Foreword

More than a bank

For over a century, we've played a crucial role as a stable financier and partner for governments and (semi-)public institutions. We know the public sector down to the finest details, oversee the playing field, and facilitate investments in areas such as housing, energy, education, healthcare, and infrastructure. We collaborate with our clients on more than just financing, building connections and thus enabling them to achieve their social goals faster and more effectively.

Every euro of BNG's equity creates approximately thirty euros in public investment opportunities—from affordable housing and strong neighborhoods to sustainable energy, future-proof schools, and healthcare institutions. These investments may seem obvious, but they're not. They're directly tangible for the residents of the Netherlands, contributing to livable, resilient communities, both now and in the future.

Loan portfolio and profit development

The steadily growing demand from our clients also formed the basis for further growth of our loan portfolio in 2025. We issued EUR 11.2 billion in new long-term loans, and the size of the loan portfolio increased from EUR 93 billion in 2024 to EUR 95.7 billion in 2025. Despite volatile market conditions and geopolitical tensions, demand for credit remained high, particularly from municipalities and housing associations. To facilitate this, we attracted EUR 16.6 billion in long-term financing. A significant portion, EUR 5.4 billion, was in ESG bonds, further strengthening our leading position in sustainable financing.

We achieved a net profit of EUR 172 million, EUR 122 million lower than in 2024, as a result of both external factors and deliberate strategic decisions. Lower interest result, a negative result on financial transactions, higher total operating expenses and impairments contributed to the decline in net profit.

Accelerate where it counts

In 2025, we took additional steps forward in the areas of housing and energy transition – two urgent societal challenges with significant impact. The housing market is stuck, with a shortage of nearly 400,000 homes. This hinders mobility, livability, and growth. Municipalities and housing associations want to accelerate this process but are hampered by complex regulations, rising costs, and infrastructure bottlenecks. We are actively contributing to addressing the shortage of social and mid-range rental housing. We do this by making loans available and putting solutions for these obstacles on the agenda of relevant decision-makers and policymakers. In this way, we contribute to a smoother housing market and accelerate construction.

At the same time, the energy transition requires clear plans, collaboration, and financial strength. We want green energy to remain accessible and affordable for everyone, so that households on a tight budget can also participate. Therefore, we are taking the lead in collaborating with the sector to create tools and frameworks, for example, through the revision of the Dutch Heat Act (Warmtewet) and a guarantee scheme for sustainable energy projects.

On the way to transition

Starting in 2026, we will launch a three-year transition program aimed at increasing our social value. We will do this by expanding our loan portfolio, intensifying partnerships with our clients, and simultaneously reducing costs.

We remain committed to contributing to increasing the supply of affordable housing and accelerating the energy transition. Our goal is to become the strategic partner for our clients, collaborating with them to design solutions, structure investment projects, and then finance them. We also want to connect clients from various sectors at the regional level and actively engage with regional investment projects, so that together we can achieve a sustainable impact.

These steps forward also require adjustments within our organisation. In 2025, we began simplifying and professionalising our internal organisation. The reorganisation we are currently undertaking will lay the foundation for greater effectiveness and productivity, accelerate digitalisation, and reduce costs. As usual, this requires temporary investments, resulting in higher short-term costs.

Our ultimate goal is to continue delivering our social and green added value. Together we make the Netherlands stronger, more livable, and more future-proof.

On behalf of the Executive Committee,

Philippine Risch

CEO

Key figures 2025

1.1 Social progress

As one of the world's three safest banks and with Triple-A rating, we offer financing that is not only affordable and accessible but also contributes to sustainability and social impact. Whether it's affordable housing, improved healthcare facilities, or investments in climate-resilient living environments, we facilitate solutions that create lasting social value. In this way, together with our clients, we contribute to a resilient and future-proof society.

