Advice.

How we aim to become the best European wholesale bank

We have identified several ‘must-win’ priorities for us to become the best

European wholesale bank and to drive impact for our clients. In

Transaction Services, we are expanding our product foundations to offer

more efficient cash management, trade finance, and payment solutions,

while diversifying our product mix to support clients’ global operations. In

Financial Markets, we are harmonising our product suite and increasing

access to green and conventional instruments, enabling clients to manage

risk and fund sustainable growth. And within Capital Markets & Advisory

(CMA), we are broadening our capabilities to deliver tailored financing and

advisory solutions, with more teams positioned close to clients for faster,

more relevant support.


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	8

In 2025 we took another step in strengthening our client offer with the

launch of a private markets unit. This will help clients access alternative

capital and diversify funding sources.

Alongside our focus on our three core differentiators, this year we also

worked towards achieving a fourth: digital. As such, we have advanced our

digitalisation efforts to enhance client experience. We expanded self-

service journeys on our InsideBusiness platform, streamlined processes,

and introduced new tools to make interactions simpler and faster. At the

same time, we equipped our front-office teams with integrated CRM and

GenAI capabilities, combining data, insights, and automation to deliver

proactive advice and deepen engagement.

We progressed our capital velocity strategy in 2025, and completed two

significant risk transfer (SRT) transactions, enabling us to deploy capital

more efficiently and expand our lending capacity. As a result, we are

better positioned to serve a wider range of clients and pursue new

business opportunities, while continuing to manage risks prudently.



	Our NPS performance One of the ways we measure our ability to deliver superior customer value is through the net promoter score (NPS). The NPS indicates whether customers would recommend ING to others. We compare our NPS to selected peers in each market. Our ambition is to achieve a number one NPS ranking in all our Retail markets. In 2025, ING ranked number one in five of our retail markets: Australia, Poland, Germany, Romania and Spain. We ran an NPS programme in 32 Wholesale Banking (WB) markets throughout 2025, to ensure a broad coverage of our client base, and achieved a 74 percent response rate. ING’s WB NPS score rose to 77 (on a scale of -100 to +100), compared to a score of 74 in 2024. The insights from the survey showed how our sector expertise, global reach and local experts are highly appreciated by clients and important reasons for why they chose ING. We also asked clients how satisfied they were with our product areas, people, processes and digital offering, with the highest scores going to our product offering, relationship management and client support. Off the back of these results, we will continue to prioritise building strong relationships with excellent execution, simplifying and automating our KYC processes and optimising our digital offering.


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	9

Sustainability at the heart

We strive to put sustainability at the heart of what

we do: it is a core pillar of our 'Growing the

difference' business strategy and central to our

long-term business resilience and commercial

success.

At ING, our sustainability strategy spans climate, nature and social

agendas, recognising their interdependencies and how they affect each

other, both positively and negatively. These issues are complex and

dynamic, so our response must evolve as scientific understanding

advances. Therefore, our climate action focuses on both mitigation and

adaptation. We are also exploring how we can play a role in halting and

reversing nature degradation and regenerating natural systems, while

respecting human rights and working to advance financial health and

inclusion.

We embed climate and nature topics into our business processes,

including risk assessment and client interactions, as these can influence

traditional banking risks. It is our ambition to play an important role in this

transition because it matters to our clients, to society and us as a bank.

To ensure the resilience and commercial success of our business means

managing risks that arise from global warming and nature degradation. As

a trusted partner, we help clients navigate these complex risks and with

the global transition underway, financing the new technologies,

infrastructure and business models for the transition of the economy

represents a growing opportunity for us and our clients.

Responding to the challenges of climate change has been central to our

sustainability approach for the past decade, from helping our clients with

their climate transition plans to contributing to governmental climate

goals. These efforts extend to the present day: in 2025 ING became the

first global systemically important bank to receive 1.5°C-aligned science-

based targets validation from the Science Based Targets initiative (SBTi).

A dynamic landscape

Our approach is also informed by, and reviewed against, a number of

external factors and trends that may influence the resilience of banks and

their customers. Many of these are constantly evolving and contribute to

heightened, and increasingly diverging, expectations from stakeholders

and society. In particular, geopolitical dynamics in 2025 have led to a

conflict of policies and laws between different national and regional legal

frameworks, affecting investment flows, regulations and corporate

disclosures. Companies and financial institutions face an increasing risk of

climate-related lawsuits, not only from activist NGOs but also due to

enforcement actions and legal challenges under laws like national

competition regulations. Society is transitioning to a low-carbon economy.

So are our clients, and so is ING. We finance a lot of sustainable activities,

but we still finance more that’s not.

Climate action

We are a large globally operating bank, so we have the opportunity to play

an important role in financing the change that is needed in the transition

to a more sustainable future. There are multiple ways in which we bring

together expertise and capital to act as a catalyst for our clients’ efforts in

the transition and for the development of wider systemic solutions. From

allocating capital towards decarbonisation to financing innovation, we can

help steer financial flows in support of our clients' transition. We play an

important role in managing and mitigating risk, and also invest in

adaptation and long-term resilience. We support an energy transition that

strengthens energy security, ensures stability of supply, and safeguards

affordability.

We base our climate actions on what we believe needs to happen in the

global transition – focusing on three action areas where we can have the

greatest impact. First, we are helping clients to transition to low-carbon

business models; second, we are building up the financing of new

technologies and sustainable systems; and third, we aim to find new ways

to enable people to play their part in the transition.

Drive down emissions: supporting clients in their transition

As a bank, we recognise the most significant contribution we can make to

help drive down global emissions is to engage with our clients, especially

those in the most carbon-intensive sectors, and help them transition to

sustainable business models. Increasingly, our large clients are setting

their own goals to drive down emissions and we are stepping up how we

support them in their transition, driving impact together.

Terra is our decarbonisation approach and the foundation of our sector

transition plans. In addition, it informs our broader process for managing

climate-related risks within the most carbon-intensive parts of our lending

book. We have implemented a data-driven assessment that has led to a

step-up in how we advise and support Wholesale Banking clients with their

sustainable business transformations. This approach strengthens our

ability to support clients in navigating their transition strategies and helps

us in identifying emerging financing opportunities. We have established a

foundation for targeted, fact-based discussions on transition planning,

helping us understand their evolving financing and advisory needs as well

as potential transition risk

¹Amount has been restated following a change in methodology.


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	10

While our main impact lies in financing and supporting our clients, we also

aim to lead by example by working towards net zero in our own

operations. We monitor and manage our progress towards this ambition

through measures such as setting a CO2 cap for business travel,

transitioning to a fully electric car fleet and sourcing 100 percent

renewable electricity for buildings under our management control. In

2025, our total operations footprint (scopes 1, 2 and scope 3 business

travel) was 44kt of CO2 emissions, representing a reduction of 5kt (2024:

49kt 1). Our ambition is to achieve a 23 percent reduction in CO2 emissions

by 2030, compared to the 2023 baseline of 54 kt¹.

Building up a sustainable future: financing technologies and

solutions for a low-carbon world

Society needs to transition to a future where the systems we rely on are

sustainable. Supporting our clients to drive down emissions and improving

efficiency of fossil fuel-based energy technologies is only one part of the

solution. At the same time, the world must build up solutions, technologies

and infrastructure needed for a resilient low-carbon world. Trillions of

euros per year are needed to make this transition a reality.

ING seeks to play an important role in financing these technologies and

solutions, including building up the affordable supply of green and

renewable energy alternatives such as offshore and onshore wind and

solar power generation, which are necessary and powerful drivers in

reducing society’s dependence on existing, fossil fuel-based power. In 2025

we committed €9.6 billion in renewable power generation financing, up

from €7.0 billion in 2024.

In the past year, we launched our Transition Accelerator to identify and

incubate promising solutions and innovative green technologies, and

mobilise the capital needed to help them to scale. Finding innovative ways

to finance these pioneering technologies and enterprises puts us in a

position to help shape these new markets as they emerge and scale.

Including everyone in the transition: finding new ways to enable

people to stay a step ahead on climate

Our purpose is empowering our customers to stay a step ahead – and that

includes staying ahead on climate. This means we’re committed to finding

new ways to include people and enable them to make an impact, starting

with our existing and prospective retail customers. Through our large

mortgage portfolio, we finance people's homes, and that gives us the

opportunity to help them contribute to the transition by making their

homes more energy and cost efficient, and future-fit. Making their homes

more sustainable matters to customers because it improves the long-term

resilience of what, for many, is their most valuable asset. And if it is in the

interests of homeowners, it is also in the interests of the bank. In helping to

make customers' homes future-fit, we are also future-proofing our

mortgage portfolio.

We incentivise sustainable home ownership in our core markets through

the mortgages we offer, with beneficial terms like attractive interest rates

linked to energy-label improvements across all energy labels, long-tenure

fixed interest periods, and mortgage features like top-ups and discounts

available to those who purchase energy-efficient homes or improve the

energy label of their property by renovating. And to tackle the challenge of

how to retrofit existing housing stock, we’re increasingly enabling

customers to upgrade their homes with dedicated renovation financing

options, incentives and related services that aim to lower any hurdles to

the renovation process.

Collaborating for impact

We engage with regulators and policymakers on policies and market

conditions which enable our clients in their transition, and clarify and

support the role of banks. That is how we can support the transition to a

sustainable, strong and resilient economy.


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	11

How we are growing the difference

We focus and continue to work on our four key

enablers that will help us grow the difference:

providing seamless digital services, using scalable

technology and operations, staying safe and

secure, and unlocking our people’s full potential.

Providing seamless digital services

Through our ‘Growing the difference’ strategy, we continue to build on our

success of making banking easy. One of the ways we aim to do this is by

making banking as frictionless and relevant as possible. We can serve our

customers better through our ‘always-on’ channels, data-enabled

personalised experiences, and end-to-end digital processes, with human

intervention where needed or desired. For Private Individuals, our ING

Banking App enables customers to open accounts in minutes, manage

investments, and receive real-time spending insights. In Business Banking,

our Mijn ING Zakelijk platform helps SMEs manage payments and link

accounting packages seamlessly, while larger corporates benefit from the

InsideBusiness portal, providing self-service access to trade finance and

cash management globally. For Private Banking & Wealth Management,

clients enjoy secure digital portfolio management and personalised

advisory services through our app, which offers tailored dashboards and

seamless access to expert support.

We use data analytics and machine learning to personalise digital services,

delivering relevant, data-driven insights that help customers make

informed financial decisions. As data becomes increasingly central to

delivering personal and relevant services, privacy and data security are

more important than ever.

Scalable technology and operations

ING uses scalable technology and operations that enable us to reach the

market faster, achieve volume more quickly, maintain consistent and

higher quality, and enhance productivity. This also helps us attract and

retain talent by offering employees the opportunity to not only work with

technology but also collaborate across countries and make an impact

globally. Scalable technology enables ING to create specific, local

propositions that serve our customers, while leveraging ING’s scale in

engineering, security, and data expertise.

Scalable technology

ING's technology vision is anchored in the 'Scalable Tech Platform', a

unified, integrated foundation. The platform hosts the IT modular

components we (re)use across countries and business lines to build and

operate customer propositions. It allows ING countries and business lines

to introduce propositions quickly, easily, and safely.

To fully unlock the potential of this platform and advance our ambition of

'Banking with Impact', the ING Tech strategy sets out three goals under the

leadership of the chief technology officer: increase productivity, excel in

customer experience, and be a top employer for engineering talent.

In 2025, we translated these longer-term goals into clear priorities for the

years ahead:

§ Operational excellence: Enhancing reliability, reinforcing cybersecurity,

and investing in our workforce to ensure resilient and secure

operations.

§ Digital product governance: Advancing our digital product capabilities,

which contributes further to control, transparency, and strategic

alignment.

§ Engineering: Driving an engineering way of working and innovation,

including AI-enabled coding.

§ Transformation: Continuing the development and expansion of our

scalable technology platform.

§ Data and AI development: Accelerating the responsible and effective

use of data and artificial intelligence to unlock new opportunities and

efficiencies.

Our scalable technology consists of three core components: ING’s private

cloud infrastructure (IPC), our engineering pipeline (OnePipeline), and our

banking technology platform.

IPC is where we store and manage applications and data such as channel

applications, core banking systems, and other banking applications. We

measure IPC adoption by the percentage of physical cores – also known as

processing cores or CPU cores – in IPC compared to the total number of

physical cores in ING data centres globally. By the end of 2025, 68 percent

(2024: 67 percent) of all physical cores in ING were on IPC. This is in line

with our objective to evolve towards a structural hybrid cloud set up, which

allows us to optimise our infrastructure landscape by using both private

and public cloud to run our applications.

OnePipeline, our continuous integration and delivery pipeline, provides

engineers with a consistent and secure global capability to develop, test,

and deploy software. At the end of 2025, 90 percent of applications were

onboarded to this pipeline (2024: 85 percent) out of the total number of

applications registered in our IT management platform across all ING

entities.

Touchpoint is part of our banking technology platform. It provides reusable

shared services that help engineers build products – like Instant Payments

and Open Banking – more quickly and easily. At the end of 2025,


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	12

approximately 81 percent of customer logins used Touchpoint (2024:

approximately 75 percent).

Digital access

In a digital society, customers expect to have round-the-clock access to

digital channels, including their banking services. To live up to their

expectations, we strive to provide uninterrupted access to our banking

services, while allowing for scheduled maintenance and downtime. For

2025, our Retail scope includes Belgium, Germany, and the Netherlands.

The combined digital channel availability for these three countries was

99.89 percent (2024: 99.86 percent).

For Wholesale Banking clients worldwide, the availability for our Inside

Business Payments channel was 99.97 percent (2024: 99.82 percent) and

for our Inside Business Connect channel (file transfer), 99.99 percent

(2024: 100 percent).

Scalable operations

Our scalable operations are driven by digitalisation and capability hubs,

focusing on becoming fully straight-through processing (STP), removing

friction towards a seamless experience for our customers in a safe and

secure way. In all we do, our customers are our point of departure. Our

processes, both digital and non-digital, are designed and executed to

embed excellent customer experience. We apply the same mindset to all

our employee journeys.

Digitalising key customer journeys allows us to enable superior customer

value at a reduced cost-to-serve, while measuring impact through NPS and

cost efficiency. In 2025, our digi index score was 81.8 percent (2024: 77.2

percent).

Capability hubs provide shared services and solutions across ING

worldwide, leveraging expertise and using scale, and sharing productive,

quality services across the ING network. The hubs are located in the

Netherlands, Poland, Romania, Slovakia, the Philippines and Türkiye. In

November 2025, ING opened a new hub in Madrid, Spain.

Through expanded and improved digital services we have reduced friction

and increased self service options, including GenAI chatbots. In 2025, we

reduced inbound contacts to contact centres by 43 percent (2024: 26

percent)

Data analytics

In 2025, ING Analytics continued to drive our strategy forward by

embedding AI and GenAI into our products, process, and interaction in

Retail, Wholesale, and the associated operations. Building on the targeted

approach in five priority domains – contact centres, Know Your Customer

(KYC), hyper-personalisation, Wholesale Banking Lending, and software

engineering – we scaled solutions and explored new opportunities.

Key milestones include the first large language model (LLM) voicebot

experiment and the introduction of machine learning-based client due

diligence assessments in Retail Banking. In Wholesale Banking, we

prioritised front-office productivity by embedding AI tools, including

enhancing liquidity management through machine learning and providing

near real-time visibility into client data to support faster, more informed

decision‑making.

We continued to advance our platform capabilities in line with ING’s

broader transformation objectives. The introduction of a unified data,

analytics, AI and agentic environment marked an important milestone in

strengthening our data infrastructure. The platform delivers analytics

initiatives with greater consistency and efficiency, while simplifying risk

assessments and strengthening data governance.

As AI adoption accelerated across 2025, moving from pilots to day‑to‑day

use in areas such as analytics, software development and customer

service, we strengthened our governance to ensure we scale AI responsibly

by establishing a dedicated central AI Risk Committee to oversee emerging

risks in new domains such as voicebots and agentic AI capabilities.

We continue to empower our workforce by shifting from AI education to

hands-on enablement across three key groups: employees, specialists,

and leaders. This year’s data fluency training reached more than 8,700

individual participants across 18 functions in 14 countries. These initiatives

aim to ensure ING talent remains at the forefront of responsible and

innovative AI adoption.

In Retail Banking, we have introduced GenAI-powered campaigns to

improve customer engagement and support sales. These tools are

currently live in Belgium, Germany, Spain, Romania, and Poland. In Spain,

early results show positive campaign uplifts. We are also assessing the use

of GenAI for educational and awareness content, including illustrated

messaging.

In consumer lending, we use AI to assess applicants and process loan

applications automatically. We enhanced the mortgage credit decision

process in Australia by introducing machine learning-based scorecards.

This improvement enables a more digitised application experience and

ensures reliable assessments aligned with our risk appetite.

Our contact centres underwent a GenAI transformation, with chatbots

now live in seven countries (the Netherlands, Belgium, Germany, Spain,

Italy, Romania, and Australia).

We integrated analytics and AI into KYC processes across Retail and

Wholesale Banking. Our Secondary Analytics Transaction Monitoring

solution distinguishes between high- and low-risk activity, improving

investigations and supporting compliance. The model is live in Belgium, the

Netherlands, Romania, and Australia.

We introduced STP 2.0 and a new Risk Assessment Model for customer due

diligence, shifting from manual checks to AI-driven risk management.

These solutions are designed to streamline processes, support compliance,

and enable dynamic risk scoring and smarter decisions globally.

In engineering, we have implemented GenAI to accelerate software

development, improve code quality, and reduce communication overhead.

Staying safe and secure

At ING, trust is the foundation of everything we do. As a digital-first bank,

we are entrusted with our customers’ money and personal data.


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	13

Safeguarding these assets is essential to maintaining the confidence of our

stakeholders.

We operate within a robust risk management framework designed to

identify, assess and manage material risks to our business. Our Risk

Appetite Framework (RAF) supports the execution of our ‘Growing the

difference’ strategy in a secure, compliant, and responsible manner,

ensuring we meet all regulatory obligations.

As we expand our customer base, we remain vigilant in protecting our

organisation, our clients and the broader financial system. Our anti-money

laundering (AML) activities include customer screening, due diligence and

transaction monitoring to detect and prevent suspicious activity. We also

continue to strengthen our fraud prevention capabilities, using innovative

technologies to reduce fraud-related harm to individuals and society.

Cybersecurity remains a top priority. We continuously monitor the threat

landscape and invest in capabilities across all cyber domains – prediction,

prevention, detection, response and recovery. In 2025, two Distributed

Denial of Service (DDoS) incidents were reported to the supervisors: one

impacted availability for individuals in Belgium, Italy, and the Netherlands,

and another caused temporary interruptions in third-party service

availability within the Polish mobile payment system. Our Chief

Information Security Office (CISO) organisation maintains 24/7 vigilance,

actively monitoring our environment, investigating emerging threats, and

taking timely action to protect our customers and essential services.

As a global financial institution, we process personal data from customers,

employees, suppliers, and partners. Protecting this data is critical. We

continuously evaluate our compliance with evolving data ethics standards

and regulatory requirements. We also foster a culture of integrity by

encouraging employees to report unethical or unlawful behaviour through

secure and anonymous channels.

For more information on ING’s policies and processes to stay safe and

secure, see ‘Risk management’.

Unlocking our people’s full potential

Unlocking our people’s full potential is a key enabler of our strategy as we

believe we have an abundance of talent and potential at ING. We attract,

develop, retain, and reward the right fit-for-future talents and skills. We

strive to deliver a superior employee experience to unlock our people’s

time and energy to grow the difference. We are dedicated to fostering a

safe and inclusive environment for our 60,000+ employees, as we aim to

create a friendly and collaborative workplace that mirrors the diverse

world we operate in. This is reinforced by our Orange Culture and Orange

Behaviours. We ask our people to act with honesty, prudence, and

responsibility, and that they strive to ‘take it on and make it happen’, ‘help

others be successful’, and are ‘always a step ahead’.

In 2025, we continued to focus on unlocking our people’s potential through

three strategic pillars: ‘talent & leadership’, ‘culture & organisation’ and

‘employee experience’.

Talent & leadership

To grow the difference and keep ING fit for the future, we need the right

people with the right skills and a readiness to learn and develop. In 2025,

we launched ING University, our new global learning platform. This brings

learning into one place for all ING employees worldwide, making

development more accessible, personal, and relevant – so everyone has

the skills to thrive today and tomorrow. Alongside this, we have continued

to empower employees to take ownership of their growth through tools

like the Individual Development Plan (IDP), available globally to help map

personal learning journeys. We also offer high-quality learning content

tailored to different roles and ambitions. Employee feedback on learning

content is positive, with colleagues actively exploring topics beyond

mandatory training – showing appetite for self-driven learning.

Our focused attention on training complements our efforts to build strong,

diverse talent pipelines. Through our annual strategic global talent reviews,

conducted for approximately 5,000 senior employees, each domain

evaluated their contributions to growing the difference and identified the

talent, leadership, and capability needs to advance our ING goals and help

future-proof our talent pipelines. In 2025, we enhanced this review cycle

by integrating near-term and forward-looking assessments of

organisational and people requirements, including future workforce needs,

skills, and capacity, as well as future leadership requirements.

One example of how we are building future-ready leaders is our Global

Leadership Accelerator, run in partnership with the IMD Business School,

where, following completion, participants are demonstrating increased

readiness for senior roles. As we strengthen the talent of today, we can

also look ahead with confidence: the International Talent Programme

continues to welcome new trainees to ING to develop their banking skills,

cultivate professional expertise and support their personal growth. This

rigorous, global two-year programme is just one of our investments in

strengthening our leadership pipeline.

Our commitment to a fair and transparent performance and rewards

process supports our talent and leadership goals. We retained the same

focus in 2025 of providing our employees with clarity and consistency. ING

follows a Pay for Performance approach, supported by a five-point

performance rating scale in our performance evaluation scheme,

introduced in 2024. Remuneration decisions are clearly linked to

performance outcomes.

ING began using a structured variable remuneration framework based on

our job architecture in 2025. This means all employees eligible for variable

remuneration have a variable remuneration target. This provides

managers with a decision framework for determining variable

remuneration rewards equitably, while having enough flexibility to

differentiate outcomes for individual performance. Employees see

increased transparency and can better understand how their personal

performance influences their variable remuneration.

Culture & organisation

At ING we aim to unlock our people's full potential through our inclusive

culture where everyone has the opportunity to develop and have impact

for our customers and society.


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	14

Strong mental, social and physical wellbeing is essential for an inclusive

environment and a healthy, high-performing and engaged workforce. We

promote flexibility through hybrid working and have introduced healthy

'Working Habits', for which we provide training and resources. We have

also included a Wellbeing Index in our Organisational Health Index (OHI)

survey to track how our people are doing, identify improvement areas, and

monitor the link between wellbeing and performance. By prioritising

wellbeing and leveraging these insights, we aim to build a resilient

workforce and drive a sustainable high-performance culture.

Equally important is the role feedback plays in sustaining our Orange

Culture. We maintain a continuous listening framework, which gives our

people formal channels to provide feedback on our strategy, working

conditions, behaviours, and experiences. Our Organisational Health Index is

the most comprehensive of these listening tools. In 2025, we held two OHI

surveys and received feedback from 80 percent of our workforce. We saw

sustained strong organisational engagement among our employees

showing that it is desirable to continue with our Orange Culture. The

feedback showed that our people continue to value and appreciate their

colleagues, the ability to work hybrid, and the opportunities that support

their wellbeing.

Employee experience

Employee experience remains a top priority at ING. We believe that

delivering a great employee experience is essential to providing excellent

customer experience and to attract and retain talent. In 2025, ING

continued the collective efforts of the Employee Experience Design Board,

which brings together representatives from Human Resources, Facilities

Services, Operations, Information Technology, and Global Communications

to enhance the employee experience globally.

Throughout the year, this group focused on operational excellence and

service quality, enabling productivity from anywhere, and using data to

prioritise work that matters most. Initiatives included improving the office

environment, streamlining facility management ticketing, creating a

unified portal for employee support, and empowering employees to

be more self-sufficient by simplifying access to information. ING will

continue to focus on the moments that matter to deliver a superior

employee experience.

Our financial performance

Our financial

performance


Our financial performance	16
Retail Banking	18
Wholesale Banking	21


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	16

Our financial performance

In 2025, we have delivered strong commercial

growth, achieving a total income of €22.9 billion.

This performance was supported by growth in our

customer base and a 15% increase in fee income

to €4.6 billion. Commercial net interest income

remained resilient at €15.3 billion. We also realised

strong volume growth, including €56.9 billion in

net core lending growth, more than double the

amount recorded in the previous year. Our net

result remained broadly stable at €6.2 billion.

Client balances

We successfully executed our strategy to accelerate growth. Net core

lending growth more than doubled to €56.9 billion in 2025, representing

an 8.3% increase in customer lending since the start of the year. Retail

Banking contributed €38.6 billion to this growth, mainly driven by a €28.5

billion increase in our residential mortgage portfolio. Further expansion

was achieved across consumer and business lending, which together

increased by €10.1 billion. Wholesale Banking achieved a net core lending

growth of €18.3 billion, driven by increased volumes in Working Capital

Solutions and short-term trade-related financing, alongside a recovery in

long-term loan demand in the second half of the year.

Net core deposits growth was also strong at €38.1 billion. This reflects the

effectiveness of promotional savings campaigns in several retail markets,

as well as successful deposit gathering within Wholesale Banking

Transaction Services and Financial Markets.


Consolidated results
	2025	2024	Change
Profit or loss (in € million)
Commercial net interest income¹	15,316	15,459	-0.9%
Other net interest income	-775	-711
Net interest income	14,542	14,749	-1.4%
Net fee and commission income	4,597	4,002	14.9%
Total investment and other income	3,752	3,584	4.7%
Total income	22,891	22,334	2.5%
Expenses excl. regulatory costs	11,710	11,234	4.2%
Regulatory costs	866	882	-1.8%
Operating expenses	12,576	12,116	3.8%
Gross result	10,315	10,219	0.9%
Addition to loan loss provisions	1,304	1,194	9.2%
Result before tax	9,012	9,025	-0.1%
Taxation	2,510	2,580	-2.7%
Non-controlling interests	275	258	6.6%
Net result²	6,226	6,187	0.6%
Key financial metrics
Net core lending growth (in € billion)³	56.9	27.7
Net core deposits growth (in € billion)³	38.1	47.4
Cost/income ratio	54.9%	54.2%
Risk costs in bps of average customer lending	19	18

¹Commercial net interest income (NII) is the sum of lending NII and liability NII (excluding significant

volatile items). For a reconciliation with 'Net interest income' see appendix 'Alternative

performance measures'.

²Net result in the table above reflects the net result attributable to shareholders of the parent.

³For a reconciliation of net core lending growth and net core deposits growth to customer lending

growth and customer deposits growth respectively, see the appendix ' Alternative performance

measures'.


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	17

Total income

In 2025, we again achieved higher revenues. Total income rose 2.5% to

€22,891 million, supported by sustained growth in our customer base. We

further expanded our loan portfolio and customer deposits, and recorded a

strong 15% increase in fee income.

Commercial net interest income remained resilient at €15,316 million. Net

interest income from lending rose by €134 million, as volume growth more

than offset a reduction in the average lending margin. This margin decline

was partly attributable to the ongoing expansion of our residential

mortgage portfolio, which delivers higher returns on equity but carries

lower average margins than other lending products. Liability net interest

income decreased by €277 million, as strong deposit growth could not

fully offset the impact of lower average margins on retail deposits and for

Payments & Cash Management in Wholesale Banking. The overall liability

margin stabilised during 2025 after the decline seen in 2024.

Other net interest income primarily comprises interest income from

Financial Markets and Treasury. The year-on-year decline mainly reflects a

structural shift in 2025, as commercial margins from our cash pooling and

netting services are now reported under commercial net interest income.

Net fee and commission income totalled €4,597 million, an increase of

15%, in line with our ambition to further diversify our income mix. In Retail

Banking, fee income from investment products rose significantly, driven by

growth in the number of investment accounts and higher customer

trading activity. Daily banking fees also increased, supported by strong

growth in primary customers and updated pricing for payment packages,

while Retail Banking also achieved solid growth in lending-related and

insurance fees. Fee income in Wholesale Banking rose 8.8%, primarily

reflecting higher deal flow in its Lending business and an increase in daily

banking fees.

Total investment and other income rose 4.7% to €3,752 million. The

majority of this amount relates to Financial Markets and Treasury. The

2025 figure included a positive revaluation of the derivative for a the

forward purchase of a stake in Van Lanschot Kempen, a €44 million gain

from the sale of an associate in Belgium, and higher income from

Corporate Investments. The previous year had included €77 million as our

share in the one-off profit of an associate in Belgium and a €53 million

receivable related to the prior insolvency of a financial institution in the

Netherlands.

Operating expenses

Operating expenses increased 3.8% to €12,576 million, including €866

million in regulatory costs — a slight decrease compared with the previous

year. Expenses in 2025 also included €297 million of incidental items,

primarily related to restructuring, versus €178 million of incidental items in

2024.

Expenses excluding regulatory costs and incidental items rose 3.2%,

reflecting inflationary pressure on salaries and other costs, as well as

continued investments to support business growth. These impacts were

partially mitigated by further increasing scalability and efficiency in our

operations, including enhanced client interactions in our contact centres,

and ongoing optimisation of our footprint across several retail countries.

Addition to loan loss provisions

Net additions to loan loss provisions amounted to €1,304 million compared

with €1,194 million in 2024. Risk costs for 2025 were equivalent to 19 basis

points of average customer lending, remaining below our through-the-

cycle average of 20 basis points.

Net additions to Stage 3 provisions declined sharply to €1,186 million,

down from €1,583 million in 2024. This reflects a limited inflow of new

Stage 3 files, as well as several repayments and recoveries on existing files

during 2025.

Total Stage 1 and 2 risk costs were €118 million (including €8 million of

modification losses). In 2024, these had amounted to €-389 million,

primarily due to a partial release of management overlays.

Net result

The net result (attributable to shareholders of the parent) for 2025

amounted to €6,226 million, slightly above the net profit of €6,187 million

achieved in 2024. The effective tax rate for 2025 was 27.9% compared

with 28.6% in the previous year.


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	18

Retail Banking


Retail Banking
	Total Retail Banking			Retail Netherlands			Retail Belgium			Retail Germany			Retail Other
in EUR million	2025	2024	Change	2025	2024	Change	2025	2024	Change	2025	2024	Change	2025	2024	Change

Commercial net interest income	11,347	11,507	-1.4%	3,687	3,647	1.1%	1,692	1,816	-6.8%	2,270	2,400	-5.4%	3,698	3,643	1.5%
Other net interest income	-98	-58		-572	-621		93	142	-34.5%	187	247	-24.3%	195	174	12.1%
Net interest income	11,250	11,449	-1.7%	3,115	3,027	2.9%	1,786	1,959	-8.8%	2,457	2,647	-7.2%	3,892	3,817	2.0%
Net fee and commission income	3,168	2,694	17.6%	1,128	1,049	7.5%	692	603	14.8%	632	433	46.0%	717	609	17.7%
Total investment and other income	1,124	1,113	1.0%	726	835	-13.1%	197	189	4.2%	-98	-173		299	263	13.7%
Total income	15,542	15,256	1.9%	4,968	4,910	1.2%	2,674	2,751	-2.8%	2,991	2,906	2.9%	4,908	4,688	4.7%
Expenses excl. regulatory costs	7,588	7,361	3.1%	2,022	2,011	0.5%	1,617	1,605	0.7%	1,330	1,215	9.5%	2,618	2,532	3.4%
Regulatory costs	647	668	-3.1%	67	114	-41.2%	261	206	26.7%	32	88	-63.6%	287	261	10.0%
Operating expenses	8,234	8,030	2.5%	2,089	2,124	-1.6%	1,878	1,811	3.7%	1,362	1,303	4.5%	2,905	2,792	4.0%
Gross result	7,307	7,226	1.1%	2,880	2,786	3.4%	797	941	-15.3%	1,628	1,604	1.5%	2,003	1,896	5.6%
Addition to loan loss provisions	754	566	33.2%	107	-8		153	134	14.2%	171	149	14.8%	323	291	11.0%
Result before taxation	6,554	6,660	-1.6%	2,773	2,793	-0.7%	644	807	-20.2%	1,457	1,455	0.1%	1,680	1,605	4.7%
Taxation	1,781	1,819	-2.1%	733	723	1.4%	178	210	-15.2%	472	505	-6.5%	398	381	4.5%
Non-controlling interests	227	223	1.8%	0	0		0	0		2	1	100.0%	225	221	1.8%
Net result IFRS	4,546	4,618	-1.6%	2,040	2,070	-1.4%	466	597	-21.9%	983	949	3.6%	1,058	1,002	5.6%
Key figures
Net core lending growth (in € billion)	38.6	25.9		16.2	9.6		2.0	3.7		6.9	4.4		13.4	8.2
Net core deposits growth (in € billion)	30.1	31.6		11.5	5.0		-0.6	6.4		6.6	7.5		12.6	12.7
Cost/income ratio	53.0%	52.6%		42.0%	43.3%		70.2%	65.8%		45.6%	44.8%		59.2%	59.6%
Risk costs in bps of average customer lending	15	12		6	0		15	14		15	14		26	26
Return on equity based on 13.0% CET1¹	21.7%	23.4%		29.4%	30.9%		10.0%	13.2%		27.1%	29.0%		18.8%	19.8%

¹After-tax return divided by average equity based on 13.0% of risk-weighted assets.


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	19

Retail Banking delivered a strong performance in 2025, supported by

sustained customer growth, solid commercial momentum and disciplined

cost management across all markets. Our mobile primary customer base

grew by more than one million during the year, in line with our ambition,

and reinforcing our position as a leading retail bank with over 15 million

mobile primary customers. Growth in customer balances and fee income

contributed to higher total income, while expenses rose only moderately.

This led to a result before tax of €6,554 million and a return on equity of

21.7%.

Net core lending growth was €38.6 billion, with €28.5 billion coming from

our residential mortgage portfolio, driven by strong production in the

Netherlands, Germany and Australia. We also continued to expand our

business and consumer lending portfolios across markets, supporting

customers and small and mid‑sized enterprises.

Net core deposits growth was €30.1 billion, complemented by significant

customer flows into investment products as more people opened

investment accounts and increased their trading activity. This strong

deposit performance was supported by targeted promotional savings

campaigns across several countries and sustained customer engagement

across our channels.

Commercial net interest income declined slightly year‑on‑year as liability

margins normalised, although this was largely offset by the substantial

growth in lending and deposits.

Fee and commission income rose by 18%, reflecting broad‑based growth

across investment products, daily banking, insurance and lending. Higher

customer activity and effective digital engagement drove increased

openings of investment accounts and higher trading volumes. Investment

and other income remained broadly stable.

Operating expenses totalled €8,234 million, including €647 million in

regulatory costs (slightly below 2024 levels) and €123 million in incidental

items (compared with €86 million in 2024). Excluding regulatory and

incidental costs, underlying expense growth remained well controlled,

reflecting continued investment in commercial growth, technology and

customer experience.

Net additions to loan loss provisions amounted to €754 million, equivalent

to 15 basis points of average customer lending. These additions were

primarily related to business and consumer lending, while risk costs

associated with mortgages remained low.

Overall, Retail Banking delivered strong balance sheet growth, deeper

customer engagement, and improved diversification in fee income,

positioning us well for continued performance in the years ahead.

Retail Netherlands

Retail Netherlands posted a result before tax of €2,773 million compared

with €2,793 million in 2024, a year in which risk costs benefited from a

modest net release. Income increased slightly year-on-year, while

operating expenses showed a small decline.

Results in 2025 were supported by a further increase in both our customer

base and customer balances. Net core lending growth was €16.2 billion,

fuelled by sustained strong mortgage production (€11.1 billion) and further

expansion across both business and consumer lending portfolios. The net

core deposits growth was €11.5 billion, primarily driven by a solid net

inflow from private individuals.

Commercial net interest income was marginally higher, with the

expansion of lending portfolios and increased savings volumes more than

offsetting margin compression. Other net interest income amounted to

€-572 million (versus €-621 million the year before), mainly reflecting

funding costs for Treasury, for which corresponding revenues are

recognised within ‘other income’.

Net fee and commission income rose 7.5%, with growth across all product

categories — most notably in investment products, supported by an

increase in assets under management. Investment and other income

totalled €726 million (compared with €835 million in 2024) and included

lower Treasury-related income.

Operating expenses decreased slightly to €2,089 million. Regulatory costs

declined by €47 million, as no contribution to the Dutch deposit guarantee

fund was required in 2025, and we benefited from an adjustment to our

DGS contribution related to previous years. Expenses excluding regulatory

costs remained broadly stable year-on-year, as salary increases under the

collective labour agreement and higher restructuring costs were almost

fully offset by operational efficiencies and savings on external staffing.

Net additions to loan loss provisions were modest at €107 million, the

equivalent of six basis points of average customer lending. In the previous

year, there had been a net release of €8 million, mainly related to

mortgages.

Retail Belgium

The result before tax for Retail Belgium (which includes our retail activities

in Luxembourg) declined to €644 million (from €807 million in the prior

year), mainly due to a lower margin on liabilities and higher regulatory

costs. However, fee income increased significantly, and expenses

excluding regulatory costs remained well-contained.

Customer balances rose year-on-year. Net core lending growth was €2.0

billion, with growth in both mortgages and other lending. Net core deposits

declined by €0.6 billion, following the conclusion of a successful

promotional campaign originated in the third quarter of 2024. The

campaign was highly effective, enabling the retention of the vast majority

of term deposits and facilitating their conversion into investment products,

thereby enhancing long-term customer value.

Commercial net interest income declined 6.8% to €1,692 million, primarily

due to reduced liability margins. Other net interest income fell by €49

million year-on-year due to Treasury, although this was fully offset by

higher investment and other income within Treasury. Investment and

other income included a €44 million gain from the sale of an associate in

2025, while 2024 had included €77 million relating to our share in the one-

off profit of another associate.


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Net fee and commission income was strong, rising 15% to €692 million.

This growth was primarily driven by higher fees from investment products,

reflecting the success of campaigns to attract new customers for

investment solutions, as well as from daily banking services.

Operating expenses amounted to €1,878 million, including €261 million in

regulatory costs (up from €206 million in 2024 due to a higher DGS

contribution) and €79 million in incidental restructuring costs (compared

with €59 million for this in 2024). These restructuring costs are part of

broader multi-year transformation programmes across Belgium and

Luxembourg, aimed at simplifying operations, increasing commercial

focus and improving long-term profitability, though they temporarily

impact reported returns. Expenses excluding regulatory costs and

incidental items declined 0.5%, as the impact of automatic salary

indexation was offset by lower accommodation and IT expenses.

The net addition to the provision for loan losses amounted to €153 million,

or 15 basis points of average customer lending, up from €134 million in

2024. Risk costs were mainly related to business lending.

Retail Germany

Retail Germany recorded a result before tax of €1,457 million, stable year-

on-year despite higher risk costs.

The business continued to demonstrate strong commercial momentum,

including a double-digit increase in the number of mobile primary

customers. Net core lending growth was €6.9 billion, with mortgages

remaining the principal driver of growth. Net core deposits increased by

€6.6 billion, reflecting the success of a promotional savings campaign, with

a portion of these funds subsequently channelled into investment

products during the second half of the year.

Commercial net interest income declined, as the positive impact of volume

growth was outweighed by narrower margins on liabilities and mortgages.

In the second half of 2025, the average liability margin improved, following

the conclusion of bonus rates for fresh money from the promotional

savings campaign that ran in the first quarter of the year.

Other net interest income for 2025 included a €-18 million impact from

incentive pay-outs linked to a customer acquisition campaign, compared

with €-51 million for a similar campaign in 2024. Treasury-related interest

income declined, although this was largely offset by an increase in

investment and other income.

Net fee and commission income surged 46% to €632 million. This was

driven by a growing customer base, a higher number of investment

product accounts, increased trading activity, and a rise in fees from daily

banking services.

Operating expenses in 2025 totalled €1,362 million. This comprised €32

million in regulatory costs, down from €88 million a year earlier, reflecting

a lower contribution to the deposit guarantee scheme. Expenses excluding

regulatory costs in both years, as well as €14 million of incidental

restructuring costs recorded in 2025, rose 8.3%. This was predominantly

due to higher internal staff expenses (related to annual salary increases)

and investments in business growth and scalability.

Net additions to loan loss provisions amounted to €171 million (15 basis

points of average customer lending) and were primarily related to

consumer lending and portfolio sales.

Retail Other

Retail Other comprises the retail markets in Spain, Italy, Australia, Poland,

Romania and Türkiye. The result before tax for Retail Other was €1,680

million compared with €1,605 million in 2024, with income growth more

than offsetting a modest increase in expenses and higher risk costs.

Net core lending growth reached €13.4 billion. This was led by an €11.1

billion expansion in the mortgage portfolio — most notably in Australia,

Italy, Spain, and Poland — alongside continued growth in business and

consumer lending. Net core deposits growth amounted to €12.6 billion,

reflecting substantial net inflows, particularly in Spain, Italy, and Poland.

Commercial net interest income rose 1.5% to €3,698 million, as the

favourable impact of higher lending and deposit volumes more than

compensated for lower liability margins and negative currency impacts.

Other net interest income increased because the prior year had included a

€-39 million impact from the Polish mortgage moratorium.

Net fee and commission income increased significantly to €717 million,

representing an 18% year-on-year rise. Fee income from investment

products grew substantially, driven by net inflows and a higher number of

trades. This was complemented by markedly higher fee income from daily

banking services and insurance, reflecting both customer growth and

successful cross-selling initiatives. Investment and other income also rose

year-on-year, thanks to an increase in Treasury-related income.

Operating expenses in 2025 amounted to €2,905 million. This included

€287 million of regulatory costs, a 10% increase, primarily due to a higher

contribution to the deposit guarantee scheme and increased bank taxes in

Poland. The previous year’s expenses had included €17 million in incidental

restructuring costs (versus €6 million in 2025) and a €35 million legal

provision. Excluding regulatory costs and these one-off items, expenses

rose 5.3%, mainly as a result of inflationary pressures and ongoing

investments in future business growth.

The net addition to loan loss provisions was €323 million, or 26 basis points

of average customer lending, with additions mainly in Poland.


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	21

Wholesale Banking


Wholesale Banking
in EUR million	2025	2024	Change
Commercial net interest income	3,969	3,952	0.4%
Other net interest income	-972	-693
Net interest income	2,997	3,259	-8.0%
Net fee and commission income	1,433	1,317	8.8%
Total investment and other income	2,579	2,405	7.2%
Total income	7,009	6,981	0.4%
of which:
Lending	3,287	3,278	0.3%
Daily Banking & Trade Finance	1,887	1,954	-3.4%
Financial Markets	1,512	1,417	6.7%
Treasury & Other	323	332	-2.7%
Total income	7,009	6,981	0.4%
Expenses excl. regulatory costs	3,618	3,346	8.1%
Regulatory costs	219	212	3.3%
Operating expenses	3,837	3,558	7.8%
Gross result	3,173	3,423	-7.3%
Addition to loan loss provisions	549	627	-12.4%
Result before taxation	2,624	2,796	-6.2%
Taxation	673	693	-2.9%
Non-controlling interests	48	35	37.1%
Net result IFRS	1,902	2,068	-8.0%
Key figures
Net core lending growth (in € billion)	18.3	1.8
Net core deposits growth (in € billion)	8.0	15.8
Cost/income ratio	54.7%	51.0%
Risk costs in bps of average customer lending	28	33
Return on equity based on 13.0% CET1¹	10.0%	10.6%

¹After-tax return divided by average equity based on 13.0% of risk-weighted assets.

Wholesale Banking delivered a robust performance in 2025, with a result

before tax of €2,624 million, compared with €2,796 million in the previous

year. Total income grew slightly amid ongoing geopolitical uncertainties,

and was supported by a 9% rise in fee income, reflecting our strategic

focus on diversifying income streams. This growth helped to mitigate the

impact of margin compression in Payments & Cash Management and

€-200 million in negative currency impacts. Earnings were also impacted

by elevated investment costs aimed at supporting future growth and €90

million in restructuring provisions. Disciplined capital management —

highlighted by the successful execution of two significant risk-transfer

transactions — supported the €3.6 billion (or 2.4%) reduction in risk-

weighted assets and a return on equity of 10.0% in 2025.

Net core lending growth was significant at €18.3 billion. This was driven by

higher volumes in Working Capital Solutions and short-term trade-related

financing, alongside a recovery in long-term loan demand in the second

half of the year.

Net core deposits growth was €8.0 billion, reflecting net inflows in

Payments & Cash Management and Financial Markets.

Total income from Lending increased slightly, supported by higher

volumes and an increase in fee income. This was partly offset by negative

currency movements. The rise in deal flow and fee income highlights the

strength of our client relationships and advisory capabilities. Through

disciplined capital management, we reduced risk-weighted assets within

Lending by 5.3%, with capital-velocity measures offsetting lending growth

and currency movements also contributing.

Income from Daily Banking & Trade Finance declined 3.4% year-on-year.

Higher revenues from increased client demand in Working Capital

Solutions and Trade Finance Services, as well as a strong performance in

our cash pooling business, were more than offset by margin compression

in Payments & Cash Management.

Financial Markets income increased 6.7% to €1,512 million. This reflects

strong results in Interest Rate Derivatives, FX, Equity Derivatives, and

Capital Markets issuance, all benefiting from healthy client flows and

favourable market conditions.

Income from Treasury & Other declined by €9 million year-on-year, as

higher income from Corporate Investments almost fully offset a €70

million one-off income recorded in 2024.

Operating expenses for 2025 included €90 million in restructuring costs

(versus €10 million in 2024), of which €85 million related to workforce

redundancies — part of our efforts to ensure our teams are well positioned

for the future. Excluding these incidental costs as well as regulatory costs

(which increased slightly to €219 million), expenses rose 5.8% year-on-

year, driven by targeted, multi-year investment initiatives — focused on

digital foundations, platforms, and product capabilities — that are required

to structurally improve long-term profitability.

Net additions to loan loss provisions declined to €549 million (equivalent to

28 basis points of average customer lending), down from €627 million in

2024. Individual Stage 3 risk costs fell sharply due to lower inflows,

repayments and recoveries. Risk costs in Stage 1 and 2 were higher, as

2024 had included releases from collective provisions, including a partial

release of management overlays.

Our leadership and corporate governance

Our leadership

and corporate

governance


Our leadership and corporate governance	23
Supervisory Board report	29
Corporate governance	38
Conformity statement	40


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Our leadership and corporate governance

Effective governance is essential for ING to realise

its strategic ambitions and to safeguard the

interests of customers and other stakeholders. Our

leadership plays a pivotal role in this: the

Supervisory Board (SB) supervises and advises the

Management Board Banking (MBB) and oversees

the activities of ING and the business connected

with it.

We aim for a balanced composition of our SB and MBB, with the boards

consisting of a selection of people with - among other things - diverse

knowledge, skills and executive experience, preferably gained in the

banking sector, in large (stock-listed) companies and in the political and

social environment in which such companies operate.

There should also be a balance of experience and affinity with the nature

and culture of the business of ING. The boards play a role in setting and

promoting the culture, and underlying values, behaviours and code of

conduct that help to run our business in a way that contributes to

sustainable long-term value creation for our customers, our people, our

shareholders and society.

ING has a matrix structure combining hierarchical and functional lines that

work together to achieve a common goal, with dedicated roles and

responsibilities and mechanisms for reporting, delegation, decision-making

and escalation. ING’s risk governance safeguards the functioning of the

matrix structure and is based on the three-lines-of-defence model, which

has segregated duties and independent internal control functions.

Read more on ING’s risk governance and three lines of defence in 'Risk

management'.


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Members of the Supervisory Board

Karl

Guha

(chairperson)

Born 1964

Nationality Dutch

Term expires 2027

Mike

Rees

(vice-chairperson)

Born 1956

Nationality British

Term expires 2027

Juan

Colombás

Born 1962

Nationality Spanish

Term expires 2028

Stuart

Graham

Born 1967

Nationality British/German

Term expires 2029

Karl was appointed chairperson of the SB at the General

Meeting in April 2023.

Karl is chairperson of the Nomination and Corporate

Governance Committee and a member of the

Remuneration Committee, the Risk Committee, the Audit

Committee, the ESG Committee and the Technology &

Operations Committee.

Mike was appointed a member of the SB at the General

Meeting in April 2019.

Mike is vice-chairperson of the SB, chairperson of the Risk

Committee and a member of the Nomination and

Corporate Governance Committee and the Audit

Committee.

Juan was appointed a member of the SB at the General

Meeting in April 2020.

Juan is chairperson of the Technology & Operations

Committee and a member of the Risk Committee, the

Audit Committee and the ESG Committee.

Stuart was appointed a member of the SB at the General

Meeting in April 2025.

Stuart is a member of the Risk Committee, the ESG

Committee, the Technology & Operations Committee and

the Audit Committee.

Former position

CEO of Van Lanschot Kempen N.V.

Relevant CRD IV position(s)

§ Chairperson of the SB

§ Member of the supervisory board of SHV Holdings N.V.

§ Non-executive board member of Exor N.V.

Other ancillary positions

§ Member of the supervisory board of Rijksmuseum Fonds

Former position

Deputy CEO of Standard Chartered Bank PLC

Relevant CRD IV position(s)

§ Vice-chairperson of the SB

§ Non-executive chairperson of the board of directors of

Midlands Mindforge

Other ancillary positions

§ Non-executive chairperson of the board of directors of

Mauritius Africa FinTech Hub

Former position

Chief operating officer, chief risk officer and executive board

member of the board of directors of Lloyds Banking Group

PLC

Relevant CRD IV position(s)

§ Member of the SB

§ Non-executive member of the board of directors of Azora

Capital S.L., Azora Investment Management S.L. and

Azora Gestion SGIIC

§ Non-executive chairperson of the board of directors of

Bluserena Spa Unipersonale

Other ancillary positions

§ Member of the global alumni advisory board of the

Institute de Empresa (IE) Business School

Former position

Co-founder and CEO of Autonomous Research

Relevant CRD IV position(s)

§ Member of the SB

Other ancillary positions

§ None


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	25

Margarete

Haase

Born 1953

Nationality Austrian

Term expires 2027

Lodewijk Hijmans

van den Bergh

Born 1963

Nationality Dutch

Term expires 2029

Petri

Hofsté

Born 1961

Nationality Dutch

Term expires 2029

Herman

Hulst

Born 1955

Nationality Dutch

Term expires 2028

Margarete was appointed a member of the SB at the

General Meeting in May 2017.

Margarete is chairperson of the Audit Committee and a

member of the Risk Committee and the Remuneration

Committee.

Lodewijk was appointed a member of the SB at the

General Meeting in April 2021.

Lodewijk is chairperson of the ESG Committee and a

member of the Risk Committee.

Petri was appointed a member of the SB at the General

Meeting in April 2025.

Petri is a member of the Risk Committee and the Audit

Committee.

Herman was appointed a member of the SB at the General

Meeting in April 2020.

Herman is a member of the Audit Committee, the Risk

Committee and the ESG Committee.

Former position

CFO of Deutz AG

Relevant CRD IV position(s)

§ Member of the SB

§ Chairperson of the supervisory board of ams-OSRAM AG

§ Member of the supervisory board of Fraport AG

Other ancillary positions

§ Chairperson of the employers association of Kölnmetall

§ Member of the German Corporate Governance

Commission

Former position

Partner/member of the management committee of De

Brauw Blackstone Westbroek N.V.

Relevant CRD IV position(s)

§ Member of the SB

§ Member of the supervisory board of HAL Holding N.V.

§ Member of the supervisory board of Heineken N.V.

Other ancillary positions

§ Chairperson of the executive committee of Vereniging

Aegon

Former position

Various supervisory board positions at financial institutions,

(former) ABN Amro Group N.V. deputy CFO and DNB division

director banking supervision

Relevant CRD IV position(s)

§ Member of the SB

§ Member of the supervisory board of Royal Friesland

Campina N.V.

§ Member of the supervisory board of Pon Holdings B.V.

Other ancillary positions

§ Chair of the foundation board of the Nyenrode

Foundation

§ Member of the board of Oranje Fonds

§ Member of the NBA Stakeholders Forum

§ Member of the committee of reporting & accountancy

(Commissie Verslaggeving & Accountancy) of AFM

Former position

Global vice-chairperson EY Japan

Relevant CRD IV position(s)

§ Member of the SB

Other ancillary positions

§ None


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	26

Harold

Naus

Born 1969

Nationality Dutch

Term expires 2028

Alexandra

Reich

Born 1963

Nationality Austrian

Term expires 2027

Herna

Verhagen

Born 1966

Nationality Dutch

Term expires 2027

Harold was appointed a member of the SB at the General

Meeting in April 2020.

Harold is a member of the Remuneration Committee, the

Risk Committee and the Technology & Operations

Committee.

Alexandra was appointed a member of the SB at the

General Meeting in April 2023.

Alexandra is a member of the Risk Committee, the

Technology & Operations Committee and the ESG

Committee.

Herna was appointed a member of the SB at the General

Meeting in April 2019.

Herna is chairperson of the Remuneration Committee and

a member of the Nomination and Corporate Governance

Committee and the Risk Committee.

Former position

Global head of Trading Risk Management and general

manager Market Risk of ING Bank and CEO of various

Cardano entities

Relevant CRD IV position(s)

§ Member of the SB

§ Chairman of the advisory board of Cardano Nederland

B.V.

§ Member of the supervisory board and chair of the Audit

Committee and the Appointment & Remuneration

Committee of N.V. Eneco

Other ancillary positions

§ None

Former position

CEO of Telenor Thailand

Relevant CRD IV position(s)

§ Member of the SB

§ Member of the non-executive board of directors of Cellnex

Telecom S.A.

§ Member of the non-executive board of directors of DELTA

Fiber

§ Non-executive director on the board of the Connecting

Europe Broadband Fund

Other ancillary positions

§ None

Former position

CEO of PostNL N.V.

Relevant CRD IV position(s)

§ Member of the SB

§ Member of the supervisory board of Koninklijke Philips

N.V.

Other ancillary positions

§ None


	Supervisory Board in numbers



				Board members 11

				Average age 62

				Nationalities 5

				Average board tenure (years) 4

				Female 36%

				Independent board members* 100%

*As defined by the Dutch Corporate Governance Code


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Members of the Executive Board and Management Board Banking

Steven van

Rijswijk

(CEO)

Born 1970

Nationality Dutch

Tanate

Phutrakul

(CFO)

Born 1965

Nationality Thai

Ljiljana

Čortan

(CRO)

Born 1971

Nationality Croatian

Pinar

Abay

Born 1977

Nationality Turkish

Steven was appointed a member of the EB in May 2017

and a member of the MBB in August 2017. He has been

CEO and chairperson of both boards since July 2020. Prior

to his appointment as CEO and chairperson, he was the

chief risk officer.

Steven is responsible for ING's strategy, including ESG and

sustainability, and leads ING's governance including the

decision-making process, results, culture, branding,

reputation and people.

Tanate was appointed as chief financial officer and a

member of the MBB in February 2019. Subsequently,

Tanate was appointed a member of the EB at the Annual

General Meeting in April 2019.

Tanate is responsible for ING's financial strategy,

budgeting, cost control, and the financing of the company.

Ljiljana was appointed as chief risk officer and a member

of the MBB effective January 2021. Ljiljana was appointed

a member of the EB at the Annual General Meeting in April

2021.

Ljiljana is responsible for ING's risk activities, including

formulating our risk management framework and risk

appetite, risk culture and awareness, risk governance and

policies and compliance.

Pinar was appointed a member of the MBB in January

2020. She is also head of Retail, Market Leaders and

Challengers & Growth Markets.

Pinar is responsible for ING's retail banking activities

globally.

Relevant CRD IV position(s)

§ CEO and chairperson of the EB and MBB

Other ancillary positions

§ Member of the management board of the Nederlandse

Vereniging van Banken (NVB)

§ Member of the Cyber Security Council (CSR)

Relevant CRD IV position(s)

§ CFO and member of the EB and the MBB

Other ancillary positions

§ None

Relevant CRD IV position(s)

§ CRO and member of the EB and the MBB

Other ancillary positions

§ None

Relevant CRD IV position(s)

§ Member of the MBB

§ Non-executive member of the board of ING Belgium N.V./

S.A.

§ Member of the supervisory board of ING-DiBa A.G.

§ Member of the board of EPI Company SE

Other ancillary positions

§ None


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	28

Andrew

Bester

Born 1965

Nationality British/South African

Marnix

van Stiphout

(COO)

Born 1970

Nationality Dutch

Daniele

Tonella

(CTO)

Born 1971

Nationality Swiss

Andrew was appointed a member of the MBB and head of

Wholesale Banking in April 2021.

Andrew is responsible for ING's wholesale banking

activities globally.

Marnix was appointed a member of the MBB and chief

operations officer in September 2021.

Marnix is responsible for translating, overseeing, and

embedding ING's strategies into a strategy for the

operations function.

Daniele was appointed a member of the MBB and chief

technology officer in August 2024.

Daniele is responsible for overseeing and managing the

total IT landscape and advising on technology-driven

business opportunities.

Relevant CRD IV position(s)

§ Member of the MBB

Other ancillary positions

§ None

Relevant CRD IV position(s)

§ Member of the MBB

Other ancillary positions

§ None

Relevant CRD IV position(s)

§ Member of the MBB

Other ancillary positions

§ Member of the Tech Advisory Board of The Hg Foundation


		Executive Board in numbers



				Board members 3

				Average age 56

				Nationalities 3

				Average board tenure (years) 6

				Female 33%


		Management Board Banking in numbers



				Board members 7

				Average age 55

				Nationalities 6

				Average board tenure (years) 4.5

				Female 29%


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	29

Supervisory Board report

This section contains the Supervisory Board report,

with information on the meetings of the SB and its

committees, attendance of SB members and the

MBB and SB annual self-evaluation.

Meetings of the Supervisory Board

The Supervisory Board (SB) met 13 times in 2025 and focused in particular

on strategy, including growth, risk, geopolitical developments, technology

and digitalisation, people & succession, and operational and regulatory

resilience. The Management Board Banking (MBB) were present at regular

SB meetings. The SB also had sessions without the MBB when this was

justified by the nature of the topics on the agenda. The purpose of these

sessions and SB-only meetings is to allow the SB to reflect independently

on and consider important matters in the absence of the MBB. The SB also

had so-called ‘Restricted SB meetings’, with only the CEO attending, except

when matters concerning the CEO were discussed. Topics addressed were

primarily nomination- and remuneration-related matters, and additional

attention was given to preliminary strategic and governance topics.

In regular SB meetings, ING staff, the auditors and advisors are frequently

asked to provide presentations on specific topics. Examples of such topics

are progress of ING’s performance in the various countries and business

lines, supervisory developments including the ECB’s Supervisory Review

and Evaluation Process (SREP), geopolitical developments including

defence, the financing of ING in accordance with ING’s capital and liquidity

adequacy, ING’s dividend and distribution policy, ING’s financials, investor

relations updates, strategy including M&A ambitions, risk appetite, audit

plans, and regulatory themes with a global ING scope. These topics

included operational resilience, cybersecurity, the use of GenAI, private

credit, third party & vendor management and ESG-related matters.

The SB was also informed throughout the year of potential financial, non-

financial and compliance risks for ING, including the political and economic

developments in various countries and regions, climate- and ESG-related

risks, cybersecurity and ransomware. Macroeconomic and geopolitical

uncertainty remains prevalent in 2025. In that context, the SB closely

monitored the macroeconomic developments and discussed the potential

consequences for ING’s operations with the MBB.

As one of the key focus areas, the SB regularly discusses the execution and

delivery of ING’s 'Growing the Difference' strategy with the MBB to accelerate

growth, increase our impact and deliver customer value, and to reach our

financial targets for 2027 and beyond. For more information, see 'Our

strategy'.

As core enablers of ING’s strategy, the SB maintained close oversight of the

digitalisation and scalability agenda. The objective is to deliver scalable

technology and operations that enable seamless, fully digital services, ensuring

an enhanced customer experience while maintaining the highest standards of

safety and security. Continued emphasis on operational resilience, supported

by robust monitoring, strengthens ING’s ability to anticipate and respond

swiftly to disruptions, thereby minimising their impact on customers.

One of the core pillars of ING’s strategy is sustainability and it is central to our

long-term commercial success. The need to support our clients in their

transition to a low-carbon business model comes with both opportunities and

risks, and it is ING’s ambition to play a an important role in supporting this

transition. That’s why we aim to put sustainability at the heart of what we do.

The MBB's focus on climate action and the Terra approach were discussion

items, including other ESG-related matters.

In addition to reviews by the SB of the composition and succession planning of

the SB and MBB, the SB also discussed broader people development,

organisational health within ING, and diversity and inclusion matters. In the

SB’s discussions with HR and the MBB, the focus is on talent and leadership,

culture and organisation, including the bank-wide diversity and inclusion

approach, and on operational excellence. Plans to develop, attract and retain

talent have been part of those discussions, as well as gender diversity targets.

The SB discusses and reconfirms all of its members’ outside positions on an

annual basis. In addition, it discusses any intended outside positions and

assesses if such positions can be approved while safeguarding the level of

engagement.


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Attendance of SB members

The attendance rates in 2025 of SB members for SB and SB committee

meetings, as well as the number of meetings held, are listed in the

following table. The continued high attendance demonstrates that SB

members are engaged with ING and are able to devote sufficient time and

attention to overseeing ING's affairs.

In addition to the information included in this SB report, information on the

SB can be found in ‘Our leadership’ and ‘Corporate governance’.


SB attendance 2025^1,2
	SB	RiCo³	AC	NCGcom⁴	RemCo	ESGcom	T&Ocom
Karl Guha (chairperson)	13/13	8/8	7/7	10/10	7/7	4/4	6/6
Mike Rees (vice-chairperson)	13/13	8/8	7/7	10/10
Juan Colombás	12/13	8/8	7/7			4/4	6/6
Stuart Graham ⁵	4/5	4/4				2/2	3/3
Margarete Haase	12/13	7/8	7/7		6/7
Lodewijk Hijmans van den Bergh	12/13	8/8				4/4
Petri Hofsté ⁶	4/5	3/3	1/1
Herman Hulst	13/13	8/8	7/7			4/4
Harold Naus	11/13	8/8			7/7		6/6
Alexandra Reich	11/13	5/8				4/4	5/6
Herna Verhagen	12/13	8/8		9/10	7/7
Total attendance ⁷	91%	95%	100%	97%	96%	100%	97%

¹This SB attendance overview shows the SB (committee) meetings that took place during the year.