1.2 The world around us

Politics

Geopolitics

Geopolitical tensions—from Ukraine to Gaza and global trade tensions—continue to put pressure on financial markets. Polarisation and fragmentation in major economies are hampering policy consensus, increasing uncertainty for investors. Since the change of power in the United States, the predictability of a major trading partner has further declined, leading to increased volatility worldwide. At the same time, concerns about concentration risks are growing as large American tech companies increasingly dominate. For a Dutch systemically important bank like BNG, this combination of geopolitical uncertainty, volatility, and market dominance means that prudent risk management, broad funding diversification, and further strengthening of the balance sheet remain essential. At the same time, BNG is seen as a safe haven in turbulent times, making us a stable factor in the financial system and contributing to market confidence and continuity.

Politics in the Netherlands

The fall of the Schoof cabinet ultimately had little direct impact on the progress of policy themes that enjoy broad political support. Regardless of party affiliation, there remains consensus on the need to invest in the public sector, particularly in affordable housing. Accelerating construction projects and supporting municipalities also remain priorities, which aligns well with our own strategic themes. Mid-market rental housing is playing an increasingly important role in this, both for politicians and for our bank. We will continue to closely monitor developments surrounding the new coalition agreement to anticipate the consequences for our clients in a timely manner. It is encouraging that the European Commission decided at the end of 2025 that Member States may provide state aid for mid-range rental housing.

Defense and Cybersecurity

The focus on defense, resilience, and strategic independence is increasing due to geopolitical tensions and high global debt ratios; the Netherlands is relatively well-positioned and can therefore invest more in defense and digital infrastructure. Structural investments in cybersecurity remain necessary for the financial sector due to ongoing attacks on critical infrastructure, which permanently increases costs for banks. Meanwhile, the focus in the debate about technological dependency is shifting from efficiency to concentration on large cloud providers and the need for digital autonomy.

Regulation

Regulatory focus in the banking sector is strongly on ESG risk management, with new European guidelines requiring banks to implement risk management practices, in which ESG risks play a significant role, alongside increasing geopolitical and macroeconomic uncertainties. New European guidelines require banks to systematically identify, measure, and report ESG risks. At the same time, stricter capital requirements are being introduced under the latest Basel III regulations, and operational resilience to digital risks has been strengthened through the Digital Operational Resilience Act (DORA). These regulations require significant invesments in risk management and reporting systems, further strengthening the sector's stability and transparency in a complex and changing environment. We are also focusing on Risk Data Aggregation and Risk Reporting (RDARR), focused on collecting and reporting risk data, which will have implications for our processes.

Economic, ecological and social

Monetary policy

Central banks are easing their policies again now that inflation is stabilising. The ECB and the Fed have gradually lowered their interest rates as the yield curve normalises. Customers are benefiting from lower borrowing costs and more short-term loans. From a risk management perspective, this is beneficial due to lower refinancing risks, although it results in slightly lower returns for the bank.

Ecology & Sustainability

Expectations regarding sustainability and social impact for financial institutions are changing due to the varying approaches to ESG in different parts of the world. We recognise these international trends and, as a bank, adhere to our own ESG agenda because we consider it important for our social contribution. We are strongly focussing on housing and the energy transition.

We have had our environmental goals independently validated by the Science Based Targets initiative (SBTi). With our impact-driven strategy, we actively respond to societal and demographic changes, in keeping with our role in a changing world.

Labor market

The labor market remains tight, and attracting talent is challenging, especially in digital and technology fields. Labor force participation is stable, with a slight increase among older employees due to adjustments in pension policies. Diversity and inclusion remain important priorities for employers and require ongoing commitment to achieve visible changes in participation rates. We expect our strong purpose to contribute to this. It already appeals to a broad group of professionals, which helps us attract and retain specialist staff. These developments require us to continuously invest in training and job satisfaction to remain competitive.

Digitisation and technological developments

Digitisation and technology

Digitisation remains a driving force in the financial sector. Banks are investing heavily in digital transformation and cybersecurity to improve customer experience and modernise technological platforms. Generative AI offers significant opportunities for productivity and revenue growth. At our bank, digitisation remains a high priority, with stability and security always prioritised. At the same time, as a bank, we choose to focus primarily on proven technologies. This ensures reliability and stability, while carefully and purposefully implementing digital innovations.