In addition to these meetings, there were 12 Restricted SB meetings in 2025 in view of nomination

and remuneration matters, with a total attendance rate of 96% percent. These are not shown

separately in the overview for year-on-year, like-for-like comparison purposes.

²Abbreviations used: RiCo = Risk Committee, AC = Audit Committee, NCGcom = Nomination and

Corporate Governance Committee, RemCo = Remuneration Committee, ESGcom = ESG Committee;

T&Ocom = Technology & Operations Committee

³In addition to the eight regular RiCo meetings, in 2025, two RiCo meetings were held in

combination with the RemCo on remuneration matters that also required a risk view.

⁴In 2025, one NCGcom meeting was held in combination with the RemCo.

⁵Stuart Graham was appointed to the SB, the RiCo, the ESGcom and the T&Ocom effective 1 July

2025. He was also appointed to the AC effective 28 January 2026 and therefore did not attend any

AC meetings in 2025. His attendance is shown relative to his tenure.

⁶Petri Hofsté was appointed to the SB effective 1 July 2025 and to the RiCo and the AC effective 1

August 2025. Her attendance is shown relative to her tenure.

⁷The numbers exclude SB observers, if any. If SB members cannot join a meeting they will always

receive the meeting materials prior to the meetings to allow them to provide feedback.


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SB committee meetings and composition

There are currently six SB committees: the Risk Committee, the Audit

Committee, the Nomination and Corporate Governance Committee, the

Remuneration Committee, the ESG Committee and the Technology &

Operations Committee. The committees report to the SB on their

deliberations and findings, prepare discussion and decision items, and

thereby play a significant role in supporting the SB in its oversight and

supervisory activities, allowing it to operate effectively. As such, all

relevant items discussed by the committees were reported to the SB, with

the SB approving those items if required from a governance

perspective.There was frequent interaction between the chairpersons of

the relevant SB committees and the members of the MBB. Furthermore,

the chairpersons of the Risk Committee and the Audit Committee

continued their informal interaction with the chairpersons of the local risk

and audit committees of ING’s five largest subsidiaries to enrich the SB

dialogue.

To manage each of the committees’ annual cycle of work and potential

committee interdependencies, each committee has drawn up an annual

work plan that is reviewed and updated throughout the year for priority-

setting and forward-looking purposes. These plans all feed into the SB’s

annual meeting cycle.


Composition of the SB committees on 31 December 2025
Supervisory Board	Risk Committee	Audit Committee	Nomination and Corporate Governance Committee	Remuneration Committee	ESG Committee	Technology & Operations Committee
Karl Guha (chairperson)	Member	Member	Chairperson	Member	Member	Member
Mike Rees (vice-chairperson)	Chairperson	Member	Member	—	—	—
Juan Colombás	Member	Member	—	—	Member	Chairperson
Stuart Graham	Member	—	—	—	Member	Member
Margarete Haase	Member	Chairperson	—	Member	—	—
Lodewijk Hijmans van den Bergh	Member	—	—	—	Chairperson	—
Petri Hofsté	Member	Member	—	—	—	—
Herman Hulst	Member	Member	—	—	Member	—
Harold Naus	Member	—	—	Member	—	Member
Alexandra Reich	Member	—	—	—	Member	Member
Herna Verhagen	Member	—	Member	Chairperson	—	—

Risk Committee

The Risk Committee met eight times in 2025, and two of these meetings

were combined with the Remuneration Committee to address

remuneration-related proposals that include risk methodology elements,

such as those relating to the Variable Remuneration Accrual Model (VRAM)

(see also ‘Remuneration Committee’). All SB members are also member of

the Risk Committee, due to the continued importance of risk and how this

is managed and supervised.

The Risk Committee assists and advises the SB with the performance of its

duties in relation to overseeing the setting and monitoring of ING’s risk

appetite and risk strategy for all types of risk. This includes but is not

limited to financial, non-financial and compliance risk, the effectiveness of

the internal risk management and control systems and other related risk

management topics.

At each quarterly Risk Committee meeting financial and model risks, non-

financial risks and compliance risks were discussed. This included the

status of ING’s accompanying metrics, such as for risks in the areas of

solvency, liquidity and funding, credit, market, non-financial risk and

compliance. The discussions were supported by different analyses

conducted on the macroeconomic and geopolitical impact and the

changing interest rate environment on ING and its customers and updates

on credit developments in certain countries and portfolios. The non-

financial and compliance risk discussions were supported by updates of

the bank-wide global financial crime prevention (GFCP) enhancement and

maturity efforts, a variety of topical dashboards such as on IT (risk),

cybersecurity, third-party risk, conduct & ethics and data protection

(including GDPR), and the status of implementation of related regulatory

programmes. The Risk Committee also regularly discussed the status of

reported whistleblower concerns, reviewed and discussed the annual

review of the Risk Appetite Framework, the annual update to ING’s

Recovery Plan and received updates on and discussed cybersecurity,

developments in AI, ING's IT risk control framework, and the management

of third-party risk in relation to outsourcing.

Thematic sessions were organised on a variety of topics to focus

specifically on themes that needed further attention and/or are forward

looking with respect to emerging risks and developments. Also, four deep

dives were organised for the Risk Committee in 2025 to contribute to a


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more in-depth understanding of, among others, non-bank financial

institutions, leveraged finance and the impact of geopolitical risk on ING.

For more information on how ING manages its risks, see ‘Risk

management’.

Audit Committee

The Audit Committee met seven times in 2025. The Audit Committee

assists and advises the SB in performing its duties relating to the integrity

and quality of ING’s financial and non-financial reporting, as well as the

effectiveness of ING’s internal risk management and control systems in

relation to financial and non-financial reporting.

Throughout 2025, the Audit Committee addressed a range of recurring

topics, including those relating to financial reporting, such as the interim

accounts and financial statements and the Annual Report. The Audit

Committee also discussed judgemental accounting topics and key audit

matters identified in the auditors’ reports. Attention was given to the

external auditor’s audit plan, including the financial audit plan, as well as

the related engagement letters, independence reporting, and fees.

Updates were provided to the Audit Committee throughout 2025 with

regard to the status of Deloitte, ING's new external auditor as per the 2026

financial year in order to comply with the mandatory external auditor

rotation. Deloitte declared its independence in relation to ING as of 28 July

2025 in its role as new external auditor and it was confirmed that

Deloitte's independence is compliant with applicable rules and regulations.

In addition, the Audit Committee reviewed the overall internal control

environment and the internal controls over financial reporting, as well as

the work performed by both internal and external audit functions. The

Audit Committee also discussed matters related to the financing of the

company, including assessments of ING’s capital and liquidity position.

In 2025, specific attention was given to several key topics, including a

review of ING’s equity stakes and joint ventures. Furthermore, the Audit

Committee reviewed IFRS 9 and ESG disclosures and considered

developments under Pillar III.

To ensure proper preparation for the regular meetings, the chairperson of

the Audit Committee held separate sessions with the external auditor, the

general manager of the Internal Audit department, the chief financial

officer, and the group controller. The chairperson also met with the newly

appointed external auditor for 2026, to monitor the auditor transition

process and with various senior managers to remain informed of key

developments within their areas of responsibility.

Directly following each Audit Committee meeting, members of the Audit

Committee held a closed session with the internal and external auditors to

seek confirmation that all relevant topics had been discussed in the Audit

Committee meetings.

Nomination and Corporate Governance Committee

The Nomination and Corporate Governance Committee met 10 times in

2025. The Nomination and Corporate Governance Committee assists the

SB in performing its duties, including the selection and nomination of

members for the SB and MBB, as well as overseeing talent management

and the effectiveness of ING’s governance arrangements.

With regard to nomination-related matters, ING aims to ensure that all of

its boards are, at all times, adequately composed to perform their duties.

As its standard practice, the Nomination and Corporate Governance

Committee therefore discusses the performance of the individual

members of the MBB (also serving as input to the Remuneration

Committee), MBB and SB composition, bench strength and medium- to

long-term succession planning. A continuing conversation on MBB

succession planning is facilitated by the chief human resources officer as

part of the regular Nomination and Corporate Governance Committee

meetings in the form of deep dives by function and business line.

When selecting suitable board succession candidates, there are various

aspects to take into account regarding the board composition, such as

strategic priorities, regulatory requirements, suitability considerations,

banking and other industry knowledge, outside positions, independence,

potential conflicts of interest and availability. Also considered are the

minimum and optimal size of a board and diversity aspects, such as how

to arrive at an appropriate balance in its representation of regions, age,

gender, knowledge and expertise. The generic profile of the SB aims to

capture these elements. The profiles can be found on ing.com. Find more

on the boards’ composition in the ‘Composition of the Management Board

Banking and Supervisory Board’ and in the Diversity and Competence

Matrix.

The Nomination and Corporate Governance Committee also focuses on

ING’s broader talent and succession planning in view of bench strength

and diversity at higher management levels, with selected key roles

receiving dedicated attention. This is done by taking into account ING’s

diversity and inclusion policy and by accelerating refreshment where

possible without jeopardising business continuity. The committee also

holds periodic conversations outside of its regular meetings with internal

talented individuals who are considered to have the potential to assume

more senior and complex roles in the organisation over time. The results of

these conversations feed into the individuals’ coaching and development

plans.

With regard to corporate governance, the Nomination and Corporate

Governance Committee discussed among other things the suitability

procedure being one of ING's key policies and its global implementation,

ING’s Governance Framework as well as organisational effectiveness,

annual updates to the corporate board charters and ING’s decision

structure.

Remuneration Committee

The Remuneration Committee met seven times in 2025. The

Remuneration Committee assists the SB with the performance of its duties

in relation to remuneration, the remuneration policies and their

application and compliance. In doing so, the Remuneration Committee

takes into account the adequacy of information provided to shareholders

on remuneration policies and practices.

As an annual recurring topic, the Remuneration Committee reviewed the

remuneration report by way of benchmarking and alignment to shareholder

expectations in order to further improve it. In addition, the Remuneration

Committee discussed the progress and performance on the annual targets

set for the MBB, the SB remuneration policy update, SB remuneration


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matters, including the benchmarking results, the identified staff and high

earner-related remuneration matters based on ING’s remuneration

governance structure, the variable remuneration and the application of ING’s

accompanying VRAM and updates to ING’s Remuneration Regulations

Framework.

ESG Committee

The ESG Committee met four times in 2025. The ESG Committee assists

the SB with matters relating to the various areas of ESG, including but not

limited to, the development of ESG and its integration in the company and

its strategy and ESG-related disclosures, reporting and assurance (the

latter together with the Audit Committee). In addition, the ESG Committee

assists the SB by monitoring and advising on potential impediments as

well as relevant trends and developments on ‘environmental’, ‘social’ and

‘governance’ topics and how to connect them with ING’s response, actions

and targets on the basis of ING’s ESG dashboard.

The ESG Committee discussed, among other things, ESG strategy

performance and updates, the outcome of the double materiality

assessment, ESG dilemmas and external ESG reporting. Given the dynamic

and continuously evolving nature of ESG, deep dives were held to

contribute to a more in-depth understanding of certain ESG- centred

topics.

Technology and Operations Committee

The Technology and Operations Committee met six times in 2025. The

Technology and Operations Committee assists the SB in relation to

oversight of ING’s use of technology and ING's operations. This includes the

technology strategy, major technology initiatives and programmes, and

other technology and operations-related topics.

The Technology and Operations Committee discussed, among other

things, ING’s cybersecurity strategy (together with the Risk Committee),

analytics developments, (Gen)AI opportunities and developments from

several perspectives, ING's data strategy and developments around the

ING Hubs. The Technology and Operations Committee was also provided

with a number of outside-in views on technology developments and

trends.

Continuous dialogue with stakeholders

At ING, we seek out open dialogue and maintain continuous interaction

with our stakeholders, responding to their views and concerns, to drive

increased collaboration. We aim to strike a balance between the interests

of all stakeholders, including customers, shareholders, employees,

regulators, supervisors, and society at large. In 2025, the SB had periodic

conversations with various stakeholders, including our clients and

shareholders, employees, supervisors and the MBB. A specific topic that

ING actively engaged on with investors and stakeholders, including

regulators, was the update of the SB remuneration policy. The SB exercised

its oversight role, which aimed to ensure that actions resulting from these

conversations were embedded in the organisation and were followed up

effectively. Examples of topics covered in 2025 in this respect are

cybersecurity, availability and reliability of ING’s channels, use of GenAI,

remuneration, climate risks, and other ESG-related topics.

The dialogue between ING and supervisors and regulators was a regular

agenda item for the SB throughout the year. This included several

discussions between the SB and the MBB on the results of and follow-up to

the annual SREP, through which the ECB aims to promote a resilient

banking system as a prerequisite for a sustainable and sound financing of

the economy. The SREP involves a comprehensive assessment of banks’

strategies, processes and risks, and takes a forward-looking view to

determine how much capital each bank needs to cover its risks.

Permanent education and other knowledge sessions

In 2025, several education sessions were organised, in line with prior years,

and delivered by both external and internal subject matter experts. These

sessions covered topics such as geopolitical and macroeconomic

developments and their impact on the bank, technology, people & talent

management, climate change, forward-looking overview of the global

regulatory environment, and governance. The sessions are aimed at

keeping the board up to date on ING relevant knowledge, skills and

expertise and at increasing the understanding of and engagement with

ING’s business operations and stakeholders.

For the newly appointed SB members, Stuart Graham and Petri Hofsté, a

comprehensive induction programme was designed to facilitate their

transition into the role.

In addition to the permanent education sessions, certain SB committees

held deep dives, which are technical discussions tailored to contribute to a

more in-depth understanding of key topics in the remit of the respective

committee.

As part of the annual business visit, the SB, together with the MBB, visited

the ING locations in Poland and Romania in September 2025. This visit

allowed the board members to get a better understanding of local clients,

business challenges and the country-specific market opportunities, also

contributing to a better mutual understanding and alignment on what

matters most to ING and its stakeholders.

The various educational sessions and the business visits provided

opportunities for SB members to interact with senior management,

subject-matter experts and local talent.


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Management Board Banking and Supervisory Board

annual collective self-evaluation

In 2025, an assessment of the MBB and SB collective self-evaluation took

place. Following this assessment, a renewed approach was adopted for the

self-evaluation, based on a recurring 3-year cycle in which a full review

followed by two interim reviews in subsequent years would take place. The

last full review took place over 2024 and therefore over 2025 an interim

review has taken place. This was facilitated by an independent external

party.

Results Management Board Banking

The MBB's collective dialogue was centred around the following questions:

1. Positive points: are the positive points previously identified still valid?

Where has the MBB further improved?

2. Priorities to improve: in the past year, did the MBB improve sufficiently

on the improvement areas previously defined? What would be the

priority areas the MBB needs to further improve in 2026?

The results of the review were positive overall and compared to previous

years, various positive points are still valid. The following points were

identified:

§ Management team composition, including skills, experience, and

diversity;

§ MBB dynamics, including quality of discussion / debate and balance of

contribution;

§ Overall management of meetings, including choreography, timing and

style of meetings and the evolution of the agendas;

§ Improved focus on operational / IT resilience and the macro-economic /

geopolitical conditions, M&A and other growth opportunities; and

§ Quality time devoted on talent management.

Areas to deprioritise were identified as follows:

§ Operational matters (e.g., KYC, model updates) that are now

considered well managed;

§ Time spent on Change & Transformation updates, given improved

governance structures; and

§ Detailed dashboards and KPIs for specific functions in order to focus

more on higher-level, strategic metrics.

Key priorities for the coming year were identified as follows:

§ Rebalancing the MBB’s focus towards strategic topics, particularly

technology and allocating more time on considering the strategic

implications of AI;

§ Increasing the consideration of customers, especially the customer

experience, digital customer journey and reducing friction;

§ Enhancing the focus on external developments, particularly

competitors and broader market trends, and spending more time on

outside-in perspectives;

§ Continuing investing in people / talent from strategic perspective to

enhance bench-strength; and

§ Effectively managing the transition and onboarding of (new) MBB

members, while defining the next phase of the culture.

Overall, the MBB agreed to a number of specific actions for 2026 to

contribute to its performance:

1. Continue educational and professional development sessions, with a

particular emphasis on AI.

2. Continue to optimise the MBB meeting agenda to enhance overall

effectiveness, including by allocating more time to strategic topics

while reducing focus on tactical and operational matters.

3. Develop the agenda for 2026 MBB ad hoc sessions to maximise impact

through incorporating external perspectives and ensuring that such

sessions are structured to facilitate the effective integration of new

MBB members.

Results Supervisory Board

The SB's collective dialogue was centred around the following questions:

1. Positive points: are the positive points previously identified still valid?

Where has the SB further improved?

2. Priorities to improve: in the past year, did the SB improve sufficiently on

the improvement areas previously defined? What would be the priority

areas the SB need to further improve in 2026?

The results of the review were positive overall and compared to previous

years, various positive points are still valid. The following points were

identified:

§ SB composition, including skills, experience, and diversity as well as the

interface between the Committees and the SB;

§ SB effectiveness at overseeing, supervising, challenging and advising

the EB and MBB;

§ Effective decision making through SB dialogues and interactions with

the EB and MBB;

§ Oversight of strategy, succession, compliance and risk;

§ Deep understanding of the external environment through enhanced

monitoring of macroeconomic and geopolitical developments and by

seeking external viewpoints; and

§ Taking into account the views of key stakeholders.

Key priorities for the coming year were identified as follows:

§ Continued focus on key topics with specific attention for strategy,

governance, succession & talent management, and digital & data;

§ Further deepen oversight of ING’s corporate structure and internal

governance model;

§ Enhanced focus on financial performance management and business

performance;

§ Continued monitoring of the external environment including

geopolitical developments, the competitive landscape and broader

market trends; and

§ Further optimised balance between strategic topics, operational

matters, governance matters, and regulatory updates to ensure

appropriate focus is given to each.

Overall, the SB agreed to a number of specific actions for 2026 to

contribute to its performance:

1. Continued attention for developments in the external environment and

potential implications for ING.

2. Increase oversight on financial performance management including

cost management and its alignment with ING strategy.

3. Support the CEO throughout the imminent composition changes of the

Executive Board and Management Board Banking.


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Composition of the Management Board Banking and

Supervisory Board

ING aims to ensure that the boards are – at all times – adequately

composed to perform their duties. ING believes that throughout 2025 its

boards were well composed and balanced. At the 2025 General Meeting,

Petri Hofsté and Stuart Graham were appointed as members of the SB and

Margarete Haase and Lodewijk Hijmans van den Bergh were reappointed

as SB members.

On 24 July 2025, it was announced that Tanate Phutrakul will step down

from his position as chief financial officer and member of the Management

Board Banking as of the 2026 General Meeting. On 29 October 2025, it was

announced that Ida Lerner will be appointed as chief financial officer and

member of the Management Board Banking effective 1 April 2026.

Furthermore, on 23 October 2025, it was announced that Ljiljana Čortan

will step down as CRO and will succeed Andrew Bester as head of

Wholesale Banking. It has since been announced that Ljiljana will start as

head of Wholesale Banking and leave her position as CRO on 24 February

2026. The process of determining a proposed successor for the role of chief

risk officer is ongoing.

On 20 January 2026, it was announced that Herna Verhagen will resign

from the Supervisory Board as of the 2026 General Meeting. Herna will also

step down as chairperson of the Remuneration Committee and as

member of the Nomination and Corporate Governance Committee and the

Risk Committee.

For more information on the composition of the SB, see 'Corporate

governance'.

Diversity and competence matrix

Please note the following:

§ The purpose of this matrix is to provide an overview of the experience

and competencies that ING considers to be the most relevant for its

stakeholders.

§ The matrix represents the extent to which ING’s board members have

such experience and competencies (either developed already before

joining ING and/or during their position(s) at ING). The matrix is

approved by the Management Board Banking and the Supervisory

Board.

§ The content of the matrix is subject to change in light of ING’s

continually changing situation, markets and environment.

§ For the appointments of new board members, all relevant

competencies are also shared with ING’s supervisors DNB/ECB based on

their standard suitability matrix to assess the collective competence of

members of the management/supervisory body.


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Management Board (EB/MBB)
	Diversity			Experience & Core Competencies
	Year of birth	Gender	Nationality	Executive experience	International experience	Banking	Finance/audit	Risk	Operations	IT & cybersecurity	ESG
Steven van Rijswijk EB/MBB, CEO	1970	Male	Dutch
Tanate Phutrakul EB/MBB, CFO	1965	Male	Thai
Ljiljana Čortan EB/MBB, CRO	1971	Female	Croatian
Pinar Abay MBB, head of Retail, Market Leaders and Challengers & Growth Markets	1977	Female	Turkish
Andrew Bester MBB, head of Wholesale Banking	1965	Male	British/ South African
Marnix van Stiphout MBB, chief operations officer	1970	Male	Dutch
Daniele Tonella MBB, CTO	1971	Male	Swiss

Meets the required knowledge/experience criteria for the role and it implies the capacity to take educated decisions on the relevant matters.
In addition is considered an expert based on experience in the current or previous roles.


Supervisory Board
	Diversity			Experience & Core Competencies
	Year of birth	Gender	Nationality	Executive experience	International experience	Banking	Finance/audit	Risk	Operations	IT & cybersecurity	ESG
Karl Guha Chairperson	1964	Male	Dutch
Mike Rees Vice-chairperson	1956	Male	British
Juan Colombás	1962	Male	Spanish
Margarete Haase	1953	Female	Austrian
Lodewijk Hijmans van den Bergh	1963	Male	Dutch
Herman Hulst	1955	Male	Dutch
Harold Naus	1969	Male	Dutch
Alexandra Reich	1963	Female	Austrian
Herna Verhagen	1966	Female	Dutch
Petri Hofsté	1961	Female	Dutch
Stuart Graham	1967	Male	British/ German


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Appreciation for management and employees

The SB would like to thank management and the employees for their

collaboration and hard work to execute our strategy to accelerate growth,

increase our impact and deliver customer value. ING delivered a strong

financial performance in 2025, despite the uncertain economic and volatile

geopolitical circumstances and this would not been possible without

dedication of our employees.

The SB expresses its sincere appreciation to all employees for their

commitment throughout the year.

Amsterdam, 23 February 2026


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Corporate governance

This section comprises ING Bank N.V.’s Corporate

Governance Statement, together with the

paragraph 'Own workforce strategy – Unlocking

our people’s full potential', the below-mentioned

booklets and other parts of this Annual Report to

which reference is made in the booklets, comprise

the corporate governance statement referred to in

section 2a of the Dutch Decree on information in

the management board report (Besluit inhoud

bestuursverslag).

Dutch Banking Code

The Dutch Banking Code is applied by ING Bank N.V. (ING Bank). The

application by ING Bank is described in the booklet ‘Application of the

Dutch Banking Code by ING Bank (FY2025)’, dated 26 February 2026,

available on ing.com. This is to be read in conjunction with and deemed to

be incorporated in the Annual Report of ING Bank. The Banking Code can

be downloaded from the website of the Dutch Banking Association

(nvb.nl).

Financial reporting

As ING Bank is a consolidated subsidiary of ING Groep N.V. (ING Group), its

policies and procedures for establishing and maintaining adequate internal

control over financial reporting are the same as those applied by ING

Group for its consolidated financial statements with respect to ING Bank

and the entities included in the latter's own consolidated financial

statements.

ING’s internal control over financial reporting is a process designed under

the supervision of our principal executive and principal financial officers to

provide reasonable assurance regarding the reliability of financial

reporting and the preparation of financial statements for external

purposes in accordance with generally accepted accounting principles.

ING's internal controls over financial reporting include those policies and

procedures that:

§ Pertain to the maintenance of records that, in reasonable detail,

accurately and fairly reflect the transactions and dispositions of the

assets of ING;

§ Provide reasonable assurance that transactions are recorded as

necessary to permit the preparation of financial statements in

accordance with generally accepted accounting principles, and that our

receipts and expenditures are being made only in accordance with

authorisations of our management and directors; and

§ Provide reasonable assurance regarding the prevention or timely

detection of unauthorised acquisition, use or disposition of assets that

could have material effect on the financial statements.

ING has a process in place where, under the supervision and with the

participation of the CEO and CFO, the effectiveness of internal control over

financial reporting is evaluated, based on the criteria of the Committee of

Sponsoring Organisations of the Treadway Commission in Internal

Reporting (COSO) - Integrated Framework (2013 Framework).

Supervisory Board composition

ING aims to have an adequate and balanced composition of its SB, with a

mix of persons with knowledge, skills and executive experience, preferably

gained in the banking sector, experience in corporate governance of large

(stock-listed) companies and experience in the political and social

environment in which such companies operate. In the selection of SB

members, ING strivess, in line with applicable laws and regulations, for a

balance in nationality, gender education and work background. In

addition, there should be a balance of experience and affinity with the

nature and culture of the business of ING.

The SB is responsible for selecting and nominating candidates for

appointment or reappointment to the SB, among others based on the SB

profile, which is available on ing.com. The SB regularly assesses the

composition of the Supervisory Board.

As from 1 July 2025, the SB consisted of seven male members and four

female members. ING believes the Supervisory Board is well-balanced in

terms of other relevant diversity aspects. Furthermore, the SB had an

international composition in 2025, with six members of Dutch nationality

and five members of other nationalities.

Relevant positions pursuant to CRD IV

Members of the SB may hold other positions, including directorships, either

paid or unpaid. The Capital Requirements Directive 4 (CRD IV) restricts the

total number of supervisory board positions or non-executive directorships

with predominantly commercial organisations that may be held by a SB

member to four, or to two, if the SB member also has an executive board

position. The ECB may, under special circumstances, permit a SB member

to fulfil an additional supervisory board position or non-executive

directorship. Positions with, inter alia, subsidiaries or qualified holdings are

not taken into account in the application of these restrictions. Such

positions may not conflict with the interests of ING Bank. It is the

responsibility of the individual member of the SB and the SB collectively to

ensure that the directorship duties are performed properly and are not

affected by any other positions that the individual may hold outside ING

Bank.


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Information on the members of the Supervisory

Board

Reference is made to the Our leadership section for information on the

members of the SB, which information is deemed incorporated by

reference. Also read more about the composition and duties of the SB and

its committees in the Supervisory Board report and on ing.com.

Management Board Banking composition

ING aims to have an adequate and balanced composition of its MBB, with a

diverse selection of persons with knowledge, skills and executive

experience, preferably gained in the banking sector, experience in

corporate governance of large (stock-listed) companies and experience in

the political and social environment in which such companies operate. In

addition, there should be a balance of experience and affinity with the

nature and culture of the business of ING. In the selection of the members

of the MBB, ING strives, in line with applicable laws and regulations, for a

balance in nationality, gender, education and work background. In

addition, there should be a balance of experience and affinity with the

nature and culture of the business of ING.

The SB regularly assesses the composition of the MBB.

The Gender Diversity Act, which came into force in the Netherlands on 1

January 2022, requires ING Group to set appropriate and ambitious targets

for gender diversity in its EB and senior management. ING Group has given

effect to that obligation on behalf of ING Bank. ING Group considers the

MBB to be part of this senior management for which the target for gender

diversity is set at at least 30% by 2025.

Relevant positions pursuant to CRD IV

Members of the MBB may hold other positions, including directorships,

either paid or unpaid. CRD IV restricts the total number of supervisory

board positions or non-executive directorships with predominantly

commercial organisations that may be held by a Management Board

Banking member to two. Positions with, inter alia, subsidiaries or qualified

holdings are not taken into account in the application of these restrictions.

Such positions may not conflict with the interests of ING Bank.

Information on the members of the Management

Board Banking

Reference is made to the Our leadership and corporate governance section

for information on the members of the Management Board Banking, which

information is deemed incorporated by reference.


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Conformity statement

The Management Board Banking is required to prepare the Financial

Statements and the Annual Report of ING Bank N.V. for each financial year

in accordance with applicable Dutch law and those International Financial

Reporting Standards (IFRS) that were endorsed by the European Union.

Conformity statement pursuant to section 5:25c paragraph 2(c) of the

Dutch Financial Supervision Act (Wet op het financieel toezicht).

The Management Board Banking is responsible for maintaining proper

accounting records, for safeguarding assets and for taking reasonable

steps to prevent and detect fraud and other irregularities. It is responsible

for selecting suitable accounting policies and applying them on a

consistent basis, making judgements and estimates that are prudent and

reasonable. It is also responsible for establishing and maintaining internal

procedures to ensure that all major financial information is known to the

Management Board Banking, so that the timeliness, completeness and

correctness of the external financial reporting are assured.

As required by section 5:25c paragraph 2(c) of the Dutch Financial

Supervision Act, each of the signatories hereby confirms that to the best of

his knowledge:

§ the ING Bank N.V. 2025 Financial Statements give a true and fair view of

the assets, liabilities, financial position and profit or loss of ING Bank

N.V. and the enterprises included in the consolidation taken as a whole;

and

§ the ING Bank N.V. 2025 Annual Report gives a true and fair view of the

position at the balance sheet date, the development and performance

of the business during the financial year 2025 of ING Bank and the

enterprises included in the consolidation taken as a whole, together

with a description of the principal risks ING Bank N.V. is being

confronted with.

Amsterdam, 23 February 2026

The Management Board Banking

S.J.A. (Steven) van Rijswijk

CEO, chairperson of the Management Board Banking

T. (Tanate) Phutrakul

CFO

L. (Ljiljana) Čortan

CRO

P. (Pinar) Abay

Head of Retail, Market Leaders and Challengers & Growth Markets

A.J.M. (Andrew) Bester

Head of Wholesale Banking

M.A. (Marnix) Stiphout

Chief operations officer

D. (Daniele) Tonella

Chief technology officer

Capital management

Capital

management


Capital management	42


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	42

Capital management

ING’s capital management strategy is designed to

maintain a robust capital position that adequately

covers all material risks, including economic risks,

across the Group, while ensuring compliance with

applicable local and global regulatory

requirements. At the same time, the strategy

supports sustainable value creation for

shareholders and enables ING to serve its clients

and underpin commercial activities. Despite an

uncertain and volatile geopolitical environment,

ING’s capital position remained strong during the

year. At both consolidated and entity levels, ING

maintains sufficient capital buffers to withstand a

range of adverse stress scenarios.

Capital management strategy

Group Treasury (GT) is responsible for maintaining adequate capitalisation

across ING Group and its banking entities to support the management of

risks associated with ING’s business activities. This includes capital

planning, allocation, and management within the Group, as well as the

execution of capital market, term capital funding, and risk management

transactions. ING employs an integrated approach to assessing capital

adequacy, whereby GT considers regulatory and internal economic capital

metrics alongside the interests of key stakeholders, including customers,

shareholders, and rating agencies.

ING applies the following main capital definitions:

§ Common Equity Tier 1 (CET1) capital consists of shareholders’ equity

after the correction for applicable regulatory adjustments. The CET1

ratio is calculated as CET1 capital divided by risk-weighted assets

(RWAs).

§ Tier 1 capital is defined as CET1 capital plus Additional Tier 1 (AT1)

securities and other regulatory adjustments. The Tier 1 capital ratio is

defined as Tier 1 capital divided by RWAs.

§ Total capital consists of Tier 1 capital plus Tier 2 subordinated liabilities,

after regulatory adjustments. The Total capital ratio is calculated as

Total capital divided by RWAs.

§ ING’s CET1 target ratio is built on the CET1 requirements specified for

ING, potential increase in the regulatory requirements, the potential

impact of a standardised and predetermined stress scenario and

available mitigating actions, and general uncertainties in its baseline

planning.

§ Leverage ratio (LR) is defined as Tier 1 capital divided by the leverage

exposure.

§ Minimum Required Eligible Liabilities (MREL)/Total Loss Absorbing

Capacity (TLAC) is Total capital plus senior unsecured bonds and

amortisations. Related MREL and TLAC ratios are expressed relative to

both risk-weighted assets and leverage exposure.

Processes for managing capital

GT ensures adherence to ING’s solvency risk appetite statements by

capital planning and executing capital management transactions. The

ongoing assessment and monitoring of capital adequacy is embedded in

the capital planning process as part of the internal capital adequacy

assessment process (ICAAP) framework. As part of the dynamic business

planning process, ING prepares a capital and funding plan on a regular

basis for all its material businesses, and continuously assesses the timing,

need and feasibility for capital management actions in scope of its

execution strategy. Sufficient financial flexibility should be preserved to

meet important financial objectives. Risk appetite statements are at the

foundation of the capital plan and are cascaded to the different businesses

in line with ING’s risk management framework. Contingency capital

measures and early warning indicators are in place – in conjunction with

ING’s contingency and recovery plan – to support the strategy in times of

stress.

Adverse planning and stress testing, which reflect the outcome of the

annual risk assessment, are integral components of ING’s risk and capital

management framework. It allows us to (i) identify and assess potential

vulnerabilities in ING’s business model, business portfolios or operating

environment; (ii) understand the sensitivities of the core assumptions used

in ING’s strategic and capital plan; and (iii) improve decision-making and

business steering through balancing risk and return following a forward-

looking and prudent management approach.


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	43

Capital position as per 31 December 2025


ING Bank capital position according to CRR III / CRD V
in EUR million	2025	2024
Shareholders’ 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.

Capital developments

ING Bank’s capital ratios increased compared with 2024, primarily driven

by higher available CET1 capital resulting from net profit. As of 1 January

2025, ING Bank’s CET1 requirement rose due to the introduction of the

Other Systemically Important Institution (O‑SII) buffer and the Pillar 2

requirement at Bank level. Consequently, ING Bank did not pay dividends

to ING Group during the first half of the year, increasing the available CET1

capital at ING Bank level. In the second half of 2025, ING Bank paid €1,129

million to ING Group. Risk-weighted assets were mainly impacted by

higher volume, currency movements, improvement in book quality and

model impacts.

ING Bank N.V. reported a CET1 ratio of 13.1% as at 31 December 2025

(2024: 12.1%), compared with an overall CET1 requirement of 11.03%. The

Bank’s Tier 1 ratio increased to 15.3% (2024: 14.5%) and its Total Capital

ratio rose to 18.4% (2024: 17.5%), both mainly driven by the increase in

available CET1 capital.

Risk transfer

ING employs securitisation initiatives as part of its capital management

strategy to achieve effective risk transfer, optimise RWAs, and support

efficient capital allocation. These transactions, which may include

securitisations but also credit insurance, credit derivatives and guarantees,

are executed in accordance with applicable EU regulatory requirements.

ING ensures that securitisation activities meet prudential standards,

maintain the continued effectiveness of risk transfer, and are supported by

a sound economic rationale. In November 2025, ING successfully executed

two significant risk transfer transactions, aligned with these objectives.

Capital velocity initiatives are embedded in ING’s capital planning

processes and are consistent with the Group’s risk appetite and capital

targets.

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‑weighted 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.

Ratings

ING’s credit ratings and outlook are shown in the table below. Each of

these ratings only reflects the view of the applicable rating agency at the

time the rating was issued. Any explanation of the significance of a rating

may only be obtained from the rating agency. Scope has been added as

fourth rating agency in 2025, with comparable credit ratings.


Main credit ratings of ING at 31 December 2025
	S&P	Moody’s	Fitch	Scope
ING Bank N.V.
Issuer rating
Long-term	A+	A1	AA-	AA-
Short-term	A-1	P-1	F1+	S-1+
Outlook	Stable	Stable	Stable	Stable
Senior unsecured rating	A+	A1	AA-	AA-

A security rating is not a recommendation to buy, sell or hold securities.

Each rating should be evaluated independently of other ratings. There is

no assurance that any credit rating will remain in effect for any given

period of time, or that it will not be lowered, suspended, or withdrawn

entirely by the rating agency if, in the rating agency’s judgement,

circumstances so warrant. ING accepts no responsibility for the accuracy

or reliability of the ratings.

Risk management

Risk

management


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	45

Risk management

As a global financial institution with a strong

European base, offering banking services, ING is

exposed to a variety of risks. We manage these

through a comprehensive risk management

framework that integrates risk management into

strategic planning and daily business activities.

This aims to safeguard ING’s financial strength and

reputation by promoting the identification,

measurement and management of risks at all

levels of the organisation. Taking measured risks

aligned with our risk appetite is core to ING’s

business.

This section sets out how ING manages its risks on a day-to-day basis.

It explains how the risk management function is embedded within the

organisation based on the ‘three-lines-of-defence’ (3 LoD) model. It

describes the key risks that arise from ING’s business model and how

these are managed. The section provides qualitative and quantitative risk

disclosures on solvency, credit, market, funding and liquidity, ESG

(environmental, social, and governance), operational, information

technology (IT), compliance, model, and business and strategy risks.



	Basis of disclosures () The risk management section contains information relating to the nature and extent of the risks of financial instruments as required by International Financial Reporting Standards (IFRS) 7 ‘Financial Instruments: Disclosures’. These disclosures are an integral part of the ING 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 ‘Additional Pillar III Report’, which can be found on our corporate website ing.com.

Top and emerging risks

The risks listed below are defined as the top existing and emerging risks

that could cause ING’s results to differ, in some instances materially, from

those anticipated. They may have a material impact on the reputation of

the company, introducing volatility in future operating results. These risks

can also impact ING’s medium- and long-term strategy, affecting its ability

to pay dividends, maintain appropriate levels of capital, or meet liquidity

and funding targets. An emerging risk is defined as a new or future risk

that might impact ING. Therefore, these risks require proactive

identification and monitoring as their impact on the organisation is more

difficult to assess compared to other risks. The key existing and emerging

risks are identified through the annual risk identification and risk

assessment process, covering both the ING Group and local entity

perspectives. Top risks are determined through an annual risk assessment

that evaluates the likelihood and potential impact of the risks, while

emerging risks are identified using horizon scanning and expert

judgement. The annual risk assessment is executed through risk surveys

and scenario analysis, with validation by senior management committees.

ING ensures that identified key risks feed into, among others, the annual

review of the Risk Appetite Framework (RAF) and Stress Testing

Framework. A number of key risks are listed below, with their sequence not

indicative of their likelihood or potential impact on ING.

Geopolitical risk

Geopolitical risk remains a key focus area for ING, requiring continuous

monitoring. In 2025, persistent policy uncertainty, intensifying trade

frictions, geo-economic confrontation and sanctions-related and supply-

chain restrictions shape the global landscape. These developments have

made cross-border trade and logistics increasingly challenging, driving up

costs and creating operational bottlenecks for global businesses. The

resulting uncertainty spills over into financial markets, heightening

volatility as investors react to tariff announcements and fluctuating risk

premium. These pressures translate into slower global growth and uneven

disinflation, with fragmented trade flows and elevated input costs

affecting productivity and monetary policy transmission. This could impact

ING beyond headline volatility, potentially leading to deteriorating credit

quality in exposed sectors, increased refinancing risk, and potential ratings

migration among ING clients. In addition, geopolitical events could trigger

the materialization of non-financial risks, for example the unavailability of

services provided by third-parties and increase of regulatory diversion.

Global trade and policy volatility

Global trade tensions intensified, reshaping economic relationships and

market dynamics. Trade relations between major economies deteriorated

as the US adopted protectionist measures through higher trade tariffs,

while the EU targeted Chinese industrial goods, including electric vehicles.

Transatlantic disputes over technology controls, digital taxation, and

green-trade measures escalated, prompting retaliatory actions from China

and the EU. Allegations of dumping and subsidy disputes added pressure

in the markets, contributing to episodic equity sell-offs, wider credit

spreads, and pressure on supply chain-linked commodities. For ING, this


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	46

backdrop could lead to reduced client cash flows, variability in collateral

quality, and changes in market risk and funding dynamics.

Europe

Fragmented policymaking and structural fiscal pressures, such as ageing

populations and higher defence spending, added complexity to the

European landscape. Due to the persistence of a higher-for-longer rate

environment, fiscal rules and national adjustment plans were closely

monitored. The challenges in implementing reforms were particularly

visible in France, as shown by its parliamentary deadlock and budget

disputes. These developments resulted in wider sovereign spreads and

tighter credit conditions. This backdrop affects ING through pressure on

corporate and household lending, changes in fixed-income pricing, and

higher costs for euro funding.

United States

US policy in 2025 featured efforts to advance a comprehensive omnibus

policy package ('One Big Beautiful Bill') combining tax reforms, industrial

policy, and border measures. The subsequent focus on reshoring and

strategic support reinforced tariff use as a negotiation tool. While

discussions on de-dollarisation gained momentum, the US dollar remained

dominant in global funding. Potential effects for ING include sector-specific

credit risk, variability in global funding costs, and changes in USD liquidity,

influencing both client exposures and wholesale funding markets.

Asia-Pacific

Security tensions persisted across key maritime and airspace zones due to

Chinese military activity near Taiwan and the Philippines. In South Asia,

renewed skirmishes and diplomatic strains between India and Pakistan

added to instability. These conditions may dampen regional investment

sentiment and equity markets, affecting ING through weaker trade finance

flows, increased counterparty risk, and potential stress on clients with

Asia-focused supply chains.

Ukraine

The war in Ukraine remained a central driver of European geopolitical risk.

Military activity continued without decisive shifts, while cross-border

strikes and attacks on energy infrastructure escalated concerns. Sanctions

tightened throughout the year, and debates over using frozen Russian

assets for Ukraine’s reconstruction raised legal and financial stability

questions. This environment heightens volatility in energy-sensitive

sectors, exposing ING to heightened credit risk across Eastern European

portfolios and increasing compliance costs linked to sanctions screening.

For more information on sanctions, see 'Compliance risk’.

Our credit exposure remained stable at €547 million (2024: €550 million),

mainly with Central Bank liquidity facilities and other lending. A significant

part is guaranteed by international parents or benefits from strong

collateral.

Exposure in Russia

In March 2022, we announced a decision to no longer do new business

with Russian counterparties. Nevertheless, ING’s remaining operations in

Russia and with Russian counterparties are subject to various risks,

including, but not limited to, credit risk, changes in laws and regulations –

including sanctions and counter sanctions – as well as conflicts of law,

potential litigations, and events that would trigger loss of control.

In December 2025, ING’s remaining credit exposures to Russian

counterparties, booked outside of Russia, was €0.6 billion (2024: €1.0

billion).

On 28 January 2025, ING announced the proposed sale of ING Bank

(Eurasia) JSC to Global Development JSC. Completion of the transaction is

subject to various regulatory approvals. This transaction will effectively

end ING’s activities in the Russian market. Under the terms of the

agreement, Global Development will acquire all shares of ING Bank

(Eurasia) JSC, taking over all Russian onshore activities and staff. Global

Development intends to continue to serve customers in Russia under a

new brand. As of the date of this report and as announced in September

2025, the buyer has not received all necessary approvals yet. We continue

working towards completing the transaction and our exit from the Russian

market. In the meantime, we are in discussion with regulators on the

conflicting regulatory requirements in various jurisdictions with respect to

the activities of ING Bank (Eurasia) JSC.

ING expects a negative P&L impact of around €0.8 billion post tax. This

includes an estimated book loss of around €0.5 billion, representing the

difference between the sale price and the book value of the business. It

also includes an estimated negative impact of around €0.3 billion from

recycling the currency translation adjustment through P&L, which is

capital neutral. The sale is expected to have a negligible impact on ING’s

CET1 ratio.

Starting from 2024 a trend emerged whereby Russian parties hold

Western banks liable in Russian courts. The Russian parties claim that such

banks, by complying with sanctions imposed by the EU, US and other

authorities, have caused damage to the Russian party. There have also

been instances where Russian courts ruled in favour of the Russian party.

In these cases, Russian courts did not recognise such sanctions, did not

respect the choice of law and courts pursuant to the applicable contracts,

and held Russian subsidiaries of Western banks liable for acts by other

entities in that banking group. For more information on litigation involving

ING, see Note 40 ‘Legal proceedings’.

Middle East

The Israel-Gaza conflict moved through fragile ceasefire phases,

repeatedly disrupted by renewed hostilities. International mediation

efforts have focused on providing humanitarian relief to alleviate civilian

suffering and to reduce the risk of regional escalation. In the Red Sea,

maritime security incidents increased the risks of wider escalation, while

concerns grew over a potential spillover involving Israeli strikes on Iran and

Qatar. These developments could destabilise energy and logistics markets,

leading to higher commodity price volatility and operational challenges in

key trading routes. For ING, this also affects valuation risks in client

portfolios and sovereign and corporate exposures in the area.

Interest rate risk

Diverging monetary policy paths among major central banks reintroduced

volatility in interest rate and foreign exchange markets. The European

Central Bank (ECB) shifted from easing policy rates to holding them steady

as euro-area disinflation continued. Meanwhile, the US Federal Reserve

adopted a gradual return towards neutral policy, implementing rate cuts

and suspending Treasury runoff amid persistent inflation pressures.


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Uneven disinflation and country-specific fiscal concerns kept interest rate

highly volatile. For ING, this environment affects funding costs, asset

valuations, and client behaviour, with knock-on effects on earnings

stability.

Cyber and Information Technology (IT) risk

Cybercrime remains an important risk. Threat actors are increasingly

sophisticated, leveraging emerging technologies such as generative AI to

develop advanced attack methods, including state-linked campaigns

targeting financial infrastructure. Regulatory requirements, including the

EU’s Digital Operational Resilience Act (DORA), reshaped expectations for

ICT risk management, incident reporting, and third-party oversight.

Operational resilience and business continuity have become central

themes, with regulators emphasising resilience testing, recovery

objectives, and contingency planning for critical service providers. The

growing complexity of IT ecosystems and reliance on cloud and third-party

vendors amplify these challenges, making resilience a systemic priority.

Disruptions in IT systems or third-party services can lead to service

outages, transaction delays, data breaches, and financial or reputational

losses for ING. IT resilience remains a priority for ING to ensure continuity

of services and protection of data. ING continues to strengthen its

measurement and reporting of IT and cyber risks while further developing

its ability to recover from large-scale ransomware events and maintain

recovery readiness for global, shared systems. These efforts are supported

by the Global Infrastructure organisation and the Chief Information

Security Office (CISO).

AI risk

AI adoption accelerated across 2025, moving from pilots to day-to-day use

in areas such as analytics, software development, and customer service.

This rapid rollout introduced risks related to data privacy and security,

model accuracy, bias, and accountability. The EU AI Act established clearer

obligations for high-risk systems; however, uneven global governance

continues to create compliance complexity and cybersecurity challenges.

These factors increase ING’s exposure to cyber incidents, misuse, and

compliance gaps, which can lead to operational and reputational impact.

As AI adoption grows, ING continues to strengthen its governance and risk

oversight through specialised structures such as the AI Risk Committee

and Centre of Excellence (CoE).

Environmental risk

Environmental risk remains an important concern for ING and the global

financial sector. This risk is increasingly shaped by the interplay of physical

climate impacts and accelerating transition pressures. Extreme weather

events and climate-related disruptions are now becoming systemic,

affecting infrastructure, supply chains, and asset valuations. The global

shift towards decarbonisation continues, but with uneven momentum:

regulatory mandates and technological advances are driving progress,

while political reality in regions such as the US and EU to ease climate

policies brings uncertainty. At the same time, increased polarisation and

politicisation of climate and broader ESG issues can produce conflicting or

rapidly changing policy signals, complicating transition pathways and

planning for financial institutions and clients. This divergence heightens

climate risk and amplifies political and macroeconomic volatility.

Biodiversity loss and resource scarcity further strain environmental

stability. These developments translate into heightened credit risk in

vulnerable sectors, market risk through valuation shifts, and operational

risks through supply chain disruptions and physical damage. Reputational

risk also intensifies as some stakeholders demand credible climate action

and others demand less.

For more details and mitigation actions, see ‘Environmental, social and

governance risk’ and ‘Credit risk’

Risk governance

Effective risk management requires company-wide risk governance. ING’s

risk and control structure is based on the ‘three-lines-of-defence’ model.

This model aims to provide a sound governance framework for risk

management by defining and implementing three lines. Each line has a

specific role and defined responsibilities, with the execution of tasks being

distinct from the control of these same tasks. The three lines work closely

together to identify, assess, mitigate, and monitor risks.

This governance framework is designed in such a way that risk is managed

in line with the risk appetite approved by the Management Board Banking

(MBB) and the Supervisory Board (SB), and this approach is cascaded

throughout ING.

Board-level risk oversight

Both the EB (for ING Group) and the MBB (for ING Bank) play an important

role in managing and monitoring our risk management framework. For

more information on the SB, MBB, and EB duties, and powers and

responsibilities in relation to risk management, see ‘Corporate

governance’.


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	48

Risk committees

In 2025, ING changed its risk-led MBB-key committees structure reporting

into the MBB. The key risk committees described below act within the

overall risk policy and delegated authorities granted by the MBB:

§ The Global Financial Risk Committee (GFRC) is the highest authority,

except for the MBB, to discuss and approve global policies,

methodologies, and procedures related to financial risk, covering

solvency, credit, market, funding & liquidity, and environmental, social

& governance risk. GFRC is a risk committee responsible for setting and

monitoring risk appetite statements & limits, stress testing and

financial risk frameworks & policies. The GFRC meets monthly.

§ The Model Risk Management Committee (MoRMC) is the owner of the

overall governance around models’ approval. MoRMC approves

frameworks, policies and procedures related to model risks. It sets

model risk strategies and monitors the model risk profile against the

RAS. The MoRMC meets monthly.

§ The Global Credit Committee – Transaction Approval (GCC(TA))

discusses and approves transactions that entail taking credit risk

(including investment risk), country, legal, and environmental and

social risk and approves Wholesale Banking transactions. The GCC(TA)

meets twice a week.

§ Group Non-Financial Risk Committee (Group NFRC) oversees the holding

company ING Group and all subsidiaries other than ING Bank N. V. It

opines on and approves non-financial risk matters. It ensures

appropriate action is taken by responsible management.

§ The Bank Non-Financial Risk Committee (Bank NFRC) is accountable for

the design and maintenance of the non-financial risk management

framework, including operational risk management, compliance and

legal policies, minimum standards, procedures and guidelines,

development of tools, methods, and key parameters (including major

changes) for risk identification, assessment, measurement, mitigating,

and monitoring/reporting. Bank NFRC meetings are held at least

monthly..

In addition, several other committees are involved in various steps in the different risk management frameworks, as illustrated in the graph below:

MBB

GFRC

Group Financial Risk Ct

MoRMC

Model Risk Management Ct

GCC-TA Global Credit Ct for

Transaction approvals

Group & Bank NFRC

Group & Bank Non-Financial Ct

CRC

Credit Risk Ct

CRMC

Credit Risk Model Ct

GUC

Global Underwriting Ct

IT BNFRC

CARC

Capital and ALM Risk Ct

AIRCO

AI Risk Ct

DREC

Distress Real Estate Ct

GPAC

Global Client Protection

and Approval Ct

TCRC

Trading and CP Risk Ct

ERC

ESG Risk Ct

²Although support functions are part of the first line of defence, they provide subject matter expertise to both the first and second lines of defence


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Three lines of defence 2

First line of defence

Second line of defence

Third line of defence

Who

Heads or their delegates of:

banking business, support functions¹,

geographies, countries

COO

CTO

Risk including Compliance

Internal audit function CAS

Responsible for

§ Running business with clients and

accountable for assessing, controlling,

mitigating, and reporting all risks affecting

their businesses, to ensure risks are within

risk appetite, i.e. 1st LoD risk management

activities

§ Completeness and accuracy of the financial

statements and risk reports with respect to

their areas of responsibility

Responsible for

§ Setting, operating, and

maintaining effective and

efficient processes and running

operations for the bank, and

managing risks arising from

these activities

Responsible for

§ Setting, operating, and

maintaining an effective and

efficient IT architecture and IT

services provision for the bank,

and managing risks arising

from these activities

Responsible for

§ Develops, owns, and maintains the risk taxonomy, including clear

and consistent risk categories and definitions, forming the basis for

consistent risk identification, measurement, reporting, and

escalation.

§ Defines and owns risk measurement methodologies, models, and

assessment frameworks used to quantify and assess risks,

including risk materiality assessment frameworks to determine

which risks are significant.

§ Designs, maintains, and monitors the Risk Appetite Framework

(RAF), ensuring that risk appetite statements, limits, and thresholds

are aligned with strategy, capital planning, and regulatory

expectations, and that breaches and emerging risks are escalated

in a timely and transparent manner.

§ Provides independent monitoring and reporting of risks to support

informed decision making and effective governance by senior

management and governing bodies.

§ Oversees, advises, and challenges the First Line of Defence on risk

management and compliance activities, providing subject matter

expertise while maintaining independence.

§ Exercises escalation and veto powers in relation to activities or

decisions assessed to present unacceptable risks, ensuring

escalation to the appropriate governance bodies when required.

Responsible for

§ Independent assurance to the MB, the

Audit Committee, and the SB on the quality

and effectiveness of ING's internal control,

risk management, governance, and

implemented systems and processes in

both the first and second lines of defence


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Regional and business unit level

ING’s regional and/or business unit management have primary

responsibility for the management of risks (credit, market, funding and

liquidity, operational, IT, compliance and model) that arise in their daily

operations. They are accountable for the implementation and execution of

appropriate risk frameworks affecting their businesses in compliance with

procedures and processes at the corporate level. Where necessary, the

implementation is adapted to local requirements.

Organisational structure

The CRO function is organised along the lines of a matrix structure

integrating (i) the Global Risk functions, (ii) the Regional/Country Risk

functions at entity level, and (iii) the Risk Segments. Global Risk functions,

organised by risk types into risk domains (departments), are ultimately

responsible and accountable for the functional steering of the respective

risk type globally. They ensure a uniform taxonomy and methodology are

used for the setting of the relevant risk appetite levels, further cascading

risk appetite into detailed risk strategies, and for the effective monitoring

and reporting of risks, on an individual and consolidated basis.

The Group Chief Risk Officer (CRO) and the Chief Compliance Officer (CCO)

each have direct access to the SB Risk Committee and its chair. Conversely,

the chair of the SB Risk Committee holds periodic bilateral consultations

individually with both the Group CRO and the CCO.

The current organisation chart outlines the reporting lines within the risk

management function. A refreshed chart will be introduced in 2026 to

align with the enhanced Risk Strategy designed to further strengthen and

future‑proof the Group Risk organisation. The proposed updates are guided

by four key principles: (i) reinforcing the Risk organisation by emphasising

its core activities, (ii) enhancing global functional steering, (iii) enabling

business strategies through expanded skills and capabilities, and (iv)

building a more effective, agile, and streamlined Risk organisation.

The departments in the purple colour reflect hierarchical reporting lines,

whereas the dotted lines are for the functional reporting lines:

The Group Chief Risk Officer

Credit Risk

Financial Risk

Non-Financial Risk

Model Risk

Integrated Risk

Risk Culture

& Behavioural Risk

Compliance Risk

Retail/

Rest of the World

Wholesale Banking

COO Risk

CRO Belgium

CRO

Netherlands

CRO Germany

Risk management framework

Risk policies and internal control documents

ING maintains a comprehensive system of risk management frameworks,

policies, mandatory instructions, procedures, and control standards

(collectively referred to as ‘internal control documents’), which establish

binding requirements for all ING locations. ING locations shall comply with

both internal control documents and local requirements. Internal control

documents are regularly reviewed, updated, and approved in accordance

with ING internal control binding principles. Senior management is

responsible for ensuring the implementation of, and staff adherence to,

internal control documents.

Internal risk management and control system

The enterprise risk management (ERM) framework and its related internal

control documents constitute the internal control framework in ING. The

ERM framework establishes an ING-wide governance model that aligns

strategy to risk appetite for all risk types. It applies to all business lines and

ING locations on the global and local level. The internal control framework

is based on the following principles:

§ Consistent Risk Governance at global and local level is defined

and adhered to using the three-lines-of-defence model and clear

decision-making.

§ Risk Appetite framework sets forward-looking risk limits and process to

ensure that risk-taking activities remain within acceptable ranges.

§ Risk Taxonomy sets a common risk language to identify and manage

all relevant risks.

§ Internal Control Documents facilitate effective risk management and

compliance with legal requirements and approved risk appetite.

§ Continuous Risk Management Cycle to identify, assess, mitigate,

monitor, and report risks supported by adequate Risk Data and Risk

Systems.

§ Strong risk culture and people that enable proactive risk management

balancing risk and reward.

The ERM Framework and underlying risk management frameworks are

based on the EBA Guidelines on Internal Governance (EBA/GL/2021/05,

2 July 2021) which is one of the drivers for the ING Governance Framework

and are aligned with the public criteria of the Committee of Sponsoring

Organisations of the Treadway Commission in Internal Reporting (COSO) –

Integrated Control Framework (2013 Framework).

Risk effectiveness

ING’s Internal Risk Management & Control (IRM&C) systems are designed

to safeguard risk effectiveness through:

§ Adequate and timely risk identification, assessment, measurement,

mitigation, monitoring, reporting, and follow up; and

§ Sufficient reliable insight that risks stay within risk appetite and can be

steered.


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Internal monitoring of risk effectiveness safeguards and confirms

adequate functioning of our IRM&C systems and enables ING to adapt

them in response to emerging risks, regulatory changes, or lessons

learned.

The effectiveness of risk management and internal control systems is

monitored through the risk management activities themselves (e.g. risk

monitoring and reporting) and through dedicated mechanisms (e.g. risk

framework monitoring and quality assurance).

Risk culture

At ING, we attach great importance to a sound risk culture, which is

essential for keeping the bank safe and secure. We determine our risk

culture as the way in which employees identify, understand, discuss, and

act on the many financial and non-financial risks we are confronted with

every day.

Learning

In 2025, we continued to expand and strengthen our required learning

curriculum. This foundational learning ensures all staff understand key

regulations, policies, and risks, supporting compliance and protecting the

bank and its customers. The curriculum is tracked centrally to support

timely completion. We continue to refine our learning formats to enhance

engagement and ensure practical application of knowledge. The topics

covered in 2025 were Conflicts of Interest, the Global Code of Conduct,

Operational Resilience, the EU AI Act, Cybersecurity, and Record Retention.

In addition, we continue to expand our learning offering on a range of risk

topics for targeted audiences across the bank, including risk staff. Working

with risk experts, the Risk Academy created and curated role-based

learning for risk colleagues, providing a wide selection of learning to

support both immediate job performance and long-term professional

growth.

Dutch Banker’s Oath

In the Netherlands, all employees working for a bank are required to take

the Banker’s Oath. By taking the oath, employees declare that they will

work with integrity, diligence, and in accordance with the related Code of

conduct (gedragscode). ING requires employees to follow trainings before

taking the actual oath – to understand the content and stress the

importance of the oath, enable all employees in the Netherlands to discuss

any dilemmas they may face in their daily work, and how to carefully

balance the interests of all ING’s stakeholders therein. All employees who

have taken the oath are subject to the Dutch Disciplinary Law and

Regulations, executed by the ‘Stichting Tuchtrecht Banken’ (Foundation for

Disciplinary Law of the banking sector).

Remuneration

ING aims to align its remuneration policy with its risk profile and the

interests of all stakeholders. For more information on ING’s remuneration

approach and its relation to the risk taken, see the Capital Requirements

Regulation (CRR) remuneration disclosure published on ing.com.

Risk cycle process

ING identifies, measures, and manages risks through five recurrent phases

of the management cycle: risk identification, risk assessment, risk

mitigation, risk monitoring, and risk reporting. The risk cycle process is

embedded within dedicated risk domain frameworks, such as the Non-

Financial Risk Framework, Model Risk Framework, and ESG Risk Framework.

Each risk domain is responsible for ensuring its risk cycle process and

frameworks are operational and effective. Key components of the risk

cycle process are defined in the Enterprise Risk Management Framework

as follows:

Risk identification

Risk identification is performed periodically through a joint effort of the

business and the risk management functions, linked to ING’s common risk

language and ad hoc in case of material internal or external change.

Risk assessment

Risk assessment ensures that each identified risk is assessed (qualitatively

and quantitatively) in a structured and fact-based manner and classified

for importance based on impact and likelihood. This enables management

to decide which of the identified risks need mitigating (control) measures,

how strict or tolerant these measures should be, and to assign a Risk

Owner.

Risk mitigation

Risks mitigation refers to the process of dealing with (and controlling) risk

exposures through one or a combination of strategies: risk-level reduction

(e.g. controls), risk avoidance (e.g. stop activity), risk transfer (e.g.

insurance or securitisation), and/or risk acceptance.

Risk monitoring

Risk monitoring is a continuous process, performed at individual and

aggregate risk level. It involves tracking and reviewing risk exposures and

the effectiveness of risk management strategies, including the design and/

or operating effectiveness of mitigating (control) measures.

Risk reporting

Risk reporting provides senior and local management with comprehensive

and actionable risk information. It facilitates the measurement,

monitoring, and oversight of risk exposures against risk appetite and

tolerance.

The Enterprise risk Management Framework is reviewed regularly to

ensure it reflects regulatory developments, and incorporates changes

based on external and internal triggers.

Risk Appetite Framework

The Risk Appetite Framework (RAF) is one of the key elements of the ERM

framework. Its objective is to set an appropriate risk appetite at a

consolidated level across different risk categories and to allocate the risk

appetite throughout the organisation.


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Procedure

The RAF procedure explains the setup of the overarching global risk

appetite. Within the RAF, ING monitors a range of financial and non-

financial risk metrics to ensure that our risk profile is in line with our risk

appetite while executing our strategy. ING’s RAF, which is approved by the

SB, defines the desired risk profile that is to be integrated in the strategic

decision-making and financial planning process. It is designed to be able to

withstand market volatility and stress, while meeting regulatory

requirements. The framework, including underlying metrics and

assumptions, is reviewed at least annually so that it remains relevant. The

RAF combines various financial and non-financial risk appetite statements

(RAS) into a single, coordinated approach.

Process

The RAF and underlying limit allocation are reviewed on an annual basis, or

more frequently if necessary, based on their monthly review in the MBB

and quarterly review in the EB and the SB. It is therefore a top-down

process, which bases itself on the ambition of the bank in terms of its risk

profile, the regulatory environment, and the economic context. Limits that

require SB approval are called boundaries, and the underlying instruments

supporting the boundaries require EB and MBB approval.

Step 1. Identify and assess ING’s key risks

The outcome of the risk-identification and risk-assessment process is used

as the starting point for the review of the RAF. Within this step, the risks

ING faces when executing its strategy are identified in the context of the

current economic, political, social, regulatory, and technological

environment. The assessment identifies whether the potential impact is

material and if it is sufficiently controlled.