Efficient processes

Due to technological advancements and new ways of working, banks are increasingly striving for efficiency in their processes. This means that many manual tasks are being automated, allowing employees to focus on activities that add more value for customers. BNG strives to improve service at lower costs through more efficient processes. To achieve this, we have initiated a reorganisation that will result in a more dynamic, efficient, and agile organisation.

1.3 Strategy

SWOT analysis

Our market-leading position is no reason to rest on our laurels. To maintain this strong position, we actively respond to new developments. With our current strategic choices, including contributing to the acceleration of housing construction and the energy transition, and further professionalisation, we are improving our organisation and working methods to remain future-proof.

We continuously review our business model and ensure that our resources and capabilities align with current needs. This allows us to manage risks and seize new opportunities. The overview below summarises our key insights and demonstrates how we maintain our strong position in a changing environment.

Our Road to Impact (2024-2025)

The Our Road to Impact strategy ran from 2024 to 2025. Within this strategy, we formulated clear goals to increase our social impact and optimally support our clients. Its core consisted of seven strategic objectives, as published on the previous page and of which we report on in this Annual Report.

Road to More Added Value (2026-2028)

2025 was a transitional year in which we laid the foundation for our transformation initiative toward a more modern and agile organisation. Through a strategic and competitive analysis, we clearly identified our strengths and areas for improvement. In discussions with stakeholders, clients, and investors, we updated our understanding of strengths, weaknesses, opportunities, and threats.

We explicitly addressed future trends, stakeholder expectations, and external risks such as ESG factors. This allows us to better understand the implications of these developments for the sustainability of our business model and our strategic choices.

With clear choices, we collaborate with clients to finance sustainable improvements and attract capital that aligns with investors' impact needs. In doing so, we are developing a strategy that responds to the opportunities and challenges of today and tomorrow.

This analysis has led to a new strategy and a sharpened ambition: creating more value with fewer resources. In 2025, we launched various improvement initiatives in the areas of strategy, structure, people, and processes. This will prepare our organisation for the transformation to a new business model, which is essential for achieving our revised strategic ambitions.

Effective 2026, the "Our Road to Impact" strategy will be replaced by a new, bank-wide strategy called "Route to More Added Value."

Our refined strategy is clear: BNG is the bank for social and green added value. We remain the reliable financier of affordable loans to the public sector, with a focus on financing solutions for the most urgent social issues. By investing in the energy transition, affordable housing, and sustainable social real estate, we are committed to concrete progress for people and communities. We are also actively exploring new financing opportunities for social challenges in the Netherlands, such as investments in defense.

2026 is the first year of a three-year transformation. The transformation focuses on the following strategic priorities:

1. Strengthening our position in the broader public sector, with a greater focus on:

   1. Accelerating the transition to affordable energy

   2. Increasing financing for affordable, social, and mid-range rental housing

2. A streamlined organisation with a low hierarchy and clear responsibilities.

3. A workforce with highly qualified and motivated employees and a culture that is highly professional, collaborative, optimistic, and entrepreneurial.

4. Customer-focused, simplified, efficient, and more digitalised processes, supported by data, data analytics, and AI.

5. A future-proof technology landscape and supporting processes.

1.4 Materiality analysis

Business Model and Strategy

As a bank of and for the public sector, we focus on increasing social value for our clients and other stakeholders. Sustainability is an integral part of our activities and is closely linked to our strategy, decision-making, and products. The materiality analysis helps us determine which sustainability topics are most relevant to BNG and its stakeholders and where we can exercise our responsibility and influence. This chapter provides an overview of the material impacts, risks, and opportunities, their relationship to our strategy (of 2025) and business model, and the methodology used for the Double Materiality Assessment (DMA).

The Double Materiality Analysis

In 2025, we conducted our first double materiality analysis in line with the requirements of the European Sustainability Reporting Standards (ESRS). In previous years, we based our materiality analysis on the GRI guidelines. The key difference is that we now assess both impact materiality and financial materiality.

A sustainability topic is considered material when it meets the criteria for impact materiality, financial materiality, or both.