Step 2. Set risk appetite framework

Based on ING’s risk assessment and risk purpose, boundaries and

instruments for the overarching risk frameworks are set. Once the

overarching risk appetite statements have been set and approved by the

EB/MBB and subsequently by the SB, the statements are translated into

risk type-specific statements and lower-level risk metrics. These are set

and approved by senior risk committees, like the Global Financial Risk

Committee (GFRC), Model Risk Management Committee (MoRMC) and Bank

Non-Financial Risk Committee (NFRC). Cascading is done via several

detailed risk appetite statements defined for each risk type. Together,

these statements aim to ensure compliance with the overarching

solvency, (credit) concentration, and funding and liquidity RAS.

ING includes climate risk in its RAF by, among other things, introducing

climate risk as one of the dimensions to determine sector concentration as

part of the credit risk appetite statements. In the coming years, ING will

extend the inclusion of climate risk impact on other risk types, ensuring

that potential risks – such as transition and physical risks – are properly

reflected in the RAF.

Step 3. Cascade into statements per risk type and business unit

The bank-wide risk appetite is defined per risk type, which is further

cascaded into the organisation. Risk appetite statements are then

translated into dedicated underlying risk limits that are used for the day-

to-day monitoring and management of ING’s risks. The risk appetite

statements serve as input for the quarterly planning process as well as for

the establishment of key performance indicators and targets for senior

management. The next graph is an illustrative and non-exhaustive

overview of the RAF.

Step 4. Monitor and manage underlying risk limits

To verify that ING remains within the RAF, it reports the risk positions vis-à-

vis their limits on a regular basis to senior management committees. A

monthly report is submitted to the MBB reflecting the exposure of ING

against the risk appetite. An extended report is submitted quarterly to the

EB and the SB’s Risk Committee. Moreover, the financial plan is checked

every quarter for potential limit excess within a one-year horizon, where in

the Strategic Dialogue the MBB can take mitigating measures or make

adjustments to the dynamic plan.

Stress testing

Stress testing is an important risk-management tool that provides input

for strategic decisions and capital planning. The purpose of stress testing is

to assess the impact of severe but plausible stress scenarios on ING’s

capital and liquidity position. Stress tests provide complementary and

forward-looking insights into vulnerabilities the bank is exposed to, with

regards to adverse macroeconomic circumstances, stressed financial

markets, changes in the political and geopolitical climate, and idiosyncratic

events. The outcomes of these stress tests help management get insight

into risk the bank is exposed to as well as mitigating actions to offset the

potential impact.

Types of stress tests

Within ING, we perform different types of stress tests. The most

comprehensive type of stress tests are the firm-wide scenario analyses,

which involve setting scenario assumptions for all the relevant

macroeconomic and financial market variables in all countries relevant to

ING. These assumptions usually follow a qualitative narrative that provides

a background to the scenario. In addition to firm-wide scenario analyses,

ING executes scenario analyses for specific countries or portfolios.

Furthermore, sensitivity analyses are performed, which focus on stressing

one or more risk drivers – usually without an underlying scenario narrative.

Finally, ING performs reverse stress tests, which aim to determine

scenarios that could lead to a predefined severe adverse outcome.

Process

ING’s stress-testing process consists of several stages:

§ Risk identification and risk assessment: it identifies and assesses the

risks ING or the relevant entity is facing when executing its strategy,

based on the current and possible future economic, political,

regulatory, and technological environment. It provides a description of

the main risks and risk drivers related to the nature of ING’s business,

activities, and vulnerabilities.

§ Scenario definition and parameterisation: based on the outcome of the

previous step, a set of scenarios is determined with the relevant scope

and set of risk drivers for each scenario, as well as its severity, the key

assumptions, and input parameters. The output of this phase includes a

quantitative description of the stress scenarios to be analysed, the

relevant output metrics, and, when applicable, a narrative description.

§ Impact calculation and aggregation: based on the quantitative

description of the stress scenarios, the impact is determined for the

relevant scenario, scope, and horizon. The impact calculation and

aggregation can be part of a recurring process or part of a specific

process set-up for one-off stress tests.


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§ Scenario reporting: for each stress test, a report is prepared after each

calculation, which describes the results of the scenario and gives a

recap of the scenario with its main assumptions and parameters. The

stress-test report is sent to the relevant risk committees and/or senior

management. It is complemented, if needed, with advice for

management action based on the stress-testing results.

§ Scenario control and management assessment: depending on the

outcomes of the stress test and the likelihood of the scenario,

mitigating actions may be proposed. Mitigating actions may include,

but are not limited to, sales or transfers of assets and reductions

of risk limits.

Methodology

Detailed and comprehensive models are used to assess the impact of the

scenarios. In these models, statistical analysis is combined with expert

opinion to make sure the results adequately reflect the scenario

assumptions. The methodologies are granular and portfolio-specific, and

use different macroeconomic and market variables as input. The stress-

testing models are subject to review by Model Risk management and

underlying assessments are in line with financial and regulatory reporting

frameworks.

Framework Policy

and Procedures

ING Group Risk Appetitie Framework (RAF)

Integrated Risk

Boundaries /

Instruments

Boundaries and instruments for overarching and risk-type specific RAS

Integrated Risk, Financial Risk, Credit Risk, Non-Financial Risk

Solvency RAS

Integrated Risk

Funding & Liquidity

RAS

Financial Risk

Concentration RAS

Credit Risk

Credit RAS

Credit risk

Market RAS

Financial Risk

Non-Financial RAS

Non-Financial Risk

Business & Strategy

RAS

Integrated Risk

Compliance RAS

Compliance Risk

Model RAS

Model Risk

Local application

of RAF

Group Treasury

Limits & Qualitative Statements

Local entity / Business Line / Unit A

Limits & Qualitative Statements

Local entity / Business Line / Unit B

Limits & Qualitative Statements

Local entity / Business Line / Unit C

Limits & Qualitative Statements


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Solvency risk

Introduction

Solvency risk is the risk of lacking sufficient capital to fulfil business

objectives, regulatory requirements, or market expectations. An insolvent

bank is unable to pay its debts and will be forced into bankruptcy.

The level and quality of capital is crucial for the resilience of individual

banks. Banks are expected to assess the risks they face and, in a forward-

looking manner, ensure they identify and manage all material risks. They

must also make sure these risks are sufficiently covered by loss-absorbing

capital to provide continuity if unexpected risks materialise in times of

stress. Given the interdependencies with other financial and non-financial

risks, this balancing act of capital adequacy needs to be done within a

sound and integrated management approach. It must coherently link and

align all the moving parts of the bank with its long-term business strategy.

ICAAP framework

ING’s internal capital adequacy assessment process (ICAAP) framework

aims to ensure that capital levels remain adequate – both forward-looking

and under adverse conditions, in terms of covering material risks-to-

capital from both a normative and an economic (internal) perspective. The

assessment of ING’s capital adequacy takes into account its business

strategy and risk profile, market environment, and operating macro

environment. This implies that views of various stakeholders, such as

regulators, shareholders, investors, rating agencies, clients, and customers

play an important role.

The continued strength of ING’s capital position, the adequacy of the

financial position, and risk management effectiveness are essential to

achieving the strategy. ING’s capital and funding strategy determines the

underlying ICAAP elements, and thereby contributes to ING’s business

continuity from different perspectives.

Managing ING’s capital entails finding the right balance between supply

and demand, while considering market and macro circumstances. The

process of balancing these strategic goals is captured in the ICAAP

framework. It is enabled by six building blocks and underlying elements

facilitating the ICAAP. The following building blocks have been defined in

the ICAAP framework, which are applied for both the ‘normative’ and

‘economic’ perspective, as defined in the ECB guide to ICAAP:

§ Risk identification and assessment;

§ Risk appetite;

§ Solvency stress testing;

§ Planning and forecasting;

§ Capital management; and

§ Continuity .

Risk identification and assessment

ING’s capital management and solvency risk management starts with the

risk-identification and risk-assessment process, which is performed on an

annual basis. In addition to this annual process, ING also reassesses its

risks as part of its capital adequacy statement, a quarterly process to

assess ING’s capital adequacy.

Risk appetite

ING has solvency risk appetite statements in place for the following

metrics: CET1 ratio, total capital ratio, leverage ratio, total loss-absorbing

capacity (TLAC), and minimum requirement for own funds and eligible

liabilities (MREL) based on RWA/leverage ratio and economic capital

adequacy.

Solvency stress testing

Solvency stress testing allows ING to examine the effect of plausible but

severe stress scenarios on the solvency position. It also provides insight

into which entities or portfolios are vulnerable to certain types of risks or

scenarios. Solvency stress testing is an important tool in identifying,

assessing, measuring, and controlling risks to capital, providing a

complementary and forward-looking perspective to other solvency risk

management tools. For solvency stress testing, ING follows the same steps

described in the overall section on stress testing.

The outcomes of solvency stress test analyses are taken into account in

capital planning, but also for setting risk appetite statements and the

capital management buffer.

Planning and forecasting

The capital and funding plan is an integral part of the dynamic plan, ING’s

financial and business planning process. For more information, see section

‘Capital management’.

Capital management

Formulation of the CET1 target is a key element in solvency risk

management. The target ratio, based on the management buffer concept,

enables ING’s senior management to steer, benchmark, and assess the

bank’s current and future capital levels much more efficiently. The target

level clearly supports trust-building among ING’s key stakeholders (e.g.

regulators, investors, and customers).

The capital management buffer aims to protect the interests of key

stakeholders and plays an important role in the overall capital adequacy

governance. The rationale behind the buffer is that it provides an

additional cushion on top of the (local) regulatory minimum requirements

(e.g. supervisory review and evaluation process (SREP) requirements) to

withstand a certain level of stress and facilitate awareness and

preparedness to take management actions. ING reviews its capital

management buffer on a regular basis to determine its effectiveness and

robustness, updating it as appropriate. For more information, see section

‘Capital management’

Continuity

Risk events with high severity or significant deteriorations of economic and

market conditions beyond ING’s control could cause deviations from the

business and capital plans, which may result in a potential capital shortfall.

ING has established a continuity (safety) net of contingency and recovery

planning. This includes ongoing monitoring of relevant indicators to

maintain awareness and enable proactive action to ensure continuity. The

intervention measures, which can be activated when deemed necessary,

consist of predefined RWA reduction measures, as well as direct capital-

increasing measures. The escalation mechanisms are defined, governed,

and detailed in the contingency and recovery plans.


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Both plans aim to restore ING’s capital adequacy. Depending on the

severity of the situation, the contingency plan can be activated at this

warning phase, as well as trigger further mitigating action and the

formation of the contingency crisis teams. Further drops in capital levels

trigger the alert phase for recovery monitoring and/or the activation of the

recovery plan and corresponding crisis teams.

Assessing capital adequacy: Capital Adequacy Statement

The Capital Adequacy Statement is ING Group’s quarterly assessment of its

capital adequacy and considers different elements with respect to its

capital position. The degree to which ING’s capital position is considered

adequate depends on a variety of internal and external drivers:

§ Current supervisory requirements and (expected) requirements going

forward;

§ Current internal requirements and (expected) requirements going

forward (economic capital/view);

§ Coherence of the available capital with the (realisation of) strategic

plans; and

§ The ability to meet internal and external requirements in the case of

stressed events or should a risk materialise.

The Capital Adequacy Statement assesses the adequacy of ING’s capital

position in relation to the above-mentioned drivers and states the extent

to which the capital position consequently is considered as adequate. The

Capital Adequacy Statement document is prepared on a quarterly basis.

Additionally, each year the EB/MBB signs and provides a comprehensive

assessment of ING’s capital adequacy, supported by the ICAAP outcomes,

in the form of a capital adequacy statement.


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Credit risk

Introduction

Credit risk is the risk of loss from the default and/or credit rating

deterioration of clients. Credit risks arise in ING’s lending, financial markets,

and investment activities. The credit risk section provides information on

how ING measures, monitors, and manages credit risk, and gives an insight

into the portfolio from a credit risk perspective.


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’s investments in bonds, commercial paper, equities, securitisations, and other similar publicly traded securities. This can be viewed as the potential loss that ING may incur from holding a position in underlying securities whose issuer's credit quality deteriorates or defaults.	4	Financial assets at fair value through profit or loss
	5	Financial assets at fair value through other comprehensive income
	6	Debt securities
Money market risk: This arises when ING places short-term deposits with a counterparty in order to manage excess liquidity. In the event of a counterparty default, ING may lose the deposit placed.	2	Cash and balances with central banks
	3	Loans and advances to banks
	7	Loans and advances to customers
Pre-settlement risk: This arises when a client defaults on a transaction before settlement and ING must replace the contract by a trade with another counterparty at the then prevailing (possibly unfavourable) market price. This credit risk category is associated with derivatives transactions (exchange-traded derivatives, over-the-counter (OTC) derivatives and securities financing transactions).	4	Financial assets at fair value through profit or loss
	14	Financial liabilities at fair value through profit or loss
	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:

§ Country risk concentration : Country risk is the risk that arises due to

events in a specific country (or group of countries). To manage the

maximum country loss ING is willing to accept, boundaries are

approved by the SB. The estimated level is correlated to the risk rating

assigned to a given country. Actual country limits are set by means of

country instruments, which are monitored monthly and updated when

needed. For countries with elevated levels of geopolitical or severe

economic cycle risk, monitoring is performed on a more frequent basis,

with strict pipeline and exposure management.

§ Single name concentration (including secondary risk): ING has an

established credit concentration risk framework to identify, measure,

and monitor single name concentration, including secondary risk. The

same concept of boundaries and instruments is applicable.

§ Sector and product concentration risk are managed via the credit risk

appetite framework.


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Credit risk models (*)

Within ING, internal CRR-compliant models are used to determine

probability of default (PD), exposure at default (EAD), and loss given

default (LGD) for regulatory and economic capital purposes. These models

also form the basis of ING’s IFRS 9 loan loss provisioning (see ‘IFRS 9

models’ below).

There are two main types of PD, EAD and LGD models used throughout the

bank:

§ Statistical models are created where a large set of default or detailed

loss data is available. They are characterised by sufficient data points

to facilitate meaningful statistical estimation of the model parameters.

The model parameters are estimated with statistical techniques based

on the data set available.

§ Hybrid models are statistical models supplemented with knowledge

and experience of experts from risk management and front-office staff,

literature from rating agencies, supervisors and academics. These

models are only used for ‘(ultra) low default portfolios’, where limited

historical defaults exist.

Credit risk rating process (*)

The majority of risk ratings are based on a risk rating (PD) model that

complies with the minimum requirements detailed in CRR/CRD, ECB

Supervisory Rules and European Banking Authority (EBA) guidelines. This

concerns all borrower types and segments.

ING’s PD rating models are based on a 1-22 internal risk rating scale (1 =

best rating; 22 = worst rating) referred to as the ‘master scale’, which

roughly corresponds to the rating grades that are assigned by external

rating agencies, such as Standard & Poor’s, Moody’s and Fitch. For

example, an ING rating of 1 corresponds to an S&P/Fitch rating of AAA and

a Moody’s rating of Aaa; an ING rating of 2 corresponds to an S&P/Fitch

rating of AA+ and a Moody’s rating of Aa1, and so on.

The 22 internal risk rating grades are composed of the following

categories:

§ Investment grade (risk rating 1-10);

§ Non-investment grade (risk rating 11-17);

§ Performing Restructuring (risk rating 18-19); and

§ Non-performing (risk rating 20-22).

The first three categories (1-19) are risk ratings for performing loans.

Ratings are calculated in IT systems with internally developed models,

based on manually or automatically fed data, or for part of the non-

performing loans set by the global or regional credit restructuring

department. Under certain conditions, the outcome of a manually fed

model can be challenged through a rating appeal process. For

securitisation portfolios, the external ratings of the tranche in which ING

has invested are leading indicators.

Risk ratings assigned to clients are reviewed at least annually, with the

performance of the underlying models monitored regularly. Some of these

models are global in nature, such as those for large corporates,

commercial banks, insurance companies, central governments, funds,

fund managers, project finance, and leveraged companies. Other models

are more regional or country-specific: there are PD models for small and

medium enterprises (SMEs) in the Netherlands, Belgium and Poland, as

well as residential mortgage and consumer loan models in the various

retail markets.

Rating models for Retail clients are predominantly statistically driven and

automated, such that ratings can be updated on a monthly basis. Rating

models for large corporates, institutions and banks include both statistical

characteristics and expert input, with the ratings being manually updated

at least annually. More frequent reviews (e.g. quarterly) are performed

where considered necessary.

Credit risk tools and data standards

The acceptance, maintenance, measurement, management, and

reporting of credit risks at all levels of ING are executed through single,

common credit risk data standards using shared credit risk tools that

support standardised and transparent credit risk practices. ING has chosen

to develop and implement credit risk tools centrally with the philosophy of

using a single source of data in an integrated way.

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’s credit

exposure is mainly related to lending to individuals (also referred to as

consumer lending, all Retail) and businesses (referred to as business

lending, both in Retail and Wholesale), followed by investments in bonds

and securitised assets, and money market (Wholesale). Loans to

individuals are mainly mortgage loans secured by residential property.

Loans (including guarantees issued) to businesses are often collateralised,

but may be unsecured based on the internal analysis of the borrower’s

creditworthiness. Bonds in the investment portfolio are generally

unsecured, but predominantly consist of bonds issued by central

governments and EU and/or OECD-based financial institutions. Secured

bonds, such as mortgage-backed securities and asset-backed securities,

are secured by the underlying diversified pool of assets (commercial or

residential mortgages, car loans and/or other assets) held by the securities

issuer. For money market, exposure is mainly deposits to central banks.

The last major credit risk source involves pre-settlement exposures which

arise from trading activities, including derivatives, repurchase transactions

and securities lending/borrowing transactions. This is also commonly

referred to as counterparty credit risk.


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Overall portfolio (*)

During 2025, ING’s portfolio size increased by €41.1 billion (4.1%) to

€1,002.9 billion outstanding. Foreign exchange rate changes had a €22.0

billion negative impact on the portfolio size, mainly driven by the

depreciation of the US dollar which had an impact of €16.6 billion mainly

in Wholesale Banking. Following this, net growth in Wholesale Banking was

€4.4 billion. Retail Banking outstandings increased by €38.4 billion mainly

due to underlying growth in residential mortgages.

Rating distribution (*)

Overall, the rating class distribution remained stable in 2025. The share of

investment grade rating classes increased from 78.1% to 79.3%, while the

share of non-investment grade decreased from 19.9% to 18.7%.

Performing restructuring outstandings remained constant at 0.6% of the

total portfolio in 2025, whereas non-performing loans (calculated including

Investment and Pre-Settlement exposures) decreased from 1.4% to 1.3%.

With respect to the rating distribution within the business lines, in

Wholesale Banking, investment grade increased to 84.3% from 83.7%,

while non-investment grade exposures decreased to 13.9% from 14.6%

compared to 2024. Performing restructuring assets increased from 0.6% to

0.7% of total Wholesale Banking assets where non-performing loans for

Wholesale Banking decreased from 1.2% to 1.1%. .

For Retail Banking, investment grade increased to 75.4% from 73.3%, while

non-investment grade exposures decreased to 22.5% from 24.4% as

compared to 2024. Performing restructuring decreased to 0.6% from 0.7%

whereas NPL remained constant at 1.5% in 2025.

Industry (*)

The industry breakdown is presented in accordance with the NAICS

definition. The increase of €41.1 billion in total volume during 2025 was

mainly due to the increase in Private Individuals (€28.7 billion) and Central

Governments (€13.4 billion) which was partially offset by the decrease in

Central Banks (€21.9 billion). The share of Private Individuals increased

from 39.5% last year to 40.7%.

Portfolio analysis per business line (*)


Outstandings per line of business (*)^{1, 2, 3}
in EUR million		Wholesale Banking		Retail Banking		Corporate line		Total
Rating class		2025	2024	2025	2024	2025	2024	2025	2024
Investment grade	1 (AAA)	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
Performing Restructuring loans	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


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Outstandings per line of business (*) - continued^{1, 2, 3}
in EUR million		Wholesale Banking		Retail Banking		Corporate line		Total
Region		2025	2024	2025	2024	2025	2024	2025	2024
Europe	Netherlands	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’s internal credit risk measurement methodologies. Economic sectors (industry) below 2% are not shown separately but grouped in Other.

³Geographical areas are based on country of residence, except for private individuals for which the geographical areas are based on the primary country of risk.

Portfolio analysis per geographical area (*)

The portfolio analysis per geographical area re-emphasises the

international distribution of ING’s credit portfolio. The Netherlands

maintains the largest portfolio share in a single country with 21.5%

(2024: 21.9%) of the total amount, followed by Germany with 16.6%

(2024: 16.2%), and Belgium with 12.4% (2024: 12.7%).

In terms of region, the majority of the portfolio balance remained in

Europe with 80.1% (2024: 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 (€25.2 billion), Romania (€14.0 billion), Switzerland (€10.9 billion),

Türkiye (€9.7 billion), and Ireland (€5.2 billion).

The main contributors for the overall increase in outstanding are Germany

(€10.6 billion), Spain (€6.1 billion), Poland (€5.8 billion), and the

Netherlands (€4.8 billion).

Private Individuals remained the largest composition of portfolio balances

for the Netherlands at 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 (€13.8 billion), Belgium (€3.6 billion) and Asia (€3.1 billion).

In individual countries, the total share of investment grade/non-

investment grade remains substantial for the Netherlands at 98.5% (2024:

98.5%), Germany at 98.7% (2024:98.9%), and Belgium 96.8% (2024:

96.6%).

In Europe, the increase in investment grade outstandings was mainly

observed in Germany (€11.9 billion), Spain (€8.4 billion), Poland (€5.2

billion) and France (€3.0 billion).

The net decrease in non-investment grade outstandings was mainly

observed in Spain (€2.4 billion), America (€1.9 billion), and Germany

(€1.7 billion).


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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.


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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.


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Credit risk mitigation (*)

ING uses various techniques and instruments to mitigate the credit risk

associated with an exposure and to reduce the losses incurred subsequent

to a default by a customer. The most common terminology used in ING for

credit risk protection is ‘cover’. While a cover may be an important

mitigant of credit risk and an alternative source of repayment, generally it

is ING’s practice to lend on the basis of the customer’s creditworthiness

rather than relying on the value of the cover.

Cover forms (*)

Within ING, there are two distinct forms of covers. First, where the asset

has been pledged to ING as collateral or security, ING has the right to

liquidate it should the customer be unable to fulfil its financial obligation.

As such, the proceeds can be applied towards full or partial compensation

of the customer's outstanding exposure. This may be tangible (such as

cash, securities, receivables, inventory, plant and machinery, and

mortgages on real estate properties) or intangible (such as patents,

trademarks, contract rights, and licences). Second, where there is a third-

party obligation, indemnification or undertaking (either by contract and/or

by law), ING has the right to claim from that third party an amount if the

customer fails in its obligations. The most common examples are

guarantees, such as parent guarantees, export credit insurances, or third-

party pledged mortgages. Insurance or reinsurance covers, including

comprehensive private risk insurance (CPRI) may be recognised as

guarantees and effectively function in an equivalent manner. ING accepts

credit risk insurance companies and export credit agencies (ECAs) as cover

providers.

Cover valuation methodology (*)

General guidelines for cover valuation are established with the objective of

ensuring consistent application within ING. These also require that the

value of the cover is monitored on a regular basis. Covers are revalued

periodically and whenever there is reason to believe that the market is

subject to significant changes in conditions. The frequency of monitoring

and revaluation depends on the type of cover.

The valuation method also depends on the type of covers. For asset

collateral, the valuation sources can be the customer’s balance sheet (e.g.

inventory, machinery, and equipment), nominal value (e.g. cash and

receivables), market value (e.g. securities and commodities), independent

valuations (e.g. commercial real estate) and market indices (e.g. residential

real estate). For third-party obligations, the valuation is based on the value

that is attributed to the contract between ING and that third party.

Where collateral values are used in the calculation of Stage 3 individual

loan loss provisions, haircuts may be applied to the valuation in specific

circumstances to sufficiently include all relevant factors impacting future

cash flows. ING applies haircuts to the collateral values of real estate,

shipping and aviation assets that are used in the calculation of the loss-

given-default in recovery scenarios. The haircut reflects the risks of

adverse price developments between the moment of valuation of an asset

and the actual settlement/cash receipt.

Cover values (*)

This section provides insight into the types of cover and the extent to

which exposures benefit from collateral or guarantees. The disclosure

differentiates between risk categories (lending, investment, money market

and pre-settlement). The most relevant types of cover include mortgages

(market values), financial collateral (cash and securities), guarantees, and

other covers (mainly pledges). The scope of covers in this overview has

been revised due to CRR3 implementation to align with regulatory

reporting. This explains the decrease in the values of 'other covers', which

had only a limited effect on the fully covered part of the portfolio, as ING's

portfolio remains well collateralised. Collateral covering financial market

transactions is valued on a daily basis (margining), and is as such not

included in the following tables. To mitigate the credit risk arising from

financial markets transactions, the bank enters into legal agreements

governing the exchange of financial collateral (high-quality government

bonds and cash).

The cover values are presented for the total portfolio of ING, both the

performing and non-performing portfolio.


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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	—	—	1,506	—	99.6%	—%	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	—	—	1,115	95	99.3%	—%	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’s total

portfolio. Excluding the pre-settlement portfolio, 56.1% (2024: 55.9%) of

ING’s outstandings were fully collateralised in 2025. Since investments

traditionally do not require covers, the ‘no covers’ percentage in this

portfolio is over 99.6%.

Consumer lending portfolio (*)

The consumer lending portfolio accounts for 40.6% (2024: 39.4%) of ING’s

total outstanding, primarily consisting of residential mortgage loans and

consequently most collateral consists of mortgages. Mortgage values are

collected in an internal central database and in most cases external data is

used to index the market value.

A significant part of ING’s residential mortgage portfolio is in the

Netherlands (2025: 35.0%, 2024: 35.0%), Germany (2025: 27.0%,

2024: 27.3%), Belgium (including Luxembourg) (2025: 12.0%, 2024: 12.2%)

and Australia (2025: 10.9%, 2024: 10.6%).

Business lending portfolio (*)

Business lending accounts for 38.2% (2024: 38.3%) of ING’s total

outstanding. Business lending presented in this section does not include

pre-settlement, investment and money market exposures.


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Credit quality (*)

ING uses three distinct statuses to categorise the management of clients

with (perceived) deteriorating credit risk profiles. ING makes use of Early

Warning Indicators (EWIs) in daily credit risk management processes,

which relate to a change in (internal and/or external) circumstances or

outlook of the specific obligor, the sector or the portfolio. ING usually

classifies a client with a 'watch list' status (Business lending only) when

there are early warning indicators triggered that detect an increased risk

profile. Watch list status requires more than usual attention, increased

monitoring and quarterly reviews. Some clients with a watch list or EWI

status may develop into a performing restructuring status or a non-

performing status. When there is increasing doubt as to the performance

and collectability of the client’s contractual obligations, the loans are

managed by Global Credit Restructuring (GCR) or by restructuring units in

the various regions and business units. The statuses and links with rating

grades are illustrated in the table below.


Credit risk ratings
Internal Rating Grade	1-10	11-17	18-19	20-22
Category	Investment Grade	Non-investment Grade	Performing restructuring	Non-performing
Credit risk management	Regular incl EWI/ watch list	Regular incl EWI/ watch list	Credit restructuring	Credit restructuring
ECL Stage	1/2¹	1/2¹	2	3
¹Stage 2 in case one of the Stage 2 triggers is hit, where Watchlist files are always Stage 2


Credit quality outstandings (*)
in EUR million	2025	2024
Performing not past due	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


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Past due obligations (*)

Retail Banking measures its portfolio in terms of payment arrears and

determines on a monthly basis if there are any significant changes in the

level of arrears. This methodology applies to Private Individuals as well as

Business lending. An obligation is considered ‘past due’ if it is more than

one day late, subject to materiality thresholds in line with Definition of

Default Regulation. ING aims to help its customers as soon as they are past

due by reminding them of their payment obligations. In its contact with

customers, ING aims to solve the (potential) financial difficulties by offering

a range of measures (e.g. payment arrangements, restructuring). If the

issues cannot be resolved because the customer is unable or unwilling to

pay, for example, the contract is sent to the recovery unit. The facility is

downgraded to risk rating 20 (non-performing) when the facility or obligor

– depending on the level at which the non-performing status is applied – is

more than 90 days past due and to risk rating 21 or 22 in case of an exit

scenario.

The table below represents the breakdown of lending and investment

credit risk outstandings that are performing by age and geographic area.

The past due but performing consumer lending outstanding increased by

€93 million, due to the increase in 1-30 days (€90 million) and 31-60 days

(€3 million).

The largest single country increase was in Belgium (€42 million), followed

by the Netherlands (€22 million), mainly in the 1-30 days bucket.

The largest decrease was seen in Australia (€21 million).


Ageing analysis (past due but performing): Consumer lending portfolio by geographic area, outstandings (*)
in EUR million		2025				2024
Region		Past due for 1–30 days	Past due for 31–60 days	Past due for 61–90 days	Total	Past due for 1–30 days	Past due for 31–60 days	Past due for 61–90 days	Total
Europe	Netherlands	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


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Ageing analysis (past due but performing): Business lending portfolio by geographic area, outstandings (*)
in EUR million		2025				2024
Region		Past due for 1–30 days	Past due for 31–60 days	Past due for 61–90 days	Total	Past due for 1–30 days	Past due for 31–60 days	Past due for 61–90 days	Total
Europe	Netherlands	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 €1.1. billion. The decrease was mainly witnessed in the 1–30 days past

due bucket (€1.6 billion) and was offset by the increase in 31-60 days

(€0.5 billion) past due bucket, fully in the United Kingdom related to

overdue fees. The largest decreases were in Belgium (€0.7 billion) and

America (€0.6 billion), while the largest increase were in Australia (€0.2

billion), Germany (€0.2 billion), Poland (€0.2 billion), and the United

Kingdom (€0.2 billion).

Forbearance (*)

Forbearance occurs when a client is unable to meet their financial

commitments due to financial difficulties they are facing or are about to

face and ING grants them concessions. Forborne assets are assets for

which forbearance measures have been granted.

Forbearance may enable clients experiencing financial difficulties to

continue repaying their debt.

For business clients, ING mainly applies forbearance measures to support

clients with fundamentally sound business models that are experiencing

temporary difficulties. The aim is to maximise the client’s repayment

ability, thereby avoiding a default situation, and help the client to return to

a performing situation.

For ING Retail units, clear criteria have been established to determine

whether a client is eligible for the forbearance process. Specific approval

mandates are in place to approve the measures, as well as procedures to

manage, monitor, and report the forbearance activities.

ING reviews the performance of forborne exposures at least quarterly,

either on a case-by-case (Business) or portfolio (Retail) basis.

Both performing (risk ratings 1-19) and non-performing (risk ratings 20-22)

exposures are eligible for Forbearance measures. ING uses specific criteria

to move forborne exposures from non-performing to performing or to

remove the forbearance statuses that are consistent with the

corresponding European Banking Authority (EBA) standards. An exposure

is reported as forborne for a minimum of two years. An additional one-

year probation period is applied to forborne exposures that move from

non-performing back to performing.


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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⁾
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⁾
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 €644 million, mainly due to the increase of

€667 million in Retail Banking, which was offset by a €24 million decrease

in Wholesale Banking. The rise in Retail Banking forborne assets was

primarily driven by residential mortgages in the Netherlands, which

contributed €608 million. This increase was largely the result of the

implementation of an updated framework, under which more clients are

classified as forborne, while outflow is only allowed after a two-year

probation period.

In terms of forbearance type, the increase is mainly witnessed in

refinancing type (€487 million) driven by a few larger files in Wholesale

Banking.

Modification of financial assets (*)

The following table shows:

§ Financial assets that were modified during the year (i.e. qualified as

forborne) while they had a loss allowance measured at an amount

equal to lifetime ECL; and

§ Financial assets that were reclassified to Stage 1 during the period

while being modified before.


Financial assets modified (*)
in EUR million	2025	2024
Financial assets modified during the period
Amortised cost before modification	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


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Wholesale Banking (*)

Wholesale Banking forborne assets amounted to €5.9 billion (2024:

€5.9 billion), which represented 1.7% (2024: 1.9%) of the total Wholesale

Banking portfolio.

The net decrease in Wholesale Banking forborne assets was driven by a

€27 million reduction in non-performing forborne exposure and partially

offset by a €3 million rise in performing forborne exposures.

Wholesale Bankings' forborne assets show an increase in Telecom due to

refinancing, which was offset by a decrease in other sectors, such as real

estate, food, beverages & personal care, chemicals, health &

pharmaceuticals and natural resources. These five sectors accounted for

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
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
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.


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Retail Banking (*)

As of year end, Retail Banking forborne assets amounted to €7.6 billion

(2024: €6.9 billion), which represented 1.4% (2024: 1.3%) of the total Retail

Banking portfolio. Retail Banking performing forborne exposure increased

by €0.6 billion.


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
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
	Türkiye	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.


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Non-performing loans (*)

ING has aligned the regulatory concept of non-performing with that of the

definition of default. Hence, borrowers are classified as non-performing

when a default trigger occurs (non-exhaustive list):

§ ING believes the borrower is unlikely to pay. The borrower has

evidenced significant financial difficulty, to the extent that it will have a

negative impact on the future cash flows of the financial asset. The

following events could be seen as indicators of financial difficulty:

– The borrower (or third party) has started insolvency proceedings;

– A group company/co-borrower has NPL status;

– Indication of fraud (affecting the company’s ability to service its

debt);

– There is doubt as to the borrower’s ability to generate stable and

sufficient cash flows to service its debt;

– Restructuring of debt; and

– ING has granted concessions relating to the borrower’s financial

difficulty, the effect of which is a reduction in expected future cash

flows of the financial asset below current carrying amount.

§ The obligor has failed in the payment of principal, interest, or fees; the

total past due amount is above the materiality threshold, and this

remains the case for more than 90 consecutive days.

Furthermore, Wholesale Banking has an individual name approach, using

early warning indicators to signal possible future issues in debt service.

Also in Retail Banking early warning indicator frameworks have been

implemented.

The table below represents the breakdown of credit risk outstandings that

have been classified as non-performing by sector and business line.


Non-performing Loans: Outstandings by economic sector and business lines (*) ¹
in EUR million	Wholesale Banking		Retail Banking		Total
Industry	2025	2024	2025	2024	2025	2024
Private Individuals	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.


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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


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In 2025, the NPL portfolio decreased to €13.0 billion (2024: €13.3 billion),

mainly driven by the decrease of €0.6 billion in Wholesale Banking. The

decrease was offset by the increase in Retail Banking (€0.3 billion) in line

with strong portfolio growth, mainly in residential mortgages.

Total net decrease was mainly seen in sectors Utilities, Real Estate and

Food, Beverage & Personal Care while the largest increase was in Private

Individuals.

Loan loss provisioning (*)

ING recognises loss allowances based on the expected credit loss (ECL)

model of IFRS 9, which is designed to be forward-looking. The IFRS 9

impairment requirements are applicable to on-balance-sheet financial

assets measured at amortised cost or fair value through other

comprehensive income (FVOCI), such as loans, debt securities, and lease

receivables, as well as off-balance-sheet items such as undrawn loan

commitments and financial- and non-financial guarantees issued.

ING distinguishes between two types of calculation methods for credit loss

allowances:

§ Collective 12-month ECL (Stage 1) and collective lifetime ECL (Stage 2)

for portfolios of financial instruments, as well as collective lifetime ECL

for credit-impaired exposures (Stage 3) below €1 million; and

§ Individual lifetime ECL for credit-impaired (Stage 3) financial

instruments with exposures above €1 million.

IFRS 9 models (*)

ING’s IFRS 9 models leverage on the internal rating-based (IRB) models (PD,

LGD, EAD), which include certain required conservatism. To include IFRS 9

requirements, such regulatory conservatism is removed from the ECL

parameters (PD, LGD and EAD). The IFRS 9 models apply two other types of

adjustments to the IRB ECL parameters: (i) to the economic outlook and (ii)

for Stage 2 and Stage 3 assets only, to the lifetime horizon. The IFRS 9

model parameters are estimated based on statistical techniques and

supported by expert judgement.

ING has aligned the definition of default for regulatory purposes with the

definition of ‘credit-impaired’ financial assets under IFRS 9 (Stage 3). ING

has also aligned its definition of default between IFRS 9 and the regulatory

technical standards (RTS) and EBA guidelines.

Climate and environmental risks in IFRS 9 models (*)

Climate risk drivers (physical and transition risks) can reduce the ability of

businesses and households to fulfil their obligations due, under existing

lending contracts. These climate risks are partly reflected in IFRS9 ECL

through regular credit risk transmission channels such as the

macroeconomic forecast and relevant risk parameters.

On the other hand, future physical or transition risks from climate change

are not yet fully captured within the current ECL models. In our

assessment of physical risks, it is generally expected that these risks will

only become financially significant on the long-term horizon.

Consequently, for short- and medium-term loans, such risks are not

expected to lead to significant credit deterioration over the exposure’s

lifetime. For the long term, the probability and timing of physical risk

events remain highly uncertain. ING is however actively enhancing the

integration of physical and transition risks into collateral valuations,

ensuring that effects on property values are appropriately captured.

In case of risk events that have already occurred (e.g. floods, stranded

assets), the impact of such events is assessed in the calculation of Stage 3

individual provisions, collective SICR or management adjustments to ECL

models. For example, we consider whether affected assets have suffered

from a significant increase in credit risk (or are credit impaired) and

whether the ECL is appropriate.

Additionally, a management adjustment to ECL models for business

clients was introduced to specifically cover for medium- to long-term

transition risk on high greenhouse gas-emitting sectors. The management

adjustment reflects the risk of financial loss foreseen on the longer horizon

for lenders with higher transition risk in these high greenhouse gas-

emitting sectors as consequence of future carbon taxation.

ING is continuously improving on climate risk data, which will enable us to

further embed climate risks into the IFRS 9 ECL models. For more

information on ESG risk management, see ‘ESG risk’.


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Reconciliation gross carrying amount (IFRS 9 eligible) and statement of financial position
in EUR million	2025							2024
	Gross carrying amount	Loan loss provisions	Cash and on- demand bank positions	Reverse repurchase transactions	Cash collateral	Other	Statement of financial position	Gross carrying amount	Loan loss provisions	Cash and on- demand bank positions	Reverse repurchase transactions	Cash collateral	Other	Statement of financial position
Amounts held at central banks	53,671	-17	-1,297			532	52,889	71,280	-14	-1,550			637	70,353
Loans and advances to banks	8,445	-18	3,053	6,836	2,649	239	21,204	4,684	-22	3,195	10,777	2,362	773	21,769
Financial instruments FVOCI loans	3,244	-6				—	3,238	1,671	-7				-56	1,608
Financial instruments FVOCI debt securities	50,868	-15				-36	50,817	42,185	-12				46	42,219
Securities at amortised cost	54,366	-11				-487	53,867	50,701	-15				-413	50,273
Loans and advances to customers	721,514	-5,894		3,866	4,595	-2,302	721,779	679,488	-5,833		3,471	4,956	-1,783	680,299
Total on-balance (IFRS 9 eligible)	892,108	-5,961	1,756	10,702	7,244	-2,055	903,794	850,009	-5,902	1,645	14,248	7,318	-796	866,521
Guarantees and irrevocable facilities (IFRS 9 eligible)	243,207	-140						198,420	-146
Total gross carrying amount (IFRS 9 eligible)	1,135,315	-6,101						1,048,429	-6,048

This table presents the reconciliation between the statement of financial

position and the gross carrying amounts used for calculating the expected

credit losses. No expected credit loss is calculated for cash, on-demand

bank positions, reverse repurchase transactions, cash collateral received in

respect of derivatives, and other. Therefore, these amounts are not

included in the total gross carrying amount (IFRS 9 eligible). Other includes

hedge valuation adjustments, deferred acquisition costs on residential

mortgages, and a receivable which is offset against a liquidity facility.

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.


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Gross carrying amount per IFRS 9 stage and rating class (*)^{1,2, 3}
in EUR million		12-month ECL (Stage 1)				Lifetime ECL not credit impaired (Stage 2)				Lifetime ECL credit impaired (Stage 3)				Total
Rating class		Gross carrying amount		Provisions		Gross carrying amount		Provisions		Gross carrying amount		Provisions		Gross carrying amount		Provisions
		2025	2024	2025	2024	2025	2024	2025	2024	2025	2024	2025	2024	2025	2024	2025	2024
Investment grade	1 (AAA)	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
Performing Restructuring	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 (€200.2 billion; 2024: €156.0 billion) and other positions (2025: nil; 2024:€6 billion) not included in credit outstandings and non-IFRS 9 eligible assets (€68.2 billion; 2024: €75.0 billion) included in credit outstandings but not

in the gross carrying amounts.

²Stage 3 lifetime credit impaired provision includes € 29 million (2024: €21 million) on purchased or

originated credit impaired.

Changes in gross carrying amounts and loan loss provisions (*)

The table below provides a reconciliation by stage of the gross carrying

amount and allowances for loans and advances to banks and customers,

including loan commitments and financial guarantees. The transfers of

financial instruments represent the impact of stage transfers upon the

gross carrying/nominal amount and associated allowance for ECL. This

includes the net-remeasurement of ECL arising from stage transfers, for

example, moving from a 12-month (Stage 1) to a lifetime (Stage 2) ECL

measurement basis.

The net-remeasurement line represents the changes in provisions for

facilities that remain in the same stage.


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Please note the following comments with respect to the movements observed in the table below:

§ Stage 3 gross carrying amount decreased by €0.2 billion from €13.7

billion as at 31 December 2024 to €13.6 billion as at 31 December 2025,

mainly as a result of €3.5 billion net inflow into NPL (credit impaired) in

2025, which is offset by €2.3 billion derecognitions and repayments

and €1.5 billion write-offs and disposals. Following the decrease in

carrying amount, Stage 3 provisions slightly decreased by €33 million

Stage 2 gross carrying amounts decreased by €2.4 billion from €79.9

billion as at 31 December 2024 to €77.5 billion as at 31 December 2025,

largely driven by €15.7 billion net transfers from Stage 1 into Stage 2,

including the impact of changes in risk drivers (including updated

macro-economic forecasts), model redevelopments mainly for Wholesale

Banking models, and new Stage 2 overlays. This was offset by a decrease

of exposure by €18.0 billion due to derecognised financial assets (including

sales and repayments) and €1.2 billion exposure moving to Stage 3. Stage

2 provisions increased by €49 million to €1.2 billion as of 31 December

2025.


Changes in gross carrying amounts and loan loss provisions (*) ^{1, 2}
in EUR million	12-month ECL (Stage 1)		Lifetime ECL not credit impaired (Stage 2)		Lifetime ECL credit impaired (Stage 3)		Total		12-month ECL (Stage 1)		Lifetime ECL not credit impaired (Stage 2)		Lifetime ECL credit impaired (Stage 3)		Total
	Gross carrying amount	Provisions	Gross carrying amount	Provisions	Gross carrying amount	Provisions	Gross carrying amount	Provisions	Gross carrying amount	Provisions	Gross carrying amount	Provisions	Gross carrying amount	Provisions	Gross carrying amount	Provisions
	2025								2024
Opening balance	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 €29 million (2024:€21 million) on purchased or originated credit impaired.

²The addition to the loan provision (in the consolidated statement of profit or loss) amounts to €1,304 million (2024: €1,194 million) of which €1,301 million (2024: €1,170 million) related to IFRS 9 eligible financial assets, €-5 million (2024: €9 million) to IFRS eligible commitments and €8 million (2024: €15 million) to

modification gains and losses on restructured financial assets.


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Exposure per stage, coverage ratio and stage ratios ²
in EUR million	2025			2024
Balance sheet	Gross carrying amount	Loan loss provisions	Stage ratio	Gross carrying amount	Loan loss provisions	Stage Ratio
Loans and advances to banks (including central banks)	62,116	35		75,964	35
Stage 1	60,430	5	97%	74,631	4	98%
Stage 2	1,609	18	3%	1,258	15	2%
Stage 3	77	12	0.12%	75	16	%

Loans and advances to customers	721,513	5,894		679,488	5,833
Of which: Residential mortgages	374,780	822		348,432	814
Stage 1	341,281	49	91%	315,774	49	91%
Stage 2	30,181	288	8%	29,341	307	8%
Stage 3	3,318	485	1%	3,317	458	1%
Of which: Consumer lending (excl. Residential mortgages)	31,306	946		28,514	957
Stage 1	27,302	137	87%	24,134	112	85%
Stage 2	2,575	159	8%	3,090	191	11%
Stage 3	1,429	649	5%	1,290	654	5%
Of which: Loans to public authorities	29,089	21		23,930	17
Stage 1	28,568	8	98%	23,214	6	97%
Stage 2	298	3	1%	464	3	2%
Stage 3	222	11	1%	252	8	1%
Of which: Corporate lending	286,339	4,105		278,612	4,045
Stage 1	251,370	197	88%	237,305	196	85%
Stage 2	27,265	661	10%	33,427	575	12%
Stage 3	7,704	3,247	3%	7,880	3,274	3%

Other IFRS 9 eligible financial Instruments ¹	351,685	173		292,977	180
Stage 1	335,286	51	95%	279,951	43	96%
Stage 2	15,559	49	4%	12,308	39	4%
Stage 3	840	72	0.2%	718	98	0.2%

Total gross carrying amount (IFRS 9 eligible)	1,135,315	6,101		1,048,428	6,048

¹Includes off-balance sheet IFRS 9 eligible guarantees and irrevocable facilities. See Note 1 'Basis of preparation and material accounting policy information'.

²The exposure classification to residential mortgages, consumer lending, and corporate lending is

aligned to the regulatory definition.


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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’s reportable ECL numbers are

sensitive to the forward-looking macroeconomic forecasts used as model

inputs, the probability weights applied to each of the three scenarios, and

the criteria for identifying a significant increase in credit risk. As such,

these crucial components require consultation and management

judgement, and are subject to extensive governance.

Baseline scenario (*)

As a baseline for IFRS 9, ING has adopted a market-neutral view combining

consensus forecasts for economic variables (GDP, unemployment) with

market forwards (for interest rates, exchange rates, and oil prices). Input

from a leading third-party service provider is used to complement the

consensus with consistent projections for variables for which there are no

consensus estimates available (most notably house prices and – for some

countries – unemployment), to generate alternative scenarios, to convert

annual consensus information to a quarterly frequency, and to ensure

general consistency of the scenarios. As the baseline scenario is consistent

with the consensus view, it can be considered as free from any bias.

The relevance and selection of macroeconomic variables is defined by the

ECL models under credit risk model governance. The scenarios are

reviewed and challenged by a panels of ING experts.

Alternative scenarios and probability weights (*)

Two alternative scenarios are taken into account: an upside and a

downside scenario. The alternative scenarios have statistical

characteristics as they are based on the forecast deviations of the leading

third-party service provider.

To understand the baseline level of uncertainty around any forecast, the

leading third-party service provider keeps track of all its deviations (so-

called forecast errors) of the past 30 years. The distribution of forecast

errors for GDP, unemployment, house prices, and share prices is applied to

the baseline forecast creating a broad range of alternative outcomes. In

addition, to understand the balance of risks facing the economy in an

unbiased way, the leading third-party service provider runs a survey with

respondents from around the world and across a broad range of

industries. In this survey, respondents put forward their views of key risks.

Following the survey results, the distribution of forecast errors (that is

being used for determining the scenarios) may be skewed.

For the downside scenario, ING has chosen the 90th percentile of that

distribution because this corresponds with the way risk management

earnings-at-risk is defined within the Group. The upside scenario is

represented by the 10th percentile of the distribution. The applicable

percentiles of the distribution imply a 20 percent probability for each

alternative scenario. Consequently, the baseline scenario has a 60 percent

probability weighting. Please note that, given their technical nature, the

downside and upside scenarios are not based on an explicit specific

narrative and have not changed compared to previous year.

Macroeconomic scenarios applied (*)

The macroeconomic scenarios applied in the calculation of loan loss

provisions are based on the consensus forecasts.

Baseline assumptions (*)

The general picture that the consensus conveys is that global economic

growth is slowing compared to recent years. US growth is expected to

continue to outpace European markets, but the gap is narrowing down.

China is expected to continue a declining growth trend, but still at higher

rates than seen in advanced markets. Inflation is expected to remain near

target for most advanced economies, but a bit above for the United States.

With interest rates moderating, monetary conditions are turning more

favourable for growth. For the housing market, continued price growth is

expected for almost all main markets.

The December 2025 consensus expects global output (as measured by the

weighted average GDP growth rate of ING’s 25 main markets) to remain at

a constant 2.4% from 2025-2027.

The eurozone economy has shown more resilience than expected despite

global headwinds, with sluggish but positive growth through 2025. The

coming years are expected to see modest growth rates as well. The trade

environment continues to be plagued by higher US tariffs and a stronger

euro. Expectations of a pickup in growth over the course of 2026 come

from stronger consumer spending and investment. German infrastructure

spending is expected to add to this momentum. Southern European

economies continue to benefit from European Recovery Fund investments.

Consensus expects the eurozone to have grown by 1.4% in 2025, before

slowing to 1.1% in 2026 and then recovering to 1.3% in 2027.

Elsewhere in Europe, the growth outlook is stronger. Poland’s growth

momentum remains solid, growing faster than its European peers. The key

growth drivers over the near-term forecast are consumption and public

investments, such as those carried out under the National Recovery Plan

(KPO). The economy is expected to grow by 3.6% in 2025, picking up to

3.7% in 2026 and settling at 3.2% in 2027. The consensus expectation for

Türkiye 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


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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 €50 million for the Commercial Real

Estate portfolio, reported at 31 December 2024 due to prevailing risks in

this sector, is released in 2025 due to improved risk profile and partially

replaced with a management adjustment for a recent model update,

which corrects for the effects of the aforementioned risks on the model

outcome. As the model update has not been implemented in production

yet, a management adjustment of €10 million is reported under the Other

Post Model Adjustments category at 31 December 2025.

As at 31 December 2025, an economic sector / portfolio-based adjustment

is reported in the Mortgages portfolio in Australia (€9 million) to address

emerging risk from inflation, interest rate increases and overall cost of

living. The management adjustment reported at 31 December 2024 for the

increased credit risk in the Mortgages and Consumer Lending portfolios in

Spain – due to the effects of floods – has been released, as the remaining

affected performing customers are reported in Stage 2. Also the

adjustment taken in the Business Banking portfolio in Germany at 31

December 2024 to cover for the increased uncertainty in the German

economy has been released due to the agreed sale of the affected

portfolio.

As of 31 December 2025, the overall mortgage portfolio adjustment

amounts to €121 million (31 December 2024: €112 million) and fully

related to the management adjustment in Stage 2 for the risk

segmentation model that captures affordability, repayment, and

refinancing risk on performing mortgage customers with a bullet loan in

the Netherlands.

As of 31 December 2025, an adjustment of €47 million is in place to

address the impact of climate transition risk in Wholesale Banking (€31

million) and in Business Banking (€16 million). Climate transition risk is

expected to lead to a structural change in credit risk, which means specific

business activities will become structurally riskier due to environmental

policies, technological progress or changes in market sentiment and

preferences. The current IFRS 9 models do not capture this (novel) risk. The

management adjustment to ECL models for business clients was made to

specifically cover for the medium- to long-term transition risk on high

greenhouse gas-emitting sectors and is reported in Stage 2. The sectors

included in the overlay represent approximately 20% of the exposure

within Wholesale and Business Banking.


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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.


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Sensitivity analysis as at December 2025 (*)
		2026	2027	2028	Unweighted ECL (€ mln)	Probability- weighting	Reportable ECL (€ 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 (€ mln)	Probability- weighting	Reportable ECL (€ 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.


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When compared to the sensitivity analysis of 2024, the baseline

macroeconomic inputs have become slightly more positive overall,

underpinned by the resilience of the global economy in the face of trade

and geopolitical tensions. House price growth expectations are lower for

the Netherlands, given a rise in supply from the sale of rental properties

and slowdown of wage growth. In the US, a weak labour and housing

market both signal underlying economic challenges due to policy and

trade uncertainty, and persistent affordability issues. The upside and the

downside scenarios are not directly comparable with those of 2024 due to

an update in the basis of their derivation.

On a total ING level, the unweighted ECL for all collective provisioned

clients in the upside scenario was €2,938 million, in the baseline scenario

€3,232 million and in the downside scenario €3,993 million compared to

€3,326 million reportable model ECL as at 31 December 2025 (excluding all

management adjustments). To perform the sensitivity analysis, a point in

time reportable ECL is used as input, which slightly deviates from the total

reportable collective provisions as presented below:


Reconciliation of reportable collective ECL to total ECL (*)
in EUR million	2025	2024
Total reportable collective provisions	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.


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Quantitative SICR thresholds (*)
	2025		2024
Average threshold ratio	Investment grade (rating grade 1-10)	Non-investment grade (rating grade 11-17)	Investment grade (rating grade 1-10)	Non-investment grade (rating grade 11-17)
Asset class category
Mortgages	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’s methodology, the

threshold is tighter the higher the riskiness at origination of the assets,

illustrated by the difference between the average threshold applied to

investment grade facilities and non-investment grade facilities.

Sensitivity of ECL to PD lifetime PD thresholds

The setting of PD threshold bands requires management judgement and is

a key source of estimation uncertainty. On Group level, the total model

ECL on performing assets, which is the ECL collective assessment without

taking management adjustments into account, was €1,501 million as at

31 December 2025 (31 December 2024: €1,328 million). To demonstrate

the sensitivity of the ECL to these PD threshold bands, hypothetically

solely applying the upside scenario would result in total model ECL on

performing assets of €1,159 million and a decrease in the Stage 2 ratio by

0.3%-point, while solely applying the downside scenario would result in

total model ECL on performing assets of €2,193 million and an increase in

the Stage 2 ratio by 1.6%-point.

Qualitative SICR thresholds

It should be noted that the lifetime PD thresholds are not the only drivers

of stage allocation as ING Group also relies on a number of qualitative

indicators to identify and assess SICR. An asset can also change stages as

a result of other triggers, such as having over 30 days arrears (used as a

backstop), the occurrence of an early warning indicator, collective SICR

assessment, being on a watch list, being under intensive care

management, having a substandard internal rating, or being forborne.


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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’s earnings, capital, market value, or

liquidity position. Market risk either arises through positions in banking

books or trading books.

The banking book positions are intended to be held for the long term (or

until maturity) or for the purpose of hedging other banking book positions.

The trading book positions are typically held with the intention of short-

term trading or to hedge other positions in the trading book. Policies and

processes are in place to monitor the inclusion of positions in either the

trading or banking book as well as to monitor the transfer of risk between

the trading and banking books.

The following sections elaborate on the various elements of the risk

management framework for:

§ Market risk in banking books;

§ Market risk in trading books; and

§ Market risk capital.

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.



Commercial books			Treasury books

Retail Banking and Wholesale Banking positions	u	Internal contracts		u	Offsetting internal positions

					Treasury books


Capital investments

Desired maturity profile				u	Swap overlay
Desired maturity profile				u	Swap overlay

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’s

earnings, capital, and market value to adverse movements in interest

rates originated from positions in the banking book.

ING centralises interest rate risk management from commercial books

(that capture the products sold to clients) to globally managed interest

rate risk books. This enables a clear demarcation between commercial

business results and results based on unhedged interest rate positions.

ING distinguishes between three types of activities that generate interest

rate risk in the banking book:

§ Investment of own funds;

§ Commercial business; and

§ Group Treasury exposures, including strategic interest rate positions.

Group Treasury is responsible for managing the investment of own funds

(core capital). Capital is invested for longer periods to contribute to stable

earnings within the risk appetite boundaries set by ALCO Bank.

Commercial activities can result in linear interest rate risk due to different

re-pricing properties of assets and liabilities. Also, interest rate risk can

arise from customer behaviour and/or convexity risk, depending on the

nature of the underlying product characteristics.

To determine interest rate risk in specific products (such as savings or

mortgages) certain assumptions may need to be applied. Customer

behaviour risk is defined as the potential future loss (value) arising from

deviations between actual client behaviour and the modelled behaviour

regarding embedded options within commercial products. General sources

of customer behaviour risk include, among other things, the state of the

economy, competition, changes in regulation, legislation and tax regime,

developments in the housing market, and interest rate developments.

From an interest rate risk perspective, commercial activities can typically

be divided into the following main product types: savings and current

accounts (funds entrusted), demand deposits, mortgages, and loans.

Savings and demand deposits are generally invested in such a way that

both the value is hedged and the sensitivity of the margin to market

interest rates is minimised. This is achieved by creating the investment

profile distributed from short term to long term, which dampens the

immediate impact from changes in the market rates and stabilises margin

in the longer horizon. Interest rate risk is modelled based on the stability of

deposits and the pass-through rate. This takes account of different

elements, such as pricing strategies, volume developments, and the level

and shape of the yield curve.

In determining the interest rate profile of mortgages, prepayment or other

embedded optionality can be an important risk driver. In modelling this

risk, both interest-rate-dependent prepayments and constant

prepayments are considered. Next to a dependence on interest rates,

modelled prepayments may include other effects such as loan-to-value,


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seasonality, and the reset date of the loan. In addition, the interest

sensitivity of embedded offered rate options is typically considered.

Wholesale Banking loans typically do not experience interest-rate-

dependent prepayment behaviour, as these are mostly floating rate

products. These portfolios are match-funded, taking the constant

prepayment model into account, and typically do not contain significant

convexity risk. Wholesale Banking loans can have an all-in rate floor or a

floor on a reference rate.

Customer behaviour in relation to mortgages, loans, savings, and demand

deposits is modelled based on extensive analysis of historical data.

However, the substantial fluctuations in the interest rate environment in

recent years make the analysis more challenging than before and may

increase model risk. Models are backtested and updated when deemed

necessary, at least annually. Model parameters and the resulting risk

measures are approved by (local) ALCO, and are closely monitored on a

monthly basis.

Linear risk transfers take place from commercial business books to the

treasury book (Group Treasury), if necessary, by using estimations of

customer behaviour. The originating commercial business is ultimately

responsible for estimating this customer behaviour, leaving convexity risk

and (unexpected) customer behaviour risk with the commercial business.

Risk measurement and the risk transfer process take place at least

monthly. If deemed necessary, additional risk transfers can take place.

The commercial business manages the convexity risk that is the result of

products that contain embedded options, like mortgages. Here the

convexity risk is defined as the optionality effects in the value due to

interest rate changes, excluding the first-order effects. In some cases,

convexity risk is hedged by treasury using cap/floor contracts and

swaptions.

NII at Risk (*)

The NII-at-Risk measures the impact of changing interest rates on the

forecasted net interest income (before tax) of the banking book, excluding

the impacts of credit spread sensitivity, fees, and fair value impact. Future

projected balance sheet developments (dynamic plan) are included in this

risk metric. NII-at-Risk provides insight into the sensitivity of ING’s NII under

shocked interest rate scenarios against what is projected in a base case

scenario.

In its risk management, ING monitors the NII-at-Risk under a three-year

time frame. Interest rates are shocked during the first year of analysis

through the gradual application of shock. The rate changes considered

encompass both upward and downward scenarios, as well as both parallel

(equal movements across the yield curve) and non-parallel scenarios.

The impact of changing interest rates on ING’s NII is predominantly caused

by the following factors:

§ Change in returns of (re)investments of client deposits;

§ Change in client deposit rates (mainly savings), (partially) tracking

changes in market interest rates;

§ Change in the amortisation profile of mortgages, due to an increase or

decrease in expected prepayments;

§ Higher/lower returns of (re-)investments of core capital investment;

§ Open interest rate positions, leading to changes in return because of

different market rates; and

§ Assumed volume development of the balance sheet in line with ING’s

dynamic plan.

For projecting the change in client deposit rates, ING uses a client rate

model that describes the relation between market interest rates and client

deposit rates. The model is calibrated under a range of interest rate

scenarios. Per scenario, the actual change in client deposit rates may

deviate from this calibrated model. The actual NII development of

customer deposits may, indeed, differ from the provided scenarios,

depending on, among other things, actual interest rate and savings client

rate evolution, as well as changes to ING’s balance sheet composition,

such as net deposit growth and relative share of savings deposits and non-

remunerated current accounts.

The NII-at-Risk figures in the table below represent a parallel, linear

interest rate shift over one year (‘ramped’) based on the assumption that

balance sheet developments follow ING’s dynamic plan within a one-year

horizon.

The NII-at-Risk is mainly influenced by the difference in the sensitivity

between client liabilities and client assets and investments to rate

changes. The primary factor of NII-at-Risk are the investments of current

accounts, while the investments of own funds have a marginal effect, as

only a relatively small portion needs to be (re)invested within a one-year

period.


NII-at-Risk banking book per currency - year one (*)
in EUR million	2025		2024
	Ramped, floored		Ramped, floored
	parallel ▼	parallel ▲	parallel ▼	parallel ▲
By currency
Euro	-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


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subsequently hedged in financial markets, resulting in overall limited

sensitivity of NII at Risk (NIIaR) compared to ING’s total net interest

income. Year-on-year NIIaR increase by €100 million under a parallel down

(worst case) scenario, is primarily driven by revised repricing assumptions

and positions taken by treasury.

Net present value (NPV) at Risk (*)

NPV-at-Risk measures the impact of changing interest rates on the value

of the positions in the banking book and it is defined as the outcome of an

instantaneous increase or decrease in interest rates from applying

currency-specific scenarios. The metric primarily reflects the impact of

interest rate fluctuations on the bank’s strategic interest rate positions

(e.g. investments of own funds), as well as on the savings and mortgage

portfolios. While strategic positions typically adjust proportionally with

changing rates, the savings and mortgage products exhibit more complex

behavior due to embedded optionalities. Customers can prepay or

reallocate their balances, resulting in non-linear value changes. As a result,

these portfolios may incur value losses both when interest rates increase

and decrease, contributing to the asymmetric NPV-at-Risk pattern

highlighted in the annual report.

The full value impact cannot be directly linked to the financial position or

profit or loss account, as fair value movements in banking books are not

necessarily reported through the profit or loss account or through other

comprehensive income (OCI). The changes in value are expected to

materialise over time in the profit and loss account if interest rates

develop according to forward rates throughout the remaining maturity of

the portfolio. The majority of the risk comes from the investments of own

funds and from positions exhibiting negative convexity due to embedded

optionality (most notably variable rate savings and fixed rate mortgages).

The metrics mentioned above are internal metrics, which therefore

deviate from the regulatory EVE SOT metric. Both internal and regulatory

measures are part of the bank’s risk appetite framework and are actively

managed.