Impact Materiality (Inside-Out Perspective)

This perspective considers the actual and potential positive and negative effects of our activities on people and the environment. For BNG, this includes, for example, the effects of the activities we finance, the contribution of our investments to social goals, and the direct impact of our products and services through our business relationships.

Financial Materiality (Outside-In Perspective)

This perspective focuses on the risks and opportunities for BNG arising from changes in society and the environment. For us, these include climate- and environment-related risks that could impact our financial position, strategy, and ability to create social value.

Our material themes

In assessing sustainability topics, we based our assessment on the ESRS themes. In addition, BNG-specific themes have been added to explicitly demonstrate how our activities contribute to social impact in the public domain, such as affordable financing and sufficient housing.

Climate change

BNG is aware of the negative impact that financing emission-intensive clients and sectors can have on CO₂ emissions. Risks include reputational risks and potential fines for insufficient climate mitigation policies. At the same time, the transition to a sustainable economy offers opportunities to encourage clients to make climate-friendly investments.

Our own employees

Our employees are the core of our organisation. Diversity, inclusion, training, and equal treatment have a positive impact on employee satisfaction. At the same time, it is important that BNG continues to strive for good employment practices by paying sufficient attention to knowledge development and work-life balance in order to limit operational and financial risks.

Affordable and accessible financing

BNG focuses on making affordable financing available to the public sector. Through our competitive terms and focus on social clients, we create a positive impact on public facilities and encourage sustainable investments through Sustainability and Social Bonds. At the same time, we ensure that internal costs do not affect BNG's competitive position. The increasing need for investment in the public sector also offers opportunities to expand our services.

Sufficient affordable housing

Housing associations are a key sector within BNG. Through affordable and accessible financing, we support the sustainability improvements of existing homes and the construction of new social housing. At the same time, we see opportunities due to the growing demand for credit for sustainability improvements and new construction, allowing BNG to make a tangible contribution to affordable and sustainable housing in the Netherlands.

The overview below shows how each material topic contributes to societal value, which risks we identify, and which opportunities arise to further increase our impact.

1.5 Stakeholder engagement and value creation

Stakeholder engagement

We actively engage with stakeholders. These conversations are often part of our daily work and take place at various levels within the organisation. The table below provides an overview.

Value creation

We aim to remain the leading financier of the Dutch public sector and contribute to a more social and greener Netherlands. We operate based on a central principle: Bank of Added Value. Social impact and the value we create together are central to everything we do. In the model below, we apply the six-capital model of the International Integrated Reporting Council (IIRC). This model provides insight into the outcomes of our strategy we strive for and the value we add for our stakeholders and society.

Since 2021, we have been reporting in accordance with the guidelines of the Global Reporting Initiative (GRI) in our Annual Report and have also done so for 2025. In this context, it is essential to map out the material themes for the organisation properly. We evaluate these themes annually and report on our progress based on identified KPIs. We focus actively on the following themes:

An explanation of the scores in 2025 can be found in the appendix in paragraph 9.2

Whether it concerns affordable housing, better healthcare facilities, or climate-resilient living environments: thanks to our strong financial position, we offer competitive financing that we pass on directly to municipalities, housing associations, healthcare and educational institutions, and organisations in infrastructure and energy. We actively think along with our clients and help provide feasible, sustainable solutions that create long-term impact.

Sustainability is an integral part of our collaboration. We support clients in achieving their goals and provide insight into their progress, enabling them to increase their social impact. We build long-term relationships as a reliable partner that works carefully and transparently. That trust forms the foundation for success.

2.1 Local authorities

As primary banker, we offer a wide range of financial services, from payment transactions to lending. This enables us to facilitate investments in essential public services, such as social infrastructure, housing, educational facilities, and energy transition projects.

Challenges and sustainable investments

The financial pressure on local governments remained noticeable in 2025. Rising costs and uncertainties required careful consideration. The financial cliff year has now shifted to 2028, but municipalities must already make smart choices to enable major renovations and sustainability projects. In the past year, we developed and implemented suitable financing solutions for many of our municipal clients.