NPV-at-Risk banking books per currency (*)
in EUR million	2025		2024
	floored		floored
	parallel ▼	parallel ▲	parallel ▼	parallel ▲
By currency
Euro	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 Śląski S.A.) with a

significant amount of Polish zloty-denominated assets and liabilities

including derivatives that are continuously rebalanced to hedge the risk

exposures.

The tables below summarise the approximate gross exposure of ING that

has yet to transition related to WIBOR, excluding exposures expiring before

the transition date of 31 December 2027.


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Non-derivative financial instruments to transition from WIBOR to POLSTR (*)
in EUR million	Financial assets non-derivative	Financial liabilities 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 ‘Basis of preparation and material accounting

policy information’ for information on the Phase 1 amendments to IFRS.

As at 31 December 2025, Phase 1 reliefs are applicable to WIBOR indexed

fair value and cash flow hedge accounting relationships as there is

uncertainty arising from the WIBOR reform with respect to the timing and

the amount of the underlying cash flows that the Group is exposed to.

Therefore, for WIBOR financial instruments designated in hedge

accounting the applicable Phase 1 reliefs will continue to apply until the

relevant contract is modified. At that point in time, the reliefs of Phase 2

amendments to IFRS will become applicable.

Following the Phase 1 reliefs that allow ING to continue applying hedge

accounting, ING has to assume that the WIBOR-based cash flows from the

hedging instrument and hedged item will remain unaffected for the

affected fair value and cash flow hedge relationships. In addition, for the

forecast transactions that are subject to cash flow hedge accounting,

under the Phase 1 reliefs ING has to assume that the WIBOR benchmark

on which the hedged cash flows are based is not altered as a result of the

reform and, therefore, the forecast transactions still meet the highly

probable requirement.

The total gross notional amounts of hedging instruments that are used in

ING’s hedge accounting relationships for which the Phase 1 amendments

to IAS 39 were applied are:


Notional amounts of hedging instruments from WIBOR to POLSTR (*)
	31 December 2025	31 December 2024
in EUR million	Nominal value	Nominal value
WIBOR	97,492	99,663

As at 31 December 2025, 50% (31 December 2024: 32%) of the notional

amounts have a maturity date beyond 31 December 2027. The notional

amounts of the derivative hedging instruments provide a close

approximation of the extent of the risk exposure ING manages through

these hedging relationships.

Credit spread risk in banking books (CSRBB) (*)

Credit spread risk is defined as risk driven by the changes of the market

price for credit risk, for liquidity and potentially other characteristics of

credit-risky instruments, which is not captured by another existing

prudential framework such as Interest Rate Risk in Banking Book or by

expected credit/(jump-to-) default risk. The CSRBB framework is

implemented based on EBA Guidelines. Metrics used are NPV-at-Risk, NII-

at-Risk and Market Value Changes-at Risk and view the positions across

different accounting treatments.

Credit spread risk is not part of the internal risk transfer towards Group

Treasury and therefore remains in the business unit it originated in. Group

Treasury itself is also an important driver of credit spread risk via its high-

quality liquid assets (HQLA) investment portfolio and issuance activities.

Risk appetite limits are set on a combination of metrics and accounting

scopes and are cascaded to local ALCOs depending on the type of limit

and materiality. Metrics and limits are monitored and reported monthly to

global and local risk committees, and various stakeholders.

Foreign exchange (FX) risk in banking books (*)

FX exposures in banking books result from core banking business activities

(business units doing business in currencies other than their base

currency), foreign currency investments in subsidiaries (including realised

net profit and loss), and strategic equity stakes in foreign currencies. The

policy regarding these exposures is briefly explained below.

Core banking business (*)

Every business unit hedges the FX risk resulting from core banking

business activities into its base currency to prevent volatility in profit and

loss. Consequently, assets and liabilities are matched in terms of currency,

within certain friction limits.

FX translation (*)

ING’s strategy is to protect the CET1 ratio against adverse impact from FX

rate fluctuations, while limiting the volatility in the profit and loss account

due to this CET1 hedging and limiting the RWA impact under the

regulatory framework. Currency exposure of Return on Equity is also

considered. Hedge accounting is applied to the largest extent possible.

Taking this into account, the CET1 ratio hedge can be achieved by

deliberately taking foreign currency positions equal to certain target

positions, such that the CET1 capital and risk-weighted assets are equally

sensitive in relative terms to changing FX rates.

Risk profile – FX translation (*)

The following table presents the currency exposures in the banking books

for the most important currencies for the FX translation result. Positive

figures indicate long positions in the respective currency. As a result of the

strategy to hedge the CET1 ratio, an open structural FX exposure exists.

To measure the volatility of the CET1 ratio from FX rate fluctuations,

different metrics are used, including the CET1 Ratio-at-Risk. The impact is

controlled via the Solvency and Financial Risk RAS.


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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.

EBA Structural FX guidelines

In line with the EBA guidelines on Structural FX, upon permission from the

competent authorities, certain currency positions are being excluded from

the calculation of net open currency positions under CRR article 352(2).

The resulting impact is presented in the Pillar 3 disclosure.

Equity price risk in banking books (*)

ING maintains a portfolio with substantial equity exposure in its banking

books.

Risk profile (*)

Equity price risk arises from the possibility that an equity security’s price

will fluctuate, affecting the values of the equity security itself as well as

other instruments whose values react similarly to the particular security, a

defined basket of securities, or a securities index. ING’s equity exposure

mainly consists of the investments in associates and joint ventures of

€1,607 million (2024: €1,679 million) and equity securities held at fair

value through other comprehensive income (FVOCI) of €2,607 million

(2024: €2,562 million). The value of equity securities held at FVOCI is

directly linked to equity security prices with increases/decreases being

recognised in the revaluation reserve.

Investments in associates and joint ventures are measured in accordance

with the equity method of accounting, and the balance sheet value is

therefore not directly linked to equity security prices. The equity sensitivity

is expressed as the equity position.

Year-on-year variance analysis (*)

In 2025, the revaluation reserve equity securities decreased by €372

million from €1,816 million to €1,444 million due to revaluation of the

shares in Bank of Beijing with €-403 million. In 2025, the equity securities

at fair value through OCI increased by €45 million mainly due to increased

stake in Van Lanschot Kempen.


Revaluation reserve equity securities at fair value through other comprehensive income (*)
in EUR million	2025	2024
Positive remeasurement	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’s

portfolio is estimated, based on equally weighted observed market

movements of the previous year (260 business days). When simulating

potential movements in risk factors, depending on the risk factor type,

either an absolute or a relative shift is used.

The data used in the computations is updated daily. ING uses HVaR with a

one-day horizon for internal risk measurement, management control, and

backtesting, and HVaR with a 10-day horizon for determining regulatory

capital. To compute HVaR with a 10-day horizon, the one-day risk factor

shifts are scaled by the square root of 10 and then used as an input for the


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revaluation. The same model is used for all legal entities within ING with

market risk exposure in the trading portfolio.

Limitations (*)

HVaR has some limitations: it uses historical data to forecast future price

behaviour, but future price behaviour could differ substantially from past

behaviour. Moreover, the use of a one-day holding period (or 10 days for

regulatory capital calculations) assumes that all positions in the portfolio

can be liquidated or hedged in one day. In periods of illiquidity or market

events, this assumption may not hold. Also, the use of a 99 percent

confidence level means that HVaR does not take into account any losses

that occur beyond this confidence level.

Backtesting (*)

Backtesting is a technique for the ongoing monitoring of the plausibility of

the HVaR model in use. Although HVaR models estimate potential future

trading results, estimates are based on historical market data. In a backtest,

the actual daily trading result (excluding fees and commissions) is

compared with the one-day HVaR.

In addition to using actual results for backtesting, ING also uses hypothetical

results, which exclude the effects of intraday trading, fees, and

commissions. When an actual or a hypothetical loss exceeds the HVaR, an

‘outlier’ occurs. Based on ING’s one-sided confidence level of 99 percent, an

outlier is expected once in every 100 business days.

On an overall level in 2025, there was one outlier for hypothetical P&L and

zero outliers for actual P&L. The hypothetical outlier occurred in the first

quarter of 2025, mainly driven by higher EUR rates due to anticipated

changes in German fiscal policy.

Stressed HVaR (*)

The stressed HVaR (SVaR) is intended to replicate the HVaR calculation that

would be generated on the bank’s current portfolio with inputs calibrated to

the historical data from a continuous 12-month period of significant

financial stress relevant to the bank’s portfolio.

To calculate SVaR, ING uses the same model that is used for 1DHVaR, with a

10-day horizon. The data for the historical stress period used currently

includes the height of the credit crisis around the fall of Lehman Brothers

(2008-2009), and this stressed period selection is reviewed annually. The

historical data period is chosen so that it gives the worst-scenario loss

estimates for the current portfolio. The same SVaR model is used for

management purposes and for regulatory purposes. The same SVaR model

is used for all legal entities within ING with market risk exposure in the

trading portfolio.

Incremental risk charge (*)

The incremental risk charge (IRC) for ING is an estimate of the default and

migration risks for credit products (excluding securitisations) in the trading

book, over a one-year capital horizon, with a 99.9 percent confidence level.

Trading positions (excluding securitisations) of ING, which are subject to

specific interest rate risk included in the internal model approach for market

risk regulatory capital, are in scope of the IRC model. By model choice,

equity is excluded from the model. For the calculation of IRC, ING performs a

Monte Carlo simulation based on a multi-factor t-copula. In the multi-factor

IRC model the supervisory asset correlations are no longer applicable and

the calibration of the correlations is based on historical market data. The

rating change is simulated for all issuers over the different liquidity horizons

(i.e. time required to liquidate the position or hedge all significant risks)

within one year. Movements across different rating categories and

probabilities of default are governed by a credit-rating transition matrix. An

internal transition matrix along with internal LGDs is used, to comply with

the consistency requirement. The financial impact is then determined for

the simulated migration to default, or for the simulated migration to a

different rating category, based on LGD or credit spread changes,

respectively.

The liquidity horizon has been set to the regulatory minimum of three

months for all positions in scope. ING reviews the liquidity horizons on a

yearly basis, based on a structured assessment of the time it takes to

liquidate the positions in the trading portfolio.

Stress testing and event risk (*)

Stress testing is a valuable risk management tool. In addition to the bank-

wide stress-test framework as described in the stress-testing section,

Trading Risk Management performs stress tests specific to the trading book

with various frequencies. The trading book stress tests evaluate the impact

on the bank’s trading book under severe but plausible stress scenarios, using

a full revaluation approach. The framework is based on historical as well as

hypothetical scenarios. The stress result is an estimate of the profit and loss

caused by a potential event and its worldwide impact for ING. The results of

the stress tests are used for decision-making, aimed at maintaining a

financially healthy going-concern institution after a severe event occurs.

In stress scenarios, shocks are applied to prices (credit spreads, interest

rates, equity, commodities, and FX rates) and volatilities. Depending on the

type of the stress test, additional scenario assumptions can be made, for

example on correlations, dividends, or recovery rates. The structural

scenarios are defined to cover market moves in various directions and

capture different asset class correlations. Scenarios are calculated using a

full revaluation approach. The worst scenarios are determined for each

product line, business line, and super business line, and compared against

limits

Other trading limits

HVaR and event risk limits are the most important limits to control the

trading portfolios. Additionally, limits have been set on SVaR and IRC, and

ING uses a variety of other controls to supplement these limits. Position

and sensitivity limits are used to prevent large concentrations in specific

issuers, sectors, or countries. Moreover, other risk limits are set with

respect to the activities in complex derivatives trading. The market risk of

these products is controlled by product-specific limits and constraints.

Risk profile

The following chart shows the development of the overnight HVaR under a

99 percent confidence level and a one-day horizon versus actual and

hypothetical daily trading profits and losses. In calculation of the

hypothetical daily profit and loss, the trading position is kept constant and

only the market movement is taken into account. The overnight HVaR is

presented for the ING trading portfolio for 2025.


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EU MR4. Consolidated trading VaR ING Bank

in EUR million

The risk figures shown in the backtesting graph above and in the following table relate to all trading books that use the internal model approach.


1d VaR for internal model approach trading portfolios
in EUR million	Minimum		Maximum		Average		Year end
	2025	2024	2025	2024	2025	2024	2025	2024
Interest rate ¹	6	6	23	17	10	12	6	11
Equity and commodity	4	2	9	7	7	4	6	6
Foreign exchange	2	1	6	14	3	3	4	2
Credit spread	2	2	6	12	3	4	2	3
Diversification ²					-9	-7	-8	-6
Total VaR ²	10	7	19	21	14	15	11	16

¹For calculation of HVaR per risk class the full valuation is performed according to HVaR methodology using a set of scenario changes for the risk factors for the particular risk class, while risk factors for all other risk classes are kept unchanged.

²The total HVaR for the columns Minimum and Maximum cannot be calculated by taking the sum of the individual components since the minimum/maximum observations for both the individual markets as well as for total HVaR may occur on different dates. Therefore, diversification is not calculated for the

minimum and maximum categories.


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Average 1D/10D HVaR, SVaR, and IRC over 2025 has decreased compared

to 2024, resulting in a decrease in overall capital for 2025. The overall

average has decreased in 2025 for all trading portfolios, mainly due to an

increase in diversification, despite high volatility due to the ongoing

geopolitical tensions and increased trade frictions.

ING does not calculate comprehensive risk capital charge and therefore it

appears as n/a in the table below.


EU MR3: internal model approach values for trading portfolios
in EUR million	2025	2024
VaR (10 day 99%)
1 Maximum value	59	73
2 Average value	41	48
3 Minimum value	29	29
4 Period end	33	47
Stressed VaR (10 day 99%)
5 Maximum value	149	175
6 Average value	90	109
7 Minimum value	47	56
8 Period end	51	98
Incremental risk charge (99.9%)
9 Maximum value	288	232
10 Average value	144	125
11 Minimum value	46	64
12 Period end	144	100
Comprehensive risk capital charge (99.9%)
13 Maximum value	n/a	n/a
14 Average value	n/a	n/a
15 Minimum value	n/a	n/a
16 Period end	n/a	n/a

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
2–4 (AA)	26	-13	-44	-27
5–7 (A)	64	-37	49	-246
8–10 (BBB)	191	-54	93	-76
11–13 (BB)	38	-14	38	-13
14–16 (B)	56	8	23	-12
17–22 (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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Internal model approach

Market risk regulatory capital has decreased during 2025 compared to

2024. This mainly reflects lower interest rate positions during 2025, as well

as the reduced regulatory-driven capital multiplier.


EU MR2-A: Market risk under internal model approach
in EUR million		2025		2024
		RWA	Total own funds requirements	RWA	Total own funds requirements
1	VaR (higher of values a and b)	1,521	122	1,964	157
(a)	Previous day’s VaR (VaRt-1)		33		49
(b)	Multiplication factor (mc) x average of previous 60 working days (VaRavg)		122		157
2	SVaR (higher of values a and b)	2,877	230	4,915	393
(a)	Latest available SVaR (SVaRt-1))		51		116
(b)	Multiplication factor (ms) x average of previous 60 working days (sVaRavg)		230		393
3	IRC (higher of values a and b)	2,014	161	1,457	117
(a)	Most recent IRC measure		144		116
(b)	12 weeks average IRC measure		161		117
4	Comprehensive risk measure (higher of values a, b and c)
(a)	Most recent risk measure of comprehensive risk measure
(b)	12 weeks average of comprehensive risk measure
(c)	Comprehensive risk measure - Floor
5	Other	582	47	340	27
6	Total	6,994	560	8,676	694

Standardised approach


EU MR1: market risk under standardised approach
in EUR million	2025	2024
	RWA	RWA
Outright products
1 Interest rate risk (general and specific)	92	31
2 Equity risk (general and specific)
3 Foreign exchange risk	4,968	4,374
4 Commodity risk
Options
5 Simplified approach
6 Delta-plus method
7 Scenario approach
8 Securitisation (specific risk)
9 Total	5,060	4,405

The MRWA under standardised approach have increased compared to

2024.

Market risk capital

Economic capital

Market risk economic capital (MREC) measures the capital ING must hold

to protect itself against losses due to market risks. MREC covers the entire

balance sheet of ING Group, and includes market risk sub-types such as:

interest rate and basis risk, credit spread risk, customer behaviour risk, FX

risk, equity risk, and commodity risk.

MREC is calculated as the 99.9 percent worst value loss that can be

incurred from one-year shocks to the underlying risk drivers. While

aggregating the different economic capital market risk figures for the

different portfolios, diversification benefits are taken into account as it is

not expected that all extreme market movements will appear at the same

moment.


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Regulatory capital

Market risk regulatory capital is the amount of capital that ING has to hold

to protect itself against losses due to market risks, as required by the

financial regulator. From a regulatory capital perspective, market risk

stems from all the positions included in a bank’s trading book, as well as

from commodity and foreign exchange risk positions in the whole balance

sheet of ING Group. According to the Capital Requirements Regulation

(CRR/CRD IV), regulatory capital (own funds requirements) for market risk

can be calculated using the standardised approach or an internal model

approach.

FX risk in banking book

Regulatory Capital requirements for FX risk in banking book is set out in

Part 3, Title IV, Chapter 3 of the Capital Requirements Regulation (CRR).

This is further supplemented by EBA guidelines on Structural FX for the

calculation of the net open currency positions (CRR Art 352(2)). ING uses

the standardised approach where the capital requirement is 8 percent of

this total net currency and gold position.

Equity risk in banking book

Equity regulatory capital is included as part of Credit RWA as prescribed by

regulations. As of January 2025, ING applies the Standardised Approach

(SA) for the calculation of Regulatory Capital as described in Capital

Requirements Regulation (CRR3) Art 133. Under CRR3 SA, the RWA amount

is calculated by multiplying the risk weight with the exposure value (not

tailored to a specific internal model). The capital requirement is 8 percent

of the RWA value.

Trading book

ING has regulatory approval to use an internal model to determine the

regulatory capital for the market risk in all trading books of ING. Market

risk capital of trading books is calculated according to the CRR, using

internal HVaR, SVaR, and IRC models, where diversification is taken into

account. Collective investment undertakings (CIUs), cryptocurrency assets

(Bitcoin NDF) and asset-backed securities (ABS) exposures in trading books

are calculated using the standardised approach with fixed risk weights.

ING does not have a correlation trading portfolio in the trading book.


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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:

§ Funding and liquidity risk framework;

§ Funding and liquidity risk management strategy and objectives;

§ Funding and liquidity adequacy and risk appetite;

§ Funding and liquidity risk indicators;

§ Liquidity stress testing; and

§ Contingency funding planning.

Funding and liquidity risk framework (*)

Macroeconomic and market environments are important considerations in

ING’s F&L framework. The macroeconomic environment is comprised of

various exogenous factors over which ING has no control, but which may

have a material impact on ING’s F&L position. Exogenous factors analysed

on a regular basis include:

§ performance of global and local macroeconomic indicators, e.g. shifts

in gross domestic product, inflation rates, unemployment rates, and

public deficit/surplus;

§ developments and risks arising from geopolitical tensions and trends;

§ monetary policy with a focus on the alternative monetary measures

employed by central banks in recent years as a result of the global

energy crisis and periods of high inflation; and

§ regulatory requirements, e.g. understanding the changing regulatory

landscape as well as the impact of ING’s actions on existing regulatory

boundaries.

The strategic ambitions of ING, together with the design and execution of

the funding plan, are assessed under both current and projected market

conditions. An emphasis is placed on understanding overall market trends

and developments, credit rating changes, and peer comparisons.

The EB, MBB, and staff departments from the CRO and CFO domains, as

well as Group Treasury, have oversight of, and are responsible for,

managing funding and liquidity risks.

Funding and liquidity management strategy and objectives (*)

The main objective of ING’s funding and liquidity risk management is to

maintain sufficient liquidity to fund the commercial activities of ING both

under normal and stressed market circumstances across various locations,

currencies and tenors.

ING’s funding consists mainly of retail and corporate deposits contributing

to 53 percent and 22 percent of total funding, respectively. These funding

sources provide a stable funding base. The remainder of the required

funding is attracted primarily through a combination of long-term and

short-term professional funding. Group Treasury manages the professional

funding in line with the F&L risk appetite with the aim of ensuring a

sufficiently diversified and stable funding base.


Funding mix ¹
	2025	2024
Funding type
Customer deposits (private individuals)	53%	52%
Customer deposits (other)	22%	23%
Lending/repurchase agreements	5%	5%
Interbank	2%	2%
CD/CP	5%	5%
Long-term senior debt	6%	6%
Subordinated debt	7%	7%
Total	100%	100%
¹Liabilities excluding trading securities and IFRS equity

ING’s 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’s liquidity position and maintain sufficient

counterbalancing capacity. A Liquidity Adequacy Statement is formulated

on a regular basis to substantiate and reflect the management view on

the current funding and liquidity position as well as the potential future

challenges. The Liquidity Adequacy Statement is an important part of

ING’s ILAAP process. Additionally, ING completes ad-hoc funding and

liquidity assessments if deemed necessary.

ING assesses its F&L adequacy through three lenses – stress, economic,

and normative:

§ Through the stress lens, ING evaluates its ability to withstand periods of

prolonged F&L stress for both normative and economic requirements.

Limits under idiosyncratic, market-related, combined idiosyncratic and

market-related, and climate risk scenarios, which lead to customer

deposit outflows, deterioration of access to funding markets, and lower

liquidity value of counterbalancing capacity are evaluated.

§ Through the economic lens, ING assesses the extent to which its

customers, professional counterparties, and investors are comfortable

to provide deposits and funding in the tenors, currencies, and

instruments necessary to sustainably fund the business (intraday,

short-term, and long-term) in a going-concern situation.

§ Through the normative lens, ING ascertains that the bank is in the

position to meet current and future domestic and host regulatory

requirements.

For each lens, ING has established a related set of risk appetite statements,

which define ING’s risk appetite, commensurate with the principles of

liquidity adequacy.


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The F&L risk appetite statements are translated into metrics with

appropriate boundaries and instruments which are used to regularly

measure and manage ING’s funding and liquidity risk. The risk appetite

with respect to the stress lens aims to have sufficient counterbalancing

capacity under various internally defined stress scenarios. Regarding the

economic perspective, an internally defined stable funding to loans (SFtL)

ratio and stable funding surplus (SFS) metric (supplemented by other

metrics) is used to stimulate a diversified funding base and to prevent

overreliance on professional funding. Finally, the liquidity coverage ratio

(LCR) and the net stable funding ratio (NSFR) regulatory metrics are

monitored in terms of both ING’s risk appetite and normative

requirements.

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’s funding and liquidity position and provides

insight into which entities, business lines, or portfolios are vulnerable to

which types of risk drivers or scenarios.

The stress-testing framework encompasses the funding and liquidity risks

of the consolidated balance sheet of ING Group, including all entities,

business lines as well as on- and off-balance sheet positions. The net

liquidity position (NLP) is the main stress-testing measure and is measured

at different time buckets.

The stress-testing framework considers idiosyncratic, market-wide,

combined (idiosyncratic and market-wide) and climate-stress scenarios.

The design of the framework is based on empirical evidence supplemented

by expert judgment. The framework can be extended to additional ad-hoc

scenarios. For example, it can be used as input for firm-wide stress testing

and reverse stress testing.

Outcomes of the stress tests are considered in the key aspects of ING’s F&L

risk framework and F&L risk management, including:

§ Risk Appetite Framework (through risk appetite statements);

§ Risk identification and assessment;

§ Monitoring of the liquidity and funding position;

§ Business actions (if needed);

§ Contingency funding plan; and

§ Early-warning indicators.

The funding and liquidity stress-testing framework is also subject to

regular internal validation by model validation.

In line with supervisory expectations, ING’s liquidity position is stress tested

on (at minimum) a monthly basis using scenarios that form part of the

F&L risk appetite statement. The results of all internal stress scenarios are

monitored and assessed on a monthly basis. In addition, ad-hoc scenarios

based on current economic and market developments are run to

determine their potential impacts on the funding and liquidity position of

ING . In 2025, this included stress-test scenarios assessing the impact of a

shutdown of US short- and long-term funding markets and FX markets.

The internal stress scenarios and their corresponding results serve as input

in the decision on holding additional contingency measures.

Contingency funding planning (*)

ING’s contingent F&L risks are addressed in its Contingency Capital and

Funding Plan (CCFP). The objectives of the CCFP include:

§ Establishment of a monitoring framework to detect approaching

contingent events as well as their impact on ING’s F&L position;

§ Provision of a plan for responding to various and increasing levels of a

bank’s liquidity and capital shortfall under adverse and stressed

conditions;

§ Designation of management responsibilities, crisis communication

methods and channels, and reporting requirements;

§ Identification of contingent capital and liquidity sources under

escalating adverse and stressed conditions; and

§ Description of the steps needed to ensure the bank’s capital and

liquidity sources are sufficient to fund scheduled operating

requirements and meet the institution’s commitments, with minimal

costs and disruption.

The contingency funding measures are developed in conjunction with the

ING Recovery Plan and are reviewed and tested on a regular basis.

¹In line with the European Central Bank (ECB) guide on Climate-related and Environmental risks

² As per the ING Group Risk Identification and Risk Assessment Procedure for ICLAAP purposes.


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Environmental, social and governance (ESG) risk

Introduction

ESG risk is defined as any negative financial and/or non-financial impact on

ING due to the present or future impact to/dependencies from factors on

and stemming from ING’s full value chain.

ESG risk is not an independent risk category/risk type but rather a set of

drivers 1 affecting the likelihood and severity of existing risk categories/risk

types. ESG risk is an overarching set of risk drivers affecting:

§ Financial risks: credit risk, market risk, funding and liquidity risk;

§ Non-financial risks and compliance risk; and

§ Other overarching risks: model risk and business and strategy risk

The risk drivers 2 are defined as risk events that lead to an impact on ING’s

financial solvency or funding and liquidity position via the above-

mentioned risk types. Our comprehensive approach ensures we integrate

ESG considerations into our risk management practices, aligning with our

commitment to sustainable growth and resilience.

Definitions

ESG factors

ESG factors are defined as environmental, social or governance matters that may have a positive or negative impact on the non-financial/financial performance

or solvency of an entity, sovereign, or individual. ING's ESG taxonomy of ESG factors are defined through the consideration of the CSRD and EUT.

Environment

§ Climate-change adaptation

§ Climate-change mitigation

§ Pollution

§ Water & marine resources

§ Circular economy

§ Biodiversity and ecosystems

Social

§ Own workforce and workers in the value chain

§ Customers

§ Communities

Governance

§ Business conduct

Value chain

Value chain is a concept derived from CSRD Annex II as 'the full range of activities, resources and relationships related to the business model(s) of the undertaking

and the external environment in which it operates'. For ING, the concept of the value chain defines the scope of the ESG risk management lifecycle.

Supply chain

Own operations

Wholesale

Banking

Business Banking

Private Individuals

& Private Banking

Treasury & other

investments

Double materiality

ING must identify both actual and potential:

§ impacts on people and the environment (impact materiality, inside-out); as well as

§ sustainability matters that impact ING's financial positions (financial materiality, outside-in).

Impact materiality and financial materiality assessments are interrelated, as financial materiality may stem from negative impact, dependency on resources and

context analysis. ING defines material ESG factor per value chain for both impact and financial materiality.

¹Important ESG factors are determined on a case by case basis and consider international standards such as the OECD Guidelines for Multinational Enterprises on responsible business conduct and the UNGPs on Business and Human Rights.


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The ESG risk framework

The ESG risk framework provides a definition of ESG risk, the governance

structure supporting the management of ESG risk, and an overview of the

various roles and responsibilities related to ESG risk. The framework assists

in managing ESG risk effectively through the application of the risk

management process at various levels of the organisation. The framework

integrates governance components, including the three lines of defence,

defined organisational responsibilities, and ESG oversight bodies, and is

underpinned by a continuous ESG Risk Management Cycle (aligned with

the Risk Management Cycle) encompassing identification, assessment,

mitigation, reporting, and monitoring, as described in detail below.

Governance

ING has a governance structure with well-defined, transparent, and

consistent lines of responsibility in managing ESG risk in line with the three

lines of defence. For more information, see ‘Three lines of defence’.

ESG risk bodies

The ESG committees and bodies at ING are responsible for overseeing and

integrating ESG matters into ING’s strategy and daily operations in line

with our sustainability governance. The following committees, bodies, and

their associated charters are relevant with regard to the framework:

§ Supervisory Board ESG Committee (SB-ESG): The ESG Committee assists

the SB by generally monitoring and advising on relevant ESG

developments.

§ Executive Board (EB) and Management Board Banking (MBB): ING’s EB/

MBB has overall responsibility for the ESG risk framework and is

accountable for having it implemented and embedded.

§ The key risk committees: Acting within delegated authorities granted

by the MBB, support on implementation and execution of the controls

mitigating material ESG risks.

§ ESG Risk Committee (ERC): A standing committee that receives its

mandate from the MBB, and is responsible for the approval of ESG risk

procedures and mandatory instructions as well as its rollout in the

different impacted functions. In addition, it advises MBB and MBB-

delegated committees on the implementation and execution of the

controls mitigating material ESG risk.

Organisational bodies

Management of ESG risk is embedded within all material risk types across

the three lines of defence. Within the CRO domain, ESG risk governance is

embedded into the existing global risk governance framework. It aligns

with the structures that steer risk categories and types globally.

The global ESG Risk department’s role is to ensure that all risk functions

incorporate ESG considerations into their processes, while the local (ESG)

risk functions are responsible for the local adoption of the global policies,

methodologies and instructions issued by the global ESG Risk department.

Managing ESG risk

The primary concern relates to the long-term impact on credit quality and

income, rather than immediate solvency. Climate and environmental-

related risks may increase the risk of borrower default and reduce income

from vulnerable sectors. The focus is on managing underlying risks by

increasing risk management intensity. The ESG risk framework assists in

managing ESG risk effectively through the application of the risk

management process at varying levels of the organisation. The risk cycle

describes the processes by which ING can identify, assess, mitigate,

monitor, and report ESG risk integrated within the existing risk types.

Risk identification

It is our policy to formalise and maintain an up-to-date ESG impact and

risk inventory. This inventory includes descriptions of the drivers of ESG

negative impacts and ESG risks. Regarding the risk drivers, the inventory

further details their transmission channels and maps them to the risk

categories where ESG risk drivers can materialise. Additionally, the

inventory briefly outlines the drivers of positive impact and opportunities.

Risk assessment

ESG metrics are defined and assessed against predetermined thresholds to

determine materiality. The outcome of the double materiality assessment

(DMA) defines the way ESG risk is adopted in the business strategy and the

risk management of each risk category/risk type to be mitigated. In

addition to the results of the DMA, ING considers some ESG factors to be

important 1 for the risk assessment and due-diligence processes that

follow.

¹ Material with reputational risk


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	Transmission channels	Material: Financial & non-financial risks 1
E1: Climate change; E4: Biodiversity and ecosystems
	Business § Property damage & Business disruption § Stranded assets & New capital expenditure Households § Loss of income § Property damage Macro economy § Shifts in prices § Productivity changes § Labour market frictions	Risk category	Short term	Medium-long term
		Credit risk	E1, E4	E1, E4

		Compliance risk	S1, S4, G1	E1, E4, S1, S4, G1

		Market risk	In scope of the assessment, no material risks identified

		Liquidity risk

		Non financial risk	S1	S1

		Business risk	E1 (climate change mitigation)	E1 (climate change mitigation)

S1: Own workforce; S4: Consumers and end-users	Social and governance § Negative customer and investor preference § Legal liability for damages caused and loss of customer preference § Negative impact on workforce

G1: Business conduct

The above visualisation and the following paragraphs illustrate the

mapping of ESG risk drivers to financial and non-financial risks across

different time horizons.

§ Credit risk

– Climate transition risk: ING has credit exposure to clients whose

business models may be more vulnerable to climate transition risks,

potentially resulting in business disruption and reduced earnings,

which could impair their ability to repay loans or meet other

financial obligations. In addition, adverse climate conditions may

lead to depreciation in the value of collateral.

• Entities may be affected by increased operating costs and

reduced revenue due to fines, taxes and adaptation costs which,

in turn, might decrease clients’ affordability and ability to repay,

thus increasing PDs.

• The transition to environmentally sustainable economies might

make carbon intensive assets in ING’s lending portfolio more

vulnerable to disinvestment and demand – leading to potential

write-offs, stranded assets, early retirement of assets (based on

carbon profiling/intensity) and a decrease in the collateral value

for brown assets. This in turn might result in higher loan to

values (LTVs) and LGDs.

– Climate physical risk: Climate-related physical impacts can lead to

significant losses, unexpected expenses, and reduced income and

profits for borrowers. This may impair their ability to repay loans,

thereby increasing credit risk for ING. Additionally, the frequency

and intensity of extreme events can affect the value of real estate

or other collateral, altering the relationship between the loan and

the asset’s value.

• Acute and chronic risks can negatively impact cash flows of

affected entities: 1) as damaged physical capital might generate

less income, 2) operational disruptions might lead to decreased

productivity and increased operational costs and 3) increased

insurance premiums. This might decrease clients’ affordability

and ability to repay debt and therefore increase PDs. For

sovereign and municipal exposures, the income effects from

physical risk events may primarily arise through lower tax

revenues and higher spending channels to compensate for

negative impacts and adaptation costs.

• Impact on LGD: Write-offs, asset devaluation and early

retirement of existing assets due to acute events decrease the

value of collateral and have a negative impact on LTVs, and

therefore LGDs.

– Biodiversity and ecosystems (impact on species): The negative

impact on biodiversity, which can result in a demise in natural

resources, can disrupt clients’ operations, leading to financial losses.

Financial losses can also occur due to reputational damage. This

may leave them unable to repay loans or meet their obligations on

other financial transactions at the same time as reducing the value

of the business.

§ Compliance risk

– Climate transition risk: Assuming that regulation in Europe will

continue to increase in the coming years and decades, the inherent

risk may rise accordingly. These risks are expected to become more

pronounced in the medium and long term, driven by increased

regulatory expectations and stronger embedding in the prudential

framework.


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– Biodiversity and ecosystems: compliance risk due to increasing

expectations on the integration of biodiversity and ecosystems into

European regulation and the prudential framework.

– Business Conduct: Financial loss, regulatory fines, and reputational

damage resulting from infringements of our corporate culture,

potential instances of bribery and corruption, and failure to protect

whistleblowers.

– Consumers and end-users: materialisation of negative impact due

to not providing access to quality information on transition and

physical risks. Also includes privacy risk when failing to protect our

customers’ data.

– Own workforce: privacy risk linked to data protection of our own

employees.

§ Non-financial risk

– Own workforce: Due to People Risk and/or Employment & Practice

Risk (EPR), regarding the employment and inclusion of persons with

disabilities and from diverse backgrounds, including gender

equality. Moreover, EPR due to significant concerns raised on

violence and harassment in the workplace.

§ Business and strategy risk

– Climate transition risk: High transition risk may materialise if ING’s

clients are unable to adapt their business models in line with

climate regulation. In such cases, increasing carbon costs,

regulatory restrictions, or declining market demand can weaken

clients’ profitability and balance‑sheet strength. This may translate

into reduced lending opportunities, ultimately affecting future

income generation.

Failing to meet the commitments made can result in a loss of trust among

ING’s customers and stakeholders, which can result in customers choosing

to take their business elsewhere. ING may therefore face increased costs

related to customer acquisition and retention efforts, ultimately affecting

profitability.

Measurement methodologies and impact

ING measures its exposure to ESG risks by assessing risks through risk

quantification methodologies and tools. The methodologies take into

account qualitative and quantitative criteria, different time horizons, and

scenario analysis and stress testing,supporting an assessment of the

organisation’s resiliency under various climate and ESG‑related conditions.

Quantification leverages on top-down and bottom-up approaches, when

applicable.

§ Physical risk tool: ING has developed a tool to measure and assign a

level of physical risk for four chronic and nine acute physical risks

across the short, medium, and long term for portfolios and geographies

in which ING operates. This range of hazards is recognised under EU

Taxonomy. The thorough selection of hazards means this tool caters

for broad, continent-spanning risks as well as local and nuanced ones.

The tool has been developed using physical risk maps obtained and

recognised by academically reputable sources.

§ Transition risk scorecard: Used by ING to quantify transition risk with a

scorecard approach at client-level. Methodology helps to identify the

pool of high-risk clients within specific sectors, in order to subsequently

manage these high-risk subsegments, taking into account ING’s public

commitments and sector-specific climate strategies (Terra approach).

This pool of high-risk clients is subsequently managed via the climate

risk-appetite setting.

§ ESG risk-assessment tool: For WB, ING has developed an ESG risk-

assessment approach which considers the (climate and)

environmental, social and governance risk factors, negative impacts

and dependencies of our WB customers, and fully integrates the

previous ESR framework, which is now embedded under the umbrella

of the new ESG Risk Framework. Tooling was developed to support the

implementation of the assessment approach in the credit granting

process. Depending on the ESG risk-assessment outcome and the

impact on financial risks, additional mitigation might be required and

factored in as one factor for the broader credit risk assessment.

§ Climate Stress Test and Resilience Analyses: ING continues enhancing

its climate stress-testing methodology to assess the impact of climate

risks on corporate and mortgage exposures from a credit risk

perspective under different climate scenarios.The methodology for

short-/medium-term stress test (referred to as Climate Stress Test or

CST) builds on existing stress test methodology (e.g. ICAAP, EBA), while

a dedicated long-term methodology has been developed (referred to

as Climate Resilience Analysis or CRA) to assess the impact on

provisions under various scenarios and portfolio assumptions.

For both CST and CRA, dedicated climate scenarios are used, developed

using NGFS short-term and long-term (Phase V) scenario publications as

foundational inputs. These scenarios cover different narratives and explore

the impact of 1) a baseline/continuation of current policies scenario, 2) a

Net-Zero smooth transition scenario, 3) a delayed and abrupt transition

scenario, 4) a low transition risk but high physical risk scenario. These

scenarios influence macro-economic variables projections (e.g. GDP,

unemployment rate, house prices, etc.) which, in turn, determine the

forecast of the main credit risk parameters (e.g. risk migrations, PDs, LGDs

etc.). This is referred to as the "macro" transmission channel.

In addition, dedicated climate overlays are incorporated to account for the

impact of transition, physical and nature risk on a more granular level. This

is referred to as the "micro" transmission channel.

For mortgages transition risk is modelled by estimating the relationship

between household income and probability of default (PD), factoring in

rising carbon prices, energy costs, and renovation expenses required for

low energy label properties. A PD multiplier is then derived per portfolio,

per energy performance certificates (EPC) level. Physical risk is assessed

using ING’s in-house Physical Risk Tool, which combines hazard maps and

property-level exposure data to estimate expected losses. LGD is adjusted

based on modelled damage functions and loss estimates of material

Physical Risk.

For corporates, the dedicated overlays are implemented in the form of PD

multipliers across 16 NACE sectors. These multipliers are derived using

ING’s EEST (Environmental Elasticity Scenario Tool) which assesses the

impact of transition, physical and nature risk shocks on the market price

and volume per sector, and subsequently the impact of these shocks on

the counterparty’s financial position. The resulting financial stress is then

reflected in PDs.

The long‑term analysis informs the resilience of the bank’s business model.

ING’s proactive portfolio steering, sector‑specific transition engagement,

and transaction‑level risk‑management measures collectively enhance the

bank’s capacity to navigate increasing climate pressures and preserve its

business resilience over time.


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Risk mitigation

The mitigation of the identified risks in line with the risk appetite can be

performed through several risk mitigating strategies, such as reducing the

risk level, avoiding risk, accepting risk, or transferring the risk. The

measures are embedded as part of the updates of the existing policies and

procedures in the different risk categories/risk types in order to mitigate

ESG risks with a material financial impact. Mitigation activities can be

performed at a process, product, portfolio, client, or transaction level and

include, but are not limited to:

§ engaging with high ESG risk counterparties to understand and support

their mitigation plans;

§ setting RAS to limit the level of acceptable risks;

§ incorporating ESG risks in the collateral valuation process; and

§ ensuring appropriate business continuity plans and insurance are in

place to reduce the impact of more frequent and severe ESG events for

ING’s value chain.

Risk monitoring, reporting and disclosures

ING aims to provide regular and transparent ESG reports and regulatory

disclosures to ensure the management body and all relevant units in ING

receive ESG risk information in a timely, accurate, concise, clear and

meaningful manner. These reports cover the identification, assessment,

measurement, monitoring, and management of ESG risks.

The ESG risk dashboard consists of comprehensive and integrated ESG risk-

related, financial and non-financial information on business activities and

own operations, summarising the following:

§ Results of the double materiality assessment, detailing negative

impacts, financial and non-financial materiality for each value chain

segment;

§ ING key climate risk indicators for material ESG risks across value chain

segments. The depth of reporting is informed by the materiality

assessments performed; and

§ The outcome of the latest climate stress-testing assessment.


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Non-Financial risk

Introduction

Non-financial risk (NFR) is defined as the risk of financial loss, legal or

regulatory sanctions, or reputational damage due to inadequate or failing

internal processes, people and systems, a failure to comply with laws,

regulations and standards, or external events.

Non-financial risk management

Risk categories

ING categorises non-financial risks in the following 10 areas:

§ Compliance risk is the risk of personal harm, financial loss, regulatory

fines, litigation, business disruption and/or reputational damage due to

impairment of ING Group’s integrity caused by a failure (or perceived

failure) to comply with applicable external laws, regulations and market

standards, societal expectations and internal ING rules.

§ Information (technology) risk is the risk of financial loss, regulatory

fines, litigation, business disruption and/or reputational damage,

breach of confidentiality, failure of integrity of systems and

information, inappropriateness or unavailability of systems and

information or inability to change information technology (IT) within a

reasonable timeframe and with reasonable costs when the

environment or business requirements change (i.e. agility). This

includes security risks resulting from inadequate or failed internal

processes or external events including cyberattacks or inadequate

physical security.

§ Operational resilience/business continuity risk is the risk of financial

loss, regulatory fines, litigation, business disruption, and/or reputational

damage due to the organisation’s inability to deliver its Critical Business

Services within their impact tolerance levels, and to respond and

recover from severe disruption or crisis within predefined time frames,

service levels, and capacity.

§ Control risk is the risk of financial loss, regulatory fines, litigation,

business disruption, and/or reputational damage due to not complying

with controls set through governance procedures and/or project

management methods, caused by improper or insufficient monitoring

(testing) of entities or activities. The key components of Control Risk

include Third and Intragroup Party Risk (TIPM) and Model Risk.

§ Processing risk is the risk of financial loss, regulatory fines, litigation,

business disruption and/or reputational damage due to unintentional

(human) error during (transaction) processing, or due to data issues

(including inadequate data governance, poor data quality, data not

available for use, or data architectures not supporting business needs

for data aggregation/consumption or reporting).

§ Unauthorised activity risk is the risk of financial loss, regulatory fines,

litigation, business disruptions and/or reputational damage due to

unauthorised employee activities, approvals, or overstepping of

authority that breach delegated mandates without constituting fraud.

§ Personal and physical security risk is the risk of financial loss,

regulatory fines, litigation, business disruption, and/or reputational

damage due to criminal and environmental threats that might

endanger the security or safety of ING personnel at work, people in ING

locations, ING assets or assets entrusted to ING, people at ING event

locations, or might impact the organisation’s confidentiality, integrity,

or availability.

§ Employment practice risk is the risk of financial loss, regulatory fines,

litigation, business disruptions and/or reputational damage due to

breaches of employment, health, and/or safety laws, regulations or

agreements from payment of personal injury claims, from diversity/

discrimination events, unsafe physical and psychosocial working

conditions, or from the unavailability of staff.

Fraud Risk consists of two risk areas:

§ Internal fraud risk is the risk of financial loss, regulatory fines, litigation,

business disruption, and/or reputational damage due to acts of fraud

performed by or in collusion with an ING employee.

§ External fraud risk is the risk of financial loss, regulatory fines, litigation,

business disruption, and/or reputational damage due to acts of fraud or

scams by individuals, and/or parties excluding ING staff (and ING

contractors).

In line with ING’s sustainability strategy and regulatory requirements

relating to ESG Risk Management, the NFR Framework has been updated

to ensure ESG Risk is properly embedded in our risk management cycle

and material risk types in line with the overarching ESG Risk Management

Framework.

Risk appetite and tolerances

ING sets a Group-wide risk appetite for non-financial risks, supported by

quantitative and qualitative tolerances. Tolerances are cascaded to

business lines and are calibrated to reflect our strategy, stakeholder

expectations, and regulatory requirements. Performance against appetite

is monitored through a suite of Key Risk Indicators and assessed quarterly

by management committees, with breaches triggering predefined

escalation and remediation. The Supervisory Board is informed of material

movements relative to appetite through regular risk reporting.

Issue management and remediation

Issues arising from risk assessments, control testing, events, audits, and

supervisory reviews are recorded in a central issue management system.

Each issue has a clearly defined owner, risk classification, target

remediation date, and acceptance criteria. Progress is tracked through

regular governance routines, and overdue items are periodically reported

to senior management for follow-up. Closure is subject to evidence-based

validation.

Measurement approach

As of 1 January 2025, following CRR3 regulation, ING is using the

Standardised Measurement Approach (SMA), a non-model-based formula

to calculate regulatory operational risk capital. An internal Operational Risk

Economic Capital (OREC) model is used for economic capital and stress

testing purposes (Pillar II). The OREC model estimates the economic capital

required to cover potential losses arising from various non-financial risks

within ING. The OREC model involves the use of historical internal and

external losses together with forward-looking and expert-driven loss

estimates to arrive at bank-level loss distribution. The outcomes of the

OREC model are reported quarterly.

Main developments in 2025

The external environment continues to present significant uncertainty and

complexity. Geopolitical tensions and regulatory divergence across

jurisdictions create challenges for global operations. These dynamics may

increase exposure to non-financial risks, requiring ongoing enhancement

of risk mitigation measures and capabilities. At the same time, evolving

consumer expectations and strengthened consumer protection


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regulations are likely to raise the standards for secure and resilient

banking operations. ING is continuously working to further mature its risk

management practices, ensuring continued readiness and resilience in this

changing landscape.

Continuity Risk

Providing safe, secure, and seamless services for our customers is central

to ING’s strategy as we focus on providing superior value to our customers.

Operational and IT Resilience measures are key in preventing disruptions

and ensuring a quick recovery when disruptions do occur. During 2025, ING

has further strengthened the implementation of the Operational Resilience

framework in the organisation. The framework aims at safeguarding the

resilience of our most critical business services and the related processes

and systems, facilities, people, data, and third- and intragroup services. As

an example, more real-life simulations of outages are performed to test

the resilience of our critical business services under severe stress scenarios,

including the effectiveness of anticipated contingency measures. The bank

continues to strengthen the framework, including measures related to

concentration risk and the oversight of material subcontractors in

outsourcing. Strengthening our Operational Resilience is a multi‑year

journey and a lot of progress has already been made. Over the coming

period, we will further enhance areas such as supplier concentration risk

management, oversight of material sub‑contractors, and the scope and

realism of our outage simulations.

Information (Technology) Risk

The mission of Information (Technology) Risk, together with the IT

organisation, is to help ING stay safe and secure by preventing and

mitigating unauthorised access to systems and safeguarding the

confidentiality, integrity, and availability of the data within them. To

deliver on this mission, we are continuously strengthening and maturing

our joint framework, ensuring it is equipped to adapt to emerging risks.

These risks arise from new or changing regulations (such as the EU

Artificial Intelligence Act (AI Act) and Payment Services Directive 3 (PSD3)),

rapidly shifting threat landscapes (e.g., AI-enabled attacks, QR-code

phishing, quantum-related risks), ongoing digitalisation of value chains,

adoption of new technologies and digital products, and geopolitical

developments. To keep ahead, ING implemented further enhancements in

measuring and reporting on IT risks in 2025, which will continue in 2026.

The overall cybersecurity maturity increased, due to in particular to

significant progress in the area of Identity & Access Management (IAM). IT

Resilience remains a key focus to prevent and mitigate disruption of

services and data. This is done by further developing capabilities to recover

from large-scale ransomware events and by enhancing failover and

recovery of global, shared systems, supported by the Global Infrastructure

organisation and the Chief Information Security Office (CISO). In 2025, ING

continued to develop, improve, and test these capabilities. Since the

external cyber threat landscape is evolving quickly, which demands

continuous improvement for the coming years.

Fraud Risk

In 2025, ING reinforced its commitment to fraud resilience, focusing on

early detection, smarter prevention, and stronger governance. Our global

strategy is designed to prevent and reduce fraud-related losses and

provide customers with tools to recognise and avoid fraud, like the ‘check

the call’ feature.

Increasing complexity and rising volumes of fraud, driven by technological

developments such as AI-enabled schemes, are already evident.

Capabilities are enhanced through predictive analytics, extended

reporting, and cross-market alignment via the Global Fraud Target

Operating Model. These efforts ensure consistent execution and

continuous improvement across countries. Collaboration remains central

to our approach. ING works closely with industry peers, regulators, and law

enforcement to address fraud as a societal challenge.

Personal & Physical Security Risk

In 2025, the complex geopolitical situation continued to pose significant

threats to the safety and security of ING’s assets and employees (e.g. wars

in Ukraine and the Middle East, hybrid warfare, and unstable political

environments). ING is monitoring these geopolitical risks closely, and

security measures and procedures are being implemented to mitigate

both current and potential impacts on ING’s assets and staff.

Rising activist actions, political extremism, and social polarisation are

creating an increasingly volatile threat landscape, heightening uncertainty

for ING and its operations. These risks require specific actions to protect

assets and people from security threats and disruptive movements,

including heightened vigilance and proactive coordination with authorities.

To strengthen and accelerate response capabilities, a dedicated global

first-line Safety and Security department was established in 2025.

Data risk management

At ING, managing Data Risk is about having the right data of good quality

readily available for business or regulatory purposes, in a secure and

compliant way. As emerging technologies such as AI continue to evolve

and data volumes expand at a rapid pace, our primary objectives are to

address data-related regulatory obligations, manage risks associated with

data-driven technologies like AI, and ensure ongoing alignment with

societal expectations. ING has set up clear governance and initiatives to

ensure the ethical handling of data, and to integrate regulatory

requirements (e.g. EU AI Act, BCBS239) in its policies and way of working.

ING’s data strategy is making steady progress, strengthening data quality

and data governance, and supporting clear accountability across the

organisation. Data Risk Management is applied to the data strategy to

oversee and anticipate business expectations (incl. regulatory

requirements), to measure (e.g. via KRIs) against our defined risk appetite

statement, as well as to monitor the status of regulatory programmes

(e.g. BCBS239). Since the Data Risk landscape is evolving rapidly, ING will

continue to enhance Data Risk Management. In the coming years ING will

invest in data literacy, scaling data capabilities, tooling and strengthening

governance for data and AI-driven technologies.


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	102

Compliance risk

Introduction

ING aims to conduct its business activities in compliance with applicable

internal rules (including ING’s risk appetite statements) and external laws

and regulations, whilst also taking societal expectations into consideration.

Compliance risk is defined as the risk of personal harm, financial loss,

regulatory fines, litigation, business disruption and/or reputational damage

due to the impairment of ING Group’s integrity caused by a failure (or

perceived failure) to comply with applicable external laws, regulations and

market standards, societal expectations and internal ING rules.

Within ING, we apply the following compliance risk categories:

§ Financial crime risk refers to the risk of the bank’s products and services

being abused for illicit purposes, generating, facilitating or disguising

financial and/or economic crimes (FEC).

§ Conduct risk refers to compliance risk arising from (the perception of)

breaching our obligations towards customers and/or other parties,

including inappropriate market conduct.

§ Data protection (personal data protection, data retention) risk refers to

the personal data protection risk of financial loss (regulatory fines,

reputational damage) due to not protecting the personal data rights of

individuals as required, and as to data retention risk, to having the

records being destroyed too soon or retained too long.

The Compliance organisation has the mission to drive compliance risk

management by desire and design throughout the organisation.

Compliance ’ s primary role is advising, challenging, and overseeing the first

line of defence in how they manage compliance risks, as well as raising

awareness and stimulating a sound compliance risk culture.

Training and awareness

At ING we believe all our people play a role in protecting our customers,

the bank and, through that, society too. A sound risk culture is promoted

by empowering our employees with the skills and knowledge they need to

manage compliance risks. In 2025, we continued to train our people with

mandatory trainings on financial crime, conduct and data protection.

Senior Management (MBB and SB) are trained on various compliance risk

topics based on a multi-year training plan.

Financial crime and fraud prevention

Financial Crime and Fraud Prevention (FCFP) in the first line of defence and

Financial Crime Compliance (FCC) in the second line of defence continue to

jointly play a major role in our aim to make sure we only engage and do

business with people and entities that meet regulatory requirements.

Knowing who we do business with is vital to keeping ING safe, secure, and

compliant. As part of our ongoing anti-money laundering efforts, we

continuously assess relationships with both new and existing customers,

monitor and screen transactions to fulfill our regulatory and reporting

obligations, whilst ensuring unusual and/or potentially suspicious

transactions are reviewed/investigated. Where applicable, we report these

to the relevant authorities.

Financial crime risk management

The day-to-day responsibility for the oversight of ING’s compliance with

our legal and regulatory obligations, in relation to financial crime risks, sits

with the global head of Financial Crime Compliance, who reports to ING’s

CCO, with oversight by the CRO. As a global financial institution combatting

financial crime, and to comply with anti-money laundering and counter-

terrorism financing (AML/CTF) laws and regulations, we have established a

reasonable and risk-based control framework to mitigate continuously

evolving financial crime risk, and seek to provide useful information to

relevant government agencies.

Operational effectiveness (OE)

ING’s global KYC policy and related control standards set the minimum

requirements and control objectives for all ING entities to guard against

involvement in financial crime activity, while reflecting relevant national

and international laws, regulations, guidance documents, and guidelines

from national, European and international authorities, (supra)national risk

assessments, and industry standards. In 2025, our focus has shifted from

foundational maturity to maintaining operational effectiveness, with

oversight and challenge from the second line of defence. This evolution is

supported by the completion of the multi-year KYC Enhancement

Programme, which strengthened our customer due diligence and

transaction monitoring capabilities.

Evolving financial crime and regulatory landscape

Financial crime continues to evolve, whether through technology, new and

sophisticated techniques used by criminals, or the results of geopolitical

events. The widespread digitalisation of the economy and use of AI has led

to a reshaping of the methods used to launder money and finance

terrorism. Criminal groups have adopted and are misusing new

technologies, AI, and anonymity-enhancing technologies, such as virtual

currencies and mixers, to commit criminal activities.

In response to this and heightened supervisory expectations, so too has

the regulatory environment evolved. The EU’s Anti-Money Laundering

Regulation (AMLR) and the establishment of the Anti-Money Laundering

Authority (AMLA) mark a significant step toward harmonised oversight

across member states, with full implementation expected by 2027.

ING actively participates in industry consultations and regulatory

dialogues to shape these frameworks, while embedding operational

effectiveness and advanced analytics into KYC and transaction monitoring

processes. These developments reflect ING’s strategic ambition to

safeguard the integrity of the financial system and strengthen resilience

against financial crime risks. In addition, we are committed to a risk-based

approach (RBA), ensuring resources are focused on higher-risk areas while

maintaining compliance with evolving global standards. This is

underpinned by investment in data-driven, continuous risk assessment

methodologies aimed at providing dynamic insights into emerging threats

and enabling proactive risk mitigation strategies.

These innovative technological capabilities enhance our cooperation with

law-enforcement agencies, industry bodies and regulators, and further

development of intelligence and data-led collaborative solutions to detect

and disrupt financial crime. In this context, this may at times include

sharing information within ING to manage our financial crime risk

exposure, in line with General Data Protection Regulation requirements

and local privacy laws and regulations.


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	103

Bribery and corruption

Bribery and corruption undermine business confidence and corporate

integrity, hinder fair business competition, and harm international trade.

Bribery and corruption risks are considered as part of our client and third-

party due diligence, and financial crime risk monitoring measures. This

supports our zero-tolerance approach to bribery and corruption, which is

also part of the governance elements of our sustainability objectives and a

main principle in our Global Code of Conduct.

Customer tax compliance

Compliance with customer tax-related regulations and reporting

obligations, under the Foreign Account Tax Compliance Act (FATCA), the

Common Reporting Standard (CRS), and Mandatory Disclosure Rules, aims

to ensure that ING is not involved in facilitating tax-related financial crime,

such as tax evasion and harmful aggressive tax-avoidance schemes, on

behalf of its customers.

Sanctions

It is ING’s policy to take into consideration the applicable sanctions regimes

as imposed by international authorities and by local mandatory sanctions

law (as applicable). ING’s policy generally prohibits relationships or

transactions involving sanctioned persons and entities or comprehensively

sanctioned countries, territories and their governments. This sometimes

also means that ING’s risk appetite may be stricter than legal obligations,

and we may choose not to support certain customer relationships,

business activities and transactions, even if permitted by law.

ING continuously monitors external developments to remain proactive to

new sanctions packages or updates to existing sanctions packages.

Throughout 2025, geopolitical risk has grown (e.g. conflict in the Middle

East and the continuation of Russia’s invasion in Ukraine), and global

sanctions regimes remained increasingly active, creating a complex

regulatory and legislative environment. There has been an increasing

focus on the potential circumvention of sanctions against Russia, and the

roles of third countries and companies in facilitating any circumvention or

undermining the sanctions’ measures. This has prompted a concerted

effort by governments to impose pressure on companies operating in

these jurisdictions, and to prevent sanctions measures being sidestepped

by targeted Russian parties. ING’s sanctions programme is designed to

comply with sanctions across the multiple jurisdictions in which ING has

business operations.

Since February 2022, ING has taken measures to not engage in new

business with and in Russia and follows an active de-risking approach. The

approach aims to reduce ING’s overall exposure towards Russia, including

measures to reduce operational risks and to further ringfence activities of

ING Bank (Eurasia) JSC. On 28 January 2025, ING announced the proposed

sale of ING Bank (Eurasia) JSC to Global Development JSC. Completion of

the transaction is subject to various regulatory approvals. As of the date of

this report and as announced in September 2025, the buyer has not

received all necessary approvals yet. We continue working towards

completing the transaction and our exit from the Russian market. In the

meantime, we are in discussion with regulators on the conflicting

regulatory requirements in various jurisdictions with respect to the

activities of ING Bank (Eurasia) JSC.

As a result of frequent evaluation of the business from economic, strategic

and risk-based perspectives, ING, with limited exception, does not engage

in business involving certain countries, including Cuba, Iran, North Korea,

Sudan, Syria and the Crimea region. ING has a policy not to enter into new

relationships with clients from these countries and processes are in place

to discontinue existing relationships involving these countries.

Public-private partnerships

We continue to work with our peers, regulators and law enforcement in

public-private partnerships (PPPs) in our major markets, and on an

international level, by being part of existing PPPs and by initiating new

partnerships, such as those with German stakeholders and counterparts.

We recognise that our risk management frameworks and controls benefit

from having a direct dialogue with public partners as well as

complementing our understanding of relevant and evolving financial crime

threats and risks. Sharing and applying these insights across the

organisation helps us move beyond technical regulatory compliance and

enhances our ability to manage risks.

Conduct compliance and ethics

ING’s product governance and conduct compliance risk management

amplify that we aim to act in the interest of our customers. Focus areas

include customer protection and transparency (referred to as customer

centricity), market conduct (including counteracting market manipulation

and abuse), anti-competitive conduct, and management of conflicts of

interest.

Customer centricity

Putting our customers at the heart of what we do continues to be reflected

in ING’s Compliance framework around customer centricity. The Customer

Centricity Policy (CCP) sets central norms to meet customer needs on a

continuous basis, from the creation of a product and throughout the full

product lifecycle. In order to ensure the customer voice is reflected in the

way we measure compliance with customer centricity norms, we

developed a data driven approach to measure customer outcomes by

combining customer experience-related data with control data, increasing

our insight into trends and allowing business and Compliance to respond

to potential customer harm at an early stage. In 2025, we have

implemented the EU Accessibility Act setting the minimum norms for the

accessibility of products and services.

ESG

In line with ING’s strategy to put sustainability at the heart of what we do,

the ESG & Ethics team in Group Compliance aims to ensure a structural

and embedded approach to ESG within Compliance. Material ESG-related

topics are increasingly influenced by fast-moving regulatory changes, and

rising stakeholder expectations. To proactively manage these risks, ING is

strengthening its Compliance framework on several fronts. We are

continuing to enhance controls to prevent greenwashing, aligning ESG

commitments with evolving disclosure standards, and integrating physical

and transition risks into customer-centricity assessments. As new

regulations emerge, they are systematically incorporated into our

compliance risk management framework.


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Speak up and ethics

ING wants to create, facilitate and maintain an environment in which

employees feel encouraged and supported to speak up at all times.

Conduct ethics is about supporting and protecting our employees by

means of (i) dealing with dilemmas; (ii) setting the right environment for

ethical decisions and behaviours; and (iii) providing for an escalation/

reporting process in case of concerns, and ensuring fair consequence

management. We rely on our Orange Code, containing the values and

behaviours that guide us, the Global Code of Conduct that prevents and

protects employees from behaving unethically, and the whistleblowing

framework in case of concerns.

A new global platform that enables anonymous reporting has been

implemented across the vast majority of ING locations. We also continued

our focus on anti-retaliation, fair consequence management, deliberate

after-care and aligning best practices and data collection across different

Speak up channels.

Data protection

At ING, data protection is at the core of our strategy and business

operations. As part of our strategic priority of ‘Staying safe & secure’ our

main principle is ‘the right people using the right data for the right

purpose’, i.e. personal data usage and record retention must be strictly

necessary and based on a legitimate basis. More information can be found

in the privacy statement on our corporate website.

As a globally operating bank, our data protection governance and

technical and organisational measures aim to ensure compliance with

European and local data protection laws. A group-wide personal data

protection framework is in place and was overhauled in 2025 to remain

compliant with changing European legislation and guidelines. In addition,

we have binding corporate rules to ensure appropriate safeguards for our

internal data transfers. It is our policy that our business entities, support

functions, as well as third parties that we engage with, ensure that the

data subject is granted a level of protection equivalent to that guaranteed

by the GDPR, especially if personal data is transferred outside of the

European economic area (EEA).

Regulatory developments which potentially lead to emerging or changing

data protection risks are monitored and managed on an ongoing basis.