We went beyond just financing. By holding strategic discussions on topics such as energy transition and social issues, we helped municipalities clearly formulate their long-term ambitions. Sustainability is central to us. This is evident in our payment transactions contracts, which include social return as standard. With these contracts, we offer opportunities to people distanced from the labor market and support local initiatives.

Primary banking services

In 2025, municipalities again confirmed their confidence in us as their primary bank. We were proud that municipal tax office Twente and the municipalities of Enschede and Hengelo-Losser extended their primary banking contracts with us. We also won the tender from the municipality of Nijmegen.

Our primary banking is about more than just products. We act as a partner that supports government financial processes and aligns with their social responsibilities. With dedicated contacts, short lines of communication, and modern digital tools, we ensure efficient and committed service.

Customer meetings

To optimally support municipalities and other local government bodies, we organised various meetings and webinars in 2025. In addition to sharing knowledge, the aim is to jointly develop visions and shape solutions. The focus was on current financial issues and practical tools for municipal financial teams. For example, we organised conferences for medium-sized municipalities, for municipalities with up to 40,000 residents, and for municipalities with more than 100,000 residents. During the Association of Netherlands Municipalities (VNG) conference in June, we focused on "From housing shortage to living pleasure." Together with housing association Trudo and the municipality of Eindhoven, we organised an excursion to Woensel-West in Eindhoven, a neighborhood that has been successfully transformed through intensive collaboration and sustainable innovation. We also focused on sustainability by organising a special Sustainability Afternoon for financial professionals, focusing on knowledge sharing and best practices.

2.2 Housing associations

Financing

We support housing associations with financing for the construction of new socialand mid-market rental housing and the sustainability improvements to existing homes. In 2025, our loan portfolio again grew significantly in this sector. In total, we provided EUR 7.2 billion in new long-term loans, and the portfolio grew by EUR 3.1 billion to EUR 54.0 billion.

Investment capacity and new construction

The investment capacity of housing associations is under pressure because many investments are unprofitable due to the growing gap between rental income and rising costs. To maintain investment power in the long term, a future-proof revenue model is needed, with more room for rent increases, lower costs such as corporate tax adjustments, and more opportunities for selling assets. The National Performance Agreements aim for housing associations to ultimately build 30,000 homes per year. Although new construction production rose to 21,761 homes in 2024, it remains uncertain whether this level can be structurally achieved from 2029 onwards due to bottlenecks in locations, procedures, and infrastructure.

Mid-rent housing

We provided EUR 385 million in financing in the mid-rental segment. We did this across both urban and regional areas. The mid-rental segment is crucial for meeting the housing needs of middle-income earners. These homes also facilitate greater mobility from social housing and contribute to mixed neighborhoods. It is now widely recognised in Europe that mid-rental housing may receive government support. Financing mid-rental housing and how to already anticipate possible future funding from the WSW (Social Support Act) is a topic of discussion with our clients. This is also a frequent topic in presentations we give, such as for members of "De Vernieuwde Stad," the partnership of housing associations operating in urban areas.

Sustainability

In addition to new construction, sustainability remains a core priority within the social housing sector, with particular attention to making homes energy-efficient (including through insulation) and making them natural gas-free. Regarding insulation and the phasing out of E, F, and G labels, the sector is on track with the National Performance Agreements. However, there are still significant challenges surrounding the long-term natural gas-free transition in homes. For example, the rollout of district heating networks is proceeding slower than necessary. Therefore, we strongly support sustainability, both financially and in our dialogue with our clients. ESG criteria are a natural part of our strategy. Last year, we introduced new options, including a pilot for green loans with ESG criteria for housing associations. This green loan will be introduced more broadly in the sector in 2026. We also actively attended conferences and meetings on this topic, such as our own BNG Corporatiemiddag.

2.3 Healthcare

Developments

Major issues continue to put pressure on healthcare institutions: staff shortages, lagging investments, rising healthcare expenditures, and political uncertainty about how to address these issues. For many healthcare institutions, 2025 was a year of recovery plans. We supported this movement with financing and strategic advice, contributing to important projects within various healthcare sectors.

Creditworthiness of the sector

The credit risk profile of the healthcare sector has further improved over the past year. The sector has been able to effectively absorb the accumulation of challenges since 2022. The overall risk picture is now comparable to the pre-COVID period. Structurally higher housing rates from 2026 and compensation for inflation by health insurers support new investments, particularly in healthcare. There is confidence in the continuation of the necessary transitions and in the government's continued support for crucial healthcare. This means that the risks for the coming years are clear and acceptable, although legitimate concerns about the long-term sustainability of the healthcare system remain.

Sustainability

Sustainability in healthcare is gaining momentum, but not progressing quickly enough everywhere. ESG risks are becoming more visible, and institutions are taking steps, although progress varies considerably by subsector. In care sector, sustainability is somewhat lagging behind that of hospitals. In various subsectors, we see investments in energy savings, circular construction, and the reuse of materials. After a relatively quiet 2024, demand for sustainable projects increased in 2025, especially in new construction and renovations. Commitment to the Green Deal ensures that the sector is actively working on CO₂ reduction and more sustainable operations. BNG plays a key role as a partner in stimulating and supporting this sustainability drive.

Technological developments

Technology offers opportunities to make healthcare processes more efficient and reduce workload. Automation, AI, and robotisation are increasingly being explored and applied, particularly to support routine tasks. By 2025, the focus will be on deploying smart sensors, the Internet of Things, and predictive analytics to collect real-time data and thus better plan care and resources. These technological trends can contribute to a future-proof and more effective healthcare sector, although broad implementation is still in development.

2.4 Education

Sustainability as a driver of innovation in education

Sustainability will continue to play a central role in educational housing in 2025. The education sector is increasingly focusing on making school buildings more sustainable by (where possible) creating gas-free and energy-neutral schools and improving the indoor climate. With thousands of school buildings requiring renovation or replacement, this presents a significant and urgent challenge, especially in primary education, where the need for healthy, sustainable, and future-proof schools is greatest. This challenge calls for an accelerated, integrated approach. Circular construction is receiving increasing attention, with economies of scale and efficiency being stimulated through collaboration and innovative financing models.

In 2025, BNG contributed to education housing, including by expanding the financing arrangement for BreedSaam, a social real estate organisation. These investments support primary and special education in Breda. We also expanded funding for Building Breda, for sustainable and future-proof housing for secondary education in Breda. Furthermore, we supported the financing of integrated childcare centers in Wijhe through the Social Real Estate Foundation.

Innovative financing and collaboration

The education sector is increasingly open to efficient, scalable, and cost-saving financing structures. These innovative financing methods enable investments in educational housing to better align with long-term sustainability goals and the budgetary frameworks of municipalities and educational institutions.

Knowledge sharing and collaboration as a foundation

We continue to actively contribute to accelerating the approach to educational housing challenges by promoting knowledge sharing, standardisation, and scaling up. Dialogue with all stakeholders involved is essential in this regard. In 2025, we organised the annual Education Afternoon in Heerhugowaard, a successful platform for collaboration and knowledge exchange. We also provided various workshops/presentations on financing options for educational housing. Furthermore, we collaborated intensively with various stakeholders and shared our knowledge and experience to realise a programmatic and integrated approach to educational housing, enabling scaling up and accelerating implementation.

2.5 Public infrastructure and energy

The energy and heating transition, the transition to a circular economy, and the development of sufficient space for living and working require significant investments. Together with (utility) companies, municipalities, and the national government, we ensure that public facilities remain future-proof. This requires long-term investments that are often passed on to society through cost-based tariffs.

We offer financing on attractive terms. We provide both unsecured and public sector-guaranteed loans. We also develop and finance (guarantee) funds. With our focus on vital public infrastructure– such as water, electricity, and heat networks, renewable energy production, waste processing, and spatial planning – we support important social goals. At the same time, we strengthen the effectiveness of our stakeholders, such as municipalities, housing associations, and healthcare and educational institutions.