Advancements in technology, particularly in artificial intelligence and

digitalisation have substantially increased the complexity of personal data

processing activities. These developments demand increased attention

and monitoring to remain within risk appetite and to make sure we

comply with privacy laws and ethical standards. Therefore, we have

further strengthened our data protection risk management by refining

procedures and guidelines, particularly around risk related to technology

and AI. This ensures alignment with applicable information security

standards and enhances our cooperation with third-party providers. This

also includes our regular monitoring and reporting approach.

We will continue to enhance our data protection assessment processes

and continuously perform regular internal audits on the personal data

processing that we do for clients and employees, including ING’s

technologies. We stay closely connected to the relevant supervisory

authorities and notify them as required.


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Model risk

Introduction

Model risk is the risk of financial loss or reputational damage resulting from

decisions that are principally based on the output of models due to errors

in the development, implementation, or use of models.

Model lines of defence

ING’s model risk and control structure is based on the three-model-lines-

of-defence (MLoD) approach and defines three different management

layers with distinct roles and oversight responsibilities.

§ The first MLoD is comprised of business entities which own, use, or

develop models.

§ The second MLoD sets the model risk management framework,

monitors and reports on model-related risk, performs independent

model validation, and challenges 1MLoD risk management activities.

§ The third MLoD is the internal audit function.

Model Risk Management (MoRM)

The ING MoRM policy framework comprises the total set of measures and

tools in place to manage model risk. ING defines and implements controls

across the model lifecycle. ING uses four classes of models that represent

their inherent level of model risk based on their criticality, financial

materiality, and complexity. The model classification determines the depth

and extent of the applied model risk management activities, including

model validation. Model validation is the independent assessment of

whether a model is valid for its intended use. Models are validated

according to procedures applicable to key model types. These procedures

are continuously being enhanced to keep up to date with regulatory and

technical developments, and industry trends.

Model risk appetite (model RAS)

The model risk appetite is designed to determine the level of model risk

ING is willing to accept in pursuit of its strategic objectives. The model RAS

metrics focus on the most material models for ING as reflected via the

model classification. These metrics are reported to the MBB monthly.

On an aggregated level, model risk is monitored via analysis of data from

the global model inventory, collected across the bank to manage ING’s

model landscape. Insights are shared with the MoRM Committee, MBB, and

other stakeholders, enabling senior management to make informed

decisions on whether to accept or further mitigate model risk.

AI risk management

In 2025, ING strengthened its commitment to responsible AI adoption by

creating an AI governance framework and control mechanisms, supported

by ethical principles that are applicable to all AI solutions. There are

dedicated staff allocated to AI risk management to support the risk

assessments in collaboration with the various risk functions. ING adopted a

qualitative Generative AI RAS (Risk Appetite Statement) focused on

customer protection, ethics, and accuracy and performance. The ING RAS

guides early-stage decision-making in areas where quantitative thresholds

are still under development, ING is committed to continue to strengthen its

AI risk management to ensure AI adoption remains safe and secure.

Business & strategy risk

Introduction

Business & strategy risk for ING has been defined as the risk inherent to

strategy decisions and internal efficiency measured by the value or

earnings loss from planning deviations, e.g. non-bank competition, internal

cost pressure, decreasing demand for loans, etc. This risk can be expressed

as earnings loss in terms of volumes, margins, expenses, and fee and

commission income. Business risk is accounted for within the economic

capital framework using a statistical model combined with a forward-

looking scenario module, which covers fee and commission income,

operating expenses, and regulatory expenses/costs.

Risk management

ING applies an explicit risk appetite statement regarding business and

strategy risk. It reflects the risks not already covered within the main risk-

type specific RAS, e.g. capturing risk costs, RWA, or NII. The underlying

economic capital risk types (expense risk, volume-margin risk, and

regulatory costs) are mitigated and managed via the financial

performance of the bank and the business units. Through this process, the

reported numbers are compared quarterly against financial projections

and discussed continuously within different parts of the organisation.

Consolidated financial statements

Consolidated

financial

statements


Consolidated statement of financial position	108
Consolidated statement of profit or loss	109
Consolidated statement of comprehensive income	110
Consolidated statement of changes in equity	111
Consolidated statement of cash flows	114
Notes to the Consolidated financial statements	117
Authorisation of Consolidated Financial Statements	207


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Contents


Consolidated financial statements	106


Consolidated statement of financial position	108
Consolidated statement of profit or loss	109
Consolidated statement of comprehensive income	110
Consolidated statement of changes in equity	111
Consolidated statement of cash flows	114


Notes to the Consolidated financial statements	117
1 Basis of preparation and material accounting policy information	117


Notes to the Consolidated statement of profit or loss	150
21 Net interest income	150
22 Net fee and commission income	151
23 Valuation results and net trading income	151
24 Investment income	152
25 Other net income	152
26 Staff expenses	152
27 Other operating expenses	153


Segment reporting	154
28 Segments	154
29 Information on geographical areas	158


Parent company financial statements	208
Parent company statement of financial position	209
Parent company statement of profit or loss	210
Parent company statement of changes in equity	211
Notes to the parent company financial statements	212


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	108

Consolidated statement of financial position

As at 31 December



in EUR million	2025	2024		2025	2024
Assets			Liabilities
Cash and balances with central banks 2	52,889	70,353	Deposits from banks 12	18,521	16,722
Loans and advances to banks 3	21,204	21,769	Customer deposits 13	724,707	699,725
Financial assets at fair value through profit or loss 4,6			Financial liabilities at fair value through profit or loss 14
– Trading assets	55,734	72,906	– Trading liabilities	23,427	35,255
– Non-trading derivatives	1,657	2,463	– Non-trading derivatives	1,338	2,101
– Designated as at fair value through profit or loss	3,448	5,740	– Designated as at fair value through profit or loss	55,764	49,539
– Mandatorily at fair value through profit or loss	72,322	56,481	Current tax liabilities	411	276
Financial assets at fair value through other comprehensive income 5,6	56,662	46,389	Deferred tax liabilities 32	365	287
Securities at amortised cost 6	53,867	50,273	Provisions 15	913	752
Loans and advances to customers 7	721,779	680,299	Other liabilities 16	10,755	10,596
Investments in associates and joint ventures 8	1,607	1,679	Debt securities in issue 17	103,116	94,459
Property and equipment 9	2,478	2,434	Senior non-preferred debt 18	48,090	49,393
Intangible assets 10	1,510	1,334	Subordinated loans 19	18,100	17,879
Current tax assets	491	599	Total liabilities	1,005,507	976,986
Deferred tax assets 32	893	1,069
Other assets 11	7,965	6,935	Equity 20
			Share capital and share premium	17,067	17,067
			Other reserves	-675	78
			Retained earnings	31,352	25,598
			Shareholders’ equity (parent)	47,744	42,743
			Non-controlling interests	1,255	995
			Total equity	48,999	43,738

Total assets	1,054,507	1,020,724	Total liabilities and equity	1,054,507	1,020,724

References relate to the accompanying notes. These are an integral part of the Consolidated financial statements.


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Consolidated statement of profit or loss

For the years ended 31 December



in EUR million	2025	2024	2023		2025	2024	2023

Interest income using effective interest rate method	43,481	49,221	44,486	Addition to loan loss provisions	1,304	1,194	520
Other interest income	7,568	9,685	7,741	Staff expenses 26	7,600	7,184	6,725
Total interest income	51,049	58,905	52,228	Other operating expenses 27	4,976	4,931	4,838
				Total expenses	13,879	13,310	12,083
Interest expense using effective interest rate method	-29,855	-35,164	-28,693
Other interest expense	-6,652	-8,993	-7,726	Result before tax	9,012	9,025	10,318
Total interest expense	-36,507	-44,157	-36,419
				Taxation 32	2,510	2,580	2,926
Net interest income 21	14,542	14,749	15,809	Net result	6,501	6,445	7,392

Fee and commission income	6,292	5,598	5,100	Net result attributable to:
Fee and commission expense	-1,695	-1,596	-1,514	Non-controlling interests	275	258	235
Net fee and commission income 22	4,597	4,002	3,586	Shareholders of the parent	6,226	6,187	7,157
					6,501	6,445	7,392
Valuation results and net trading income 23	3,422	3,407	2,910
Investment income 24	129	13	95
Share of result from associates and joint ventures 8	209	205	149
Impairment of associates and joint ventures 8	-9	-35	-5
Net result on derecognition of financial assets measured at amortised cost	0	-2	3
Other net income 25	3	-3	-146	Dividend per ordinary share	2.43	10.72	22.08
Total income	22,891	22,334	22,401	Total amount of dividend paid (in million euros)	1,129	4,986	10,269

References relate to the accompanying notes. These are an integral part of the Consolidated financial statements.


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Consolidated statement of comprehensive income

For the years ended 31 December



in EUR million	2025	2024	2023
Net result	6,501	6,445	7,392

Other comprehensive income
Items that will not be reclassified to the statement of profit or loss:
Unrealised revaluations property in own use	7	3	10
Remeasurement of the net defined benefit asset/liability	-4	-16	-85
Change in fair value of equity instruments at fair value through other comprehensive income	-364	664	-30
Changes in fair value related to changes in own credit risk for financial liabilities designated at fair value through profit or loss	-34	-46	-39

Items that may subsequently be reclassified to the statement of profit or loss:
Change in fair value of debt instruments at fair value through other comprehensive income	457	-261	68
Realised gains/losses on debt instruments at fair value through other comprehensive income reclassified to the statement of profit or loss	-21	63	9
Changes in cash flow hedge reserve	763	383	1,138
Exchange rate differences	-774	563	-85
Total other comprehensive income	30	1,353	986
Total comprehensive income	6,531	7,798	8,378

Total comprehensive income attributable to:
Non-controlling interests	456	303	444
Shareholders of the parent	6,075	7,495	7,934
	6,531	7,798	8,378

Each component of the other comprehensive income is presented after taxation. For the disclosure on the income tax effects on each component, reference is made to Note 32 'Taxation'.


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Consolidated statement of changes in equity



in EUR million	Share capital and share premium	Other reserves	Retained earnings	Shareholders' equity (parent)	Non-controlling interests	Total equity
Balance as at 31 December 2024	17,067	78	25,598	42,743	995	43,738
Net result		14	6,212	6,226	275	6,501
Other comprehensive income		-151		-151	181	30
Total comprehensive income net of tax		-137	6,212	6,075	456	6,531

Dividends			-1,129	-1,129	-195	-1,324
Employee share-based compensation plans			52	52	0	52
Transfers		-616	616
Other changes			3	3	-1	2

Balance as at 31 December 2025	17,067	-675	31,352	47,744	1,255	48,999

Changes in individual Reserve components are presented in Note 20 'Equity'.


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Consolidated statement of changes in equity - continued



in EUR million	Share capital and share premium	Other reserves	Retained earnings	Shareholders' equity (parent)	Non-controlling interests	Total equity
Balance as at 31 December 2023	17,067	-769	23,893	40,191	944	41,135
Net result		125	6,062	6,187	258	6,445
Other comprehensive income		1,307		1,307	46	1,353
Total comprehensive income net of tax		1,432	6,062	7,495	303	7,798

Dividends			-4,986	-4,986	-253	-5,239
Employee share-based compensation plans			45	45	0	45
Transfers		-585	585
Other changes			-1	-1	0	-1

Balance as at 31 December 2024	17,067	78	25,598	42,743	995	43,738

Changes in individual Reserve components are presented in Note 20 'Equity'.


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Consolidated statement of changes in equity - continued



in EUR million	Share capital and share premium	Other reserves	Retained earnings	Shareholders' equity (parent)	Non-controlling interests	Total equity
Balance as at 31 December 2022	17,067	-984	26,462	42,546	504	43,050
Impact of changes in accounting policies ¹			-45	-45	-1	-46
Balance as at 1 January 2023	17,067	-984	26,417	42,500	503	43,004
Net result		336	6,821	7,157	235	7,392
Other comprehensive income		777		777	209	986
Total comprehensive income net of tax		1,113	6,821	7,934	444	8,378

Dividends			-10,269	-10,269	-3	-10,272
Employee share-based compensation plans			30	30	0	30
Transfers		-899	899
Other changes			-5	-5	0	-5

Balance as at 31 December 2023	17,067	-769	23,893	40,191	944	41,135

¹Changes in policy following the adoption of IFRS 17 and change in policy for non-financial guarantees.

Changes in individual Reserve components are presented in Note 20 'Equity'.


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Consolidated statement of cash flows



in EUR million, for the years ended 31 December		2025	2024	2023
Cash flows from operating activities
Result before tax		9,012	9,025	10,318
Adjusted for:	– Depreciation and amortisation	665	673	674
	– Addition to loan loss provisions	1,304	1,194	520
	– Revaluations	3,437	-780	-2,836
	– Exchange rate differences and other	-427	1,134	447
Taxation paid		-2,250	-2,753	-2,700
Changes in:	– Loans and advances to banks, not available on demand	3,546	-7,736	12,693
	– Deposits from banks, not payable on demand	1,098	-7,819	-31,804
	– Trading assets	17,211	-12,663	-3,366
	– Trading liabilities	-11,829	-1,964	-1,869
	– Loans and advances to customers	-58,376	-34,416	-5,815
	– Customer deposits	31,488	38,916	12,541
	– Non–trading derivatives	1,486	-54	2,409
	– Assets designated at fair value through profit or loss	1,218	35	256
	– Assets mandatorily at fair value through profit or loss	-18,984	274	-7,402
	– Other assets	-915	265	1,724
	– Other financial liabilities at fair value through profit or loss	10,024	-7,801	4,384
	– Provisions and other liabilities	1,152	-635	2,143
Net cash flow from/(used in) operating activities		-11,140	-25,105	-7,682

Cash flows from investing activities
Investments and advances:	- Associates and joint ventures	-1	-26	-55
	- Financial assets at fair value through other comprehensive income	-43,294	-21,091	-19,995
	– Securities at amortised cost¹	-152,945	-110,052	-49,614
	– Property and equipment	-351	-332	-246



		2025	2024	2023
	– Other investments	-421	-383	-310
Disposals and redemptions:	– Associates and joint ventures	225	107	164
	- Financial assets at fair value through other comprehensive income	33,095	16,949	11,913
	– Securities at amortised cost¹	147,953	108,732	49,525
	– Property and equipment	39	50	57
	– Other investments	4	13	15
Net cash flow from/(used in) investing activities		-15,697	-6,033	-8,545

Cash flows from financing activities
Proceeds from senior non-preferred debt		7,464	9,533	7,013
Repayments of senior non-preferred debt		-6,749	-3,692	-5,451
Proceeds from debt securities ¹		142,965	115,308	110,477
Repayments of debt securities ¹		-129,996	-109,358	-86,061
Proceeds from issuance of subordinated loans		3,734	4,603	2,225
Repayments of subordinated loans		-2,808	-2,931	-2,894
Repayments of principal portion of lease liabilities		-282	-290	-291
Dividends and other cash distributions paid		-1,324	-5,239	-10,272
Net cash flow from/(used in) financing activities		13,006	7,935	14,746


Net cash flow		-13,831	-23,203	-1,481

Cash and cash equivalents at beginning of year		69,068	93,011	95,390
Effect of exchange rate changes on cash and cash equivalents		-1,089	-740	-898
Cash and cash equivalents at end of year		54,148	69,068	93,011

¹Cash flows are reported on a gross basis and include investments and borrowings of short term securities.


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Consolidated statement of cash flows - continued


Cash and cash equivalents
in EUR million	2025	2024	2023
Treasury bills and other eligible bills included in securities at AC	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'.


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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.


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Notes to the Consolidated financial statements

1 Basis of preparation and material accounting policy information

1.1 Reporting entity and authorisation of the Consolidated financial statements

ING Bank N.V. (Naamloze Vennootschap) is a company domiciled in Amsterdam, the Netherlands. Commercial

domiciled in Amsterdam, the Netherlands. These Consolidated financial statements, as at and for the year ended

31 December 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.

The ING Bank Consolidated financial statements, as at and for the year ended 31 December 2025, were authorised

for issue in accordance with a resolution of the Management Board Banking on 23 February 2026. The General

Meeting of the Shareholder may decide not to adopt the financial statements, but may not amend these.

1.2 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 ‘carve-out’ from IAS 39 ‘Financial Instruments: Recognition and

Measurement’ (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 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 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 ‘Financial instruments:

Disclosures’ are included in the ‘Risk management’ section of the Annual Report.

These disclosures are an integral part of ING Bank Consolidated financial statements and are indicated in the ‘Risk

management’ section by the symbol (*). Chapters, paragraphs, graphs or tables within the risk management

section that are indicated with this symbol in the respective headings or table header are considered to be an

integral part of the Consolidated financial statements.

1.3 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 Other operating expenses, to enhance its

relevance and improve comparability. Consequently, comparative figures for 2024 and 2023 have been updated

accordingly.

1.3.1 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:

§ 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.


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1.3.2 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):

§ Amendments to IFRS 9 'Financial Instruments' and IFRS 7 'Financial Instruments: Disclosures':

Classification and Measurement of Financial Instruments (issued in May 2024). The amendments clarify that a

financial liability is derecognised on the ‘settlement date’ and introduce an accounting policy choice to

derecognise financial liabilities settled using an electronic payment system before the settlement date. Other

clarifications relate to the classification of financial assets with ESG linked features, non-recourse loans and

contractually linked instruments. Further, additional disclosure requirements introduced for equity investments

at fair value through other comprehensive income (FVOCI) and financial instruments with contingent cash flow

features.

§ Amendments to IFRS 9 'Financial Instruments' and IFRS 7 'Financial Instruments: Disclosures': Contracts

Referencing Nature-dependent Electricity (issued in December 2024). Amendments clarify accounting for

renewable electricity contracts, including own-use and hedge accounting and related disclosures.

§ Annual Improvements to IFRS Accounting Standards: Volume 11 (issued in July 2024). Amendments include

minor clarifications and corrections across a number of Standards to improve consistency and clarity.

The implementation of the above amendments is expected to have no significant impact on ING Bank's

Consolidated financial statements as they become effective.

Effective in 2027:

§ Amendments to IAS 21 'The Effects of Changes in Foreign Exchange Rates': Translation to a Hyperinflationary

Presentation Currency (issued in November 2025, 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.

§ 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:

– present specified categories (operating, investing, financing, income tax and discontinued operations) and

defined subtotals in the statement of profit or loss;

– provide disclosures on management-defined performance measures (MPMs) in the notes to the financial

statements; and

– improve aggregation and disaggregation.

The implementation of IFRS 18 is expected to have no significant impact on ING 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:

§ IFRS 18 will not affect ING's net profit, but will reclassify income and expenses into new categories in the

statement of profit or loss and introduce a new subtotal line item 'operating profit'.

§ The line items presented in the primary financial statements might change as a result of the enhanced

principles introduced on 'aggregation and disaggregation'. ING does not expect there to be a significant change

in the information that is currently disclosed in the notes because the requirements to disclose material

information remain unchanged.

§ New disclosure requirements for management-defined performance measures (MPMs).

§ For the statement of cash flows, the starting point for calculating cash flows from operating activities will

change to 'operating profit' as noted above.

In addition, in May 2024, the IASB also issued a new accounting Standard IFRS 19 'Subsidiaries without Public

Accountability: Disclosures'. However, it is not applicable for the consolidated financial statements of ING Bank.

1.4 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:

§ Loan loss provisions (financial assets) (refer to Note 1.5.6 ‘Impairment of financial assets');

§ The determination of the fair values of financial assets and liabilities (refer to Note 1.5.3 for ‘Fair values of

financial assets and liabilities’);

§ Investment in associate - assessment of additional impairment losses or reversal of previous impairment losses

(refer to Note 1.10 ‘Investment in associates and joint ventures');

§ Investment in associate - determination of significant influence over associates (refer to Note 1.10 'Investment

in associates and joint ventures'); and

§ Provisions (refer to Note 1.15 ‘Provisions, contingent liabilities and contingent assets’).


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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 Financial instruments

ING Bank applies IFRS 9 ‘Financial Instruments’ to the recognition, classification and measurement, and

derecognition of financial assets and financial liabilities and the impairment of financial assets. ING Bank applies

the requirements of IAS 39 ‘Financial Instruments: Recognition and Measurement’ for hedge accounting purposes.

1.5.1 Recognition and derecognition of financial instruments

Recognition of financial assets

Financial assets are recognised in the balance sheet when ING 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 Classification and measurement of financial instruments

Financial assets

ING Bank classifies its financial assets in the following measurement categories:

§ those to be measured subsequently at fair value (either through OCI, or through profit or loss); and

§ those to be measured at amortised cost (AC).

At initial recognition, ING Bank measures a financial asset at its fair value plus, in the case of a financial asset not

at FVPL, transaction costs that are directly attributable to the acquisition of the financial asset. Transaction costs

of financial assets carried at fair value through profit or loss (FVPL) are expensed in the statement of profit or loss.

Financial assets – Debt instruments

The classification depends on the entity’s business model for managing the financial assets and the contractual

terms of the cash flows at initial recognition.

Business models

Business models are classified as Hold to Collect (HtC), Hold to Collect and Sell (HtC&S) or Other depending on how

a portfolio of financial instruments as a whole is managed. ING Bank’s business models are based on the existing

management structure of the bank, and refined based on an analysis of how businesses are evaluated and

reported, how their specific business risks are managed and on historic and expected future sales. Sales are

permissible in a HtC business model when these are due to an increase in credit risk, take place close to the

maturity date (where the proceeds from the sales approximate the collection of the remaining contractual cash

flows), are insignificant in value (both individually and in aggregate) or are infrequent.

Contractual cash flows Solely Payments of Principal and Interest (SPPI)

The contractual cash flows of a financial asset are assessed to determine whether they represent SPPI. Interest

includes consideration for the time value of money, credit risk and for other basic lending risks such as

consideration for liquidity risk and costs associated with holding the financial asset for a particular period of time.

In addition, interest can include a profit margin that is consistent with a basic lending arrangement. Financial

assets with embedded derivatives are considered in their entirety when determining whether their cash flows are

SPPI.


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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’s 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:

§ Amortised Cost (AC):

Debt instruments that are held for collection of contractual cash flows under a HtC business model where those

cash flows represent SPPI are measured at AC. Interest income from these financial assets is included in Interest

income using the Effective Interest Rate (EIR) method. Any gain or loss arising on derecognition is recognised

directly in profit or loss. Impairment losses are presented as a separate line item in the statement of profit or

loss.

§ FVOCI:

Debt instruments that are held for collection of contractual cash flows and for selling the financial assets under a

HtC&S business model, where the assets’ cash flows represent SPPI, are measured at FVOCI. Movements in the

carrying amount are recognised in OCI, except for the recognition of impairment gains or losses, interest revenue

and foreign exchange gains and losses which are recognised in profit or loss. When the financial asset is

derecognised, the cumulative gain or loss previously recognised in OCI is reclassified from equity to profit or loss

and presented in Investment income or Other net income, based on the specific characteristics of the business

model. Interest income from these financial assets is included in Interest income using the EIR method.

Impairment losses are presented as a separate line item in the statement of profit or loss.

§ FVPL:

Debt instruments that do not meet the criteria for AC or FVOCI are measured at FVPL. This includes debt

instruments that are held-for-trading (presented separately as Trading assets) and all other debt instruments

that do not meet the criteria for AC or FVOCI (presented separately as Mandatorily at FVPL). ING 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 – 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’s core banking

activities.

There is no subsequent recycling of fair value gains and losses to profit or loss following the derecognition of

investments if elected to be classified and measured as FVOCI. However, the cumulative gain or loss is transferred

within equity to retained earnings on derecognition of such equity instruments. Dividends from such investments

continue to be recognised in profit or loss as investment income when ING’s right to receive payments is

established. Impairment requirements are not applicable to equity investments classified and measured as FVOCI.

Other remaining equity investments are measured at FVPL. All changes in the fair value are recognised in

Valuation result and Net trading income in the Consolidated statement of profit or loss.

Financial liabilities

Financial liabilities are classified and subsequently measured at AC, except for financial guarantee contracts,

derivatives and liabilities designated at FVPL. Financial liabilities classified and measured at FVPL are presented as

follows:

§ The amount of change in the fair value that is attributable to changes in own credit risk of the liability

designated at FVPL is presented in OCI. Upon derecognition this Debit Valuation Adjustment (DVA) impact does

not recycle from OCI to profit or loss; and

§ The remaining amount of change in the fair value is presented in profit or loss in ‘Valuation results and net

trading income’. Interest on financial liabilities at FVPL is also recognised in the valuation result, except for items

voluntarily designated as FVPL for which interest is presented within ‘Other interest income (expense).

A financial guarantee contract is a contract that requires ING 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 ‘Financial instruments’ (see section 'Impairment of financial assets') and (b) the amount initially recognised

less, when appropriate, cumulative amortisation recognised in accordance with the revenue recognition principle

of IFRS 15 ‘Revenue from contracts with customers’.


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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 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 ‘Day One Profit or Loss’) 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’s own credit risk by means of a DVA.

To include the funding risk, ING Bank applies an additional ‘Funding Valuation Adjustment’ (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).


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	Significant judgements and critical accounting estimates and assumptions: § Even if market prices are available, when markets are less liquid there may be a range of prices for the same security from different price sources. Selecting the most appropriate price requires judgement and could result in different estimates of fair value. § Valuation techniques are subjective in nature and significant judgement is involved in establishing fair values for certain financial assets and liabilities. Valuation techniques involve various assumptions regarding pricing factors. The use of different valuation techniques and assumptions could produce significantly different estimates of fair value. § Price testing is performed to assess whether the process of valuation has led to an appropriate fair value of the position and to minimise the potential risks of economic losses due to incorrect or misused models. § Assessing whether a market is active, and whether an input is observable and significant, requires judgement. ING 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. § Reference is made to Note 33 'Fair value of assets and liabilities ' and to the ‘Market risk’ paragraph in the ‘Risk management’ section of the Annual Report for the basis of the determination of the fair value of financial instruments and related sensitivities.

1.5.4 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’s 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


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recognised immediately in the statement of profit or loss. Amounts accumulated in the Other Comprehensive

Income are recycled to the statement of profit or loss in the periods in which the hedged item affects net result.

When a hedging instrument expires or is sold, or when a hedge no longer meets the criteria for hedge accounting,

any cumulative gain or loss existing in the Other Comprehensive Income at that time remains in the Other

Comprehensive Income and is recognised when the forecast transaction is ultimately recognised in the statement

of profit or loss. When a forecast transaction is no longer expected to occur, the cumulative gain or loss that was

reported in the Other Comprehensive Income is transferred immediately to the statement of profit or loss.

Net investment hedges

Hedges of net investments in foreign operations are accounted for in a similar way to cash flow hedges. Any gain

or loss on the hedging instrument relating to the effective portion of the hedge is recognised in the Other

Comprehensive Income and the gain or loss relating to the ineffective portion is recognised immediately in the

statement of profit or loss. Gains and losses accumulated in the Other Comprehensive Income are included in the

statement of profit or loss when the foreign operation is disposed.

Benchmark rate reform – specific policies for hedges directly affected by the benchmark rate reform

As explained in the ‘Impact of the benchmark rate reform’ paragraph of the ‘Risk management’ section, a

fundamental review of important interest rate benchmarks has been carried out, and is still ongoing for some of

them (for instance, WIBOR). Interest Rate Benchmark Reform Phase 1 and Phase 2 amendments to IFRS provide

specific reliefs that allow hedge accounting relationships to continue when the benchmark rate reform is ongoing.

Phase 1 reliefs remained relevant for ING 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’s policy is to cease applying Phase 1 reliefs when the relevant contract

(hedging instrument or hedged item) is modified. When this occurs, Phase 2 reliefs become applicable still

allowing hedge accounting relationships to continue. Refer to note ‘Risk management/Impact of the benchmark

rate reform’ for further details on WIBOR transition and ING’s exposures related to WIBOR that have yet to

transition.

Non-trading derivatives that do not qualify for hedge accounting

Derivative instruments that are used by ING Bank as part of its risk management strategies, but which do not

qualify for hedge accounting under ING Bank’s accounting policies, are presented as non-trading derivatives. Non-

trading derivatives are measured at fair value with changes in the fair value taken to the statement of profit or

loss.

1.5.5 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 ‘Offsetting financial assets and liabilities’.

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:

§ Stage 1

Financial assets that have not had a significant increase in credit risk since initial recognition (i.e. no Stage 2 or

3 triggers apply). Assets are classified as Stage 1 upon initial recognition (with the exception of purchased or

originated credit impaired (POCI) assets) and ECL is determined by the probability that a default occurs in the

next 12 months (12 months ECL);

§ Stage 2

Financial assets showing a significant increase in credit risk since initial recognition. For assets in Stage 2 ECL

reflects an estimate on the credit losses over the remaining maturity of the asset (lifetime ECL); or

§ Stage 3

Financial assets that are credit-impaired. Also for these assets ECL is determined over the remaining maturity

of the asset.


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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 ‘Criteria for identifying a significant increase in credit risk (SICR)’ in the ‘Risk

management’ section of the Annual Report.

An asset that is in Stage 2 will move back to Stage 1 when none of the above criteria are in place anymore.

However, if the asset was moved to Stage 2 based on the forbearance status, then the asset stays in Stage 2 for at

least 24 months. If the asset was classified as Stage 2 due to the '30 days past due' trigger, then the asset is

moved back to Stage 1 only after three months from when the trigger no longer applies.

Credit-impaired financial assets (Stage 3)

Financial assets are assessed for credit-impairment at each reporting date and more frequently when

circumstances warrant further assessment. Evidence of credit-impairment includes arrears of over 90 days on any

material credit obligation, indications that the borrower is experiencing significant financial difficulty, a breach of

contract, bankruptcy or distressed restructuring. The definition of 'credit-impaired' under IFRS 9 (Stage 3) is aligned

with the definition of 'default' used by ING 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 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’ 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’s expected credit loss models (PD, LGD, EAD) used for regulatory purposes

have been adjusted. These adjustments include removing embedded prudential conservatism (such as floors) and

converted through-the-cycle estimates to point-in-time estimates. The models assess ECL on the basis of forward-

looking macroeconomic forecasts and other inputs. For most financial assets, the expected life is limited to the

remaining maturity. For overdrafts and certain revolving credit facilities, such as credit cards, the maturity is

estimated based on historical data as these do not have a fixed term or repayment schedule.

Individually assessed assets (Stage 3)

ING 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.


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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’s restructuring/recovery strategy.

The best estimate of ECL is calculated as the weighted-average of the shortfall (gross carrying amount minus

discounted expected future cash flow using the original EIR) per scenario, based on best estimates of expected

future cash flows. Recoveries can arise from, among other things, repayment of the loan, collateral recovery and

the sale of the asset. Cash flows from collateral and other credit enhancements are included in the measurement

of ECL of the related financial asset when it is part of or integral to the contractual terms of the financial asset and

the credit enhancement is not recognised separately. For the individual assessment, with granular (company or

asset-specific) scenarios, specific factors can have a larger impact on the future cash flows than macroeconomic

factors.

When a financial asset is credit-impaired, interest income is no longer recognised based on the gross carrying

amount of the asset. Instead, interest income is calculated by applying the original effective interest rate to the

amortised cost of the asset, which is the gross carrying amount less the related loan loss provision.

Purchased or Originated Credit Impaired (POCI) assets

POCI assets are financial assets that are credit-impaired on initial recognition. Impairment on a POCI asset is

determined based on lifetime ECL from initial recognition. POCI assets are recognised initially at an amount net of

ECL and are measured at AC using a credit-adjusted effective interest rate. In subsequent periods any changes to

the estimated lifetime ECL are recognised in profit or loss. Favourable changes are recognised as an impairment

gain if the lifetime ECL at the reporting date is lower than the estimated lifetime ECL at initial recognition.

Write-off and debt forgiveness

Loans and debt securities are written off (either partially or in full) when there is no reasonable expectation of

recovery and/or collectability of amounts due. The following events can lead to a write-off:

§ After a restructuring has been completed and there is a high improbability of recovery of part of the remaining

loan exposure (including partial debt forgiveness);

§ In a bankruptcy liquidation scenario;

§ After divestment or sale of a credit facility at a discount; and

§ Specific fraud cases with no recourse options.

When a loan is uncollectable, it is written off against the related loan loss provision. Subsequent recoveries of

amounts previously written off are recognised in ‘Addition to loan loss provisions’ in the Consolidated statement of

profit or loss.

Debt forgiveness (or debt settlement) involves write-off, but also involves the forgiveness of a legal obligation, in

whole or in part. This means that ING 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.


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	Significant judgements and critical accounting estimates and assumptions: The calculation of ECL requires a number of judgements and estimates. In particular: § 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. § Forward-looking macroeconomic scenarios used in impairment assessments are uncertain in nature. The use of alternate forward-looking macroeconomic scenarios can produce significantly different estimates of ECL. This is demonstrated in the sensitivity analysis in the ‘Risk Management’ section of the annual report, where the un-weighted ECL under each of the three scenarios for some significant portfolios is disclosed. § When determining whether the credit risk on a financial asset has increased significantly (criteria for identifying a significant increase in credit risk), ING 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’s PD with the PD banding thresholds determines its ECL Stage. Assets in Stage 1 are allocated a 12 month ECL, and those in Stage 2 are allocated a lifetime ECL, and the difference is often significant. As such, the judgement made in assigning financial asset PDs and the PD banding thresholds constitutes a significant judgement. Analysis of the sensitivity associated with the assessment of a significant increase in credit risk is presented in the ‘Risk Management’ section of the Annual Report. § Judgement is exercised in management’s evaluation of whether there is objective evidence that exposures are credit-impaired. § To reflect the risks that are not properly captured by the ECL models (including climate risk), a number of management adjustments to the model-based ECL were necessary as at 31 December 2025, which required significant judgement. Reference is made to the ‘Management adjustments applied this reporting period’ paragraph in the ‘Risk management’ section of the Annual Report.

1.5.7 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 ‘Risk Management’

section of the Annual Report for more details) and require analysis on whether the contractual terms have been

substantially modified or not. A similar assessment is needed when contractual terms are modified for reasons

other than forbearance.

ING 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 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 ‘Net interest income’ for the presentation

of ING Bank’s participation in TLTRO programmes.

1.5.9 Financial guarantees purchased (ING as holder)

When ING purchases a financial guarantee, it assesses whether the guarantee is integral or non‑integral to the

related loan.

Integral financial guarantees are not accounted for separately but included in the accounting for the loan under

IFRS 9:


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§ For loans measured at amortised cost or FVOCI, the guarantee is reflected in the expected credit loss (ECL)

measurement. Premiums paid are treated as transaction costs and recognised as part of Interest income using

the effective interest rate method.

§ For loans measured at FVTPL, the guarantee is included in the fair value of the loan. Premiums paid are treated

as transaction costs and recognised within Fee and commission expense.

Non‑integral financial guarantees are accounted for separately, within Other assets, by analogy to

reimbursements under IAS 37 'Provisions, Contingent Liabilities and Contingent Assets':

§ For loans measured at amortised cost or FVOCI, a compensation right asset is recognised and measured based

on ECL, provided recovery is virtually certain.

§ Changes in compensation right assets are recognised as a reduction in risk costs within Addition to loan loss

provisions line in profit or loss. Premiums paid are recognised within Fee and commission expense.

§ For loans measured at FVTPL, non‑integral financial guarantees are designated at FVTPL, with premiums

recognised within Fee and commission expense.

1.6 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 ‘Principal subsidiaries’ 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’s own funds over the sum of the paid-up capital and reserves

required by law. Certain Group companies are also subject to other restrictions in certain countries, in addition to

the restrictions on the amount of funds that may be transferred in the form of dividends, or otherwise, to the

parent company.

Furthermore, in addition to the restrictions regarding the minimum capital requirements that are imposed by

industry regulators in the countries in which the subsidiaries operate, other limitations exist in certain countries.

1.7 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 Hyperinflation accounting

Since the second quarter of 2022, Türkiye has been considered a hyperinflationary economy for accounting

purposes. As ING Bank has a subsidiary in Türkiye, ING Bank has applied IAS 29 ‘Financial Reporting in

Hyperinflationary Economies’ to its operations since then. IAS 29 continued to be relevant for ING’s operations in

Türkiye in 2023, 2024 and 2025. Under IAS 29, the results of the operations in Türkiye should be stated in terms of

the current purchasing power at the reporting date. For that, the consumer price index (CPI) as determined by the

Turkish Statistical Institute was used.The CPI for Türkiye (2003=100) at 31 December 2025 was 3,513.87, at 31

December 2024 was 2,684.55 and at 31 December 2023 it was 1,859.38 (movement 2025: 30.89%; 2024: 44.38%,

2023: 64.77%). The effect of such restatement for inflation in the current period of the statement of

comprehensive income and the balance sheet has been recognised in the statement of profit or loss within ‘Other

net income’ as a ‘Net monetary gain or loss’. The net monetary loss for the period represents the loss of

purchasing power by the net monetary position (monetary assets exceeding monetary liabilities) of ING Türkiye.

After the application of the above restatement procedures in Turkish Lira under IAS 29, the financial position and

the results for the period of ING Türkiye were translated and presented in EUR at the exchange rate on 31

December 2025. For the statement of comprehensive income this is in contrast with the usual translation

procedures where items of comprehensive income are translated at the exchange rate at the date of transaction.

Furthermore, ING Bank chose to present both the restatement effect resulting from restating ING Bank’s interest in

the equity of ING Türkiye 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.


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1.9 Foreign currency translation

Functional and presentation currency

Items included in the financial statements of each of ING Bank’s entities are measured using the currency of the

primary economic environment in which the entity operates (the functional currency). The Consolidated financial

statements are presented in euros, which is ING Bank’s presentation currency.

Transactions and balances

Foreign currency transactions are translated into the functional currency using the exchange rate prevailing at the

date of the transactions. Exchange rate differences resulting from the settlement of such transactions and from

the translation at year-end exchange rates of monetary assets and liabilities denominated in foreign currencies

are recognised in the statement of profit or loss, except when deferred in equity as part of qualifying cash flow

hedges or qualifying net investment hedges.

Non-monetary items that are measured in terms of historical cost in a foreign currency are translated using the

exchange rate at the date of the transaction.

Exchange rate differences on non-monetary items, measured at fair value through profit or loss, are reported as

part of the fair value gain or loss. Non-monetary items are retranslated at the date the fair value is determined.

Exchange rate differences on non-monetary items measured at fair value through other comprehensive income

are included in other comprehensive income and get accumulated in the revaluation reserve in equity.

Exchange rate differences in the statement of profit or loss are generally included in ‘Valuation results and net

trading income’. Reference is made to Note 23 ‘Valuation results and net trading income’, which discloses the

amounts included in the statement of profit or loss. Exchange rate differences relating to the disposal of debt and

FVPL equity securities are considered to be an inherent part of the capital gains and losses recognised in

Investment income. As mentioned below, in Group companies relating to the disposals of group companies, any

exchange rate difference deferred in equity is recognised in the statement of profit or loss in ‘Result on disposal of

group companies’. Reference is also made to Note 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:

§ Assets and liabilities are translated at the closing rate at the date of the statement of financial position;

§ Income and expenses are translated at average exchange rates (unless this average is not a reasonable

approximation of the cumulative effect of the rates prevailing on the transaction dates, in which case income

and expenses are translated at the dates of the transactions). However, under hyperinflation accounting,

income and expenses of ING Türkiye are translated at the closing rate; and

§ All resulting exchange rate differences are recognised in a separate component of equity.

On consolidation, exchange rate differences arising from the translation of a monetary item that forms part of the

net investment in a foreign operation, and of borrowings and other instruments designated as hedges of such

investments, are taken to shareholders’ equity. When a foreign operation is sold, the corresponding exchange rate

differences are recognised in the statement of profit or loss as part of the gain or loss on sale.

Goodwill and fair value adjustments arising from the acquisition of a foreign operation are treated as assets and

liabilities of the foreign operation and translated at the exchange rate prevailing at the balance sheet date.

1.10 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:

§ Representation on the board of directors;

§ Participation in the policymaking process; and

§ Interchange of managerial personnel.

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’s investment in associates and joint ventures (net of any accumulated

impairment loss) includes goodwill identified on acquisition. ING Bank’s share of its associates and joint ventures

post-acquisition profits or losses is recognised in the statement of profit or loss, and its share of post-acquisition

changes in reserves is recognised in equity. The cumulative post-acquisition changes are adjusted against the

carrying amount of the investment. When ING Bank’s share of losses in an associate or joint venture equals or

exceeds its interest in the associate or joint venture, including any long-term interests in the associate like

uncollateralised loans that are neither planned nor likely to be settled in the foreseeable future, ING 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’s interest in the associates and joint ventures. Unrealised losses are also eliminated unless they

provide evidence of an impairment of the asset transferred. Accounting policies of associates and joint ventures

have been changed where necessary to ensure consistency with the policies adopted by ING Bank.


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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’s investment in TMBThanachart Bank Public Company Limited (hereafter: TTB), an associate, requires significant judgement. When there is objective evidence of impairment or indicators that prior period impairment losses no longer exist or may have decreased, value in use (VIU) needs to be determined. Estimation of VIU involves significant estimates and management assumptions. See Note 8 ‘Investment in associates and joint ventures’. Determination of significant influence over associates It is presumed that an entity has significant influence when it holds 20% or more of the voting power of the investee. Conversely, it is presumed that an entity does not have significant influence when voting power is less than 20% in the investee. Depending on the facts and circumstances, the presumption is rebutted when ING can clearly demonstrate whether or not it has power to participate in the investee’s financial and operating policy decisions. The consideration of all relevant factors requires judgement, including, amongst others, the investment purpose, investee’s governance structure and legal regime, ability to obtain meaningful board representation and participation in policymaking decisions. Refer to Note 5 'Financial assets at fair value through other comprehensive income' regarding ING’s accounting for its investment in Van Lanschot Kempen.

1.11 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 20–50 years). On disposal, the related revaluation

reserve is transferred to retained earnings.

Equipment

Equipment is stated at cost less accumulated depreciation and any impairment losses. The cost of the assets is

depreciated on a straight line basis over their estimated useful lives, which are generally as follows: two to five

years for data processing equipment, and four to ten years for fixtures and fittings.

Disposals of property and equipment

The difference between the proceeds on disposal and net carrying value is recognised in the statement of profit or

loss under Other net income.

Right-of-use assets - ING 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’s useful life and the lease term on a straight-line basis.

Assets and liabilities arising from a lease are initially measured on a present value basis. Lease liabilities include

the net present value of the following lease payments:

§ Fixed payments (including in-substance fixed payments), less any lease incentives receivable;

§ Variable lease payments that are based on an index or a rate;

§ Amounts expected to be payable by the lessee under residual value guarantees;

§ The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and

§ Payments of penalties for terminating the lease, if the lease term reflects the lessee exercising that option.


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The lease payments are discounted using the interest rate implicit in the lease. If that rate cannot be readily

determined, the lessee’s incremental borrowing rate is used, being the rate that the lessee would have to pay to

borrow the funds necessary to obtain an asset of similar value in a similar economic environment with similar

terms and conditions.

Right-of-use assets are measured at cost comprising the amount of the initial measurement of the lease liability,

any lease payments made at or before the commencement date less any lease incentives received and any initial

direct costs and restoration costs.

The right-of-use asset is included in the statement of financial position line-item ‘Property and equipment’. The

lease liability is included in the statement of financial position line-item ‘Other liabilities’. Refer to Note 9 ‘Property

and equipment’ and to Note 16 ‘Other liabilities’.

Subsequent to initial recognition, the right-of-use asset amortises using a straight-line method to the income

statement over the life of the lease. The lease liability increases for the accrual of interest and decreases when

payments are made. Any remeasurement of the lease liability due to a lease modification or other reassessment

results in a corresponding adjustment to the carrying amount of the right-of-use asset.

1.12 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 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 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.


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1.15 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’ 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 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.


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1.17 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:

§ Return on plan assets are recognised as staff costs in the statement of profit or loss. It is determined using a

high quality corporate bond rate (identical to the discount rate used in determining the defined benefit

obligation) at the start of the reporting period; and

§ Remeasurements which are recognised in Other comprehensive income.

The defined benefit obligation is calculated by internal and external independent qualified actuaries through

actuarial models and calculations using the projected unit credit method. This method considers expected future

payments required to settle the obligation resulting from employee service in the current and prior periods,

discounted using a high quality corporate bond rate. Inherent in these actuarial models are assumptions including

discount rates, rates of increase in future salary and benefit levels, mortality rates, consumer price index and the

expected level of indexation. The assumptions are based on available market data as well as management

expectations and are updated regularly.

Changes in the defined benefit obligation include mainly:

§ Service cost which is recognised as staff costs in the statement of profit or loss;

§ Interest expenses are recognised as staff costs in the Statement of profit or loss. It is determined using a high

quality corporate bond rate at the start of the period;

§ Remeasurements which are recognised in Other comprehensive income (equity) and not recycled to the

Statement of profit or loss;

§ Any past service cost relating to a plan amendment is recognised in profit or loss in the period of the plan

amendment; and

§ Gains and losses on curtailments and settlements are recognised in the Statement of profit or loss when the

curtailment or settlement occurs.

The recognition of a net defined benefit asset in the Consolidated statement of financial position is limited to the

present value of any economic benefits available in the form of refunds from the plans or reductions in future

contributions to the plans.

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 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 ‘Interest income (expense) using effective interest rate method’.

Interest result on financial assets and liabilities voluntarily designated as at FVPL and derivatives in so called

economic hedges and instruments designated at fair value are presented in ‘Other interest income (expense)’.

Interest result on all other financial assets and liabilities at FVTPL is recognised in ‘Valuation results and net trading

income’.


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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 – such as

the arrangement of the acquisition of shares or other securities or the purchase or sale of businesses – are

recognised on completion of the underlying transaction. Portfolio and other management advisory and service

fees are recognised based on the applicable service contracts as the service is provided. Asset management fees

related to investment funds and investment contract fees are recognised on a pro-rata basis over the period the

service is provided. The same principle is applied for wealth management, financial planning and custody services

that are continuously provided over an extended period of time. Fees received and paid between banks for

payment services are classified as commission income and expenses.

Lease income

The proceeds from leasing out assets under operating leases are recognised on a straight-line basis over the life of

the lease agreement. Lease payments received in respect of finance leases when ING 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’s net investment in the lease.

1.19 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’s customers. Costs are generally presented as ‘Commission expenses’ if they are specific, incremental,

directly attributable and identifiable to generate income.

Share-based payments

ING 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 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.

1.21 Parent company financial statements

The Parent company financial statements of ING Bank N.V. are prepared in accordance with the financial reporting

requirements included in Part 9 of Book 2 of the Dutch Civil Code. In accordance with subsection 8 of section 362,

Book 2 of the Dutch Civil Code, the recognition and measurement principles applied in the Parent company

financial statements are the same as those applied in the Consolidated financial statements.


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Notes to the Consolidated statement of financial position

2 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	68,708
Cash and bank balances	1,756	1,645
	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’s 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 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 million (2024: EUR -22 million) of Loan loss provisions.

Loans and advances include balances of reverse repurchase transactions. For more information, refer to Note 4

'Financial assets at fair value through profit or loss' . Furthermore, it includes on-demand and term loans, and cash

collateral transactions. Reference is made to Note 7 'Loans and advances to customers' for information on finance

lease receivables included in Loans and advances to banks.

As at 31 December 2025 and at 31 December 2024, all loans and advances to banks are non-subordinated.

4 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.


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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’s 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
- fair value hedges	578	617
- cash flow hedges	459	158
- 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

‘Financial assets designated at fair value through profit or loss’ is partly economically hedged by credit derivatives.

The hedges do not meet the criteria for hedge accounting and the loans and debt securities are recorded at fair

value to avoid an accounting mismatch. The maximum credit exposure of the loans and receivables and debt

securities included in ‘Financial assets designated at fair value through profit or loss’ approximates its carrying

value and amounts to EUR 3,448 million (2024: EUR 5,740 million). In 2025, the change in fair value of these loans

and debt securities amounts to EUR -177 million (2024: EUR 5 million).


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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 million (2024: EUR 24 million). The cumulative change in fair value attributable to changes in credit

risk for the financial assets non-economically hedged with credit derivatives is EUR 513 million (2024: EUR

489 million) and the change for the current year is EUR 23 million.

The notional value of the related credit derivatives is EUR 2,486 million (2024: EUR 3,807 million). The cumulative

change in fair value of the credit derivatives since the financial assets were first designated, amounts to EUR

-85 million (2024: EUR -214 million) and the change for the current year is EUR 128 million (2024: EUR -95 million).

The changes in fair value attributable to changes in credit risk have been calculated by determining the changes in

credit spread implicit in the fair value of loans and bonds issued by entities with similar credit characteristics.

Mandatorily at fair value through profit or loss


Mandatorily at fair value through profit or loss by type
in EUR million	2025	2024
Equity securities	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 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 December 2025 ING holds 13% (2024: 13%) of the shares of Bank of Beijing, a bank listed on the Shanghai

Stock Exchange. The stake in Bank of Beijing is part of the Corporate Line. As per regulatory requirements set by

the China Banking and Insurance Regulatory Commission, ING, as a shareholder holding more than 5% of the

shares, is required to supply additional capital when necessary. No request for additional capital was received in

2025 (2024: nil).

In 2025 ING increased its ownership in Van Lanschot Kempen by acquiring an additional 17.6% stake, raising its

total interest based on the issued share capital from 2.7% to 20.3%. Despite ING holding over 20% voting rights in

VLK (a presumption of significant influence in IFRS), this presumption is rebutted given that ING holds rights similar

to other ordinary shareholders where voting does not include financial and operating policy decisions and ING

does not have the rights or ability to obtain board representation. Therefore, the increased investment in VLK is

designated at fair value through other comprehensive income consistent with ING’s passive investment purpose.

The stake is part of the Corporate Line.


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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 million (31 December 2024: EUR 62 million) are mainly related to the stake

in Bank of Beijing following the depreciation of CNY versus EUR. In 2025, changes in unrealised revaluations of

equity securities are mainly related to a revaluation of the stake in Bank of Beijing of EUR -225 million (31

December 2024: EUR 590 million) following a change in the share price.

FVOCI debt instruments

In 2025, changes in interest rates and portfolio composition resulted in changes in unrealised revaluations of debt

securities of EUR 322 million (31 December 2024: EUR -96 million).

Reference is made to Note 6 'Debt securities' for details on ING Bank’s total exposure to debt securities.

6 Debt securities

ING Bank’s 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’s total exposure to debt securities (excluding debt securities held in the trading portfolio) of EUR 107,783

million ( 31 December 2024: EUR 97,999 million ) is specified as follows:


Debt securities by type of exposure
	Debt Securities at FVPL ¹		Debt Securities at FVOCI		Debt Securities at AC		Total
in EUR million	2025	2024	2025	2024	2025	2024	2025	2024
Government bonds	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.


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7 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 ‘Risk management – Credit risk’ – paragraphs ‘Credit

quality’ and 'Loan loss provisioning'.

As at 31 December 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
- within 1 year	4,121	3,962
- between 1-2 years	3,040	2,961
- between 2-3 years	2,408	2,283
- between 3-4 years	1,563	1,577
- between 4-5 years	935	902
- 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 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).


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8 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’s statutory

reporting date is 31 December. For the year ending 31 December 2025, ING recognised the associate’s results

using TTB’s financial statements for the 12‑month period ending 30 September 2025.


Selected balance sheet information TMBThanachart Bank Public Company Limited
As at 30 September in EUR million	2025	2024
Loans to customers and accrued interest receivables, net	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’s

financial interest and other arrangements, such as participation in the Board of Directors.

The associates and joint ventures of ING are subject to legal and regulatory restrictions regarding the amount of

dividends they can pay to ING. These restrictions are, for example, dependent on the laws in the country of

incorporation for declaring dividends or as a result of minimum capital requirements that are imposed by industry

regulators in the countries in which the associates and joint ventures operate.


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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 million (2024: EUR 123 million) and

a EUR 44 million gain from the sale of an associate in Belgium, while 2024 included EUR 77 million as our share in

the result of an associate in Belgium following its one-off profit.

Impairments and reversal thereof on the investment in TTB

Accumulated impairments on the investment in TTB of EUR 395 million (2024: EUR 395 million) were recognised in

previous years. There is no impairment trigger observed as per 31 December 2025. A Value in Use ('VIU') was

estimated following the prolonged increase of the quoted TTB share price over the original cost price of the

investment and the sustained improved broker consensus outlook. As the VIU did not significantly exceed the

carrying amount of the investment in TTB, no reversal of impairment was recognised.

Methodology

The recoverable amount is determined as the higher of the fair value less costs of disposal and VIU. Fair value less

costs of disposal is based on observable share price. The VIU calculation uses discounted cash flow projections

based on management’s best estimates. VIU is derived using a Dividend Discount Model (DDM) where distributable

equity, i.e. future earnings available to ordinary shareholders, is used as a proxy for future cash flows. The

valuation looks at expected cash flows into perpetuity resulting in two main components to the VIU calculation:

§ The estimation of future earnings over a 5-year forecast period; and

§ The terminal value being the extrapolation of earnings into perpetuity applying a long-term growth rate. The

earnings that are used for extrapolation represent the stable long-term financial results and position of TTB, i.e.

a steady state. The terminal value comprises the majority of the total VIU.

Key assumptions used in the VIU calculation as at 31 December 2025

The VIU is determined using a valuation model which is subject to multiple management assumptions. The key

assumptions, i.e. those to which the overall result is most sensitive to, are the following:

§ Expected future earnings of TTB: Short- to medium-term expectations are based on forecasts derived from

broker consensus. Longer-term and steady-state expectations into perpetuity are derived using reasonable

and supportable assumptions capturing a combination of TTB specific and market data points; A capital

maintenance charge is applied, which is management’s forecast of the earnings that need to be withheld in

order for TTB to meet target regulatory requirements over the forecast period;

§ Discount rate (cost of equity): 10.17% (2024: 10.96%), based on the capital asset pricing model (CAPM)

calculated for TTB using current market data and expert judgement; and

§ Terminal growth rate: 2.41% (2024: 2.74%) consistent with current long term government bond yield in

Thailand as a proxy for a risk-free rate.

The model was evaluated for reasonably possible changes to key assumptions in the model. This reflects the

sensitivity of the VIU to each key assumption on its own and it is possible that more than one favourable and/or

unfavourable change may occur at the same time. The selected rates of reasonably possible changes to key

assumptions are based on external analysts’ forecasts and other relevant external data sources, which can change

period to period. The sensitivity of the VIU to each key assumption is as follows:

§ A favourable change of 10% in the cash flows would result in an increase in VIU of EUR 89 million (2024: EUR 57

million), while an unfavourable change of -10% would result in a decrease in VIU of EUR -90 million (2024: EUR

-59 million);

§ A favourable change of 1% in the discount rate would result in an increase in VIU of EUR 159 million (2024: EUR

95 million), while an unfavourable change of -1% would result in a decrease in VIU of EUR -122 million (2024:

EUR -75 million);

§ A favourable change of 1% in the terminal growth rate would result in an increase in VIU of EUR 118 million

(2024: EUR 68 million), while an unfavourable change of -1% would result in a decrease in VIU of EUR -90

million (2024: EUR -53 million).


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9 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 871 million ). Cost or the purchase price less accumulated depreciation and

impairments would have been EUR 599 million ( 2024: EUR 476 million) had property in own use been valued at

cost instead of at fair value.

10 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.


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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.

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’s judgement. The long-term growth rate is

based on the long-term inflation rate obtained from market sources. The impacts of climate risk are included to

the extent that they are observable in discount rates and assets prices.

Sensitivity of key assumptions

Key assumptions in the goodwill impairment test model are the projected locally available cash flows (based on

local capital requirements and projected profits), discount rates (cost of equity), and long-term growth rates.

The recoverable amounts of the CGUs are sensitive to the above key assumptions. A decrease in the available cash

flows of 10%, an increase in the discount rate of 1 percent point or a reduction of the future growth rate to zero

are considered reasonably possible changes in key assumptions. If the aforementioned changes occur to one of

the above key assumptions holding the other key assumptions constant, goodwill of the remaining CGUs will

continue to be recoverable.

Software

Software includes internally developed software amounting to EUR 956 million (2024: EUR 768 million). Software

capitalisation amounts increased in 2025 following the significant IT-platform investments in our Retail business.

Software is reviewed for indicators of impairment. Irrespective of whether there is an indication of impairment,

software under development is tested annually for impairment.

11 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


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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.

12 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 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 million (2024: EUR 107,068 million ), EUR 347,234 million (2024: EUR 324,134 million) and

EUR 50,033 million (2024: EUR 56,599 million ).


Customer deposits by type
	Netherlands		Rest of the world		Total
in EUR million	2025	2024	2025	2024	2025	2024
Non-interest bearing	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.

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.

14 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:
- fair value hedges	54	79
- cash flow hedges	254	573
- 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


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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 December 2025, the change in the fair value of financial liabilities designated at fair value through profit

or loss attributable to changes in credit risk is EUR 57 million on a cumulative basis (2024: EUR 17 million ). This

change has been determined as the amount of change in fair value of the financial liability that is not attributable

to changes in market conditions that gave rise to market risk (i.e. mainly interest-rate risk based on yield curves).

The amount that ING 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 11,376 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'.

15 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 ‘Risk

management – Credit risk’ paragraph 'Loan loss provisioning'.


Changes in provisions
	Reorganisation		Litigation		Other provisions		Total
in EUR million	2025	2024	2025	2024	2025	2024	2025	2024
Opening balance as at 1 January	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

or Loss.

As at 31 December 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.


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16 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 million (2024: EUR 290 million).

Amounts to be settled include primarily transactions not settled at the balance sheet date. The nature of these

transactions is short term and have settled after the closing date of the balance sheet. The line Other relates

mainly to amounts payable to suppliers.

17 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 – 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 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.


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19 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- 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.

20 Equity


Total equity
In EUR million	2025	2024	2023
Share capital and share premium
- Share capital	525	525	525
- Share premium	16,542	16,542	16,542
	17,067	17,067	17,067

Other reserves
- Revaluation reserve: Equity securities at FVOCI	1,444	1,816	1,152
- Revaluation reserve: Debt instruments at FVOCI	-41	-479	-277
- Revaluation reserve: Cash flow hedge	-1,096	-1,693	-2,058
- Revaluation reserve: Credit liability	-49	-15	31
- Revaluation reserve: Property in own use	156	161	178
- Net defined benefit asset/liability remeasurement reserve	-345	-333	-317
- Currency translation reserve	-2,774	-1,986	-2,527
- Share 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’ 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 ‘Hyperinflation’ on its investment in Türkiye since 2022. The IAS 29 indexation impact on equity

was EUR 34 million (2024: EUR 50 million; 2023: EUR 54 million) of which EUR 123 million (2024: EUR 202 million;

2023: EUR 284 million) in the currency translation reserve, EUR 0 million ( 2024: EUR 4 million; 2023: EUR 3 million)

in revaluation reserves and EUR -89 million (2024: EUR -156 million; 2023: EUR -234 million) in profit or loss.


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Share capital and share premium


Share capital
	Ordinary shares (par value EUR 1.13)
	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 million (2024: EUR 664 million; 2023: EUR -35 million) includes

revaluation of shares in Bank of Beijing for EUR -403 million (2024: EUR 652 million; 2023: EUR -24 million).


Changes in cash flow hedge and credit liability reserve
	Cash flow hedge			Credit liability
In EUR million	2025	2024	2023	2025	2024	2023
Opening balance	-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


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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 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’s own funds over the sum of the paid-up capital and reserves required by law. Moreover, ING Bank N.V.’s

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’s 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


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determining the appropriate levels of equity in the Bank’s subsidiaries, associates and joint ventures. These

considerations and limitations include, but are not restricted to, minimum capital requirements that are imposed

by industry regulators in the countries in which the subsidiaries, associates and joint ventures operate, or other

limitations which may exist in certain countries and may or may not be temporary in nature. It is not possible to

disclose a reliable quantification of these limitations. 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.’s creditors opposes such a

repayment within two months following the announcement of a resolution to that effect.


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Notes to the Consolidated statement of profit or loss

21 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.


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22 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’s 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 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
– fair value hedges	3,481	-766	-3,028
– cash flow hedges (ineffective portion)	10	35	48
– 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’s

trading books are managed based on internal limits and comprise a mix of products whose results may neutralise

one another. A significant part of the derivatives in the trading portfolio are related to servicing corporate clients in

their risk management to hedge for example currency or interest rate exposures. From a risk perspective, the

gross amount of trading assets must be considered together with the gross amount of trading liabilities, which are

presented separately on the statement of financial position. However, IFRS does not always allow the netting of

these positions in the statement of financial position. Reference is made to Note 4 'Financial assets at fair value

through profit or loss' and Note 14 'Financial liabilities at fair value through profit or loss' for information on trading

assets and trading liabilities respectively.

Securities trading results include the results of market making in instruments such as government securities,

equity securities, corporate debt securities, and money-market instruments. The majority of the risks involved in

security and currency trading are economically hedged with derivatives. The securities trading results are partly

offset by results on these derivatives. Derivatives trading results include the results of derivatives such as interest

rate swaps, options, futures, and forward contracts. Trading gains and losses relating to trading securities still held

as at 31 December 2025 amount to EUR 1,219 million (2024: EUR 20 million; 2023: EUR 160 million).


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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 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’s equity stake in Bank of Beijing.

25 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 Türkiye's

statement of financial position and statement of profit or loss with an offsetting effect in the currency translation

reserve.

26 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 million (2024: EUR 45 million; 2023: EUR 30 million)

relating to equity-settled share-based payment arrangements.


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,


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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 December 2025, total unrecognised compensation costs related to share awards amount to EUR 33

million (2024: EUR 25 million; 2023: EUR 15 million). These costs are expected to be recognised over a weighted

average period of 2.0 years ( 2024: 2.0 years; 2023: 2.0 years).

27 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’s auditors and increases are due to

one-off additional audit procedures and inflation.


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Segment reporting

28 Segments

ING Bank’s 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 Türkiye
Wholesale Banking Rest of World	Other countries in Europe & Middle East, Americas, Asia
Other	Corporate Line


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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’s financial performance,

because it allows investors to understand the primary method used by management to evaluate the Bank’s

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’ book

equity and the currency they operate in.

Corporate Line also includes certain other income and expenses that are not allocated to the banking businesses,

such as our investments in Bank of Beijing and TMBThanachart Bank (Asian stakes) as well as our stake in Van

Lanschot Kempen (which in 2025 was increased to 20.3%). Furthermore, as from 2022, results in the Corporate

Line have been impacted by the application of hyperinflation accounting in the consolidation of our subsidiary in

Türkiye (IAS 29).

Total income within the Corporate Line increased 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 Türkiye). In both years, results also included a receivable related to the prior insolvency

of a financial institution in the Netherlands: EUR 16 million in 2025 and EUR 53 million in 2024.

Operating expenses for the Corporate Line decreased to EUR 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.


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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
	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
– 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
– 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
– 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.


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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
– of which share of result from associates and joint ventures	1	54			11		133	200	-45	87			8		120	170	31				7		107	144
– 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
– 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.


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29 Information on geographical areas

ING Bank’s 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’s country of domicile.

In order to increase ING Bank’s 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

The table below provides additional information, for the years 2025, 2024 and 2023 respectively, on names of

principal subsidiaries and branches, the nature of main activities and the average number of employees on a full

time equivalent basis by country/tax jurisdiction.


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Additional information by country
Geographical area	Country/Tax jurisdiction	Name of principal subsidiary	Main (banking) activity	Average number of employees at full-time equivalent basis			Total income			Total assets			Result before tax			Taxation			Tax paid
				2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023
Netherlands	Netherlands	ING Bank N.V.	Wholesale / Retail	15,280	14,821	14,449	5,434	4,618	5,370	302,740	300,167	292,868	1,444	833	1,651	475	371	514	297	589	601
Belgium	Belgium	ING België N.V.	Wholesale / Retail	5,828	5,994	6,392	3,114	3,274	3,246	137,150	137,225	128,437	890	1,266	1,209	246	325	339	245	272	169
	Luxembourg	ING Luxembourg S.A.	Wholesale / Retail	865	887	939	405	492	608	14,104	13,942	14,392	114	215	349	28	54	89	113	116	40
Germany	Germany	ING DiBa A.G.	Wholesale / Retail	5,673	5,460	5,499	3,733	3,848	3,931	182,899	172,828	168,991	1,887	2,119	2,467	588	686	807	549	663	904
Rest of Europe	Poland ¹	ING Bank Slaski S.A	Wholesale / Retail	11,130	11,575	11,677	2,798	2,620	2,350	61,344	56,090	52,134	1,411	1,313	1,236	310	280	286	241	231	136
	Spain	Branch of ING Bank N.V.	Wholesale / Retail	1,748	1,692	1,576	1,208	1,230	1,165	38,559	35,912	33,083	553	555	541	182	176	128	170	185	114
	Italy	Branch of ING Bank N.V.	Wholesale / Retail	1,335	1,235	1,190	522	514	438	20,313	16,448	14,836	116	120	133	41	38	55	13	16	19
	Romania ¹	Branch of ING Bank N.V.	Wholesale / Retail	4,514	4,282	3,971	778	749	690	14,151	12,937	11,496	364	401	396	63	67	61	69	76	55
	Türkiye	ING Bank A.S.	Wholesale / Retail	2,574	2,795	2,973	208	142	14	4,958	4,897	4,770	-73	-110	-232	3	18	-20	11	5	29
	UK	Branch of ING Bank N.V.	Wholesale	762	741	722	782	811	758	63,746	59,615	50,572	385	249	510	88	52	131	55	70	101
	Switzerland	Branch of ING Bank N.V.	Wholesale	305	300	292	214	228	248	9,641	9,086	8,501	90	104	137	14	16	19	14	29	52
	France ²	Branch of ING Bank N.V.	Wholesale	209	194	194	244	241	252	7,780	7,819	8,322	115	4	122	37	4	33	7	9	7
	Ireland	Branch of ING Bank N.V.	Wholesale	147	119	82	107	135	83	4,047	3,592	3,907	99	99	65	15	15	8	12	10	8
	Czech Republic	Branch of ING Bank N.V.	Wholesale	124	122	134	75	77	76	3,561	3,382	3,191	27	37	33	6	8	6	8	4	10
	Hungary	Branch of ING Bank N.V.	Wholesale	131	128	127	54	63	85	2,183	2,179	1,893	-2	6	35	3	3	7	2	9	9
	Russia	ING Bank (Eurasia) Z.A.O.	Wholesale	239	236	259	186	139	136	1,086	764	925	157	99	151	38	19	31	35	21	20
	Slovakia ¹	Branch of ING Bank N.V.	Wholesale	1,605	1,489	1,347	19	22	20	686	612	618	3	8	11	1	3	2	2	4	2
	Portugal	Branch of ING Bank N.V.	Wholesale	12	11	10	23	23	17	714	815	620	16	18	12	4	4	3	6	4	2
	Ukraine	PJSC ING Bank Ukraine	Wholesale	94	92	91	38	45	53	567	651	590	24	29	44	6	14	22	10	25	7
	Bulgaria	Branch of ING Bank N.V.	Wholesale	64	64	61	25	27	23	611	570	530	6	13	11	1	2	1	3	2	1
	Austria	Branch of ING Bank N.V.	Wholesale	23	20	17	12	10	9	845	394	383	-1	-2	-4	0	0	-1	0	0	1

¹Includes significant number of FTEs in relation to global services provided.

²Public subsidies received, as defined in article 89 of the CRD IV, amounts to EUR 0.0 million (2024: EUR 0.1 million; 2023: EUR 0.2 million).


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Additional information by country (continued)
Geographical area	Country/Tax jurisdiction	Name of principal subsidiary	Main (banking) activity	Average number of employees at full time equivalent basis			Total income			Total assets			Result before tax			Taxation			Tax paid
				2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023
Rest of the World	Australia	ING Bank (Australia) Ltd.	Wholesale / Retail	2,050	1,994	1,820	971	994	1,033	55,976	53,895	52,734	485	460	572	150	142	174	174	195	185
	USA	ING Financial Holdings Corp.	Wholesale	714	659	603	1,262	1,277	1,124	61,483	65,197	66,143	598	759	654	160	195	185	161	175	183
	Singapore	Branch of ING Bank N.V.	Wholesale	590	572	576	403	474	354	38,414	34,593	26,816	206	333	172	30	44	24	44	24	13
	Japan	Branch of ING Bank N.V.	Wholesale	40	32	32	43	42	40	7,401	9,570	14,267	16	25	17	8	5	7	5	4	10
	South Korea	Branch of ING Bank N.V.	Wholesale	89	86	86	84	86	92	8,343	8,050	6,167	34	32	39	8	7	9	-6	7	24
	Hong Kong	Branch of ING Bank N.V.	Wholesale	100	100	104	70	76	101	3,469	3,512	4,378	18	24	-18	3	4	-2	0	0	0
	Taiwan	Branch of ING Bank N.V.	Wholesale	38	37	37	34	27	39	6,054	3,507	2,597	16	4	0	6	1	1	1	3	0
	China	Branch of ING Bank N.V.	Wholesale	80	78	78	25	29	18	1,129	1,935	998	-8	-5	-12	-3	-1	2	2	0	-9
	Philippines ¹	Branch of ING Bank N.V.	Wholesale	6,392	5,290	4,079	16	16	10	496	477	403	17	14	1	2	3	2	3	3	2
	United Arab Emirates	Branch of ING Bank N.V.	Wholesale	14	12	11	0	0	-2	1	1	1	0	0	-3	0	0	0	0	0	0
	Sri Lanka	Branch of ING Hubs B.V.	Global services	1	5	4	0	0	0	2	0	0	0	0	0	0	0	0	0	0	0
	Brazil	ING ADMINISTRAÇÃO LTDA.	In run-off / liquidation	0	0	2	4	4	18	55	63	73	3	3	17	1	25	0	1	1	4
	Mexico	ING Consulting, S.A. de C.V.	In run-off / liquidation	0	0	0	0	0	0	0	0	0	0	0	0	0	0	0	0	0	0
	Canada	Payvision Canada Services Ltd.	Dissolved in 2023	0	0	0	0	0	0	0	0	0	0	0	0	0	0	0	0	0	0
Total				62,770	61,121	59,434	22,891	22,334	22,401	1,054,507	1,020,724	975,636	9,012	9,025	10,318	2,510	2,580	2,926	2,250	2,753	2,700

¹Includes significant number of FTEs in relation to global services provided.


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2025

The higher tax charge of 33% in the Netherlands (compared to the statutory rate of 25.8%) was mainly caused by

the non-deductible Dutch bank tax (EUR 256 million) and other non-deductible expenses.

Since the Russian invasion of Ukraine, ING has a policy in place to take on no new business with Russian clients. In

2025, we have further scaled down operations and continued actions to separate the business from ING’s

networks and systems, which resulted in additional workload for the local operation. On 28 January 2025, an

agreement was announced on the sale of our business in Russia to Global Development JSC. As of the date of this

report, and as announced in September 2025, the buyer has not received all necessary approvals yet. We continue

to work towards completing the transaction and our exit from the Russian market. As reported earlier, on

completion of the divestment we expect a negative P&L impact of around EUR 0.8 billion post tax and a negligible

impact on our CET1 ratio. The local income and result on a standalone basis over 2025 are driven by the high local

interest rate as most of the assets are deposited at the Russian central bank, supported by the appreciation of the

rouble against the euro. Under local law and banking regulations, ING Russia must accept rouble inflows and

deposits from existing clients. We are in discussion with regulators on the conflicting regulatory requirements in

various jurisdictions with respect to the activities of ING Bank (Eurasia) JSC. For further information, reference is

made to Note 32 'Potential sale of ING Bank (Eurasia) JSC'.

2024

The higher tax charge of 45% in the Netherlands (compared to the statutory rate of 25.8%) was mainly caused by

the non-deductible Dutch bank tax (EUR 246 million) and other non-deductible expenses.

The positive tax charge reported for ING Türkiye with respect to its loss was mainly caused by the non-deductibility

for tax purposes of the accounting loss based on hyperinflation accounting.

The high tax charge in Brazil was caused by tax corrections for prior periods in connection with the run-off of our

Brazilian operations.

2023

The higher tax charge of 31% in the Netherlands (compared to the statutory rate of 25.8%) was mainly caused by

the non-deductible Dutch bank tax (EUR 189 million) and other non-deductible expenses.

The lower tax charge in Spain was caused by a tax refund (EUR 43 million) regarding previous years.

ING continued reducing Russian-related exposure during 2023, the local results on a standalone basis were

positively impacted by releases of loan loss provisions following improved macroeconomic indicators and decrease

in exposures following sales and repayments.

The lower negative tax charge reported for ING Türkiye with respect to its loss was mainly caused by the non

deductibility for tax purposes of the accounting loss based on hyperinflation accounting.


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Additional notes to the consolidated financial statements

30 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’s

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’s 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’s CET1 ratio.

31 Pensions and other post-employment benefits

Most group companies sponsor defined contribution pension plans. The assets of all ING Bank’s 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’s

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.


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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 December 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 December 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:


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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’ 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 million (2024: EUR -118 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 million (2024: EUR 94

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 million(EUR -345 million after tax) as at 31 December 2025 (2024: EUR -447 million; EUR -333 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


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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’s 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.

32 Taxation

Statement of financial position – 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 (-) Net asset (+) opening balance	Change through equity	Change through net result	Exchange rate differences	Changes in the composition of the group and other changes	Net liability (-) Net asset (+) 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:
– Deferred tax liabilities	-287					-365
– 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 ‘Other’, 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

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.


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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 Türkiye.


Changes in deferred tax
in EUR million 2024	Net liability (-) Net asset (+) opening balance	Change through equity	Change through net result	Exchange rate differences	Changes in the composition of the group and other changes	Net liability (-) Net asset (+) 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:
– deferred tax liabilities	-184					-287
– 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 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
Türkiye	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’s investments in subsidiaries and associates as any economic benefit from those investments will not be

taxable at parent company level.


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Statement of profit or loss – 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’s 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 Türkiye, 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 Türkiye, interest expenses, and bank- and local taxes in various countries. Adjustments to prior

periods mainly relate to a tax refund in Spain.

Equity – 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


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33 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.

c) Valuation adjustments

Valuation adjustments are an integral part of the fair value. They are the adjustments to the output from a

valuation technique in order to appropriately determine a fair value in accordance with IFRS13. ING considers

various fair value adjustments including Bid-Offer adjustments, Model Risk adjustments, Bilateral Valuation

Adjustments (BVA, consisting of Credit Valuation Adjustments or CVA, and Debit valuation Adjustments or DVA),

Collateral Valuation Adjustment (CollVA) and Funding Valuation Adjustment (FVA).

For financial instruments where the fair value at initial recognition is based on one or more significant unobservable

inputs, a difference between the transaction price and the fair value resulting from the internal valuation process

can occur. Such difference is referred to as Day One Profit or Day One Loss (hereafter: DOP). ING defers material

DOP of instruments with significant unobservable valuation inputs, which are the financial instruments classified as

Level 3 and financial instruments with material unobservable inputs into CVA which are not necessarily classified as

Level 3. The DOP is amortised over the life of the instrument, or until the significant unobservable inputs become

observable, or until the significant unobservable inputs become non-significant. 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:
– of which release	13	27
– of which amortisation and exchange differences	27	32
Closing balance at 31 December	-91	-94


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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’s

own credit risk by means of DVA.

Bid-Offer Adjustment

For positions priced based upon mid-market input parameters, Bid-Offer adjustments are required in order to

reflect the valuation of that position based on bid price or offer price. In practice this adjustment accounts for the

difference in valuation from ‘mid to bid’ and ‘mid to offer’ 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’s credit risk (i.e. Credit Valuation Adjustment or

CVA) and ING’s own credit risk (Debit Valuation Adjustment or DVA) are taken into account:

§ 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’s credit risk).

§ 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’s credit risk).

The calculation of CVA and DVA on derivatives is based on their expected exposures, and the counterparties’ and

ING’s risk of default, taking into account the collateral agreements as well as netting agreements. The

counterparties’ 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’s exposure to the counterparty increases (decreases))

and right-way risk (which occurs when the probability of default by the counterparty increases (decreases) when

ING’s 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.


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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 – (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 – 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 – 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
– Debt securities	899	824	7,289	8,437	15	67	8,204	9,328
– Deposits	0	0	47,751	45,648	0	0	47,751	45,648
– Trading securities	2,534	3,631	11	12	9	10	2,554	3,653
– 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


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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’s

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. 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 ‘no-arbitrage’ 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.


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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’s 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 December 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’s 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 December 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’s 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 3 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).


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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
– Rates	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%
– FX	2	6	4	8	Option pricing model	Implied volatility (%)	1.7%	2%	42%	15%
– Credit	134	39	48	241	Present value techniques	Credit spread (bps)	10	0	88	91
					Price based	Price (%)	0%	0%	100%	100%
– Equity	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%
– Other	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
– Equity	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.


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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.


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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
	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 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 ‘Valuation results and net trading income’ 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 ‘Net change in fair value of debt instruments at fair value through other comprehensive income’.

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.


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Changes in Level 3 Financial liabilities
	Trading liabilities		Non-trading derivatives		Financial liabilities designated as at fair value through profit or loss		Total
	Trading liabilities		Non-trading derivatives				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 ‘Valuation results and net trading income’ in the statement of profit or loss. The total amount includes EUR 158 million

(2024: EUR -206 million) 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 ‘Valuation results and net trading income’ 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 value movements from using reasonable possible alternatives		Negative fair value 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.


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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’s own credit risk.


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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.


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34 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’s 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’s detailed accounting policies for these three hedge models are set out

in paragraph 1.5 ‘Financial instruments’ of Note 1 ‘Basis of preparation and material accounting policy

information’.

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’s progress in completing the transition with

respect to derivatives in hedge accounting relationships.

Fair value hedge accounting

ING’s 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’s approach to managing market

risk, including interest rate risk, is discussed in ‘Risk management –Market risk’. ING’s exposure to interest rate risk

is disclosed in paragraph ‘Interest rate risk in banking book’.

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 ‘carve-out’ 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.


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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
– Interest rate swaps	26,279	19,625	26,963	24,107
– Other interest derivatives	213	13	207	23
Hedging instrument on FX rate risk
– Cross currency swaps			12	3

The derivatives used for fair value hedge accounting are included in the statement of financial position line-item

‘Financial assets at fair value through profit or loss – Non-trading derivatives’ for EUR 578 million (2024: EUR 617

million) respectively ‘Financial liabilities at fair value through profit or loss – Non-trading derivatives’ 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
– Interest rate swaps	4,133	304	17,551	-373	10,494	2,859	-2,524	-52,863	-20,419
– 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
– Other interest derivatives	-4	29	182	248	91	-193	121	383	858
Hedging instrument on FX rate risk
– 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.


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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
– Debt securities at fair value through other comprehensive income	44,165		n/a		-480
– Loans at FVOCI			n/a
– Loans and advances to customers	71,093		-7,441		-2,352
– Debt instruments at amortised cost	20,695		-438		-284
– Debt securities in issue		40,839		-1,193	280
– Senior non-preferred debt		46,566		-934	-325
– Subordinated loans		18,058		-327	-287
– Customer deposits and other funds on deposit		10,040		-9	3
– 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
– Debt securities at fair value through other comprehensive income	35,119		n/a		269
– Loans at FVOCI			n/a		1
– Loans and advances to customers	73,364		-5,177		1,771
– Debt instruments at amortised cost	13,802		-179		49
– Debt securities in issue		38,246		-915	-594
– Senior non-preferred debt		45,423		-1,320	-544
– Subordinated loans		17,143		-665	-188
– Customer deposits and other funds on deposit		29		-1	-14
– 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.


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The main sources of ineffectiveness are:

§ differences in maturities of the hedged item(s) and hedging instrument(s);

§ different interest rate curves applied to discount the hedged item(s) and hedging instrument(s);

§ 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’s 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’s approach to manage market risk, including interest rate risk and foreign currency exchange rate risk, is

discussed in ‘Risk management – Market risk’. 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 ‘Net interest income’ 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 ‘Valuation results and net trading income’.

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 December
Hedging instrument on interest rate risk
– Interest rate swaps	9,414	10,066	10,635	12,814
Hedging instrument on FX rate risk
– Cross currency swaps	1,042	139	472	339
Hedging instrument on combined interest and FX rate risk
– 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

‘Financial assets at fair value through profit or loss – Non-trading derivatives’ EUR 459 million (2024: EUR 158

million) respectively ‘Financial liabilities at fair value through profit or loss – Non-trading derivatives’ 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).


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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
– 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
– Cross currency swaps	456	964	654	-1,271	-446	607	-601	-1,572	-1,210
Hedging instrument on combined interest and FX rate risk
– Cross currency interest rate swaps				-1,246	-1,518				-2,765
As at 31 December 2024
Hedging instrument on interest rate risk
– 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
– Cross currency swaps		-241	-972	122	-1,029	-262	-238	-999	-3,619
Hedging instrument on combined interest and FX rate risk
– 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:


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Cash flow hedging – 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:
– Floating rate lending	-1,265	-1,157	536
– Floating rate borrowing	289	-141	-146
– Other
– Discontinued hedges		-323	7
Total interest rate risk	-977	-1,619	397	602	7
FX rate risk on:
– Floating rate lending	-15	-58	-171
– Floating rate borrowing	34	-4	-38
– Other
– Discontinued hedges			-1
Total FX risk	20	-62	-209	195	3
Combined interest and FX rate risk on:
– Floating rate lending	37	47	-39
– Floating rate borrowing
– Other
– 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 – 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:
– Floating rate lending	-668	-2,850	496
– Floating rate borrowing	114	125	-425
– Other	1	1
– Discontinued hedges		89	-51
Total interest rate risk	-553	-2,635	20	526	39
FX rate risk on:
– Floating rate lending	-79	-55	-121
– Floating rate borrowing	12	5	-37
– Other
– Discontinued hedges			-4
Total FX risk	-67	-51	-162	220	-3
Combined interest and FX rate risk on:
– Floating rate lending	70	72	-68
– Floating rate borrowing
– Other
– 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).


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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:

§ Differences in timing of cash flows of the hedged item(s) and hedging instrument(s); and

§ 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’s 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’s

financial statements. ING’s 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’s 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
– 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 ‘Financial assets at fair value through profit or loss – Non-trading derivatives’ EUR 68 million (2024: EUR 82

million) respectively ‘Financial liabilities at fair value through profit or loss – Non trading derivatives’ EUR 74 million

(2024: EUR 117 million).

For ING’s 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
– FX forwards and cross currency swaps	-6,683	-4,298	-86						-11,066
As at 31 December 2024
– FX forwards and Cross currency swaps	-8,681	-4,158	-76						-12,916


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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 – 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.


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35 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 ‘Risk Management – Funding and liquidity risk’.


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
– Trading assets	20,958	3,508	7,988	11,974	11,305		55,734
– Non-trading derivatives	160	62	185	517	732		1,657
– Mandatorily at fair value through profit or loss	31,075	14,907	14,182	9,967	1,881	310	72,322
– 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
– Equity securities						2,607	2,607
– Debt securities	135	628	1,136	23,026	25,892		50,817
– 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
– Trading assets	22,154	8,044	14,501	16,006	12,202		72,906
– Non-trading derivatives	602	368	465	356	672		2,463
– Mandatorily at fair value through profit or loss	30,002	11,263	7,222	5,931	1,835	228	56,481
– 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
– Equity securities						2,562	2,562
– Debt securities	365	456	2,027	18,064	21,307		42,219
– 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.


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36 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:

§ Perpetual liabilities are included in the column ‘Maturity not applicable’.

§ 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.

§ Undiscounted future coupon interest on financial liabilities payable is included in a separate line and in the

relevant maturity bucket.

§ Non-financial liabilities are included based on a breakdown of the amounts per statement of financial position,

per expected maturity.

§ Loans and other credit-related commitments are classified on the basis of the earliest date they can be drawn

down.

ING Bank’s 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 ‘Risk Management – Funding and liquidity risk’ for a description on how liquidity risk

is managed.


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Liabilities and off-balance sheet commitments by 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	Adjustment ²	Total
Deposits from banks	10,307	2,433	2,392	1,737	1,617		34	18,521
Customer deposits	649,957	26,346	37,769	6,769	2,049		1,816	724,707
Financial liabilities at fair value through profit or loss
– Other trading liabilities	704	48	110	1,028	610		247	2,745
– Trading derivatives	2,509	2,290	4,604	7,508	2,459		1,311	20,681
– Non-trading derivatives	170	199	229	304	128		309	1,338
– Designated at fair value through profit or loss	39,279	6,980	937	4,110	4,558	36	-137	55,764
Debt securities in issue	1,268	17,674	40,682	26,598	17,731		-838	103,116
Senior non preferred debt	2,032	1,139		28,600	16,791		-473	48,090
Subordinated loans					10,612	7,627	-139	18,100
Lease liabilities	15	34	172	574	304		-50	1,050
Financial liabilities	706,242	57,144	86,894	77,227	56,860	7,663	2,081	994,112

Other liabilities ³	7,289	843	2,221	490	553			11,395

Total liabilities	713,531	57,986	89,115	77,717	57,413	7,663	2,081	1,005,507

Coupon interest due on financial liabilities	1,913	1,331	4,661	11,837	8,866	476		29,086

Commitments:
– Guarantees	28,690			552				29,242
– Irrevocable letters of credit	15,230							15,230
Irrevocable facilities	200,000	39	6	77	76			200,198
	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.


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Liabilities and off-balance sheet commitments by maturity
in EUR million
2024	Less than 1 month ¹	1–3 month	3–12 months	1–5 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
– Other trading liabilities	5,790	230	313	1,325	1,465		-34	9,089
– Trading derivatives	2,631	2,367	3,730	7,641	5,499		4,298	26,166
– Non-trading derivatives	419	57	-36	711	149		801	2,101
– 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:
– Guarantees	26,355			3	550			26,908
– 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.

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.


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37 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
– Cash and balances with central banks	499	397
– 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
– equity securities	21,494	22,815
– debt securities	144,257	140,285

of which sold or repledged at fair value
– equity securities	16,018	12,024
– 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'.


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38 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:

§ 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

§ 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’s 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 ‘Credit risk mitigation'.


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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 in the statement of financial position		Net amount	Amounts not subject to enforceable netting arrangements	Statement of financial position total ¹
in EUR million 2025		Gross amounts of recognised financial assets			Financial instruments	Cash and financial instruments received as collateral	Net amount	Amounts not subject to enforceable netting arrangements	Statement of financial position total ¹
Statement of financial position line item	Financial instrument
Loans and advances to banks ²	Reverse repurchase, securities 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‘The statement of financial position total’ is the sum of ‘Net amounts of financial assets presented in the statement of financial position’ and ’Amounts not subject to enforceable master netting arrangements’.

²At 31 December 2025, the total amount of ‘Loans and advances to banks’ 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 ‘Loans and advances to customers’ 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 ‘Other Assets – Amounts to be settled’ 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.


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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 in the statement of financial position		Net amount	Amounts not subject to enforceable netting arrangements	Statement of financial position total ¹
in EUR million 2024		Gross amounts of recognised financial assets			Financial instruments	Cash and financial instruments received as collateral	Net amount	Amounts not subject to enforceable netting arrangements	Statement of financial position total ¹
Statement of financial position line item	Financial instrument
Loans and advances to banks ²	Reverse repurchase, securities 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

²At 31 December 2024, the total amount of ‘Loans and advances to banks’ 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 ‘Loans and advances to customers’ 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 ‘Other Assets – Amounts to be settled’ 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.


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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 ¹
in EUR million 2025		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	Amounts not subject to enforceable netting arrangements	Statement of financial position total ¹
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‘The statement of financial position total’ is the sum of ‘Net amounts of financial liabilities presented in the statement of financial position’ and ’Amounts not subject to enforceable master netting arrangements’.

²At 31 December 2025, the total amount of ‘Deposits from banks’ 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 ‘Customers deposits’ 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 ‘Other Liabilities – Amounts to be settled’ 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.


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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 ¹
in EUR million 2024		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	Amounts not subject to enforceable netting arrangements	Statement of financial position total ¹
Statement of financial position line item	Financial instrument
Deposits from banks²	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

²At 31 December 2024, the total amount of ‘Deposits from banks’ 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 ‘Customers deposits’ 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 ‘Other Liabilities – Amounts to be settled’ 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.


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39 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
– Guarantees	29,242	26,908
– 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’s foreign and domestic trade

transactions in order to finance a shipment of goods. ING Bank’s 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’s credit risk and interest

rate risk in these transactions is limited. The unused portion of irrevocable credit facilities is partly secured by

customers’ 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 “in substance irrevocable” 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 (‘Einlagensicherungsfonds’ 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.

40 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’s 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


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prosecution of ING’s former CEO. In December 2025, the Court decided that ING’s 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 million. 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’s 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 ‘Tribunal Correctionnel’ 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 Türkiye: ING Bank Türkiye has received numerous

claims from (former) customers of legal predecessors of ING Bank Türkiye. The claims are based on offshore

accounts held with these banks, which banks were seized by the Savings Deposit Insurance Fund (“SDIF”) prior to

the acquisition of ING Bank Türkiye in 2007 from OYAK. Pursuant to the acquisition contract, ING Bank Türkiye can

claim compensation from SDIF if a court orders ING Bank Türkiye to pay amounts to the offshore account holders.

SDIF has made payments to ING Bank Türkiye 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’ compensation claims starts on the transfer date of the account holders to the

offshore accounts.

In 2024 SDIF initiated enforcement procedures against ING Bank Türkiye, based on the decision in April 2022 by the

Turkish Supreme Court referred to above. SDIF alleges that this decision means that ING Bank Türkiye 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 Türkiye 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 Türkiye 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,


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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’s 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’ 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’ Association (Consumentenbond) on the

compensation methodology for revolving credits. Based on a Kifid ruling regarding similar products, ING has


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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’ 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 ‘interest-on-interest’-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.

41 Principal subsidiaries, investments in associates and joint ventures

For the majority of ING’s 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’s 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:

§ Representation on the board of directors;

§ Participation in the policymaking process; and

§ 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	Türkiye	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'.


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42 Structured entities

ING Bank’s 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’s 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’s 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’s 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’ 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


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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’s 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.

43 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.


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Associates and joint ventures


Transactions with ING Bank’s 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
– Base salary	4,615	4,306	8,921
– Collective fixed allowances ²	1,094	984	2,078
– Pension costs	83	111	194
– Severance benefits ³	1,347	444	1,791
Variable compensation
– Upfront cash		745	745
– Upfront shares	330	745	1,075
– Deferred cash		1,118	1,118
– Deferred shares	494	1,118	1,613
– Other emoluments⁴	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 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.


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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
– Base salary	4,388	3,598	7,987
– Collective fixed allowances ²	1,033	790	1,823
– Pension costs	84	95	179
– Severance benefits
Variable compensation
– Upfront cash		609	609
– Upfront shares	302	609	911
– Deferred cash		914	914
– Deferred shares	453	914	1,367
– 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	Executive Board of ING Groep N.V.	Management Board Banking ¹	Total
Fixed Compensation
– Base salary	4,220	4,200	8,420
– Collective fixed allowances ²	1,002	887	1,889
– Pension costs	78	107	185
– Severance benefits		734	734
Variable compensation
– Upfront cash		598	598
– Upfront shares	293	598	891
– Deferred cash		897	897
– Deferred shares	439	897	1,336
– 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).

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 thousand). 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 million (2024: EUR 324 thousand)


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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

44 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’s business activities. This includes capital

planning, allocation, and management within the Group, as well as the execution of capital market, term capital

funding, and risk management transactions. ING employs an integrated approach to assessing capital adequacy,

whereby GT considers regulatory and internal economic capital metrics alongside the interests of key

stakeholders, including customers, shareholders, and rating agencies.

ING applies the following main capital definitions:

§ Common Equity Tier 1 (CET1) capital consists of shareholders’ equity after the correction for applicable

regulatory adjustments. The CET1 ratio is calculated as CET1 capital divided by risk-weighted assets (RWAs).

§ Tier 1 capital is defined as CET1 capital plus Additional Tier 1 (AT1) securities and other regulatory adjustments.

The Tier 1 capital ratio is defined as Tier 1 capital divided by RWAs.

§ Total capital consists of Tier 1 capital plus Tier 2 subordinated liabilities, after regulatory adjustments. The Total

capital ratio is calculated as Total capital divided by RWAs.

§ ING’s CET1 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.

§ Leverage ratio (LR) is defined as Tier 1 capital divided by the leverage exposure.

§ Minimum Required Eligible Liabilities (MREL)/ Total Loss Absorbing Capacity (TLAC) is Total capital plus senior

unsecured bonds and amortisations. Related MREL and TLAC ratios are expressed relative to both risk-weighted

assets and leverage exposure.

Capital position as per 31 December 2025


ING Bank capital position according to CRR III / CRD V
in EUR million	2025	2024
Shareholders’ 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‑weighted assets.


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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.

45 Subsequent events

There are no subsequent events to report.


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Authorisation of Consolidated Financial Statements

Amsterdam, 23 February 2026

The Supervisory Board

K.K. (Karl) Guha, chairperson

A.M.G. (Mike) Rees, vice-chairperson

J. (Juan) Colombás

M. (Margarete) Haase

L.J. (Lodewijk) Hijmans van den Bergh

H.A.H. (Herman) Hulst

H.H.J.G. (Harold) Naus

A. (Alexandra) Reich

H.W.P.M.A. (Herna) Verhagen

P.H.M. (Petri) Hofsté

S.O. (Stuart) Graham

The Management Board Banking

S.J.A. (Steven) van Rijswijk, CEO and chairperson

T. (Tanate) Phutrakul, CFO

L. (Ljiljana) Čortan, CRO

P. (Pinar) Abay, head of Retail, Market Leaders and Challengers & Growth Markets

A.J.M. (Andrew) Bester, head of Wholesale Banking

M.A. (Marnix) van Stiphout, Chief operations officer

D. (Daniele) Tonella, Chief technology officer

Parent company financial statements

Parent company

financial

statements


Parent company statement of financial position	209
Parent company statement of profit or loss	210
Parent company statement of changes in equity	211
Notes to the parent company financial statements	212
Authorisation of Parent company financial statements	229


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Parent compan y statement of financial position

as at 31 December before appropriation of result



in EUR million	2025	2024	in EUR million	2025	2024
Assets			Liabilities
Cash and balances with central banks 2	19,949	34,633	Deposits from banks 13	39,356	39,625
Short-dated government paper 3	1,169	270	Customer deposits 14	388,252	368,569
Loans and advances to banks 4	83,588	78,966	Debt securities in issue 15	69,399	61,656
Loans and advances to customers 5	404,283	366,825	Other liabilities 16	52,849	63,675
Debt securities 6	56,049	55,059	Provisions 17	867	697
Equity securities 7	11,495	9,925	Senior non-preferred debt 18	48,090	49,393
Investments in group companies 8	32,613	31,692	Subordinated loans 19	18,109	17,861
Investments in associates and joint ventures 9	1,396	1,378	Total liabilities	616,923	601,475
Intangible assets 10	694	634
Property and equipment 11	1,013	963	Equity 20
Other assets 12	51,607	63,386	Share capital	525	525
Accrued assets	811	488	Share premium	16,542	16,542
			Revaluation reserves	739	733
			Legal and statutory reserves	-1,414	-655
			Other reserves	26,029	21,256
			Unappropriated result	5,323	4,342
			Total equity	47,744	42,743

Total assets	664,667	644,218	Total liabilities and equity	664,667	644,218

T he comparative balances 2024 have been adjusted due to legal mergers using the 'pooling of interests' method. Reference is made to Note 1 'Basis of presentation'.

References relate to the accompanying notes. These form an integral part of the Parent company financial statements.


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Parent company statement of profit or loss

for the years ended 31 December



in EUR million	2025	2024
Interest income	26,399	31,513
Interest expense	-21,037	-26,460
Net interest income 21	5,362	5,053

Investment income and results from participating interests 22	4,047	4,389

Fee and commission income	3,010	2,720
Fee and commission expense	-815	-660
Net fee and commission income 23	2,195	2,060

Results from financial transactions 24	2,252	2,022
Other income	-26	13
Total income	13,830	13,537

Staff expenses 25	3,880	3,657
Depreciation, amortisation and impairments 26	335	354
Other expenses 27	2,144	2,154
Addition to loan loss provisions	273	399
Total expenses	6,633	6,565

Result before tax	7,198	6,972
Taxation 28	971	785
Result after tax	6,226	6,187

The comparative balances 2024 have been adjusted due to legal mergers using the 'pooling of interests' method.

Reference is made to Note 1 'Basis of presentation'

References relate to the accompanying notes. These form an integral part of the Parent company financial

statements.


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Parent company statement of changes in equity



in EUR million	Share capital	Share premium	Revaluation reserves	Legal and statutory reserves	Other reserves	Unappropriated results	Total
Balance as at 31 December 2023	525	16,542	-163	-557	22,379	1,465	40,191

Net result				125		6,062	6,187
Amounts net of tax recognised directly in equity			898	409			1,307

Dividends and other cash distributions					-2,500	-2,486	-4,986
Transfers			-3	-631	1,333	-699
Other changes					44		44

Balance as at 31 December 2024	525	16,542	733	-655	21,256	4,342	42,743

Net result				14		6,212	6,226
Amounts net of tax recognised directly in equity			6	-157			-151

Dividends and other cash distributions					-240	-889	-1,129
Transfers			0	-616	4,958	-4,342
Other changes					55		55

Balance as at 31 December 2025	525	16,542	739	-1,414	26,029	5,323	47,744

Changes in individual Reserve components are presented in Note 20 'Equity'.


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Notes to the parent company financial statements

1 Basis of presentation

ING Bank N.V. ( Naamloze Vennootschap) is registered at Bijlmerdreef 106, 1102 CT Amsterdam, the Netherlands

(Commercial Register of Amsterdam under number 33031431). ING Bank N.V. is a wholly-owned subsidiary of ING

Groep N.V. domiciled in Amsterdam, the Netherlands. ING Bank is a global financial institution with a strong

European base, offering a wide range of retail and wholesale banking services to customers. These Parent financial

statements, as at and for the year ended 31 December 2025, comprise ING Bank N.V. also referred to as ING Bank.

The Parent company financial statements of ING Bank are prepared in accordance with the financial reporting

requirements included in Part 9 of Book 2, of the Dutch Civil Code. In accordance with subsection 8 of section 362,

Book 2 of the Dutch Civil Code, the recognition and measurement principles applied in these Parent company

financial statements are the same as those applied in the ING Bank Consolidated financial statements, reference is

made to Note 1 'Basis of preparation and material accounting policy information' of the consolidated financial

statements.

Investments in group companies are accounted in the Parent company accounts according to the equity method.

In addition to the notes to these financial statements, further information is included in the notes to the

consolidated financial statements. A list containing the information referred to in Section 379 (1), Book 2, of the

Dutch Civil Code has been filed with the office of the Commercial Register of Amsterdam, in accordance with

Section 379 (5), Book 2 of the Dutch Civil Code.

The parent company financial statements are presented in euros, rounded to the nearest million, unless stated

otherwise. Amounts may not add up due to rounding. The ING Bank Parent financial statements, as at and for the

year ended 31 December 2025, were authorised for issue in accordance with a resolution of the Management

Board Banking on 23 February 2026.

Parent company equity and related reserves

The total amount of equity in the Parent company financial statements equals Shareholders’ equity (parent) in the

Consolidated financial statements. Certain components within equity are different, as a result of the following

presentation differences between the parent company accounts and consolidated accounts:

§ Unrealised revaluations including those related to cash flow hedges within consolidated group companies,

presented in Other reserves - Revaluation reserve in the consolidated accounts, are presented in the Share of

associates and joint ventures reserve in the parent company accounts;

§ Foreign currency translation from consolidated group companies, presented in Other reserves - Currency

translation reserve in the consolidated accounts, is presented in the Share of associates and joint ventures

reserve in the parent company accounts;

§ Revaluations on investment property and certain participations recognised in income and consequently

presented in Retained earnings in the consolidated accounts, is presented in the Share of associates and joint

ventures reserve in the parent company accounts.

A legal reserve is carried at an amount equal to the share in the results of associates and joint ventures since their

first inclusion at net asset value less the amount of profit distributions to which rights have accrued in the interim.

Profit distributions which can be repatriated to the Netherlands without restriction are likewise deducted from the

Share of associates and joint ventures reserve.

On 1 July 2025, B.V. Maatschappij van Onroerende Goederen 'Het Middenstandshuis' (a wholly owned subsidiary of

ING Bank N.V.) legally merged into its parent company, ING Bank N.V. The 2025 parent company financial

statements of ING Bank N.V. reflect the combined operations of the merged entities using the 'pooling of interests'

method which requires that the parent's financial statements include the merged business as if the merger was

always effective. Accordingly, 2025 results of ING Bank N.V. include the results of 'Het Middenstandshuis' for the

full year and the comparative figures for prior year have also been updated. The impact on the financial

statements has been limited. Both assets and liabilities of ING Bank N.V. decreased by EUR 0.3 billion in total in

2024. There was no impact on total Equity and total Profit or Loss. The merger had no impact on the activities of

the bank.

Presentation parent company assets and liabilities

The presentation of assets and liabilities in the parent company financial statements differs from the presentation

in the consolidated financial statements. In below tables a reconciliation is included between the presentation in

the parent company versus consolidated financial statements.


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Presentation Parent company financial statements versus Consolidated financial statements, Assets
in EUR million	Parent company statement of financial position
Assets as at 31 December 2025	Cash and balances with central banks	Short-dated government paper	Loans and advances to banks	Loans and advances to customers	Debt securities	Equity securities	Investments in associates and joint ventures	Intangible assets	Property and equipment	Accrued and other assets	Total
Included in Consolidated statement of financial position:
Cash and balances with central banks	19,949										19,949
Loans and advances to banks			58,950								58,950
Financial assets at fair value through profit or loss
– Trading assets		473	783	871	6,743	8,957				36,412	54,239
– Non-trading derivatives										10,270	10,270
– Designated as at fair value through profit or loss		3	871	193	1,915						2,981
– Mandatorily at fair value through profit or loss			22,932	33,168	767	58					56,925
Financial assets at fair value through other comprehensive income		191	52	2,334	22,131	2,480					27,188
Securities at amortised cost		502			24,493						24,995
Loans and advances to customers				367,716							367,716
Investments in associates and joint ventures							1,396				1,396
Property and equipment									1,011		1,011
Intangible assets								694			694
Current tax assets										225	225
Deferred tax assets										473	473
Other assets									2	5,038	5,040
Total assets	19,949	1,169	83,588	404,283	56,049	11,495	1,396	694	1,013	52,418	632,054


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Presentation Parent company financial statements versus Consolidated financial statements, Liabilities
in EUR million	Parent company statement of financial position
Liabilities as at 31 December 2025	Deposits from banks	Customer deposits	Debt securities in issue	Other liabilities	Provisions	Senior non- preferred debt	Subordinated loans	Total
Included in Consolidated statement of financial position:
Deposits from banks	25,373							25,373
Customer deposits		372,616						372,616
Financial liabilities at fair value through profit or loss
– Trading liabilities	90	107		35,078				35,275
– Non-trading derivatives				12,504				12,504
– Designated as at fair value through profit or loss	13,893	15,529	7,881				131	37,433
Current tax liabilities				110				110
Deferred tax liabilities					298			298
Provisions					561			561
Other liabilities				5,157	8			5,166
Debt securities in issue			61,518					61,518
Senior non-preferred debt						48,090		48,090
Subordinated loans							17,978	17,978
Total liabilities	39,356	388,252	69,399	52,849	867	48,090	18,109	616,923


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Notes to the Parent company statement of financial position

2 Cash and balances with central banks

Amounts held at central banks amount to EUR 19,022 million (2024: EUR 33,737 million). In 2025, the movement in

Cash and balances with central banks reflects ING’s active liquidity management.

3 Short-dated government paper

Short-dated government paper includes Dutch and international government paper amounting to EUR 1,169

million (2024: EUR 270 million) for the company.

4 Loans and advances to banks


Loans and advances to banks
in EUR million	2025	2024
Non-subordinated receivables from:
Group companies	37,369	34,124
Third parties	42,359	41,328
	79,728	75,453

Subordinated receivables from:
Group companies	3,860	3,513
	83,588	78,966

As at 31 December 2025, Loans and advances to banks includes receivables with regard to securities, which have

been acquired in reverse repurchase transactions amounting to EUR 30,779 million ( 2024: EUR 32,908 million).

5 Loans and advances to customers


Loans and advances to customers
in EUR million	2025	2024
Non-subordinated receivables from:
ING Groep N.V.	76	67
Group companies	31,544	29,178
Third parties	371,261	336,177
	402,880	365,422

Subordinated receivables from:
Group companies	1,402	1,403
	404,283	366,825

As at 31 December 2025, receivables included in Loans and advances to customers that are part of the trading

portfolio amount to EUR 871 million (2024: EUR 10,961 million).

Loans and advances to customers includes receivables with regard to securities which have been acquired in

reverse repurchase transactions amounting to EUR 34,789 million (2024: EUR 30,682 million) for the company.

6 Debt securities


Debt securities by issuer
in EUR million	2025	2024
Public sector	37,226	33,522
Other	18,823	21,537
	56,049	55,059


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Debt securities by listing
in EUR million	2025	2024
Listed	44,818	41,760
Unlisted	11,231	13,299
	56,049	55,059


Debt securities includes the following non subordinated debt securities:
in EUR million	2025	2024
Non-subordinated debt securities issued by:
Third parties	55,137	54,184
	55,137	54,184


Changes in debt securities¹
in EUR million	2025	2024
Opening balance	41,156	38,072
Additions	31,279	27,616
Amortisation	-38	-60
Changes in unrealised revaluations	-14	-135
Disposals and redemptions	-24,140	-25,275
Exchange rate differences	-1,919	891
Other changes	300	46
Closing balance	46,624	41,156

¹ Excluding fair value through profit or loss portfolio.

7 Equity securities


Equity securities by listing
in EUR million	2025	2024
Listed	11,307	9,756
Unlisted	188	169
	11,495	9,925


Changes in equity securities at fair value through OCI
in EUR million	2025	2024
Opening balance	2,444	1,778
Additions	396	9
Changes in unrealised revaluations	-165	596
Disposals	-1	-1
Exchange rate differences	-178	61
Other changes	-16	0
Closing balance	2,480	2,444

The cost or purchase price of the shares in the trading portfolio of EUR 8,957 million (2024 : EUR 7,450 million)

approximates their fair value. As at 31 December 2025 the cost or purchase price of shares excluding trading

portfolio is EUR 1,408 million lower (2024: EUR 1,773 million lower) than the carrying amount.


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8 Investments in group companies


Investments in group companies
in EUR million		2025		2024
	Interest held (%)	Statement of financial position value	Interest held (%)	Statement of financial position value
ING Holding Deutschland GmbH	100	11,507	100	10,457
ING Belgium S.A./N.V.	100	9,056	100	9,388
ING Bank (Australia) Limited	100	3,348	100	3,466
ING Financial Holdings Corporation	100	2,872	100	3,378
ING Bank Slaski S.A.	75	3,759	75	2,981
ING Bank A.S.	100	511	100	573
ING Bank (Eurasia) JSC	100	598	100	390
ING Corporate Investments B.V.	100	78	100	58
ING Lease (Nederland) B.V.	100	185	100	135
ING Hubs B.V.	100	139	100	149
Other (including financing companies)		559		718
		32,613		31,692

As at 31 December 2025, Investments in group companies includes credit institutions of EUR 17,412 million (2024:

EUR 16,936 million).

As at 31 December 2025 listed investments in group companies amount to EUR 3,759 million (2024: EUR 2,981

million).


Changes in investments in group companies
in EUR million	2025	2024
Opening balance	31,692	30,979
Repayment of capital injection	-162	-33
Revaluations	611	-132
Results from group companies	3,813	4,207
Dividends received	-4,380	-4,745
Capital contribution¹	1,550	1,200
Mergers and liquidations	0	3
Exchange rate differences	-459	209
Other changes	-51	4
Closing balance	32,613	31,692

¹Capital contribution includes EUR 1.6 billion (2024: EUR 1.2 billion) additional Tier 1 subordinated loan provided to ING Holding Deutschland GmbH.

9 Investments in associates and joint ventures


Investments in associates and joint ventures
in EUR million		2025		2024
	Interest held (%)	Statement of financial position value	Interest held (%)	Statement of financial position value
TMBThanachart Bank Public Company	23	1,307	23	1,266
Other		89		111
		1,396		1,378


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Changes in investments in associates and joint ventures
in EUR million	2025	2024
Opening balance	1,378	1,243
Additions	1	6
Share of results	131	115
Dividends received	-82	-70
Disposals	-2
Impairments		-3
Revaluations	35
Exchange rate differences	-54	87
Other changes	-11
Closing balance	1,396	1,378

10 Intangible assets


Changes in intangible assets
		Goodwill		Software		Other		Total
in EUR million	2025	2024	2025	2024	2025	2024	2025	2024
Opening balance	120	119	512	461	1	2	634	582
Additions			211	206			211	206
Disposals			-2	-10			-2	-10
Amortisation			-142	-140	0	0	-142	-140
Impairments			-4	-6			-4	-6
Exchange rate differences	1	1	-2	0	0	0	-1	1
Other changes			0		0		0
Closing balance	121	120	572	512	1	1	694	634

Goodwill is tested for impairment annually.

11 Property and equipment


Changes in property and equipment
in EUR million	2025	2024
Opening balance	963	907
Additions	217	228
Depreciation	-190	-204
Disposals	-2	-8
Impairments	-2	-6
Reversal of impairments	3	2
Exchange rate differences	-3	4
Other changes	27	42
Closing balance	1,013	963

Gross carrying amount as at 31 December	2,396	2,263
Accumulated depreciation as at 31 December	-1,383	-1,300
Net carrying value	1,013	963

Property and equipment includes EUR 30 million (2024: EUR 27 million) cumulative revaluation surplus.

12 Other assets


Other assets
in EUR million	2025	2024
Derivatives	46,682	58,003
Deferred tax assets	473	587
Income tax receivables	225	356
Pension asset	411	445
Other receivables	3,816	3,995
	51,607	63,386

Derivatives includes transactions with group companies of EUR 26,508 million ( 2024: EUR 32,333 million).

Other receivables includes EUR 2,378 million (2024: EUR 2,434 million) related to transactions still to be settled at

balance sheet date. As at 31 December 2025, an amount of EUR 808 million (2024: EUR 676 million) is expected to

be settled after more than one year from the balance sheet date.


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13 Deposits from banks


Deposits from banks by counterparty
in EUR million	2025	2024
Group companies	14,911	18,081
Third parties	24,445	21,543
	39,356	39,625

14 Customer deposits


Customer deposits by counterparty
in EUR million	2025	2024
ING Groep N.V.	3,849	8,583
Group companies	11,539	8,754
Third parties	372,865	351,232
	388,252	368,569


Customer deposits by type
in EUR million	2025	2024
Current accounts / Overnight deposits	129,858	126,253
Savings deposits	177,313	161,578
Time deposits	63,672	65,423
Other	17,409	15,314
	388,252	368,569

15 Debt securities in issue


Debt securities in issue by type
in EUR million	2025	2024
Long term bonds	19,510	17,199
Covered bonds	27,824	25,916
Commercial paper	17,747	14,825
Other	4,319	3,716
	69,399	61,656

16 Other liabilities


Other liabilities
in EUR million	2025	2024
Derivatives	45,965	55,325
Trading liabilities	1,617	2,845
Costs payable	1,035	877
Income tax payable	110	109
Other taxation and social security contribution	199	195
Other amounts payable	3,923	4,324
	52,849	63,675

Derivatives includes transactions with group companies of EUR 28,553 million ( 2024: EUR 32,131 million).

Other amounts payable includes EUR 2,439 million (2024 : EUR 2,817 million) related to transactions still to be

settled at balance sheet date. As at 31 December 2025, an amount of EUR 71 million ( 2024: EUR 74 million) is

expected to be settled after more than one year from the balance sheet date.

17 Provisions


General provisions
in EUR million	2025	2024
Deferred tax liabilities	298	256
Pension liabilities and other staff-related liabilities	8	10
Reorganisations and relocations	193	101
Other	367	330
	867	697

As at 31 December 2025, an amount of EUR 344 million ( 2024: EUR 296 million) is expected to be settled after

more than one year from the balance sheet date.

18 Senior non-preferred debt

All senior non-preferred debt instruments are loans from ING Groep N.V. The average interest rate of Senior non-

preferred debt with a maturity of more than 1 year is 3.4% (2024: 3.3%).


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19 Subordinated loans


Subordinated loans by group companies and third parties
in EUR million	2025	2024
ING Groep N.V.	18,430	18,523
Third parties including value changes hedged part loans	-321	-663
	18,109	17,861


Subordinated loans by type
in EUR million	2025	2024
Capital debentures	2	2
Private loans	18,106	17,858
	18,109	17,861

The subordinated loans rank subordinated to the other liabilities in a winding-up of ING Bank.

The average interest rate of subordinated loans with a maturity of more than 1 year is 4.7% (2024: 4.5% ).

20 Equity


Equity
in EUR million	2025	2024
Share capital	525	525
Share premium	16,542	16,542
Revaluation reserves	739	733
Legal and statutory reserves	-1,414	-655
Other reserves	26,029	21,256
Unappropriated result	5,323	4,342
Total equity	47,744	42,743


Share capital
	Ordinary shares (par value EUR 1.13)
	Number x 1,000		Amount in EUR million
	2025	2024	2025	2024
Authorised share capital	1,600,000	1,600,000	1,808	1,808
Unissued share capital	1,134,965	1,134,965	1,283	1,283
Issued share capital	465,035	465,035	525	525

No changes occurred in the issued share capital and share premium in 2025 and 2024.

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) amounting to EUR 8 ( 2024: EUR

8).


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Changes in revaluation reserves
in EUR million
2025	Property in own use reserve	Equity securities at fair value through other comprehensive income	Debt instruments at fair value through other comprehensive income	Cash flow hedge reserve	Net defined benefit assets/- liability remeasurement reserve	Credit liability	Total
Opening balance	39	1,773	-305	-729	-30	-15	733
Unrealised revaluations	-7	-365	277			-30	-125
Realised gains/losses transferred to the statement of profit or loss			-8				-8
Changes in cash flow hedge reserve				147			147
Change in net defined benefit assets/liability					-8		-8
Closing balance	31	1,408	-36	-582	-38	-45	739
2024
Opening balance	46	1,119	-208	-1,142	-8	30	-163
Unrealised revaluations	-4	654	-125			-46	480
Realised gains/losses transferred to the statement of profit or loss			27				27
Realised revaluations reclassified to retained earnings	-3						-3
Changes in cash flow hedge reserve				413			413
Change in net defined benefit assets/liability					-22		-22
Closing balance	39	1,773	-305	-729	-30	-15	733


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Changes in legal and statutory reserves
in EUR million
2025	Share of associates and joint ventures reserves	Currency translation reserve	Statutory reserves	Capitalised software	Total
Opening balance	11	-2,023	897	460	-655
Result for the year			14		14
Unrealised revaluations available-for-sale investments and other	170				170
Realised gains/losses transferred to the statement of profit or loss	-13				-13
Changes in cash flow hedge reserve	450				450
Unrealised revaluation property in own use	2				2
Changes in net defined benefit asset/liability remeasurement reserve	-5				-5
Exchange rate differences	-26	-762			-788
Changes in composition of the group and other changes	139		-802	74	-590
Closing balance	729	-2,785	108	534	-1,414
2024
Opening balance	0	-2,567	1,602	408	-557
Result for the year			125		125
Unrealised revaluations available-for-sale investments and other	-131				-131
Realised gains/losses transferred to the statement of profit or loss	35				35
Changes in cash flow hedge reserve	-48				-48
Unrealised revaluation property in own use	-10				-10
Changes in net defined benefit asset/liability remeasurement reserve	6				6
Exchange rate differences	-3	544			541
Changes in composition of the group and other changes	163		-830	52	-614
Closing balance	11	-2,023	897	460	-655

The Share of associates and joint ventures reserve includes the following components: Reserve for non-

distributable retained earnings of associates of EUR 1,389 million (2024: EUR 1,250 million), Revaluation reserve of

associates and joint ventures EUR -363 million (2024: EUR -973 million), Currency translation reserve of EUR 11

million (2024: EUR 37 million) and Net defined benefit asset/liability remeasurement reserve of EUR -308 million

(2024: EUR -303 million).

The Statutory reserves include non-distributable reserves of EUR 108 million (2024: EUR 897 million) related to the

former Stichting Regiobank and the former Stichting Vakbondspaarbank SPN that cannot be freely distributed in

accordance with the article 23.1 of the articles of association. The reserve have been utilized for an amount of EUR

-802 million (2024: EUR -830 million) which is presented as part of Changes in the composition of the group and

other changes.

Changes in the value of hedging instruments that are designated as net investment hedges, are included in the

line Exchange rate differences and other.


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Changes in other reserves, retained earnings
in EUR million	2025	2024
Opening balance	21,256	22,379
Transfer from unappropriated result	4,342	699
Dividends and other cash distributions	-240	-2,500
Employee share plans	52	45
Changes in the composition of the group and other changes	619	633
Closing balance	26,029	21,256

Dividends and other cash distributions includes the cash distributions to the parent company ING Groep N.V. to

fund the share buyback programmes.

The reserve for cash flow hedges is included in the Share of associates and joint ventures reserve on a net basis.

The Revaluation reserve, Share of associates and joint ventures reserve and Currency translation reserve cannot be

freely distributed. Retained earnings can be freely distributed, except for an amount equal to the negative balance

in each of the components of the Revaluation reserve , Share of associates and joint ventures reserve and the

Currency translation reserve. Unrealised gains and losses on derivatives, other than those used in cash flow

hedges, are presented in the statement of profit or loss and are therefore part of Retained earnings and are not

included in Share of associates and joint ventures reserve.

The total amount of non-distributable reserves, in accordance with the financial reporting requirements per Part 9

of Book 2 of the Dutch Civil Code, is EUR 6,225 million (2024: EUR 5,672 million).

Reference is made to Note 20 'Equity' and Note 44 'Capital management' in the ING Bank Consolidated financial

statements for additional information, including restrictions with respect to dividend and repayment of capital.


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Notes to the Parent company statement of profit or loss

21 Net interest income


Net interest income
in EUR million	2025	2024		2025	2024
Interest income on loans	16,390	18,748	Interest expense on deposits from banks	977	1,307
Interest income on impaired loans	67	91	Interest expense on customer deposits¹	8,741	9,486
Negative interest on liabilities	12	8	Interest expense on debt securities	1,614	1,899
Total interest income on loans	16,468	18,846	Interest expense on subordinated loans	813	752
			Interest expense on securities at fair value through profit or loss	2,009	2,153
Interest income on financial assets at fair value through OCI	702	551	Interest expense on non-trading derivatives (no hedge accounting)	2,617	4,641
Interest income on financial assets at amortised cost	539	496	Interest expense on non-trading derivatives (hedge accounting)	4,202	6,149
Interest income on securities at fair value through profit or loss	3,083	3,221	Other interest expense	50	64
Interest income on non-trading derivatives (no hedge accounting)	2,532	4,569	Negative interest on assets	14	9
Interest income on non-trading derivatives (hedge accounting)	3,062	3,800	Interest expense	21,037	26,460
Other interest income	12	30
Interest income	26,399	31,513	Net interest income	5,362	5,053

¹Includes interest paid on customer deposits and senior non-preferred debt.

Interest income includes EUR 3,695 million (2024: EUR 5,366 million) from group companies. Interest expense includes EUR 4,839 million (2024: EUR 5,776 million) to group companies.

22 Investment income and results from participating interest


Investment income and results from participating interests
in EUR million	2025	2024
Results from shares and other non-fixed income securities	103	69
Results from group companies	3,813	4,207
Results from associates, joint ventures and other participations	131	116
Impairment of associates and joint ventures	0	-3
	4,047	4,389

Impairments

There were no material impairments of associates and joint ventures in 2025 and 2024.


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23 Net fee and commission income


Fee and commission income
in EUR million	2025	2024
Payment services	1,490	1,341
Securities business	278	240
Insurance and other broking	116	103
Portfolio Management fees	346	299
Lending business	364	336
Financial guarantees and other commitments	265	261
Other	151	140
	3,010	2,720


Fee and commission expenses
in EUR million	2025	2024
Payment services	479	379
Securities business	110	89
Distribution of products (Externally)	111	98
Other	114	94
	815	660

24 Results from financial transactions


Results from financial transactions
in EUR million	2025	2024
Results from securities trading portfolio	2,443	985
Results from foreign exchange transactions	1,877	-287
Results from non-trading derivatives	-864	1,992
Other	-1,204	-668
	2,252	2,022

Result from financial transactions includes EUR -721 million (2024: EUR 358 million) from group companies. Other

includes EUR -629 million (2024: EUR 46 million) related to fair value changes on trading derivatives.

25 Staff expenses


Staff expenses
in EUR million	2025	2024
Salaries	2,626	2,426
Social security costs	325	293
Pension costs and other staff related benefit costs	371	341
Other staff expenses	559	596
	3,880	3,657

The average number of FTE's was 23,743 ( 2024: 23,071 ) of which outside the Netherlands 8,504 (2024 : 8,287).

Remuneration of Senior management, Management board and Supervisory board Reference is made to Note 43

'Related parties' in the ING Bank Consolidated financial statements.

26 Depreciation, amortisation and impairments


Depreciation and amortization
in EUR million	2025	2024
Depreciation of equipment	190	204
Amortisation of software and other intangible assets	142	140
Impairments and reversal of impairments	4	10
	335	354

Impairments includes software (EUR 4 million, 2024 : EUR 6 million) and equipment (EUR 2 million, 2024: EUR 6

million).


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27 Other expenses


Other expenses¹
in EUR million	2025	2024
Promotional and clients acquisition costs	208	212
IT related expenses (excluding outsourcing and subcontracting)	452	407
Outsourcing and subcontracting	420	413
Facilities	130	124
Market data services	98	84
Advisory fees	194	210
Audit and supervisory fees	90	90
Indirect taxes	103	135
Regulatory costs	334	398
Additions and releases of provisions	181	119
Other	(66)	(38)
	2,144	2,154

¹ ING changed the presentation of Other operating expenses as of 2025. The comparative figures for 2024 have been updated accordingly. The

reclassifications do not affect the total amount of Other operating expenses.

28 Taxation



in EUR million	2025	2024
Current taxation	900	760
Deferred taxation	72	25
	971	785


Reconciliation of the weighted average statutory income tax rate to ING Bank’s effective income tax rate
in EUR million	2025	2024
Result before tax from continuing operations	7,198	6,972
Weighted average statutory tax rate	25.0%	24.7%
Weighted average statutory tax amount	1,802	1,725

Permanent differences affecting current tax
Participation exemption	-1,019	-1,144
Other income not subject to tax	-68	-23
Expenses not deductible for tax purposes	255	230
Current tax from previously unrecognised amounts	0	-1
State and local taxes	21	21
Adjustments to prior periods	-22	-27
Differences affecting deferred tax
Impact on deferred tax from change in tax rates	1	0
Deferred tax from previously unrecognised amounts	0	0
Write-off/reversal of deferred tax assets	1	4
Effective tax amount	971	785

Effective tax rate	13.5%	11.3%

For more information on the reconciliation of the weighted average statutory income tax rate to ING Bank’s

effective income tax rate reference is made to Note 32 'Taxation' in the ING Bank Consolidated financial

statements.


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29 Maturity of certain assets and liabilities


Analysis of certain assets and liabilities by maturity
in EUR million 2025	Less than 1 month	1–3 months	3–12 months	1–5 years	Over 5 years	Maturity not applicable	Total
Assets
Loans and advances to banks	14,887	3,629	7,480	27,078	5,850	24,663	83,588
Loans and advances to customers	42,663	12,669	28,617	117,834	168,363	34,138	404,283

Liabilities
Deposits from banks	11,542	2,768	4,626	4,756	948	14,717	39,356
Customer deposits	321,096	18,839	24,828	4,143	2,137	17,209	388,252
Debt securities in issue	1,243	9,365	22,256	12,138	12,334	12,064	69,399
Senior non-preferred debt	2,032	1,139		28,600	16,791	-473	48,090
Subordinated loans					18,117	-8	18,109


Analysis of certain assets and liabilities by maturity
in EUR million 2024	Less than 1 month	1–3 months	3–12 months	1–5 years	Over 5 years	Maturity not applicable	Total
Assets
Loans and advances to banks	17,947	2,602	6,630	23,375	5,151	23,261	78,966
Loans and advances to customers	32,786	13,626	26,729	108,417	155,219	30,047	366,825

Liabilities
Deposits from banks	12,816	4,331	6,837	1,150	673	13,817	39,625
Customer deposits	301,928	13,765	26,156	9,195	2,192	15,333	368,569
Debt securities in issue	1,852	9,305	13,179	13,162	10,602	13,555	61,656
Senior non-preferred debt		975		30,121	19,153	-856	49,393
Subordinated loans					18,237	-376	17,861

30 Assets not freely disposable


Assets not freely disposable
in EUR million	2025	2024
Equity and debt instruments	14,775	22,366
Lending	47,112	46,207
Banks	8,604	6,456
Other assets	407	439
	70,897	75,468

The table includes assets relating to securities lending as well as sale an d repurchase transactions.

31 Commitments


Commitments by type
in EUR million	2025	2024
Guarantees	47,571	48,908
Irrevocable letters of credit	11,822	11,720
Contingent debts	59,393	60,628

Irrevocable facilities	103,763	93,736
	163,155	154,364


Contingent debts
in EUR million	2025	2024
Group companies	28,957	31,535
Third parties	30,435	29,092
	59,393	60,628


Irrevocable facilities
in EUR million	2025	2024
Group companies	0	0
Third parties	103,763	93,736
	103,763	93,736


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32 Other

Guarantees

ING Bank has issued guarantees as participant in collective arrangements of national banking funds and as a

participant in required collective guarantee schemes. For example, ING Bank N.V. provided a guarantee to the

German Deposit Guarantee Fund (‘Einlagensicherundsfonds’ or ESF) under section 5 (10) of the by-laws of this

fund, where ING Bank N.V. indemnifies the Association of German Banks Berlin against any losses it might incur as

result of actions taken with respect to ING Germany. The ESF is a voluntary collective guarantee scheme for retail

savings and deposits in excess of EUR 100,000.

ING Bank N.V. has issued statements of liabilities in connection with Section 403 Book 2 of the Dutch Civil Code

(‘403 statements’) and issued third party guarantees (and third party letters of comfort/awareness) in a limited

number of cases. Third party guarantees are used when ING Bank N.V. is requested to issue a guarantee to a third

party creditor of one of its subsidiaries in order to guarantee the (financial) performance of this subsidiary. 403

statements have been issued for the following Dutch subsidiaries:

§ B.V. Deelnemings- en Financieringsmaatschappij 'Nova Zembla'

§ BMG monumenten B.V.

§ Cofiton B.V.

§ Entero B.V.

§ ING Bank Personeel B.V.

§ ING Hubs B.V.

§ ING Commercial Finance B.V.

§ ING Corporate Investments B.V.

§ ING Corporate Investments Mezzanine Fonds B.V.

§ ING Corporate Investments Participaties B.V.

§ ING Corporate Investments Structured Finance B.V.

§ ING Lease (Nederland) B.V.

§ ING Sustainable Investments B.V.

§ ING Vastgoed Ontwikkeling B.V.

§ Nationale-Nederlanden Intervest II B.V.

§ WestlandUtrecht Verzekeringen B.V.

Claim agreements

In the ordinary course of business we have entered into a number of agreements whereby we are provided

indemnifications related to sale of our past businesses and agreements whereby we made detailed arrangements

regarding allocation and handling of claims.

Fiscal unity

ING Bank N.V. forms a fiscal unity with ING Groep N.V. and several Dutch banking entities for corporation tax

purposes. ING Bank N.V. and ING Groep N.V. and its banking subsidiaries that form part of the fiscal unity are jointly

and severally liable for taxation payable by the fiscal unity. Settlements of corporate income tax paid or received

are executed by ING Bank N.V.

33 Proposed appropriation of results

For 2025 , it is proposed that the result, insofar at the disposal of the General Meeting, will be appropriated as

follows:


Proposed appropriation of result
in EUR million	2025
Net result	6,226
- Addition to reserves pursuant to Article 25 of the Articles of Association	14
- Proposed to be added to the Other Reserves pursuant to Article 25 of the Articles of Association	4,624
- Available for dividend distribution	1,588

The total dividend of EUR 1,588 million was paid in November 2025 (EUR 889 million) and in February 2026 (EUR

699 million) as an interim dividend.

34 Subsequent events

There are no subsequent events to report.


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Authorisation of Parent company financial statements

Amsterdam, 23 February 2026

The Supervisory Board

K.K. (Karl) Guha, chairperson

A.M.G. (Mike) Rees, vice-chairperson

J. (Juan) Colombás

M. (Margarete) Haase

L.J. (Lodewijk) Hijmans van den Bergh

H.A.H. (Herman) Hulst

H.H.J.G. (Harold) Naus

A. (Alexandra) Reich

H.W.P.M.A. (Herna) Verhagen

P.H.M. (Petri) Hofsté

S.O. (Stuart) Graham

The Management Board Banking

S.J.A. (Steven) van Rijswijk, CEO and chairperson

T. (Tanate) Phutrakul, CFO

L. (Ljiljana) Čortan, CRO

P. (Pinar) Abay, head of Retail, Market Leaders and Challengers & Growth Markets

A.J.M. (Andrew) Bester, head of Wholesale Banking

M.A. (Marnix) van Stiphout, Chief operations officer

D. (Daniele) Tonella, Chief technology officer

Other information and appendices

Other information

and appendices


Independent auditor's report	231
Alternative performance measures	239
Articles of Association – Appropriation of results	241
Disclaimer	258


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Independent auditor's report

To: the General Meeting of the Shareholder and the Supervisory Board

of ING Bank N.V.

Report on the audit of the financial statements 2025

included in the annual report

Our opinion

In our opinion:

• the accompanying consolidated financial statements give a true and

fair view of the financial position of ING Bank N.V. as at 31

December 2025 and of its result and its cash flows for the year then

ended, in accordance with International Financial Reporting

Standards (IFRS) as endorsed by the European Union (EU) and with

Part 9 of Book 2 of the Dutch Civil Code;

• the accompanying company financial statements give a true and fair

view of the financial position of ING Bank N.V. as at 31 December

2025 and of its result for the year then ended in accordance with

Part 9 of Book 2 of the Dutch Civil Code.

What we have audited

We have audited the financial statements 2025 of ING Bank N.V. (the

’Company’ or ‘ING Bank’) based in Amsterdam. The financial

statements include the consolidated financial statements and the

company financial statements.

The consolidated financial statements comprise:

1 the consolidated statement of financial position as at 31 December

2025;

2 the following consolidated statements for 2025: the statement of

profit or loss, the statements of comprehensive income, changes in

equity and cash flows; and

3 the notes comprising material accounting policy information and

other explanatory information.

The company financial statements comprise:

1 the parent company statement of financial position as at 31

December 2025;

2 the parent company statement of profit or loss and the statement of

changes in equity for 2025; and

3 the notes comprising the basis of preparation and other explanatory

information.

Basis for our opinion

We conducted our audit in accordance with Dutch law, including the

Dutch Standards on Auditing. Our responsibilities under those

standards are further described in the ‘Our responsibilities for the audit

of the financial statements’ section of our report.

We are independent of ING Bank N.V. in accordance with the

‘Verordening inzake de onafhankelijkheid van accountants bij

assurance-opdrachten’ (ViO, Code of Ethics for Professional

Accountants, a regulation with respect to independence) and other

relevant independence regulations in the Netherlands. Furthermore, we

have complied with the ‘Verordening gedrags- en beroepsregels

accountants’ (VGBA, Dutch Code of Ethics).

We designed our audit procedures in the context of our audit of the

financial statements as a whole and in forming our opinion thereon. The

information in respect of going concern, fraud and non-compliance with

laws and regulations, climate-related risks and the key audit matters

was addressed in this context, and we do not provide a separate

opinion or conclusion on these matters.

We believe the audit evidence we have obtained is sufficient and

appropriate to provide a basis for our opinion.

Information in support of our opinion

Summary

Materiality

•Group materiality of EUR 350 million (2024: EUR 350 million).

•3.9% of profit before tax (2024: 3.9% of profit before tax).

Group audit

•Performed audit procedures over 70% of profit before tax.

•Performed audit procedures over 90% of total assets.


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Risk of material misstatements related to Fraud, Non-compliance

with laws and regulations, Going concern and Climate-related risks

•Fraud risks: presumed risk of management override of controls and

the risk of management override over the collective loan loss

provisioning identified and incorporated in our audit response.

•Non-compliance with laws and regulations (NOCLAR) risks: our

risk assessment procedures related to NOCLAR risks did not result

in the identification of a risk of material misstatement of the 2025

financial statements.

•Going concern risks: no going concern risks identified.

Key audit matters

•Assessment of expected credit losses on loans and advances to

customers and loans and advances to banks.

•User access and change management.

Materiality

Based on our professional judgement we determined the materiality for

the financial statements as a whole at EUR 350 million (2024: EUR 350

million). The materiality is determined with reference to profit before tax

and represents 3.9% (2024: 3.9%) of that number. We consider profit

before tax as the most appropriate benchmark based on our

assessment of the general information needs of the users of the

financial statements and given the fact that ING Bank is a profit-oriented

listed entity. We have also taken into account misstatements and/or

possible misstatements that in our opinion are material for the users of

the financial statements for qualitative reasons.

We agreed with the Audit Committee of the Supervisory Board that

misstatements identified during our audit in excess of EUR 17.5 million

(2024: EUR 17.5 million) would be reported to them, as well as smaller

misstatements that in our view must be reported on qualitative grounds.

Scope of the group audit

ING Bank is at the head of a group of components. The financial

information of this group is included in the consolidated financial

statements of ING Bank.

ING Bank is structured in six segments: Retail Netherlands, Retail

Belgium, Retail Germany, Retail Other, Wholesale Banking and

Corporate Line, each comprising of multiple legal entities and/or

covering different countries.

Because we are ultimately responsible for the group audit, we are

responsible for directing, supervising and performing the group audit. In

this respect, we have determined the nature and extent of audit

procedures to be carried out for group entities or so-called components.

We performed risk assessment procedures throughout our audit to

determine which of ING Bank’s components are likely to include risks of

material misstatement to the 2025 financial statements. To appropriately

respond to those assessed risks, we planned and performed further

audit procedures, either at component level or centrally. Across 16

countries we identified 22 components associated with a risk of material

misstatement. For 17 out of these 22 components we involved

component auditors. We as group auditor audited the remaining

components.

In supervising and directing our component auditors, we:

• Held our annual planning conference in The Netherlands, for

material components in scope of the group audit. Besides discussing

our risk assessment and audit approach with our component

auditors, our component auditors were also directly informed by

ING’s senior management on current internal and external

developments relevant to ING Bank.

• Held risk assessment discussions with component auditors to obtain

their input and to identify matters relevant to the group audit.

• All components in scope for group reporting are audited by KPMG

member firms. We sent detailed audit instructions to all component

auditors, covering significant areas such as the identified risks of

material misstatement on a group level and further set out the

information that is required to be reported to the group audit team.

We received written communication about the results of the work

performed at the component level.

• We set component performance materiality levels considering the

component’s size and risk profile. Component materiality ranges

from EUR 53 million to EUR 125 million, based on the mix of their

relative size and the nature of the risks of material misstatements

identified for the components, in order to reduce aggregation risk to

an acceptable level.

• We held conference calls and/or had remote meetings with the audit

teams of our components and attended closing meetings with

management for components in The Netherlands, Belgium and

Germany. During these meetings and calls, planning, risk

assessment, procedures performed, findings and observations

reported to the group auditor were discussed in detail and any

further work deemed necessary by the group audit team was then

performed.

• Inspected the work performed by component auditors in the

Netherlands, Belgium, Germany, Poland and the United States and

evaluated the appropriateness of audit procedures performed and

conclusions drawn from the audit evidence obtained, and the

relation between communicated findings and work performed. In our

inspection we mainly focused on expected credit losses on loans

and advances to customers as well as procedures performed to

address the risk of management override.

• We performed on site visits of components in Belgium, Luxembourg,

Germany, Poland, Spain and the United States.


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The consolidation of the financial information of components in the

group, the preparation of the disclosures in the financial statements and

certain accounting topics that are performed on a group level were

further covered by the group audit team. Procedures performed by the

group audit team included, but were not limited to, substantive

procedures with respect to equity and certain elements of the expected

credit loss provisioning process.

We have performed audit procedures for 70% of ING Bank’s profit

before tax (2024: 72%) and 90% of ING Bank’s total assets (2024:

90%). At group level, we assessed the aggregation risk in the remaining

financial information and concluded that there is a less than reasonable

possibility of a material misstatement.

We consider that the scope of our group audit forms an appropriate

basis for our audit opinion. Through performing the procedures

mentioned above we obtained sufficient and appropriate audit evidence

about the ING Bank’s financial information to provide an opinion on the

financial statements as a whole.

Audit response to the risk of fraud and non-compliance with

laws and regulations

Introduction

In the Chapter ‘Risk management’, specifically the sections ‘Non-

financial risk’ and Compliance risk’ of the annual report and note 40 of

the financial statements, the Management Board Banking describes its

procedures in respect of the risk of fraud and non-compliance with laws

and regulations. In the Supervisory Board report the assessment in

respect of these topics is described.

As part of our audit, we have gained insights into the Company and its

business environment and the Company’s risk management in relation

to fraud and non-compliance.

Our procedures included, among other things, assessing the

Company’s code of conduct, whistleblowing procedures, incidents

and non-compliance. Furthermore, we performed relevant inquiries with

management, the Audit Committee of the Supervisory Board and other

relevant functions, such as Internal Audit, Legal Counsel and

Compliance. We corroborated these inquiries with the results of our

inspection of correspondence with relevant supervisory authorities and

regulators. We have also incorporated elements of unpredictability in

our audit, such as making changes to our high-risk criteria that we

applied to journal entry testing, varying the timing of audit procedures

including testing of controls and involving forensic specialists in our

audit procedures.

Non-compliance with laws and regulations

As a result of our risk assessment, we identified the following laws and

regulations as those most likely to have a material effect on the financial

statements in case of non-compliance:

• fraud, corruption and anti-bribery law (reflecting the Company’s

significant and geographically diverse nature of operations and

clients);

• data protection law (reflecting the processing of sensitive data

inherent to the Company’s business activities);

• prudential and supervision regulations (reflecting the Company’s

nature of operations);

• anti-money laundering and anti-terrorist financing law (reflecting the

Company’s involvement in a number of ongoing investigations and

(regular) inspections by national competent authorities); and

• sanction law (reflecting the Company’s significant and

geographically diverse nature of operations and clients).

Our procedures did not result in the identification of a reportable risk of

material misstatement in respect of non-compliance with laws and

regulations.

Fraud risk

We assessed the presumed fraud risk on revenue recognition as not

significant as the accounting of interest income and commission income

is based on automatically generated accruals based on static data

taken from the source systems and therefore contains routine

transactions not subject to management judgement. Furthermore, the

contracts used in the financial sector generally use standardised

definitions which reduce the complexity of revenue recognition to a low

level.

Based on the above and on the auditing standards, we identified the

following fraud risks that are relevant to our audit and responded as

follows:

• Management override of controls (presumed fraud risk)

Management is in a unique position to manipulate accounting records

and prepare fraudulent financial statements by overriding controls that

otherwise appear to be operating effectively, such as reporting fictitious

journal entries.

We evaluated the design and the implementation and tested the

operating effectiveness of internal controls that mitigate fraud risks,

such as processes related to journal entries and estimates related to

loan loss provisions. We also performed a data analysis of high-risk

journal entries and evaluated key estimates and judgments for bias by

the Company’s management. Where we identified instances of

unexpected journal entries or other risks through our data analytics, we

performed additional audit procedures to address each identified journal

entry, including testing of transactions back to source information.

• Management override of collective loan loss provisioning

(ECL)

With respect to the fraud risks and responses for management override

of Expected Credit Loss (ECL) provision results, we refer to the Key

audit matter ‘Assessment of Expected Credit Losses on loans and

advances to customers and loans and advances to banks’.

Our evaluation of procedures performed in relation to fraud and non-

compliance with laws and regulations did not result in an additional key

audit matter. Our audit procedures did not reveal indications and/or

reasonable suspicion of fraud and non-compliance that are considered

material for our audit.


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We communicated our risk assessment, audit responses and results to

the Management Board Banking and the Audit Committee of the

Supervisory Board.

Audit response to going concern

As explained on page 117 of the financial statements, the Management

Board Banking has performed its going concern assessment and has

not identified a going concern risk. To assess the Management Board

Banking’s assessment, we have performed, inter alia, the following

procedures:

• we considered whether the Management Board Banking’s

assessment of the going concern risks includes all relevant

information of which we are aware as a result of our audit;

• we considered whether the developments in interest rates,

geopolitical uncertainty and risks of disruption due to innovation and

the emergence of new competitors from the technology sector

indicate a going concern risk;

• we analysed the Company’s financial position as at year-end and

compared it to the previous financial year in terms of indicators that

could identify going concern risks; and

• we inspected regulatory correspondence to obtain an understanding

of the Company’s capital and liquidity position, that underpins

management’s assessment of the going concern assumption for

financial reporting.

The outcome of our risk assessment procedures on the going concern

assessment, including our consideration of findings from our audit

procedures on other areas, did not give reason to perform additional

audit procedures on the Management Board Banking’s going concern

assessment.

Audit response to climate-related risks

In planning our audit, we considered the potential impact of risks arising

from climate change on the Company’s business and its financial

statements. The Company has set out its commitments and ambitions

relating to climate change in the chapters ‘Strategy, business model and

value chain’ (‘Sustainability at the heart’) and ‘Risk

management’ (‘Environmental, social and governance (ESG) risk’) of

the annual report. Besides reaching net zero in its own operations, the

Company focusses on three action areas: helping its clients to transition

to low-carbon business models; building up ING Bank’s financing of

new technologies and sustainable systems; and finding new ways to

enable people to play their part in the transition.

Management assessed, against the background of the Company’s

business and operations, how climate-related risks and opportunities,

and the Company’s own commitments and ambitions, could have a

significant impact on its business or could impose the need to modify its

strategy and operations. Management has considered the impact of

both transition and physical risks on the financial statements in

accordance with the applicable financial reporting framework, more

specifically the impact on expected credit losses (‘ECL’) on loans and

advances, as described in the section ‘Risk management – Climate and

environmental risks in IFRS 9 models’ of the annual report.

Management prepared the financial statements, including considering

whether the implications from climate-related risks and commitments

and the current financial effects relating to sustainability matters have

been appropriately accounted for and disclosed.

As part of our audit, we assessed whether the impact of climate-related

risk and the Company’s commitments and ambitions in respect of

climate change could result in a risk of material misstatement of the

2025 financial statements that requires a response in our audit. We

performed the following:

• To understand management's processes:

◦ we performed an analysis of the external environment and

obtained an understanding of relevant sustainability themes and

issues relevant for the Company;

◦ we made inquiries with the Management Board Banking, other

senior management, members of the ESG Committee and the

Audit Committee of the Supervisory Board;

◦ we have inspected minutes (such as of the Management Board

Banking and the Supervisory Board) and documents relevant for

assessing the climate-related risks in the audit;

◦ we inspected regulatory correspondence to obtain an

understanding of how climate risk impacts financial reporting and

specifically credit risk;

◦ we gained an understanding whether any current and/or future

regulations may impact ING Bank, such as greenhouse gas

emission regulations, potential increases in taxes on certain

products and future climate reporting obligations; and

◦ we gained an understanding of the Company’s Net Zero

alignment pathways, including the intermediate target setting for

2030.

• The parent company of ING Bank, ING Groep N.V., prepared a

Sustainability Statement in accordance with the European

Sustainability Reporting Standards (ESRS). As part of risk

assessment procedures for the financial statements audit of ING

Bank, we have read the draft of this Sustainability Statement, which

includes information over material sustainability matters relating to

material impacts, risks and opportunities relating to climate change.

We specifically considered the current financial effects of

sustainability matters, such as the impact on ECL on loans and

advances and whether these have been appropriately accounted for

and disclosed.

• We have evaluated climate related fraud risk factors, such as

management board remuneration being linked to climate related

KPIs. This did not result in an additional key audit matter.

• We inquired with the Legal Counsel on any climate risk related

allegations and claims against the Company, as disclosed in Note 40

Legal Proceedings.

• We used our credit risk modelling experts to assist in gaining

understanding how climate-related risks are of impact on the

expected credit loss estimation, including the credit risk models, as

determined by the Company.

• We challenged the Company’s conclusion, as included in the section

‘Climate and environmental risks in IFRS 9 models’ on page 72 of

the annual report that:

◦ part of the impact of climate risk on ECL is not explicitly

observable but is embedded in other credit-risk drivers such as

macro-economic forecasts and relevant risk parameters that are

inputs into (IFRS 9 ECL) credit risk models.


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◦ the effect of physical climate risk (except for events that have

already occurred) is expected to become financially significant on

the longer-term horizon. It therefore does not impact ECL for

ING’s predominantly short and medium-term loan book.

◦ at this point the impact of climate-related risk on ECL can only be

separated for physical climate risks that have already occurred

and the ECL from the transition risks of clients in certain high

greenhouse gas-emitting sectors for which management

recorded an adjustment to the model based ECL.

Based on our risk assessment procedures, we did not identify a risk of

material misstatement specific to climate-related risk, including on the

determination of expected credit losses on loans and advances. As a

result, no further audit response was considered necessary and hence

reflected in our key audit matters.

Furthermore, we have read the ‘Other information’ relating to climate

change as included in the annual report and considered whether such

information contains material inconsistencies with the financial

statements or our knowledge obtained through the audit, in particular as

described above and our knowledge obtained otherwise.

Our key audit matters

Key audit matters are those matters that, in our professional judgement,

were of most significance in our audit of the financial statements. We

have communicated the key audit matters to the Audit Committee of the

Supervisory Board. The key audit matters are not a comprehensive

reflection of all matters discussed.

Assessment of expected credit losses on loans and advances to

customers and loans and advances to banks

Description

As discussed in the Credit Risk section on pages 56 to 82 and in Note 3

and Note 7 in the consolidated financial statements, the Loans and

advances to customers amount to EUR 722 billion and Loans and

advances to banks amount to EUR 21 billion as at 31 December 2025.

These loans and advances are measured at amortised cost less

expected credit losses (‘ECL’) of EUR 5.9 billion. For collectively

determined ECL, management uses models that estimate expected

credit losses using three components: probability of default (‘PD’), loss

given default (‘LGD’) and exposure at default (‘EAD’). Management also

applied forward looking economic scenarios with associated weights.

Relevant macroeconomic factors include the gross domestic product

(‘GDP’), house price index (‘HPI’) and the unemployment rate.

The current economic conditions, most notably the heightened

geopolitical tensions, are outside the bounds of historical experience

used to develop ECL model methodologies and result in greater

uncertainties to estimate ECLs. These uncertainties are considered by

management in their assessment of whether judgemental overlays to

model-based provisions need to be applied. For individually determined

provisions, management estimates ECL using the amount and timing of

future expected recovery scenarios and applying probability weights if

more than one recovery scenario is present.

Our response

Based on our risk assessment procedures, including those in relation to

the impact of climate-related risk on ECL as described in the section

‘Audit response to climate-related risks’, we identified the assessment

of ECL on loans and advances to customers and loans and advances to

banks as a key audit matter. Predominantly, because of the significant

and complex auditor judgment and specialised skills and knowledge

required to evaluate the following elements of the overall ECL estimate:

• The judgements used to develop the model-driven PD and LGD

parameters.

• The use of forward-looking macroeconomic forecasts in ECL,

including determining macroeconomic factors such as GDP, HPI and

unemployment rate.

• The consistent identification and application of criteria for identifying

significant increase in credit risk (‘SICR’).

• The determination of management overlays to the modelled ECL

considering the volatility and uncertainty in the economic

environment combined with the delay in which the models capture

emerging risks.

• The determination of the amount and timing of expected future

recovery cash flows for individual loan provision assessments for

impaired loans and advances and the probability weights applied in

case of more than one recovery scenario.

• The following are the primary procedures we performed to address

this key audit matter.

• We evaluated the design and tested the operating effectiveness of

certain internal controls related to the estimation of ECL for loans

and advances to customers and loans and advances to banks. This

included controls relating to the selection of key assumptions

(including PD, LGD and macroeconomic forecasts), review and

authorisation of model outputs, governance and monitoring of the

ECL process, determination of credit risk ratings, the estimation of

future recovery cash flows of individual loan loss provisions and

associated scenario weights assigned and the determination of

management overlays to the modelled ECL.

• We involved credit risk professionals with specialised skills and

knowledge who assisted in evaluating the assumptions used to

determine the PD and LGD parameters in models used by the

Company to determine the collective provisions, including the

evaluation of the recalibrated and redeveloped credit risk models.

This included reperforming back-testing of certain models to

evaluate the current model performance and evaluation of the

identification of SICR in loans and advances by challenging the

scope of management’s criteria used in staging assessments,

consistent application of the thresholds applied within each criterion,

and the ability of staging criteria to identify SICR prior to loans and

advances being credit impaired. In addition, the credit risk

professionals assisted in testing management overlays recorded.

• We involved economic professionals with specialised skills and

knowledge, who assisted in assessing the Company’s methodology

to determine the macroeconomic forecasts used in determining the

ECL. We tested the reasonableness of management’s forecasts

against other external benchmarks and our own internal forecasts.


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• We involved valuation and credit risk professionals with specialised

skills and knowledge, who assisted in assessing the methodologies,

cash flows and collateral values used in expected future recovery

cash flow assessments of individual loan loss provisions for impaired

loans and advances and in challenging management’s use of

recovery scenarios and expected cash flows by comparing against

industry trends and comparable benchmarks and recalculating

recovery amounts.

Our observation

Based on our procedures performed, we found management’s overall

assessment relating to the valuation of loans and advances to

customers and banks within an acceptable range and adequately

disclosed in Note 3 and Note 7 of the consolidated financial statements.

User access and change management

Description

ING Bank is highly dependent on its IT environment for the continuity of

operations and reliability of financial reporting. The IT environment of

ING Bank evolves over time, which includes the implementation of

tooling to support automated control execution related to user access

and change management of IT assets. We consider general IT controls,

and in particular user access and change management controls, that

support the effective operations of automated controls a key audit

matter.

Our response

Our audit approach relies to a large extent on the operating

effectiveness of automated controls, which are dependent on user

access and change management general IT controls to operate

effectively. With the support of our IT auditors, we test the design,

implementation and operating effectiveness of automated controls and

general IT controls for applications, databases, operating systems and

supporting tooling. The general IT controls include access provisioning,

high privileged user access and monitoring, and the testing and

approval of changes prior to implementation.

Our audit procedures identified deficiencies in high privileged user

access and monitoring in several systems, including access to modify

configurations, deploy code and/or change data. These deficiencies

were similar in nature, however, due to management’s progress in

remediation, less severe compared to prior year. Since these

deficiencies were open during (some of) the year, we performed

additional procedures to respond to the risk of unauthorised and/or

unintentional access or changes to automated controls and/or data.

These procedures included testing compensating controls implemented

by management and additional substantive procedures when

necessary.

Our observation

Our testing of controls and additional substantive procedures did not

identify unauthorised user activities in the systems relevant to financial

reporting which would have required us to significantly expand the

extent of our planned detailed testing.

Report on the other information included in the annual

report

In addition to the financial statements and our auditor’s report thereon,

the annual report contains other information.

Based on the following procedures performed, we conclude that the

other information:

• is consistent with the financial statements and does not contain

material misstatements; and

• contains the information as required by Part 9 of Book 2 of the Dutch

Civil Code for the management report and other information.

We have read the other information. Based on our knowledge and

understanding obtained through our audit of the financial statements or

otherwise, we have considered whether the other information contains

material misstatements.

By performing these procedures, we comply with the requirements of

Part 9 of Book 2 of the Dutch Civil Code and the Dutch Standard 720.

The scope of the procedures performed is less than the scope of those

performed in our audit of the financial statements.

The Management Board Banking is responsible for the preparation of

the other information, including the information as required by Part 9 of

Book 2 of the Dutch Civil Code.

Report on other legal and regulatory requirements and

ESEF

Engagement

We were initially appointed by the General Meeting of Shareholders as

auditor of ING Bank N.V. on 11 May 2015, as of the audit for the year

2016 and have operated as statutory auditor ever since that financial

year. We have been reappointed by the General Meeting of

Shareholders on 24 April 2023 to continue to serve ING Bank as its

external auditor for the financial years 2024 and 2025. Due to the

legally required mandatory audit firm rotation requirements in the

Netherlands, our mandate has ended upon completion of the audit of

the 2025 financial statements.

No prohibited non-audit services

We have not provided prohibited non-audit services as referred to in

Article 5(1) of the EU Regulation on specific requirements regarding

statutory audits of public-interest entities.

Services rendered

For the period to which our statutory audit relates, in addition to this

audit, we have provided the following services to the Company and its

controlled undertakings:

• agreed-upon procedures and assurance engagements for the

benefit of external stakeholders, largely driven by regulatory

requirements.


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European Single Electronic Format (ESEF)

The Company prepared its annual report in ESEF. The requirements for

this are set out in the Delegated Regulation (EU) 2019/815 with regard

to regulatory technical standards on the specification of a single

electronic reporting format (hereinafter: the RTS on ESEF).

In our opinion the annual report prepared in XHTML format, including

the (partly) marked-up consolidated financial statements as included in

the reporting package by ING Bank, complies in all material respects

with the RTS on ESEF.

The Management Board Banking is responsible for preparing the

annual report including the financial statements in accordance with the

RTS on ESEF, whereby the Management Board Banking combines the

various components into one single reporting package.

Our responsibility is to obtain reasonable assurance for our opinion

whether the annual report in this reporting package complies with the

RTS on ESEF. We performed our examination in accordance with

Dutch law, including Dutch Standard 3950N ’Assurance-opdrachten

inzake het voldoen aan de criteria voor het opstellen van een digitaal

verantwoordingsdocument’ (assurance engagements relating to

compliance with criteria for digital reporting). Our examination included

among others:

• Obtaining an understanding of the entity's financial reporting

process, including the preparation of the reporting package.

• Identifying and assessing the risks that the annual report does not

comply in all material respects with the RTS on ESEF and designing

and performing further assurance procedures responsive to those

risks to provide a basis for our opinion, including:

◦ obtaining the reporting package and performing validations to

determine whether the reporting package containing the Inline

XBRL instance document and the XBRL extension taxonomy files

have been prepared in accordance with the technical

specifications as included in the RTS on ESEF; and

◦ examining the information related to the consolidated financial

statements in the reporting package to determine whether all

required mark-ups have been applied and whether these are in

accordance with the RTS on ESEF.

Description of responsibilities regarding the financial

statements

Responsibilities of the Management Board Banking and the

Supervisory Board for the financial statements

The Management Board Banking is responsible for the preparation and

fair presentation of the financial statements in accordance with

International Financial Reporting Standards (IFRS) as adopted by the

European Union (EU) and Part 9 of Book 2 of the Dutch Civil Code.

Furthermore, the Management Board Banking is responsible for such

internal control as the Management Board Banking determines is

necessary to enable the preparation of the financial statements that are

free from material misstatement, whether due to fraud or error. In that

respect the Management Board Banking, under supervision of the

Supervisory Board, is responsible for the prevention and detection of

fraud and non-compliance with laws and regulations, including

determining measures to resolve the consequences of it and to prevent

recurrence.

As part of the preparation of the financial statements, the Management

Board Banking is responsible for assessing the Company’s ability to

continue as a going concern. Based on the financial reporting

frameworks mentioned, the Management Board Banking should

prepare the financial statements using the going concern basis of

accounting unless the Management Board Banking either intends to

liquidate the Company or to cease operations or has no realistic

alternative but to do so. The Management Board Banking should

disclose events and circumstances that may cast significant doubt on

the Company’s ability to continue as a going concern in the financial

statements.

The Supervisory Board is responsible for overseeing the Company’s

financial reporting process.

Our responsibilities for the audit of the financial statements

Our objective is to plan and perform the audit engagement in a manner

that allows us to obtain sufficient and appropriate audit evidence for our

opinion.

Our audit has been performed with a high, but not absolute, level of

assurance, which means we may not detect all material errors and

fraud during our audit.

Misstatements can arise from fraud or error and are considered material

if, individually or in the aggregate, they could reasonably be expected to

influence the economic decisions of users taken on the basis of these

financial statements. The materiality affects the nature, timing and

extent of our audit procedures and the evaluation of the effect of

identified misstatements on our opinion.

A further description of our responsibilities for the audit of the financial

statements is included in the appendix of this auditor's report. This

description forms part of our auditor’s report.

Utrecht, 23 February 2026

KPMG Accountants N.V.

P.A.M. de Wit RA

Appendix:

Description of our responsibilities for the audit of the financial

statements


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Appendix

Description of our responsibilities for the audit of the

financial statements

We have exercised professional judgement and have maintained

professional scepticism throughout the audit, in accordance with Dutch

Standards on Auditing, ethical requirements and independence

requirements. Our audit included among others:

• identifying and assessing the risks of material misstatement of the

financial statements, whether due to fraud or error, designing and

performing audit procedures responsive to those risks, and obtaining

audit evidence that is sufficient and appropriate to provide a basis for

our opinion. The risk of not detecting a material misstatement

resulting from fraud is higher than the risk resulting from error, as

fraud may involve collusion, forgery, intentional omissions,

misrepresentations, or the override of internal control;

• obtaining an understanding of internal control relevant to the audit in

order to design audit procedures that are appropriate in the

circumstances, but not for the purpose of expressing an opinion on

the effectiveness of the Company’s internal control;

• evaluating the appropriateness of accounting policies used and the

reasonableness of accounting estimates and related disclosures

made by the Management Board Banking;

• concluding on the appropriateness of the Management Board

Banking’s use of the going concern basis of accounting, and based

on the audit evidence obtained, whether a material uncertainty exists

related to events or conditions that may cast significant doubt on the

Company’s ability to continue as a going concern. If we conclude

that a material uncertainty exists, we are required to draw attention

in our auditor’s report to the related disclosures in the financial

statements or, if such disclosures are inadequate, to modify our

opinion. Our conclusions are based on the audit evidence obtained

up to the date of our auditor’s report. However, future events or

conditions may cause a company to cease to continue as a going

concern;

• evaluating the overall presentation, structure and content of the

financial statements, including the disclosures; and

• evaluating whether the financial statements represent the underlying

transactions and events in a manner that achieves fair presentation.

We are responsible for planning and performing the group audit to

obtain sufficient appropriate audit evidence regarding the financial

information of the entities or business units within the group as a basis

for forming an opinion on the financial statements. We are also

responsible for the direction, supervision and review of the audit work

performed for purposes of the group audit. We bear the full

responsibility for the auditor’s report.

We communicate with the Supervisory Board regarding, among other

matters, the planned scope and timing of the audit and significant audit

findings, including any significant findings in internal control that we

identify during our audit. In this respect we also submit an additional

report to the audit committee in accordance with Article 11 of the EU

Regulation on specific requirements regarding statutory audits of public-

interest entities. The information included in this additional report is

consistent with our audit opinion in this auditor’s report.

We provide the Supervisory Board with a statement that we have

complied with relevant ethical requirements regarding independence,

and to communicate with them all relationships and other matters that

may reasonably be thought to bear on our independence, and where

applicable, related safeguards.

From the matters communicated with the Supervisory Board, we

determine the key audit matters: those matters that were of most

significance in the audit of the financial statements. We describe these

matters in our auditor’s report unless law or regulation precludes public

disclosure about the matter or when, in extremely rare circumstances,

not communicating the matter is in the public interest.


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Alternative performance measures

Our financial information is prepared in accordance with IFRS as detailed in

the financial statements of our Annual Report. In addition, in the

discussion of our financial performance, we use a number of alternative

performance measures, including resilient net profit, commercial net

interest income and net core lending and deposits growth. Resilient net

profit is defined as net profit adjusted for significant items not linked to the

normal course of business, reference is made to 'Capital Management' for

a reconciliation.

We consider commercial net interest income, and the derived commercial

net interest margin, to be useful information because the scope is

restricted to those products that are mainly interest driven and excludes

the interest on products where performance measurement is primarily

done based on fee income or at the total income level (including Financial

Markets and Treasury). Commercial net interest income also excludes

significant volatile items in lending and liability net interest income, thus

removing items that distort period-on-period comparisons.

We consider net core lending and deposits growth as useful information to

track our real commercial growth in customer balances. It measures the

development of our customer lending and deposits adjusted for currency

impacts and changes in the Treasury and run-off portfolios. The below

tables show how these measures can be reconciled to the nearest IFRS

measure.


Reconciliation commercial net interest income (NII)
	Retail Netherlands			Retail Belgium			Retail Germany			Retail Other			Wholesale Banking			Corporate Line			Total
in EUR million	2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023
Net interest income IFRS	3,115	3,027	3,096	1,786	1,959	2,063	2,457	2,647	2,862	3,892	3,817	3,437	2,997	3,259	4,028	295	40	323	14,542	14,749	15,809
Exclude: Other NII (excl. significant volatile items) ¹	-572	-621	-535	93	142	198	205	298	151	195	213	207	-972	-693	-171	295	40	323	-757	-621	171
Exclude: Significant volatile items²							-18	-51			-39			70					-18	-20
Commercial net interest income	3,687	3,647	3,631	1,692	1,816	1,866	2,270	2,400	2,711	3,698	3,643	3,231	3,969	3,882	4,199				15,316	15,389	15,638

¹Other NII mainly includes NII for Financial Markets and Treasury. In Financial Markets this primarily reflects the funding costs of positions for which associated revenue is reported in 'other income'. For Treasury, it includes the funding costs of specific money market and FX transactions where an offsetting revenue is

recorded in 'other income', as well as interest income from other Treasury activities (such as foreign currency ratio hedging) that are not allocated to Retail or Wholesale. Furthermore, other NII includes the funding costs for our equity stakes, the NII related to investment portfolios, as well as the effect of indexation

of NII required by IAS 29 due to hyperinflation in Türkiye.

²Significant volatile items in lending and liability NII are lending- and liability-related interest items that management would consider as outside the normal course of business and large enough to distort a proper period-on-period comparison. For the years 2025 and 2024, it includes €-18 million (2025) and €-51

million (2024) for incentives to attract new customers (Retail Germany), €-39 million for the Polish mortgage moratorium (2024), and a €+70 million one-off in Wholesale Banking (2024).


Customer lending and Net core lending growth by business line
	Retail Netherlands			Retail Belgium			Retail Germany			Retail Other			Wholesale Banking			Corporate Line			Total
in EUR billion	2025	2024	change	2025	2024	change	2025	2024	change	2025	2024	change	2025	2024	change	2025	2024	change	2025	2024	change
Customer lending IFRS-EU ¹	179.2	164.3	14.9	100.1	98.3	1.8	116.6	110.2	6.4	128.4	117.2	11.2	203.1	195.8	7.3	0.3	0.3	0.0	727.7	686.1	41.6
Exclude: FX impact			0.0			0.0			0.0			2.3			8.9						11.2
Exclude: Treasury, run-off portfolios and other			1.3			0.3			0.5			-0.1			2.1			0.0			4.1
Net core lending growth			16.2			2.0			6.9			13.4			18.3			0.0			56.9

¹Loans and advances to customers excluding LLP.


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Customer deposits and Net core deposits growth by business line
	Retail Netherlands			Retail Belgium			Retail Germany			Retail Other			Wholesale Banking			Corporate Line			Total
in EUR billion	2025	2024	change	2025	2024	change	2025	2024	change	2025	2024	change	2025	2024	change	2025	2024	change	2025	2024	change
Customer deposits IFRS-EU	209.1	200.7	8.5	96.5	97.1	-0.6	157.7	151.1	6.6	173.4	163.2	10.2	84.6	79.6	5.0	3.3	8.1	-4.7	724.7	699.7	25.0
Exclude: FX impact			0.0			0.0			0.0			2.3			1.4						3.7
Exclude: Treasury, run-off portfolios and other			3.1			-0.1			0.0			0.1			1.6			4.7			9.4
Net core deposits growth			11.5			-0.6			6.6			12.6			8.0			0.0			38.1


Customer lending and Net core lending growth by business line
	Retail Netherlands			Retail Belgium			Retail Germany			Retail Other			Wholesale Banking			Corporate Line			Total
in EUR billion	2024	2023	change	2024	2023	change	2024	2023	change	2024	2023	change	2024	2023	change	2024	2023	change	2024	2023	change
Customer lending IFRS-EU ¹	164.3	152.8	11.4	98.3	94.3	4.0	110.2	102.9	7.3	117.2	109.8	7.4	195.8	188.0	7.8	0.3	0.3	0.0	686.1	648.1	38.1
Exclude: FX impact			0.0			0.0			0.0			0.9			-4.7						-3.8
Exclude: Treasury, run-off portfolios and other			-1.9			-0.4			-2.9			-0.2			-1.3			0.0			-6.6
Net core lending growth			9.6			3.7			4.4			8.2			1.8			0.0			27.7

¹Loans and advances to customers excluding LLP.


Customer deposits and Net core deposits growth by business line
	Retail Netherlands			Retail Belgium			Retail Germany			Retail Other			Wholesale Banking			Corporate Line			Total
in EUR billion	2024	2023	change	2024	2023	change	2024	2023	change	2024	2023	change	2024	2023	change	2024	2023	change	2024	2023	change
Customer deposits IFRS-EU	200.7	199.7	1.0	97.1	91.2	5.9	151.1	143.6	7.5	163.2	151.0	12.1	79.6	64.8	14.9	8.1	11.7	-3.7	699.7	662.0	37.7
Exclude: FX impact			0.0			0.0			0.0			0.6			-0.4						0.3
Exclude: Treasury, run-off portfolios and other			4.0			0.5			0.0			-0.1			1.3			3.7			9.4
Net core deposits growth			5.0			6.4			7.5			12.7			15.8			0.0			47.4


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Articles of Association – Appropriation of results

Appropriation of results

The result is appropriated pursuant to Article 25 of the Articles of Association of ING Bank N.V., the relevant

stipulations of which state that the result shall firstly be appropriated to the Stichting Regio Bank Reserve,

respectively the Reserve Stichting Vakbondsspaarbank SPN or charged to that reserves in proportion to the

ratio between the Stichting Regio Bank Reserve, respectively the Reserve Stichting Vakbondsspaarbank SPN and

the company's equity at the end of the relevant financial year and that the remainder shall be at the disposal

of the General Meeting.


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Risk factors

Summary of risk factors

The following is a summary of the principal risk factors that could have a

material adverse effect on the reputation, business activities, financial

condition, results and prospects of ING. Please carefully consider all the

information presented in this section for a detailed description of these

risks.

Risks related to financial conditions, market environment and

general economic trends

§ Our revenues and earnings are affected by volatility, regime shifts and

cross-market contagion of the economic, business, liquidity, funding

and capital markets environments of the various geographic regions in

which we conduct business, as well as by changes in customer

behaviour in these regions, and an adverse change in any one region

could have an impact on our business, results and financial condition.

§ Inflation and deflation scenarios, as well as interest rate volatility and

changes may adversely affect our business, results and financial

condition.

§ The default of a major market participant could disrupt the markets

and may have an adverse effect on our business, results and financial

condition.

§ Continued risk of political instability and fiscal uncertainty around the

globe, as well as ongoing volatility in the financial markets and the

economy generally have adversely affected, and may continue to

adversely affect, our business, results and financial condition.

§ Market conditions, including those observed over the past few years,

may increase the risk of loans being impaired and have a negative

effect on our results and financial condition.

§ Discontinuation of interest rate benchmarks may negatively affect our

business, results and financial condition.

§ We may incur losses due to failures of banks falling under the scope of

resolution funding or deposit schemes.

Risks related to the regulation and supervision of the Group

§ Non-compliance with laws and/or regulations could result in fines and

other liabilities, penalties or consequences for us, which could

materially affect our business and reputation and reduce our

profitability.

§ Changes in laws and/or regulations governing financial services or

financial institutions or the application of such laws and/or regulations

may increase our operating costs and limit our business activities.

§ We are subject to additional legal and regulatory risk in certain

countries with less developed or less predictable legal and regulatory

frameworks or the supervision thereof.

§ We are subject to the regulatory supervision of the ECB and other

regulators and public bodies with extensive supervisory and

investigatory powers.

§ Failure to meet minimum capital and other prudential regulatory

requirements as applicable to us from time to time may have a

material adverse effect on our business, results and financial condition

and on our ability to make payments on certain of our securities.

§ Our US commodities and derivatives business is subject to CFTC and SEC

regulation under the Dodd-Frank Act.

§ We are subject to the EU recovery and resolution regime and several

other bank recovery and resolution regimes that include statutory

write-down and conversion as well as other powers, which remain

subject to significant uncertainties as to the scope and impact on us.

Risks related to litigation, enforcement proceedings and

investigations and to changes in tax laws

§ We may be subject to litigation, enforcement proceedings,

investigations or other regulatory actions, and adverse publicity.

§ We are subject to different tax regulations in each of the jurisdictions

where we conduct business, and are exposed to changes in tax laws

and risks of non-compliance resulting in proceedings or investigations

with respect to tax laws.

§ Our reputation could be harmed and we could be subject to

enforcement actions, fines and penalties if we fail to comply with our

obligations under tax laws and regulations.

§ ING is exposed to the risk of claims from customers or stakeholders

who feel misled or treated unfairly because of advice or information

received.

Risks related to the Group’s business and operations

§ ING may be unable to meet evolving expectations or requirements with

respect to ESG-related matters.

§ ING may be unable to adapt its products and services to meet

changing customer behaviour and demand, including as a result of

ESG-related matters.

§ ING’s business and operations are exposed to transition risks related to

climate change.

§ ING’s business and operations are exposed to physical risks, including

as a direct result of climate change.

§ Operational and IT risks, such as systems disruptions or failures,

breaches of security, human error, changes in operational practices,

inadequate controls including in respect of third parties with which we

do business or outbreaks of communicable diseases may adversely

impact our reputation, business and results.

§ We are subject to increasing risks related to cybercrime and

compliance with cybersecurity regulation.

§ Because we operate in highly competitive markets, including our home

market, we may not be able to increase or maintain our market share,

which may have an adverse effect on our results.


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§ We may not always be able to protect our intellectual property

developed in our products and services and may be subject to

infringement claims, which could adversely impact our core business,

inhibit efforts to monetise our internal innovations and restrict our

ability to capitalise on future opportunities.

§ The inability of counterparties to meet their financial obligations or our

inability to fully enforce our rights against counterparties could have a

material adverse effect on our results.

§ Ratings are important to our business for a number of reasons, and a

downgrade or a potential downgrade in our credit ratings could have

an adverse impact on our results and net results.

§ An inability to retain or attract key personnel may affect our business

and results.

§ We may incur further liabilities in respect of our defined benefit

retirement plans if the value of plan assets is not sufficient to cover

potential obligations, including as a result of differences between

actual results and underlying actuarial assumptions and models.

Risks related to the Group’s risk management practices

§ Risks relating to our use of quantitative models to model client

behaviour for the purposes of our calculations may adversely impact

our results and reputation.

§ We may be unable to manage our risks successfully through

derivatives.

Risks related to the Group’s liquidity and financing activities

§ We depend on the capital and credit markets, as well as customer

deposits, to provide the liquidity and capital required to fund our

operations, and adverse conditions in the capital and credit markets, or

significant withdrawals of customer deposits, may negatively impact

our liquidity, borrowing and capital positions, as well as increase the

cost of liquidity, borrowings and capital.

Risk factors

Any of the risks described below could have a material adverse effect on

the business activities, financial condition, results and prospects of ING as

well as ING’s reputation. ING may face a number of the risks described

below simultaneously and some risks described below may be

interdependent. While the risk factors below have been divided into

categories, some risk factors could belong in more than one category and

investors should carefully consider all of the risk factors set out in this

section. Additional risks of which the Company is not presently aware, or

that are currently viewed as immaterial, could also affect the business

operations of ING and have a material adverse effect on ING’s business

activities, financial condition, results and prospects. The market price of

ING shares or other securities could decline due to any of those risks

including the risks described below, and investors could lose all or part of

their investments.

Although the risk factors that ING currently believes to be most material

have been presented first within each category, the order in which the risk

factors are presented is not necessarily an indication of the likelihood of

the risks actually materialising, of the potential significance of the risks or

of the scope of any potential negative impact to our business, results,

financial condition and prospects.

Risks related to financial conditions, market environment and

general economic trends

Our revenues and earnings are affected by volatility, regime shifts and

cross-market contagion of the economic, business, liquidity, funding and

capital markets environments of the various geographic regions in which

we conduct business, as well as by changes in customer behaviour in

these regions, and an adverse change in any one region could have an

impact on our business, results and financial condition.

Because ING is a multinational banking and financial services corporation,

with a global presence and serving 40 million customers, corporate clients

and financial institutions in 38 countries, ING’s business, results and

financial condition may be significantly impacted by turmoil and volatility

in the worldwide financial markets or in the particular geographic areas in

which we operate. In Retail Banking, our products include savings,

payments, investments, loans and mortgages. In Wholesale Banking, we

provide specialised lending, tailored corporate finance, debt and equity

market solutions, payments & cash management, trade and treasury

services. Negative developments in relevant financial markets and/or

countries or regions have in the past had and may in the future have a

material adverse impact on our business, results and financial condition,

including as a result of the potential consequences listed below.

Factors such as inflation or deflation, interest rates, government spending,

geopolitical events and trends, supply chain disruptions, shortages,

terrorism, pandemics and epidemics (such as Covid-19 pandemic) or other

widespread health emergencies, securities prices, the volatility and

strength of the capital markets, exchange rates, credit spreads, liquidity

spreads, real estate values and private equity valuations, consumer

spending, business investment, changes in customer behaviour and

climate change, all impact the business and economic environment and,

ultimately, our solvency, liquidity and the amount and profitability of

business we conduct in a specific geographic region. Some of these risks

are often experienced globally as well as in specific geographic regions and

are described in greater detail below under the headings: ‘Inflation and

deflation scenarios, as well as interest rate volatility and changes may

adversely affect our business, results and financial condition'; 'Market

conditions, including those observed over the past few years may increase

the risk of loans being impaired and have a negative effect on our results

and financial condition'; and 'Continued risk of political instability and fiscal

uncertainty, as well as ongoing volatility in the financial markets and the

economy generally have affected, and may adversely affect, our business,

results and financial condition'. All of these are factors in local and regional

economies as well as in the global economy, and we may be affected by

changes in any one of these factors in any one country or region, and

more if more of these factors occur simultaneously and/or in multiple

countries or regions or on a global scale.

In case one or more of the factors mentioned above adversely affects the

profitability of our business, this might also result, among other things, in

the following:

§ inadequate reserves or provisions, in relation to which losses could

ultimately be realised through profit and loss and shareholders’ equity;

§ the write-down of tax assets impacting net results and/or equity;

§ impairment expenses related to goodwill and other intangible assets,

impacting our net result and equity; and/or


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§ movements in risk-weighted assets for the determination of required

capital.

In particular, we are exposed to financial, economic, market and political

conditions in the Benelux countries and Germany, from which we derive a

significant portion of our revenues in both Retail Banking and Wholesale

Banking, and which could present risks of economic downturn. Though less

material, we also derive substantial revenues in the following geographic

regions: United States, Türkiye, Poland and the remainder of Eastern

Europe, Southern Europe, East Asia and Australia. In an economic

downturn affecting some or all of these jurisdictions, we expect that higher

unemployment, lower family income, lower corporate earnings, higher

corporate and private debt defaults, lower business investments and lower

consumer spending would adversely affect the demand for banking

products, and that ING may need to increase its reserves and provisions,

each of which may result in overall lower earnings. Securities prices, real

estate values and private equity valuations may also be adversely

impacted, and any such losses would be realised through profit and loss

and shareholders’ equity. We also offer a number of financial products

that expose us to risks associated with fluctuations in interest rates,

securities prices, corporate and private default rates, the value of real

estate assets, exchange rates and credit spreads. As a result, their impact

may continue to affect our business. We also have wholesale banking

activities in both Russia and Ukraine, as well as investments in Russia,

some of which are denominated in local currency. In response to Russia’s

invasion of Ukraine, the international community imposed various punitive

measures, including sanctions, capital controls, restrictions on SWIFT

access and restrictions on central bank activity. These measures and

Russia’s response thereto have significantly impacted, and may continue

to significantly impact, Russia’s economy, our activities in Russia and our

activities involving Russian-owned parties. They have contributed to

heightened instability in global markets and increased inflation due in part

to supply chain constraints, as well as continued volatile and periodic

elevation of energy and commodity prices. Should prices remain elevated

for an extended period, most businesses and households would be

negatively impacted, and our business in Russia and Ukraine, as well as

our broader business, may be adversely affected, including through spill-

over risk to the entire wholesale banking portfolio (e.g. commodities

financing, energy and utilities and energy-consuming clients).

On 28 January 2025, ING announced its intention to sell its business in

Russia to a third party. As the buyer has not received all necessary

approvals, ING has been unable to complete the deal within the expected

timeframe. There is no guarantee that any such approvals will be received,

or any certainty as to the timing or occurrence of closing of the proposed

transaction, or the ultimate divestment of ING’s business in Russia.

Environmental and/or climate risks have also directly and indirectly

impacted ING without significant financial impact, for example through,

among other things, losses suffered as a result of extreme weather events,

the impact of climate-related transition risk on the risk and return profile

or value of security or operations of certain categories of customer to

which ING has exposure. In addition, these risks may also increase ING’s

reputational and litigation risk if the economic activity that ING supports is

not in line with community expectations or ING’s external commitments or

legal or regulatory requirements (this includes, but is not limited to,

greenwashing risk).

For more information on ING’s exposure to particular geographic areas,

see Note 29 ‘Information on geographical areas’ to the consolidated

financial statements.

Inflation and deflation scenarios, as well as interest rate volatility and

changes may adversely affect our business, results and financial

condition.

In general, both inflation and deflation may influence consumers’

spending habits, affecting the economic activity and consequently our

core revenue stream (e.g. in terms of overall financial health of borrowers

and loan demand, and collateral management, among other things).

Furthermore, inflation and deflation may have repercussions on interest

rate spreads, and therefore on the profitability of traditional banking

activities. Overall, both inflation and deflation can pose significant

challenges, impacting our ability to generate revenue, manage risk, and

maintain a stable financial position.

Furthermore, a significant and sustained increase in inflation has

historically also been associated with decreased prices for equity securities

and sluggish performance of equity markets generally. A sustained decline

in equity markets may:

§ result in impairment charges to equity securities that we hold in our

investment portfolios and reduced levels of unrealised capital gains

available to us which would reduce our net income, and;

§ lower the value of our equity investments impacting our capital

position.

Central banks continue to adopt a cautious stance in response to

persistent inflationary pressures, moderate economic growth, and

elevated geopolitical risks. With EU inflation converging toward the 2%

target and expected to remain near this level over the medium term,

markets anticipate stable interest rates through 2026.

Changes in interest rates may impact our business. In case of increased

interest rates, we may:

§ experience a decrease of the estimated fair value of certain fixed

income securities that we hold in our investment portfolios, resulting in:

– reduced levels of unrealised capital gains available to us, which

could negatively impact our solvency position and net income, and/

– a decrease in collateral values;

§ face an increased withdrawal of certain savings products, particularly

those with fixed rates below market rates;

§ be required, as an issuer of securities, to pay higher interest rates on

debt securities that we issue in the financial markets from time to time

to finance our operations, which would increase our interest expenses

and reduce our results;

§ experience further customer defaults as interest rate rises flow through

into payment stress for lower credit quality customers.

On the other hand, a decrease in prevailing interest rates may lead to

lower interest income from loans and investments, reduced profitability of


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traditional banking activities, and potential declines in the value of certain

fixed income securities we hold in our investment portfolio, as well as

negatively affecting our business in other ways, including leading to:

§ compress in the net interest income margins because of a potential

reduction in the interest income earned from loans;

§ lower earnings over time on investments, as reinvestments will earn

lower rates;

§ increased prepayment or redemption of mortgages and fixed maturity

securities in our investment portfolios, as well as increased

prepayments of corporate loans. This as borrowers seek to borrow at

lower interest rates potentially combined with lower credit spreads.

Consequently, we may be required to reinvest the proceeds into assets

at lower interest rates;

§ lower profitability as the result of a decrease in the spread between

client rates earned on assets and client rates paid on savings, current

account and other liabilities;

§ higher costs for certain derivative instruments that may be used to

hedge certain of our product risks;

§ lower profitability since we may not be able to fully track the decline in

interest rates in our savings rates;

§ lower profitability since we may not always be entitled to impose

surcharges to customers to compensate for the decline in interest

rates;

§ lower profitability since we may have to pay a higher premium for the

defined contribution scheme in the Netherlands for which the premium

paid is dependent on interest rate developments and the Dutch Central

Bank’s (DNB) methodology for determining the ultimate forward rate;

§ lower interest rates that may cause asset margins to decrease, thereby

lowering our results. This may, for example, be the consequence of

increased competition for investments as result of the low rates,

thereby driving margins down; and/or

§ (depending on the position) a significant collateral posting requirement

associated with our interest rate hedge programs, which could

materially and adversely affect liquidity and our profitability.

In addition, given the volatility in inflation and related volatility in interest

rates, a failure to accurately anticipate inflation on an ongoing basis and

factor it into our product pricing assumptions may result in the mispricing

of our products, which could materially and adversely impact our results.

Each of the preceding risks, should they materialise, may adversely affect

our business, results and financial condition.

The default of a major market participant could disrupt the markets and

may have an adverse effect on our business, results and financial

condition.

Within the financial services industry, the severe distress or default of any

one institution (including sovereigns and central counterparties (CCPs))

could lead to defaults by, or the severe distress of, other market

participants. While prudential regulation may reduce the probability of a

default by a major financial institution, the actual occurrence of such a

default could have a material adverse impact on ING. Such distress of, or

default by, a major financial institution could disrupt markets or clearance

and settlement systems and lead to a chain of defaults by other financial

institutions, since the commercial and financial soundness of many

financial institutions may be closely related as a result of credit, trading,

clearing or other relationships. Also, the perceived lack of creditworthiness

of a sovereign or a major financial institution (or a default by any such

entity) may lead to market-wide liquidity problems and losses or defaults

by us or by other institutions. This risk is also referred to as ‘systemic risk’

and may adversely affect financial intermediaries, such as clearing

agencies, clearing houses, banks, securities firms and exchanges with

whom we interact on a daily basis, and financial instruments of sovereigns

in which we invest. Systemic risk could impact ING directly, by exposing it

to material credit losses on transactions with defaulting counterparties or

indirectly by significantly reducing the available market liquidity on which

ING and its lending customers depend to fund their operations and/or

leading to a write-down of loans or securities held by ING. In addition, ING

may also be faced with additional open market risk for which hedging or

mitigation strategies may not be available or effective (either by hedges

eliminated by defaulting counterparties, or reduced market liquidity).

Systemic risk could have a material adverse effect on our ability to raise

new funding and on our business, results and financial condition. In

addition, such distress or failure could impact future product sales as a

potential result of reduced confidence in the financial services industry.

Continued risk of political instability and fiscal uncertainty around the

globe, as well as ongoing volatility in the financial markets and the

economy generally have adversely affected, and may continue to

adversely affect, our business, results and financial condition.

Our global business and results are materially affected by conditions in the

global capital markets and the economy generally. In Europe, there are

continuing concerns over weaker economic conditions, levels of

unemployment in certain countries, as well as geopolitical developments,

including tariffs or other trade barriers introduced by the United States and

responses to those trade barriers, the availability and cost of credit, as well

as credit spreads. In addition, geopolitical issues, including military

conflicts, the risk of further military escalation, trade tensions between

major economies, increasing protectionism between key countries, and

issues with respect to North Korea and the Middle East, may all contribute

to adverse developments in the global capital markets and the economy

generally. Sustained uncertainty about, or worsening of, current global

economic conditions and further escalation of trade tensions between the

US and its trading partners, especially China, could result in a global

economic slowdown and long-term changes to global trade. In particular,

Russia’s invasion of Ukraine, the conflict in the Middle East and other

existing or emerging military conflicts, as well as the risk that such

conflicts could escalate or widen, and related international response

measures have had, and are expected to continue to have, a negative

impact on regional and global economic conditions, including heightened

instability in global markets and increased inflation due in part to supply

chain constraints, as well as higher energy and commodity prices. Should

prices remain elevated for an extended period, most businesses and

households would be negatively impacted, and our business in Russia and

Ukraine, as well as our broader business, may be adversely affected,

including through spill-over risk to our entire Wholesale Banking portfolio,

in areas such as commodities financing, energy and utilities and energy-

consuming clients

Moreover, there is a risk that an adverse credit event at one or more

European sovereign debtors (including a credit rating downgrade, such as


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that experienced by France in 2025, or a default) could trigger a broader

economic downturn in Europe and elsewhere. In addition, the confluence

of these and other factors has resulted in volatile foreign exchange

markets. International equity markets have also continued to experience

heightened volatility and turmoil. These events, market upheavals and

continuing risks, including high levels of volatility, may have an adverse

effect on our results, in part because we have a large investment portfolio.

There is also continued uncertainty over the long-term outlook for the tax,

spending and borrowing policies of the US, the future economic

performance of the US within the global economy and any potential future

budgetary restrictions in the US, with a potential impact on a future

sovereign credit ratings downgrade of the US government, including the

rating of US Treasury securities. A downgrade of US Treasury securities

could also impact the ratings and perceived creditworthiness of

instruments issued, insured or guaranteed by institutions, agencies or

instrumentalities directly linked to the US government. US Treasury

securities and other US government-linked securities are key assets on the

balance sheets of many financial institutions and are widely used as

collateral by financial institutions to meet their day-to-day cash flows in

the short-term debt market. The impact of any further downgrades to the

sovereign credit rating of the US government or a default by the US

government on its debt obligations would create broader financial turmoil

and uncertainty, which would weigh heavily on the global financial system

and could consequently result in a significant adverse impact to the

Group’s business and operations.

In many cases, the markets for investments and instruments have been

and remain illiquid, and issues relating to counterparty credit ratings and

other factors have exacerbated pricing and valuation uncertainties.

Valuation of such investments and instruments is a complex process

involving the consideration of market transactions, pricing models,

management judgement and other factors, and is also impacted by

external factors, such as underlying mortgage default rates, interest rates,

rating agency actions and property valuations. Historically these factors

have resulted in, among other things, valuation and impairment issues in

connection with our exposures to European sovereign debt and other

investments.

Any of these general developments in global financial and political

conditions could negatively impact our business, results and financial

condition in future periods.

Discontinuation of interest rate benchmarks may negatively affect our

business, results and financial condition.

Changes to major interest rate benchmarks may adversely affect our

business, including net interest revenue. Historically, financial markets

relied on Interbank Offered Rates (IBORs) such as LIBOR, EONIA, CDOR, and

EURIBOR. While some benchmarks like EURIBOR have been reformed and

remain in use, others such as EONIA, CDOR, and LIBOR have been

discontinued and replaced by alternative rates.

In Poland, the National Working Group has established a roadmap to

replace WIBOR with POLSTR (Polish Short-Term Rate), a risk-free overnight

benchmark based on actual transactions. POLSTR was selected in

December 2024 and began publication in June 2025, including

compounded 1-, 3-, and 6-month versions. Treasury bonds referencing

POLSTR were launched in late 2025, with broader adoption in loans and

mortgages expected in 2026. Full transition and WIBOR phase-out are

anticipated by the end of 2027

The discontinuation of benchmarks and adoption of new rates may create

legal, operational, and financial risks, including documentation changes,

conduct risks, and potential earnings volatility from contract modifications

and hedge accounting adjustments.

ING continues to monitor market developments and reform plans for other

rates to anticipate the impact on our customers and any related risks.

Market conditions, including those observed over the past few years,

may increase the risk of loans being impaired and have a negative effect

on our results and financial condition.

We are exposed to the risk that our borrowers (including sovereigns) may

not repay their loans according to their contractual terms and that the

collateral securing the payment of these loans may be insufficient. We

may see adverse changes in the credit quality of our borrowers and

counterparties, for example, as a result of their inability to refinance their

indebtedness or in the case of a decline in financial performance. Adverse

changes in the credit quality of our borrowers and/or decreasing collateral

values would result in increased capital requirements and provisions, and

any deterioration of market conditions may lead to increasing

delinquencies, defaults and insolvencies across a range of sectors. This

may lead to impairment charges on loans and other assets, higher costs

and additions to loan loss provisions. A significant increase in the size of

our provision for loan losses could have a material adverse effect on our

business, results and financial condition.

ING manages concentration risk through a comprehensive framework of

limits on single names, countries, and sectors, supported by regular

monitoring and portfolio steering to ensure exposures remain within its

risk appetite. If we are significantly exposed to a concentrated set of

customers or counterparties, an adverse event affecting these parties

could lead to increased losses for the Group, and adversely affect our

business, results and financial condition.

We may incur losses due to failures of banks falling under the scope of

resolution funding or deposit schemes.

While prudential regulation is intended to minimise the risk of bank

failures, in the event such a failure occurs, given our size, we may incur

significant compensation payments to be made under the Dutch Deposit

Guarantee Scheme (DGS), which we may be unable to recover from the

bankrupt estate, and therefore the consequences of any future failure of

such a bank could be significant to ING. Such costs and the associated

costs to be borne by us may have a material adverse effect on our results

and financial condition. On the basis of the EU Directive on deposit

guarantee schemes, ING pays quarterly risk-weighted contributions into a

DGS-fund. The Dutch DGS-fund reached its intended target size of 0.8

percent of all deposits guaranteed under the DGS, in July 2024. Further,

quarterly risk-weighted contributions are only required when individual

and / or collective covered deposits show an increase in a quarter. In case

of failure of a Dutch bank, depositor compensation is paid from the DGS-

fund. If the available financial means of the fund are insufficient, Dutch


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banks, including ING, may be required to pay extraordinary ex-post

contributions not exceeding 0.5 percent of their covered deposits per

calendar year. In exceptional circumstances, and with the consent of the

competent authority, higher contributions may be required. However,

extraordinary ex-post contributions may be temporarily deferred if, and

for so long as, they would jeopardise the solvency or liquidity of a bank.

Depending on the size of the failed bank, the available financial means in

the DGS-fund, and the required additional financial means, the impact of

the extraordinary ex-post contributions on ING may be material.

Since 2015, the EU has been discussing the introduction of a pan-European

deposit guarantee scheme (EDIS), which would (partly) replace or

complement national compensation schemes. As of the date of this

report, negotiations regarding EDIS have stalled and no such scheme has

been introduced.

On 18 April 2023, the European Commission published its proposals for the

revision of the common framework for bank crisis management and

deposit insurance (CMDI) that focuses on small and medium-sized banks,

but will affect banks in the EU. The CMDI framework consists of the Bank

Recovery and Resolution Directive (BRRD), the Single Resolution

Mechanism Regulation (SRMR) and the Deposit Guarantee Schemes

Directive (DGSD). The European Parliament adopted its first-reading reports

on the proposals in April 2024. The Council agreed on a negotiating

mandate for the revision of the CMDI on 19 June 2024. With this

agreement, the Council is ready to negotiate with the European

Parliament on the final form of this legislative proposal. On 25 June 2025,

the Council and the European Parliament reached a political agreement on

the reformed CMDI framework. The co-legislators are now expected to

finalise the legal text, after which the revised framework is expected to be

formally adopted and enter into force. The revision of the CMDI framework

is part of the debate on the completion of the Banking Union and in

particular its third and missing pillar EDIS.

Risks related to the regulation and supervision of the Group

Non-compliance with laws and/or regulations could result in fines and

other liabilities, penalties or consequences for us, which could materially

affect our business and reputation and reduce our profitability.

ING has faced, and in the future may continue to face, the consequences

of non-compliance with applicable laws and regulations, including the

potential initiation of regulatory investigations or legal proceedings. For

additional information on legal proceedings, see Note 40 ‘Legal

proceedings’ in the consolidated financial statements. There are potential

risks in areas where applicable regulations may be unclear, subject to

multiple interpretations or under development; where regulations may

conflict with one another; or where regulators revise their previous

guidance or courts overturn previous rulings. These could result in our

failure to comply with applicable standards. Regulators and other

authorities have the power to initiate investigations and/or administrative

or judicial proceedings against us, which may result, among other things,

in suspension or revocation of our licences, cease and desist orders, fines,

civil penalties, criminal penalties or other disciplinary measures, which

could materially harm our results and financial condition as well as ING’s

reputation. If we fail, or appear to fail to properly address, any of these

matters, our reputation may be harmed and we may be exposed to

additional legal risk, which in turn may increase the size and number of

claims and damages brought against us or subject us to enforcement

actions, fines and penalties.

Furthermore, as a financial institution, we are exposed to the risk of

unintentional involvement in criminal activity in connection with financial

economic crimes, including the circumvention of sanctions, money

laundering and the funding of terrorist and other criminal activities. The

failure or perceived failure by us to comply with legal and regulatory

requirements with respect to financial economic crimes may result in

adverse publicity, claims and allegations, litigation and regulatory

investigations and sanctions, which may have a material adverse effect on

our business, results, financial condition and/or prospects in any given

period. For further information on the impact of litigation, enforcement

proceedings, investigations or other regulatory actions with respect to

financial economic crimes, see 'We may be subject to litigation,

enforcement proceedings, investigations or other regulatory actions, and

adverse publicity' below.

Changes in laws and/or regulations governing financial services or

financial institutions or the application of such laws and/or regulations

may increase our operating costs and limit our business activities.

We are subject to detailed banking laws and financial regulations in the

jurisdictions in which we conduct business. The regulations governing the

industries in which we operate have become more extensive and complex,

while also attracting supervisory scrutiny. Compliance with current and

new laws and regulations is resource-intensive and may materially

increase our operating costs. Moreover, these regulations are designed to

protect our customers, markets and society as a whole and can limit or

redirect our activities, among others, through stricter net capital, market

conduct and transparency requirements and restrictions on the businesses

in which we can operate or invest.

Our revenues and profitability and those of our industry have been and

continue to be affected by requirements relating to capital, additional loss-

absorbing capacity, leverage, minimum liquidity and long-term funding

levels, resolution and recovery planning requirements, derivatives clearing

and margin rules and levels of regulatory oversight, as well as restrictions

on which and, if permitted, how certain business activities may be carried

out by financial institutions.

We are subject to additional legal and regulatory risk in certain

countries with less developed or less predictable legal and regulatory

frameworks or the supervision thereof.

In certain countries where we operate or where our clients reside, judicial

and dispute resolution systems may be less effective. As a result, in the

event of a breach of contract, we have experienced in the past and may

continue to have difficulties in making and enforcing claims against

contractual counterparties and, if claims are made against us, we have

experienced in the past and may continue to encounter difficulties in

mounting a defence against such allegations. If we become party to legal

proceedings in a market with an insufficiently developed judicial system, it

could have an adverse effect on our operations and net results. For


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additional information on legal proceedings, see Note 40 ‘Legal

proceedings’ in the consolidated financial statements.

In addition, as a result of our operations in certain countries, we are

subject to risks of possible nationalisation, expropriation, price controls,

exchange controls and other restrictive government actions, as well as the

outbreak of hostilities and/or war, in these markets. In particular, we have

wholesale banking activities in both Russia and Ukraine, as well as

investments in Russia, some of which are denominated in local currency.

Furthermore, the current economic environment in certain countries in

which we operate may increase the likelihood for regulatory initiatives to

enhance consumer protection or to protect homeowners from

foreclosures. Any such regulatory initiative could have an adverse impact

on our ability to protect our economic interest, for instance in the event of

defaults on residential mortgages.

We are subject to the regulatory supervision of the ECB and other

regulators and public bodies with extensive supervisory and

investigatory powers.

In its capacity as the principal prudential supervisor in the EU, the ECB has

extensive supervisory and investigatory powers, including the ability to

issue requests for information, to conduct regulatory investigations and

on-site inspections, and impose monetary and other sanctions. For

example, under the Single Supervisory Mechanism (SSM), the relevant

(national) competent authorities, including the ECB, can conduct stress

tests and have the discretionary power to impose capital surcharges on

financial institutions for risks not otherwise recognised in risk-weighted

assets or other surcharges depending on the individual situation of the

bank, and take or require other measures, such as restrictions on or

changes to the Group’s business. Competent authorities may also prohibit

the Group from making dividend payments to shareholders or distributions

to holders of its regulatory capital instruments if the Group fails to comply

with regulatory requirements, in particular with regard to supervisory

measures, minimum capital requirements (including buffer requirements)

or with liquidity requirements, or if there are deficiencies in its governance

and risk management processes. A perceived failure to comply with

prudential or conduct regulations may have a material adverse effect on

the Group’s business, results and financial condition.

Failure to meet minimum capital and other prudential regulatory

requirements as applicable to us from time to time may have a material

adverse effect on our business, results and financial condition and on

our ability to make payments on certain of our securities.

ING is subject to a variety of regulations that require us to comply with

minimum requirements for capital (own funds) and additional loss-

absorbing capacity, as well as for liquidity, and to comply with leverage

restrictions. In addition, such capital, liquidity and leverage requirements

and their application and interpretation may change. Any changes may

require us to maintain more capital or to raise a different type of capital by

disqualifying existing capital instruments from continued inclusion in

regulatory capital, requiring replacement with new capital instruments

that meet the new criteria. Sometimes changes are introduced subject to

a transitional period during which the new requirements are being phased

in, gradually progressing to a fully phased-in, or fully-loaded, application of

the requirements.

Any failure to comply with these requirements, or to adapt to changes in

such requirements, may have a material adverse effect on our business,

results and financial condition, and may require us to seek additional

capital. Failures to meet minimum capital or other prudential

requirements may also result in ING being prohibited from making

payments on certain of our securities. Because implementation phases

and transposition into EU or national regulation where required may often

involve a lengthy period, the impact of changes in capital, liquidity and

leverage regulations on our business, results and financial condition, and

on our ability to make payments on certain of our securities, is often

unclear.

Our US commodities and derivatives business is subject to CFTC and SEC

regulation under the Dodd-Frank Act.

Our affiliate ING Capital Markets LLC is registered with the Commodity

Futures Trading Commission (CFTC) as a swap dealer and is subject to CFTC

regulation pursuant to Title VII of the US Dodd-Frank Wall Street Reform

and Consumer Protection Act (Dodd-Frank). Operating as a swap dealer

requires compliance with CFTC regulatory requirements, which may be

burdensome, impose additional compliance costs and could adversely

affect the profitability of this business, as well as exposing ING to the risk of

non-compliance with these regulations.

ING Capital Markets LLC is also registered with the SEC as a security-based

swap dealer. Operating as a security-based swap dealer requires

compliance with SEC regulatory requirements, which may be burdensome,

impose additional compliance costs and could adversely affect the

profitability of this business, as well as exposing ING to the risk of non-

compliance with these regulations. While most of these SEC requirements

apply to ING Capital Markets LLC, in addition to its CFTC swap dealer

requirements, SEC rules have permitted an Alternative Compliance

Mechanism that allows for compliance, subject to eligibility requirements,

with CFTC capital and margin rules applying to swap dealers in lieu of SEC

capital and margin rules applying to security-based swap dealers. ING

Capital Markets LLC has elected to use the Alternative Compliance

Mechanism. However, should ING Capital Markets LLC in the future be

ineligible for the Alternative Compliance Mechanism, it would be subject to

SEC security-based swap dealer rules for margin, capital, and related

financial reporting instead of the CFTC swap dealer rules which could be

more capital- intensive.

Any of the foregoing factors, and any further regulatory developments

with respect to commodities and derivatives, could have a material impact

on our business, results and financial condition.

We are subject to the EU recovery and resolution regime and several

other bank recovery and resolution regimes that include statutory write-

down and conversion as well as other powers, which remains subject to

significant uncertainties as to scope and impact on us.

We are subject to several recovery and resolution regimes, including the

Single Resolution Mechanism (SRM) and the Bank Recovery and Resolution

Directive (BRRD) as implemented in national legislation such as the Dutch

Financial Supervision Act. The SRM applies to banks that are supervised by

the ECB under the SSM, with the aim of ensuring an orderly resolution of

failing banks at minimum cost for taxpayers and the real economy. The

BRRD establishes a common framework for the recovery and resolution of

banks within the European Union, with the aim of providing supervisory

authorities and resolution authorities with common tools and powers to


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address banking crises pre-emptively to safeguard financial stability and

minimise taxpayers’ exposure to losses. Any application of statutory write-

down and conversion or other powers would not be expected to constitute

an event of default under our securities entitling holders to seek

repayment. If any of these powers were to be exercised in respect of ING,

there could be a material adverse effect on both ING and on holders of ING

securities, including through a material adverse effect on credit ratings

and/or the price of our securities. Investors in our securities may lose their

investment if resolution measures are taken under current or future

regimes.

Risks related to litigation, enforcement proceedings and

investigations and to changes in tax laws

We may be subject to litigation, enforcement proceedings,

investigations or other regulatory actions, and adverse publicity.

We are involved in governmental, regulatory, arbitration and legal

proceedings and investigations involving claims by and against us which

arise in the ordinary course of our businesses, including in connection with

our activities as financial services provider, employer, investor and

taxpayer. As a financial institution, we are subject to specific laws and

regulations governing financial services and/or financial institutions. See

'Changes in laws and/or regulations governing financial services or

financial institutions or the application of such laws and/or regulations

may increase our operating costs and limit our activities' and 'Our US

commodities and derivatives business is subject to CFTC and SEC

regulation under the Dodd-Frank Act' above. Financial reporting

irregularities involving other large and well-known companies, possible

findings of government authorities in various jurisdictions which are

investigating several processes, notifications made by whistleblowers,

increasing regulatory and law enforcement scrutiny of ‘know your

customer’ anti-money laundering regulations, tax evasion, prohibited

transactions with countries or persons subject to sanctions, and bribery or

other anti-corruption measures and anti-terrorist-financing procedures

and their effectiveness, regulatory investigations of the banking industry,

and litigation that arises from the failure or perceived failure by us to

comply with legal, regulatory, tax and compliance requirements could

result in adverse publicity and reputational harm. Such developments

could lead to increased regulatory supervision, affect our ability to attract

and retain customers and employees and maintain access to the capital

markets, result in cease and desist orders, claims, enforcement actions,

fines and civil and criminal penalties, other disciplinary action or have

other material adverse effects on us in ways that are not predictable. With

respect to sanctions, Russia’s continued occupation of Ukraine and the

associated conflict has seen successive significant sanctions packages

imposed and continued focus of the EU, US, and other governments on the

potential circumvention of sanctions against Russia, and the roles of third

countries and companies in facilitating the circumvention or undermining

of such sanctions' measures. The EU’s additional measures combating

sanctions circumvention has led to focus on several locations as potential

diversion hubs. While various sanctions include grace periods before full

compliance is required, there is no guarantee that ING will be able to

implement all required procedures within the applicable grace periods. In

addition, some claims and allegations may be brought by or on behalf of a

class and claimants may seek large or indeterminate amounts of

damages, including compensatory, liquidated, treble and punitive

damages. Our reserves for litigation liabilities may prove to be inadequate.

Claims and allegations, should they become public, need not be well

founded, true or successful to have a negative impact on our reputation. In

addition, press reports and other public statements that assert some form

of wrongdoing could result in inquiries or investigations by regulators,

legislators and law enforcement officials, and responding to these inquiries

and investigations, regardless of their ultimate outcome, is time

consuming and expensive. Adverse publicity claims and allegations,

litigation and regulatory investigations and sanctions have had in the past

and may continue to have in the future a material adverse effect on our

business, results, financial condition and/or prospects.

We are subject to different tax regulations in each of the jurisdictions

where we conduct business, and are exposed to changes in tax laws and

risks of non-compliance resulting in proceedings or investigations with

respect to tax laws.

Changes in tax laws (including case law) and tax treaties (including the

termination thereof) could increase our taxes and our effective tax rates

and could materially impact our tax receivables and liabilities as well as

deferred tax assets and deferred tax liabilities, which could have a material

adverse effect on our business, results and financial condition. Changes in

tax laws could also make certain ING products less attractive, which could

have adverse consequences for our businesses and results.

Because of the geographic spread of its business, ING may be subject to

tax audits, investigations and procedures in numerous jurisdictions at any

point in time. Although we believe that we have adequately provided for

all our tax positions, the ultimate resolution of these audits, investigations

and procedures may result in liabilities which are different from the

amounts recognised. In addition, increased bank taxes in countries where

the Group is active result in increased taxes on ING’s banking operations,

which could negatively impact our operations, financial condition and

liquidity.

Our reputation could be harmed and we could be subject to enforcement

actions, fines and penalties if we fail to comply with our obligations

under tax laws and regulations.

Due to the nature of its business, ING is subject to various provisions of EU,

US, and other local tax laws in relation to its customers. These include,

amongst others, the Foreign Account Tax Compliance Act (FATCA), which

requires ING to provide certain information for the US Internal Revenue

Service (IRS); the Qualified Intermediary (QI) requirements, which require

withholding tax on certain US-source payments; and the Common

Reporting Standards (CRS) which requires ING to provide certain

information to local tax authorities. Failure to comply with these

requirements and regulations could harm our reputation and could subject

the Group to enforcement actions, fines and penalties, which could have a

material adverse effect on our business, reputation, revenues, results,

financial condition and prospects.

ING is exposed to the risk of claims from customers or stakeholders who

feel misled or treated unfairly because of advice or information

received.

Our products and services, including banking products and advice services

for third-party products are exposed to claims from customers who might

allege that they have received insufficient advice or misleading

information from advisers (both internal and external) as to which

products were most appropriate for them, or that the terms and


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conditions of the products, the nature of the products or the

circumstances under which the products were sold, were misrepresented

to them. When new financial products are brought to the market, it is

ING’s policy to engage in a multidisciplinary product approval process in

connection with the development and distribution of such products,

including production of appropriate marketing and communication

materials. Notwithstanding these processes, customers have made in the

past and may continue to make in the future claims against ING if the

products do not meet their expectations, either at the purchase/execution

of the product and/or through the life of the product. Customer protection

regulations, as well as changes in interpretation and perception by both

the public at large and governmental authorities of acceptable market

practices, influence customer expectations.

Products distributed through person-to-person sales forces have a higher

exposure to such claims as the sales forces may provide face-to-face

financial planning and advisory services. Complaints may also arise if

customers feel that they have not been treated reasonably or fairly, or

that the duty of care has not been complied with. While a considerable

amount of time and resources have been invested in reviewing and

assessing historical sales practices and products that were sold in the past,

and in the maintenance of risk management, legal and compliance

procedures to monitor current sales practices, there can be no assurance

that all of the issues associated with current and historical sales practices

have been or will be identified, nor that any issues already identified will

not be more widespread than presently estimated.

The negative publicity associated with any sales practices, any

compensation payable in respect of any such issues and regulatory

changes resulting from such issues, have had and could have a material

adverse effect on our reputation, business, results, financial condition and

prospects. For additional information regarding legal proceedings or

claims, see Note 40 ‘Legal proceedings’ to the consolidated financial

statements.

Risks related to the Group’s business and operations

ING may be unable to meet evolving expectations or requirements with

respect to ESG-related matters.

Environmental, Social and Governance (ESG) is an area of significant and

increased public dialogue and focus for governments and regulators,

investors, ING’s customers and employees, and other stakeholders or third

parties (e.g. non-governmental organisations or NGOs). As a result, an

increasing number of laws, regulations and legislative actions have been

introduced to address ESG-related matters, including in relation to the

financial sector’s operations and strategy. Such ESG-related matters may

relate to climate change, sustainability, diversity, equity and inclusion (DEI)

or other ESG-related matters. Such recent regulations include the EU

Sustainable Finance Disclosure Regulation (SFDR), EU Taxonomy regulation

and EU Green Bond Standards, which broadly focus on disclosure

obligations, standardised definitions and classification frameworks for

environmentally sustainable activities, and the EU Corporate Sustainability

Reporting Directive (CSRD), which requires certain companies, including

ING, to disclose information on what they see as the risks and

opportunities arising from environmental, social and governance issues,

and on the impact of their activities on people and the environment.

Similarly, the State of California’s legislation requires broad disclosure of

greenhouse gas emissions and other climate-related information.

National or international regulatory actions or developments may also

result in financial institutions coming under increased pressure from

internal and external stakeholders regarding the management and

disclosure of their ESG risks and related lending and investment activities.

ING may regularly adopt or update ESG-related policies, frameworks or

disclosures in connection with the conduct of its business and operations.

However, these approaches may change regularly and, ultimately, there is

no guarantee that ING will be able to fully comply with all applicable

requirements within anticipated timeframes, or at all. Our ability to satisfy

evolving ESG-related laws, regulations, initiatives, targets, ambitions, aims

or expectations and to accurately report performance or developments

with respect to such matters is subject to numerous risks, many of which

are outside of our control, including the evolving legal environment,

regulatory requirements for the tracking and reporting of standards or

disclosures, the actions of suppliers, partners, and other third parties, and

data that is outside of ING’s control.

Our stakeholders may hold differing views on ESG-related matters,

including DEI, which may result in negative attention in traditional and

social media or a negative perception of our response to concerns

regarding these matters. In addition, we may also face potentially

conflicting supervisory directives as certain US regulatory and non-US

authorities have prioritized ESG-related issues while Congress and certain

US state governments have signaled pursuing potentially conflicting

priorities. These circumstances, among others, may result in pressure from

investors, unfavourable reputational impacts, including inaccurate

perceptions or a misrepresentation of our actual ESG-related practices and

diversion of management’s attention and resources. Any failure, or

perceived failure, by us to adhere to our public statements, comply fully

with developing interpretations of ESG-related laws and regulations,

including with respect to DEI-related matters, or meet evolving and varied

stakeholder expectations and standards could negatively impact our

reputation or result in legal and enforcement proceedings against ING. For

instance, Friends of the Earth Netherlands (Milieudefensie) has alleged that

ING has contributed to climate change and has initiated legal proceedings

against ING. For additional information on legal proceedings, including

climate related litigation, see Note 40 ‘Legal proceedings’ in the

consolidated financial statements.

Any of these factors may have an adverse impact on ING’s reputation and

brand value, or on ING’s business, financial condition and operating results.

ING may be unable to adapt its products and services to meet changing

customer behaviour and demand, including as a result of ESG-related

matters.

Customers or other counterparties may increasingly assess sustainability

or other ESG-related matters in their economic decisions. For instance,

customers may choose investment products or services based on

sustainability or other ESG criteria or may look at a financial institution’s

ESG-related lending strategy when choosing to make deposits. At the

same time, market and stakeholder views, including those of regulatory or

governmental authorities, on ESG-related matters may vary across


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jurisdictions and over time, and we have faced scrutiny, reputational risk,

product boycotts, lawsuits or market access restrictions from these parties

regarding our ESG-related policies, including with respect to DEI matters.

To remain competitive and to safeguard its reputation, ING is required to

continuously adapt its business strategy, products and services to respond

to emerging, increasing or changing sustainability and other ESG-related

demands from customers, investors and other stakeholders. However,

there is no guarantee that ING’s current or future products or services will

meet applicable ESG-related regulatory requirements, customer

preferences or investor expectations.

ING’s business and operations are exposed to transition risks related to

climate change.

The transition to a low-carbon or net-zero economy gives rise to risks and

uncertainties associated with climate change-related laws, regulations

and oversight, changing or new technologies, and shifting customer

sentiment. For instance, ING may be required to change its lending

portfolio to comply with new climate change-related regulations and other

ESG-related demands from customers, investors and other stakeholders.

Such changes could affect ING’s ability to continue or expand certain

customer relationships. This could result in claims or legal challenges

against ING. At the same time, market and stakeholder views, including

those of regulatory or governmental authorities, on ESG-related matters

may vary across jurisdictions and over time, and we may face scrutiny,

reputational risk, product boycotts, lawsuits or market access restrictions

from these parties regarding our ESG-related policies. This transition may

also adversely impact the business and operations of ING’s customers and

other counterparties. Further, there is a risk that changing community

standards and market expectations could lead to a reduction in demand

and a decline in valuations for certain assets, which may affect the value

of collateral we hold or the financial strength of certain of our portfolios. If

ING fails to adequately factor in such risks in its lending or other business

decisions, ING could be exposed to losses.

The low-carbon or net-zero transition may also require ING to modify or

implement new compliance systems, internal controls and procedures or

governance frameworks. The integration and automation of internal

governance, compliance, and disclosure and reporting frameworks across

ING could lead to increased operational costs for ING and other execution

and operational risks. The implementation cost of these systems may

especially be higher in the near term as ING seeks to adapt its business, or

address overlapping, duplicative or conflicting regulatory or other

requirements in this fast-developing area. Furthermore, ING’s ongoing aim

to implement appropriate systems, controls and frameworks increasingly

requires ING to develop adequate climate change-related risk assessment

and modelling capabilities (as there is currently no standard approach or

methodology available), and to collect customer, third-party or other data.

There are significant risks and uncertainties inherent in the development of

new risk modelling methodologies and the collection of data, potentially

resulting in systems or frameworks that could be inadequate, inaccurate,

incomplete or susceptible to incorrect customer, third-party or other data.

Any delay, change or failure in developing, implementing or meeting ING’s

climate change-related policies and complying with applicable regulatory

requirements may have a material adverse impact on our business,

financial condition, operating results and reputation, and lead to climate

change or ESG-related investigations, enforcement proceedings or

litigation.

ING’s business and operations are exposed to physical risks, including as

a direct result of climate change.

ING’s business and operations are exposed to the impacts of physical risks

arising from climate and weather-related events, including heatwaves,

droughts, flooding, storms, rising sea levels, other extreme weather events

or natural disasters, and to the impacts of physical risks arising from

environmental degradation, including the loss of biodiversity, water or

resource scarcity, pollution or waste management. Such physical risks

have disrupted in the past and could continue in the future to disrupt ING’s

business continuity and operations or impact ING’s premises or property

portfolio, as well as its customers’ property, business or other financial

interests. These risks could potentially result in impairing asset values,

financial losses, declining creditworthiness of customers and increased

defaults, delinquencies, write-offs and impairment charges in ING’s

portfolio, etc. In particular, changing climate patterns resulting in more

frequent and extreme weather events, such as the severe flooding that

occurred in Spain in October 2024 or the severe flooding in Germany in

mid-2024, could lead to unexpected business interruptions or losses for

ING or its customers.

Furthermore, ING’s ongoing aim to implement appropriate systems,

controls and frameworks increasingly requires ING to develop adequate

physical risk assessment and modelling capabilities (as there is currently

no standard approach or methodology available), and to collect customer,

third-party or other data. There are significant risks and uncertainties

inherent in the development of new risk modelling methodologies and the

collection of data, potentially resulting in systems or frameworks that

could be inadequate, inaccurate, incomplete or susceptible to incorrect

customer, third-party or other data.

For a description of physical risks to our operations and business other

than resulting from natural disasters as a result of climate change, see

'Operational and IT risks, such as system disruptions or failures, breaches

of security, cyber attacks, human error, changes in operational practices,

inadequate controls including in respect of third parties with which we do

business or outbreaks of communicable diseases may adversely impact

our reputation, business and results' below.

Operational and IT risks, such as systems disruptions or failures,

breaches of security, human error, changes in operational practices,

inadequate controls including in respect of third parties with which we

do business or outbreaks of communicable diseases may adversely

impact our reputation, business and results.

Operational and IT risks are inherent to our business. Our clients depend on

our ability to process and report a large number of transactions efficiently

and accurately. In addition, we routinely transmit, receive and store

personal, confidential and proprietary information electronically. Losses

can result from inadequately trained or skilled personnel, IT failures

(including due to a cyber attack), inadequate or failed internal control

processes and systems, regulatory breaches, human errors, employee

misconduct, (including fraud), or from natural disasters or other external

events that interrupt normal business operations. As the role of artificial

intelligence in the finance industry and in our business increases, losses

may also result from incomplete, inaccurate or otherwise flawed outputs


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from the algorithms and data sets utilised. Such losses may adversely

affect our reputation, business and results.

We depend on the secure processing, storage and transmission of

confidential and other information in our IT systems and networks. The

equipment and software used in our computer systems and networks may

not always be capable of processing, storing or transmitting information

as expected. Despite our business continuity plans and procedures, certain

of our computer systems and networks may have insufficient recovery

capabilities in the event of a malfunction or loss of data. We are

consistently managing and monitoring our IT risk profile globally. ING is

subject to increasing regulatory requirements including EU General Data

Protection Regulation (GDPR) and EU Payment Services Directive (PSD2)

and the new Digital Operational Resilience Act (DORA) which applies from

17 January 2025. Failure to appropriately manage and monitor our IT risk

profile could affect our ability to comply with these regulatory

requirements, to securely and efficiently serve our clients or to timely,

completely and accurately process, store and transmit information, and

may adversely affect our reputation, business and results. For further

description of the particular risks associated with cybercrime, which is a

specific risk to ING as a result of its strategic focus on technology and

innovation, see 'We are subject to increasing risks related to cybercrime

and compliance with cybersecurity regulation' below.

In addition, as the use of artificial intelligence in the financial services

industry increases, data protection and information security risks may also

increase. Our or our customers’ sensitive, proprietary, or confidential

information could be leaked, disclosed, or revealed as a result of or in

connection with our or our third-party providers’ use of generative or other

artificial intelligence technologies. Any such information input into a third-

party generative or other artificial intelligence or machine learning

platform could be revealed to others, including if information is used to

train the third party's artificial intelligence models. Additionally, where an

artificial intelligence model ingests personal information and makes

connections using such data, those technologies may reveal other

sensitive, proprietary, or confidential information generated by the model.

The EU AI Act entered into force in 2024. Certain prohibitions and AI-

literacy requirements apply from February 2025, governance and GPAI

model provisions from August 2025, and obligations for high-risk system

are expected to phase in during 2026 and 2027. We are implementing AI

governance and model risk controls to comply with these requirements.

Widespread of communicable diseases (including pandemics or other

large scale public health emergencies) may impact the health of our

employees, increasing absenteeism, or may cause a significant increase in

the utilisation of health benefits offered to our employees, and may also

disrupt broader economic activity and cross border operations, either or

both of which could adversely impact our business. Further, a significant

portion of our staff continue to work from home on a full- or part-time

basis, which may raise operational risks, including with respect to

information security, data protection, availability of key systems and

infrastructure integrity. In addition, other events including unforeseeable

and/or catastrophic events can lead to an abrupt interruption of activities

and cause operational losses. Losses can result from destruction or

impairment of property, financial assets, trading positions, and the loss of

key personnel.

If our business continuity plans are implemented effectively or, do not

sufficiently take such events into account, losses may increase further.

We are subject to increasing risks related to cybercrime and compliance

with cybersecurity regulation.

Like other financial institutions and global companies, we are regularly the

target of cyber attacks, which are a specific risk to ING as a result of its

strategic focus on technology and innovation. In particular, threats from

Distributed Denial of Service (DDoS), targeted attacks (also called

Advanced Persistent Threats) and ransomware have intensified worldwide,

and attempts to gain unauthorised access and the sophistication of

techniques used for such attacks is increasing. Cyber threats are

constantly evolving and the techniques used in these attacks change,

develop and evolve rapidly, including the use of emerging technologies,

such as advanced forms of artificial intelligence and quantum computing.

The new cyber risks introduced by these changes in technology require us

to devote significant attention to the identification, assessment and

analysis of the risks and the implementation of corresponding

preventative measures. We have faced, and expect to continue to face, an

increasing number of cyber attacks (both successful and unsuccessful) as

we have further digitalised. This includes the continuing expansion of our

mobile- and other internet-based products and services, as well as our

usage and reliance on cloud technology.

A substantial majority of our customers interact with us primarily through

digital channels. This increased reliance on digital banking and remote

working may increase the risk of cybersecurity breaches, loss of personal

data and related reputational risk. If any of these risks were to materialise

that may adversely affect our business, results and financial condition.

Cybersecurity, the use and safeguarding of customer data and data

privacy have become the subject of increasing legislative and regulatory

focus. The EU’s second Payment Services Directive (PSD2), GDPR, DORA,

NIS2 and the Cyber Resilience Act are examples of such regulations. The

EU Cyber Resilience Act entered into force on 10 December 2024. Certain

vulnerability and incident reporting obligations apply from 11 September

2026, with full obligations applicable from 11 December 2027. In 2024, the

ECB conducted its first cyber resilience stress test to assess banks’ ability

to respond to and recover from a severe cyber incident. The results,

reflected in the 2024 SREP, identified areas for improvement in our

response and recovery capabilities, leading to enhancements in our cyber

resilience measures. In certain locations where ING is active, there are

additional local regulatory requirements and legislation on top of EU

regulations that must be followed for business conducted in that

jurisdiction. Some of these legislations and regulations may be conflicting

due to local regulatory interpretations. We may become subject to new

legislation or regulation concerning cybersecurity, security of customer

data in general or the privacy of information we may store or maintain.

Compliance with such new legislation or regulation could increase the

Group’s compliance cost. Failure to comply with applicable laws or

regulation could harm our reputation and could subject the Group to

enforcement actions, fines and penalties.

ING may be exposed to the risks of misappropriation, unauthorised access,

including through malware (such as ransomware), other malicious code,

cyber attacks and internal breaches for purposes of misappropriating

assets or sensitive information, corrupting data, or impairing operational

performance, each of which could have a security impact. These events


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could also jeopardise our confidential information or that of our clients or

our counterparties. These events can potentially result in financial loss and

harm to our reputation, hinder our operational effectiveness, result in

regulatory censure, compensation costs or fines resulting from regulatory

investigations and could have a material adverse effect on our business,

reputation, revenues, results, financial condition and prospects. Even when

we are successful in defending against cyber attacks, such defence may

consume significant resources or impose significant additional costs on

ING.

Because we operate in highly competitive markets, including our home

market, we may not be able to increase or maintain our market share,

which may have an adverse effect on our results.

There is substantial competition in the Netherlands and the other

countries in which we do business for the types of wholesale banking,

retail banking, investment banking and other products and services we

provide. Customer loyalty and retention can be influenced by several

factors, including brand recognition, reputation, relative service levels, the

prices and attributes of products and services, scope of distribution, credit

ratings and actions taken by existing or new competitors (including non-

bank or financial technology competitors). A decline in our competitive

position as to one or more of these factors could adversely impact our

ability to maintain or further increase our market share, which would

adversely affect our results. Such competition is most pronounced in our

more mature markets of the Netherlands, Belgium, the rest of Western

Europe and Australia. In recent years, however, competition in emerging

markets, such as Asia and Central and Eastern Europe, has also increased

as large financial services companies from more developed countries have

sought to establish themselves in markets which are perceived to offer

higher growth potential, and as local institutions have become more

sophisticated and competitive and proceeded to form alliances, mergers

or strategic relationships with some of our competitors. The Netherlands is

our largest market. Our main competitors in the banking sector in the

Netherlands are ABN AMRO Bank and Rabobank.

Competition could also increase due to new entrants (including non-bank

and financial technology competitors) in the markets that may have new

operating models that are not burdened by potentially costly legacy

operations and that are subject to reduced regulation. Competitive

dynamics continue to evolve as a result of platform-based players and

fintechs, regulatory changes affecting payments and data access, and

accelerated cloud-native operating models, which may intensify price and

service-level pressure across retail and wholesale. New entrants may rely

on new technologies, advanced data and analytic tools, lower cost to

serve, less extensive oversight from regulators compared to the

frameworks established in respect of traditional banks and/or faster

processes to challenge traditional banks. Developments in technology

have also accelerated the use of new business models, and ING may not

be successful in adapting to this pace of change or may incur significant

costs in adapting its business and operations to meet such changes. For

example, new business models have been observed in retail payments,

consumer and commercial lending (such as peer-to-peer lending), foreign

exchange and low-cost investment advisory services. In particular, the

emergence of disintermediation in the financial sector resulting from new

banking, lending and payment solutions offered by rapidly evolving

incumbents, challengers and new entrants, in particular with respect to

payment services and products, and the introduction of disruptive

technology may impede our ability to grow or retain our market share and

impact our revenues and profitability.

Increasing competition in the markets in which we operate (including from

non-banks and financial technology competitors) may significantly impact

our results if we are unable to match the products and services offered by

our competitors. Future economic turmoil may accelerate additional

consolidation activity. Over time, certain sectors of the financial services

industry have become more concentrated, as institutions involved in a

broad range of financial services have been acquired by or merged into

other firms or have declared bankruptcy. These developments could result

in our competitors gaining greater access to capital and liquidity,

expanding their ranges of products and services, or gaining geographic

diversity. We may experience pricing pressures as a result of these factors

in the event that some of our competitors seek to increase market share

by reducing prices, which may have a material adverse impact on our

business, results and financial condition.

We may not always be able to protect our intellectual property

developed in our products and services and may be subject to

infringement claims, which could adversely impact our core business,

inhibit efforts to monetise our internal innovations and restrict our

ability to capitalise on future opportunities.

In the conduct of our business, we rely on a combination of contractual

rights with third parties and copyright, trademark, trade name, patent and

trade secret laws to establish and protect our intellectual property, which

we develop in connection with our products and services. Third parties

may infringe or misappropriate our intellectual property. We may have to

litigate to enforce and protect our copyrights, trademarks, trade names,

patents, trade secrets and know-how or to determine their scope, validity

or enforceability. In that event, we may be required to incur significant

costs, and our efforts may not prove successful. The inability to secure or

protect our intellectual property assets could have an adverse effect on

our core business and our ability to compete, including through the

monetisation of our internal innovations.

We may also be subject to claims made by third parties for (i) patent,

trademark or copyright infringement, (ii) breach of copyright, trademark or

licence usage rights, or (iii) misappropriation of trade secrets. Any such

claims and any resulting litigation could result in significant expense and

liability for damages. If we were found to have infringed or

misappropriated a third-party patent or other intellectual property right

(including where we or a third party have used generative artificial

intelligence outputs based on data for which the generative model may

not have had consent), we could in some circumstances be enjoined from

providing certain products or services to our customers or from utilising

and benefiting from certain methods, processes, copyrights, trademarks,

trade secrets or licences. Alternatively, we could be required to enter into

costly licensing arrangements with third parties or to implement a costly

workaround. Any of these scenarios could have a material adverse effect

on our business and results and could restrict our ability to pursue future

business opportunities.


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The inability of counterparties to meet their financial obligations or our

inability to fully enforce our rights against counterparties could have a

material adverse effect on our results.

Third parties that have payment obligations to ING, or obligations to return

money, securities or other assets, may not pay or perform under their

obligations. These parties include the issuers and guarantors (including

sovereigns) of securities we hold, borrowers under loans originated,

reinsurers, customers, trading counterparties, securities lending and

repurchase counterparties, counterparties under swaps, credit default and

other derivative contracts, clearing agents, exchanges, clearing houses

and other financial intermediaries. Defaults by one or more of these

parties on their obligations to us due to bankruptcy, lack of liquidity,

downturns in the economy or real estate values, volatile oil or other

commodity prices, operational failure or other factors, or even rumours

about potential defaults by one or more of these parties or regarding a

severe distress of the financial services industry generally, could have a

material adverse effect on our results, financial condition and liquidity.

Given the high level of interdependence between financial institutions, we

are and will continue to be subject to the risk of deterioration of the

commercial and financial soundness, or perceived soundness, of

sovereigns and other financial services institutions. This is particularly

relevant to our franchise as an important and large counterparty in equity,

fixed income and foreign exchange markets, including related derivatives.

We routinely execute a high volume of transactions, such as unsecured

debt instruments, derivative transactions and equity investments with

counterparties and customers in the financial services industry, including

brokers and dealers, commercial and investment banks, mutual and hedge

funds, insurance companies, institutional clients, futures clearing

merchants, swap dealers, and other institutions, resulting in large periodic

settlement amounts, which may result in us having significant credit

exposure to one or more of such counterparties or customers. As a result,

we could face concentration risk with respect to liabilities or amounts we

expect to collect from specific counterparties and customers. We are

exposed to increased counterparty risk as a result of past financial

institution failures and weakness and will continue to be exposed to the

risk of loss if counterparty financial institutions fail or are otherwise unable

to meet their obligations. As a result of the Russian invasion of Ukraine and

related international response measures, including sanctions and capital

controls, we may be exposed to an increased risk of default of

counterparties located in Russia and Ukraine, counterparties of which the

ultimate parent is located in Russia or may be considered effectively

controlled or influenced through Russian involvement, and other

counterparties in sectors affected by the response measures. Also,

liquidity or currency controls enforced by the Russian central bank may

impact Russian companies’ ability to pay. In addition, we have

counterparty exposure to Russian entities in connection with foreign

exchange derivatives for future receipt of foreign currencies against the

Russian rouble (RUB). Remaining at risk for ING at year-end 2025 is €600

million of credit exposures booked outside of Russia and €550 million with

clients in Ukraine. A default by, or even concerns about the

creditworthiness of, one or more of these counterparties or customers or

other financial services institutions could therefore have an adverse effect

on our results or liquidity.

With respect to secured transactions, our credit risk may be exacerbated

when the collateral held by us cannot be liquidated or is liquidated at

prices not sufficient to recover the full amount of the loan or derivative

exposure due to us. We also have exposure to a number of financial

institutions in the form of unsecured debt instruments, derivative

transactions and equity investments. For example, we hold certain hybrid

regulatory capital instruments issued by financial institutions which permit

the issuer to cancel coupon payments on the occurrence of certain events

or at their option. Pursuant to regulatory powers and resolution

frameworks, the ECB has indicated that, in certain circumstances, it may

require these financial institutions to cancel payment. If this were to

happen, we expect that such instruments may experience ratings

downgrades and/or a drop in value and we may have to treat them as

impaired, which could result in significant losses. There is no assurance

that losses on these assets would not materially and adversely affect our

business, results or financial condition.

In addition, we are subject to the risk that our rights against third parties

may not be enforceable in all circumstances, including sanction risk. The

deterioration or perceived deterioration in the credit quality of third parties

whose securities or obligations we hold could result in losses and/or

adversely affect our ability to rehypothecate or otherwise use those

securities or obligations for liquidity purposes. A significant downgrade in

the credit ratings of our counterparties could also have a negative impact

on our income and risk weighting, leading to increased capital

requirements. While in many cases we are permitted to require additional

collateral from counterparties that experience financial difficulty, disputes

may arise as to the amount of collateral we are entitled to receive and the

value of pledged assets. Collateral valuation is performed in accordance

with internal policies aligned with market data hierarchies; however,

disputes may still occur under stress. Also in this case, our credit risk may

also be exacerbated when the collateral we hold cannot be liquidated at

prices sufficient to recover the full amount of the loan or derivative

exposure due to us, which is most likely to occur during periods of

illiquidity and depressed asset valuations, such as those experienced

during the financial crisis of 2008. The termination of contracts and the

foreclosure on collateral may subject us to claims. Bankruptcies,

downgrades and disputes with counterparties as to the valuation of

collateral tend to increase in times of market stress and illiquidity. Any of

these developments or losses could materially and adversely affect our

business, results, financial condition, and/or prospects.

Ratings are important to our business for a number of reasons, and a

downgrade or a potential downgrade in our credit ratings could have an

adverse impact on our results and net results.

Credit ratings represent the opinions of rating agencies regarding an

entity’s ability to repay its indebtedness. Our credit ratings are important

to our ability to raise capital and funding through the issuance of debt and

to the cost of such financing. In the event of a downgrade, the cost of

issuing debt will increase, having an adverse effect on our net results.

Certain institutional investors may also be obliged to withdraw their

deposits from ING following a downgrade, which could have an adverse

effect on our liquidity. They can also have lower risk appetite for our debt

notes, leading to lower purchases of (newly issued) debt notes. We have

credit ratings from S&P, Moody’s, Fitch and Scope. Each of the rating

agencies reviews its ratings and rating methodologies on a recurring basis

and may decide on a downgrade at any time.


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As rating agencies continue to evaluate the financial services industry, it is

possible that rating agencies will heighten the level of scrutiny that they

apply to financial institutions, increase the frequency and scope of their

credit reviews, request additional information from the companies that

they rate and potentially adjust upward the capital and other

requirements employed in the rating agency models for maintenance of

certain ratings levels. It is possible that the outcome of any such review of

us would have additional adverse ratings consequences, which could have

a material adverse effect on our results and financial condition. We may

need to take actions in response to changing standards or capital

requirements set by any of the rating agencies, which could cause our

business and operations to suffer. We cannot predict what additional

actions rating agencies may take, or what actions we may take in

response to the actions of rating agencies.

Furthermore, ING’s assets are risk-weighted. Downgrades of these assets

could result in a higher risk-weighting, which may result in higher capital

requirements. This may impact net earnings and the return on capital, and

may have an adverse impact on our competitive position.

An inability to retain or attract key personnel may affect our business

and results.

ING Group relies to a considerable extent on the quality of its senior

management, such as members of the executive committee, and

management in the jurisdictions which are material to ING’s business and

operations. The success of ING Group’s operations is dependent, among

other things, on its ability to attract and retain highly qualified personnel.

Competition for key personnel in most countries in which ING Group

operates, and globally for senior management, is intense. ING Group’s

ability to attract and retain key personnel, in senior management and in

particular areas such as technology and operational management, client

relationship management, finance, risk and product development, is

dependent on a number of factors, including prevailing market conditions

and compensation packages offered by companies competing for the

same talent.

The increasing restrictions on, and public and political scrutiny of,

remuneration (especially in the Netherlands), may continue to have an

impact on existing ING Group remuneration policies and individual

remuneration packages for personnel. For example, under the EU’s

amended Shareholder Rights Directive, known as SRD II, which came into

effect on 10 June 2019, ING is required to hold a shareholder binding vote

on ING’s Executive Board remuneration policy and Supervisory Board

remuneration policy at least every four years. Furthermore, the

shareholders have an advisory vote on ING’s remuneration report

annually. This may restrict our ability to offer competitive compensation

compared with companies (financial and/or non-financial) that are not

subject to such restrictions and it could adversely affect ING Group’s ability

to retain or attract key personnel, which, in turn, may affect our business

and results.

We may incur further liabilities in respect of our defined benefit

retirement plans if the value of plan assets is not sufficient to cover

potential obligations, including as a result of differences between actual

results and underlying actuarial assumptions and models.

ING Group companies operate various defined benefit retirement plans

covering the post-employment benefits of a number of our employees.

The liability recognised in our consolidated balance sheet in respect of our

defined benefit plans is the present value of the defined benefit obligations

at the balance sheet date, less the fair value of each plan’s assets,

together with adjustments for unrecognised actuarial gains and losses and

unrecognised past service costs. We determine our defined benefit plan

obligations based on internal and external actuarial models and

calculations using the projected unit credit method. Inherent in these

actuarial models are assumptions, including discount rates, rates of

increase in future salary and benefit levels, mortality rates and the

consumer price index. These assumptions are based on available market

data and are updated annually. Nevertheless, the actuarial assumptions

may differ significantly from actual results due to changes in market

conditions, economic and mortality trends and other assumptions. Any

changes in these assumptions could have a significant impact on our

present and future liabilities and costs associated with our defined benefit

plans.

Risks related to the Group’s risk management practices

Risks relating to our use of quantitative models to model client

behaviour for the purposes of our calculations may adversely impact our

results and reputation.

We use quantitative methods, systems or approaches that apply

statistical, economic, financial, or mathematical theories, techniques and

assumptions to process input data into quantitative estimates. Errors in

the development, implementation, use or interpretation of such models, or

from incomplete or incorrect data, can lead to inaccurate, noncompliant or

misinterpreted model outputs, which may adversely impact our results

and reputation. In addition, we use assumptions to model client behaviour

for risk calculations in our banking books. Assumptions are used to

determine the interest rate risk profile of savings and current accounts and

to estimate the embedded option risk in loans and investment portfolios.

Assumptions based on past client behaviour may not always be a reliable

indicator of future behaviour. The use of different assumptions to

determine client behaviour could have a material adverse effect on the

calculated risk figures and, ultimately, our future results or reputation.

Furthermore, we may be subject to risks related to changes in laws and

regulations (e.g. with reference to client rates, prepayment compensation,

etc.) governing the risk management practices of financial institutions. For

more information, see 'Risks related to the regulation and supervision of

the Group – Changes in laws and/or regulations governing financial

services or financial institutions or the application of such laws and/or

regulations may increase our operating costs and limit our activities'

above. As noted there, regulation of the industries in which we operate is

becoming increasingly more extensive and complex, while also attracting

supervisory scrutiny. Compliance failures may lead to changes in the laws

and regulations governing the risk management practices and materially

increase our operating costs.

We may be unable to manage our risks successfully through derivatives.

We employ various economic hedging strategies with the objective of

mitigating the market risks that are inherent in our business and

operations. These risks include currency fluctuations, changes in the fair

value of our investments, the impact of interest rates, equity markets and

credit spread changes, the occurrence of credit defaults and changes in


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client behaviour. We seek to control these risks by, among other things,

entering into a number of derivative instruments, such as swaps (e.g. CCY,

IR, etc.), options, futures and forward contracts, including, from time to

time, macro hedges for parts of our business, either directly as a

counterparty or as a credit support provider to affiliate counterparties.

Developing an effective strategy for dealing with these risks is complex,

and no strategy can completely insulate us from risks associated with

those fluctuations. Our hedging strategies also rely on assumptions and

projections regarding our assets, liabilities, general market factors and the

creditworthiness of our counterparties that may prove to be incorrect or

prove to be inadequate. Accordingly, our hedging activities may not have

the desired beneficial impact on our results or financial condition. Poorly

designed strategies or improperly executed transactions could actually

increase our risks and losses. Hedging strategies involve transaction costs

and other costs, and if we terminate a hedging arrangement, we may also

be required to pay additional costs, such as transaction fees or breakage

costs. There have been periods in the past, and it is likely that there will be

periods in the future, during which we have incurred or may incur losses

on transactions, possibly significant, after taking into account our hedging

strategies. Further, the nature and timing of our hedging transactions

could actually increase our risk and losses. Hedging instruments we use to

manage product and other risks might not perform as intended or

expected, which could result in higher realised or unrealised losses, such as

credit value adjustment risks or unexpected P&L effects, and unanticipated

cash needs to collateralise or settle such transactions. Adverse market

conditions can limit the availability and increase the costs of hedging

instruments, and such costs may not be recovered in the pricing of the

underlying products being hedged. In addition, hedging counterparties

may fail to perform their obligations, resulting in unhedged exposures and

losses on positions that are not collateralised. As such, our hedging

strategies and the derivatives that we use or may use may not adequately

mitigate or offset the risks they intend to cover, and our hedging

transactions may result in losses.

Our hedging strategy additionally relies on the assumption that hedging

counterparties remain able and willing to provide the hedges required by

our strategy. Increased regulation, market shocks, worsening market

conditions, and/or other factors that affect or are perceived to affect the

financial condition, liquidity and creditworthiness of ING may reduce the

ability and/or willingness of such counterparties to engage in hedging

contracts with us and/or other parties, affecting our overall ability to

hedge our risks and adversely affecting our business, results and financial

condition.

Risks related to the Group’s liquidity and financing activities

We depend on the capital and credit markets, as well as customer

deposits, to provide the liquidity and capital required to fund our

operations, and adverse conditions in the capital and credit markets, or

significant withdrawals of customer deposits, may negatively impact

our liquidity, borrowing and capital positions, as well as increase the

cost of liquidity, borrowings and capital.

Adverse capital market conditions may negatively impact our cost of

borrowed funds and our ability to borrow on a secured and unsecured

basis, thereby impacting our ability to support and/or grow our businesses.

From a liquidity perspective, central banks have continued its path of

quantitative tightening by decreasing its balance sheet, which may reduce

the liquidity provided to the financial system. Consequently, banks have

significantly increased debt issuance and heightened competition for

client deposits is observed.

We require liquidity to fund new and ongoing business, to pay our

operating expenses and interest on our debt as well as dividends on our

capital stock, maintain our securities lending activities and replace

maturing liabilities. Without sufficient liquidity, we will be forced to curtail

our operations and our business will suffer. The principal sources of our

funding include a variety of short- and long-term instruments, including

deposit funds, repurchase agreements, commercial paper, medium- and

long-term debt, subordinated debt securities, capital securities and

shareholders’ equity.

In addition, as we rely on customer deposits to fund our business and

operations, the confidence of customers in financial institutions may be

tested in a manner that may adversely impact our liquidity and capital

position. Consumer confidence in financial institutions may, for example,

decrease due to ING’s or our competitors’ failure to communicate to

customers the terms of, and the benefits and risks to customers of,

complex or high-fee financial products. Reduced customer confidence

could have an adverse effect on our liquidity and capital position through

the withdrawal of deposits, as well as on our revenues and total financial

results. As a significant percentage of our customer deposit base is

originated via internet banking, a loss of customer confidence may result

in a rapid withdrawal of deposits over the internet.

In the event that our current resources do not satisfy our liquidity

requirements, we may need to seek additional financing. The availability of

additional financing will depend on a variety of factors, such as market

conditions, the general availability of credit, the volume of trading

activities, the overall availability of credit to the financial services industry,

our credit rating and credit capacity, as well as the possibility that

customers or lenders could develop a negative perception of our long- or

short-term financial prospects. See also under the heading 'Ratings are

important to our business for a number of reasons, and a downgrade or a

potential downgrade in our credit ratings could have an adverse impact on

our results and net results'. Similarly, our access to funding may be limited

if regulatory authorities or rating agencies take negative actions against

us. If our internal sources of liquidity prove to be insufficient, there is a risk

that we may not be able to successfully obtain additional financing on

favourable terms, or at all. Any actions we might take to access financing

may, in turn, cause rating agencies to re-evaluate our ratings.

Disruptions, uncertainty or volatility in the capital and credit markets may

also limit our access to capital. Such market conditions may in the future

limit our ability to raise additional capital to support business growth, to

counterbalance the consequences of losses, or to meet increased

regulatory capital and rating agency capital requirements. This could force

us to (i) delay raising capital, (ii) reduce, cancel or postpone payment of

dividends on our shares, (iii) reduce, cancel or postpone interest payments

on our other securities, (iv) issue capital of different types or under

different terms than we would otherwise, or (v) incur a higher cost of

capital than in a more stable market environment. This would have the

potential to decrease both our profitability and our financial flexibility. Our

results, financial condition, cash flows, regulatory capital and rating


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agency capital positions could be materially adversely affected by

disruptions in the financial markets.

Furthermore, regulatory liquidity requirements in certain jurisdictions in

which we operate remain stringent, undermining our efforts to maintain

centralised management of our liquidity. This may continue to cause

trapped pools of liquidity and capital, resulting in inefficiencies in the cost

of managing our liquidity and solvency, and hinder our efforts to integrate

our balance sheet. An example of such trapped liquidity includes our

operations in Germany where German regulations impose separate

liquidity requirements that restrict ING’s ability to move a liquidity surplus

out of the German subsidiary.


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Disclaimer

Certain of the statements contained herein are not historical facts,

including, without limitation, certain statements made of future

expectations and other forward-looking statements that are based on

management’s current views and assumptions and involve known and

unknown risks and uncertainties that could cause actual results,

performance or events to differ materially from those expressed or implied

in such statements. Actual results, performance or events may differ

materially from those in such statements due to a number of factors,

including, without limitation: (1) changes in general economic conditions

and customer behaviour, in particular economic conditions in ING’s core

markets, including changes affecting currency exchange rates and the

regional and global economic impact of the invasion of Russia into Ukraine

and related international response measures (2) changes affecting interest

rate levels (3) any default of a major market participant and related

market disruption (4) changes in performance of financial markets,

including in Europe and developing markets (5) fiscal uncertainty in Europe

and the United States (6) discontinuation of or changes in ‘benchmark’

indices (7) inflation and deflation in our principal markets (8) changes in

conditions in the credit and capital markets generally, including changes in

borrower and counterparty creditworthiness (9) failures of banks falling

under the scope of state compensation schemes (10) non-compliance with

or changes in laws and regulations, including those concerning financial

services, financial economic crimes and tax laws, and the interpretation

and application thereof (11) geopolitical risks, political instabilities and

policies and actions of governmental and regulatory authorities, including

in connection with the invasion of Russia into Ukraine, other existing or

emerging military conflicts, the risk of further military escalation,

geopolitical tensions, trade restrictions and the related international

response measures (12) legal and regulatory risks in certain countries with

less developed legal and regulatory frameworks (13) prudential

supervision and regulations, including in relation to stress tests and

regulatory restrictions on dividends and distributions (also among

members of the group) (14) ING’s ability to meet minimum capital and

other prudential regulatory requirements (15) changes in regulation of US

commodities and derivatives businesses of ING and its customers (16)

application of bank recovery and resolution regimes, including write-down

and conversion powers in relation to our securities (17) outcome of current

and future litigation, enforcement proceedings, investigations or other

regulatory actions, including claims by customers or stakeholders who feel

misled or treated unfairly, and other conduct issues (18) changes in tax

laws and regulations and risks of non-compliance or investigation in

connection with tax laws, including FATCA (19) operational and IT risks,

such as system disruptions or failures, breaches of security, cyber-attacks,

human error, changes in operational practices or inadequate controls

including in respect of third parties with which we do business and

including any risks as a result of incomplete, inaccurate, or otherwise

flawed outputs from the algorithms and data sets utilized in artificial

intelligence (20) risks and challenges related to cybercrime including the

effects of cyberattacks and changes in legislation and regulation related to

cybersecurity and data privacy, including such risks and challenges as a

consequence of the use of emerging technologies, such as advanced

forms of artificial intelligence and quantum computing (21) changes in

general competitive factors, including ability to increase or maintain

market share (22) inability to protect our intellectual property and

infringement claims by third parties (23) inability of counterparties to

meet financial obligations or ability to enforce rights against such

counterparties (24) changes in credit ratings (25) business, operational,

regulatory, reputation, transition and other risks and challenges in

connection with climate change, diversity, equity and inclusion and other

ESG-related matters, including data gathering and reporting and also

including managing the conflicting laws and requirements of

governments, regulators and authorities with respect to these topics (26)

inability to attract and retain key personnel (27) future liabilities under

defined benefit retirement plans (28) failure to manage business risks,

including in connection with use of models, use of derivatives, or

maintaining appropriate policies and guidelines (29) changes in capital and

credit markets, including interbank funding, as well as customer deposits,

which provide the liquidity and capital required to fund our operations, and

(30) the other risks and uncertainties detailed in the most recent annual

report of ING Bank N.V. (including the Risk Factors contained therein) and

ING’s more recent disclosures, including press releases, which are available

on ing.com.

This document may contain ESG-related material that has been prepared

by ING on the basis of publicly available information, internally developed

data and other third-party sources believed to be reliable. ING has not

sought to independently verify information obtained from public and

third-party sources and makes no representations or warranties as to the

accuracy, completeness, reasonableness or reliability of such information.

This document may also discuss one or more specific transactions and/or

contain general statements about ING’s ESG approach. The approach and

criteria referred to in this document are intended to be applied in

accordance with applicable law. Due to the fact that there may be

different or even conflicting laws, the approach, criteria or the application

thereof, could be different.

Materiality, as used in the context of ESG, is distinct from, and should not

be confused with, such term as defined in the Market Abuse Regulation or

as defined for Securities and Exchange Commission (‘SEC’) reporting

purposes. Any issues identified as material for purposes of ESG in this

annual report are therefore not necessarily material as defined in the

Market Abuse Regulation or for SEC reporting purposes. In addition, there is

currently no single, globally recognized set of accepted definitions in

assessing whether activities are “green” or “sustainable”. Without limiting

any of the statements contained herein, we make no representation or

warranty as to whether any of our securities constitutes a green or


ING Bank Annual Report 2025	Contents	Strategy, business model and value creation	Our financial performance	Our leadership and corporate governance	Capital management	Risk management	Consolidated financial statements	Parent company financial statements	Other information and appendices	259

sustainable security or conforms to present or future investor expectations

or objectives for green or sustainable investing. For information on

characteristics of a security, use of proceeds, a description of applicable

project(s) and/or any other relevant information, please reference the

offering documents for such security.

This annual report may contain inactive textual addresses to internet

websites operated by us and third parties. Reference to such websites is

made for information purposes only, and information found at such

websites is not incorporated by reference into this annual report. ING does

not make any representation or warranty with respect to the accuracy or

completeness of, or take any responsibility for, any information found at

any websites operated by third parties. ING specifically disclaims any

liability with respect to any information found at websites operated by

third parties. ING cannot guarantee that websites operated by third parties

remain available following the publicaton of this annual report or that any

information found at such websites will not change following the

publication of this annual report. Many of those factors are beyond ING’s

control.

This document is the PDF version of the 2025 Annual Report of ING made

available on ing.com. Another version of this document has been prepared

in the European single electronic reporting format (ESEF) and such ESEF

reporting package is also available on ing.com. In the event of any

discrepancies between this PDF version and the ESEF reporting package,

the ESEF reporting package governs.

Any forward-looking statements made by or on behalf of ING speak only

as of the date they are made, and ING assumes no obligation to publicly

update or revise any forward-looking statements, whether as a result of

new information or for any other reason.

This document does not constitute an offer to sell, or a solicitation of an

offer to purchase, any securities in the United States or any other

jurisdiction.