Client partnership in the sector

By 2025, we will have further strengthened our position as a financier of the Public Infrastructure and Energy sector. This year was characterised by both large and small financing transactions, with a total outstanding portfolio of EUR 5,074 million, an increase of EUR 52 million compared to 2024.

Networks

At Networks, the focus is on making energy, drinking water, and heat management systems more sustainable. We play an active role in this through financing of and collaboration with public and private partners. In 2025, the Collective Heat Act (WCW) was passed by the Senate and House of Representatives. The Heat Guarantee Scheme (GRW) is expected to be implemented in mid-2026. In 2025, municipalities continued to establish municipal energy and/or heat companies. Further steps were also taken to create regional heat network companies to achieve market consolidation in the long term. BNG is and will remain actively involved with all parties to contribute to the optimal implementation of the relevant legislation and to add value to important developments and transactions in the heat network sector. In 2026, we will continue our role as a partner with municipalities, the national government, and other public parties in the sector.

Energy

In 2025, the energy sector continued to grow, despite significant challenges such as grid congestion and price fluctuations in the energy market. In the Netherlands, significant sustainable energy generation capacity has been added in recent years, such as wind farms and rooftop and ground-mounted solar farms. This has led to greater discrepancies between electricity supply and demand, resulting in more frequent periods of negative electricity prices. This dynamic has a direct impact on existing business cases, including for projects financed by BNG. As a result, well-fitting

financing solutions are becoming increasingly important. The realisation of new wind and solar projects is also challenging due to a lack of suitable space. New large-scale rooftop solar projects are scarcer because the most suitable roofs have already been occupied. Attention to sufficient local support is becoming more important. We are increasingly seeing local governments taking the initiative to set up energy projects and remaining involved in the operational phase. BNG aims to make a difference specifically in these projects, as our focus is on energy projects in which the public sector has a direct or indirect interest.

The "Future-Proof Maintenance Fund" initiative, established in 2024 and financed by BNG, focuses on energy savings while simultaneously offering housing associations the opportunity to invest in mixed homeowners' associations (VvEs). The fund has provided 23 loans totalling EUR 4.7 million. Thanks to these loans, 639 flat owners were able to invest in (overdue) maintenance and sustainability improvements to their homes. The fund thus contributes to the further sustainability and energy efficiency of real estate in the Netherlands.

As a social bank, we feel a clear responsibility to contribute to making the Netherlands more sustainable. Financing the energy transition – such as investments in renewable energy, energy-efficient buildings and infrastructure – is closely aligned with our purpose and our role in society. These projects contribute to climate goals and have a demonstrable positive impact on our customers' living environment.
At the same time, we recognise that the energy transition is not without risk: technologies are developing rapidly in markets that are not always fully predictable or mature, with long depreciation and payback periods, and where the risks are sometimes heavily concentrated in the start-up phase.
Examples of (still) immature markets are the solar and (to a lesser extent) wind energy sectors, where a lack of network and storage capacity means that generated electricity cannot always be sold, which has clearly changed the original business case.
Examples of long maturities with large(r) upfront risks include investments in geothermal energy and heat networks, where a more risky investment phase is usually followed by a (long and) more stable payback phase. This creates a tension with our very conservative risk profile, which is in line with the business model of a bank such as BNG. The stability and creditworthiness of our loan portfolio are paramount. This means that we must constantly weigh up how much scope there is to support impactful, but sometimes riskier projects, without compromising our solid credit position. This balance requires ongoing dialogue, sharp risk analyses and clear choices.

Environment

In the Environment department, we provided various financing options last year that contribute to making waste collection and processing more sustainable. For example, we provided financing to collectors such as Reinigingsbedrijf Midden Nederland and De Meerlanden for further electrification of small equipment and their fleet. For collector Blink, we financed the land on which their new headquarters is planned. A significant milestone was reached last June for processor Twence, where, after a construction period of almost three years, one of the first carbon capture facility was officially opened by Her Majesty Queen Máxima. As part of the consortium, BNG financed this plant at the end of 2023.

Mobility

In the Mobility department, we provided various financing options last year that directly contribute to making public transport and the major seaports and airports in the Netherlands more sustainable. With our financial support, we help these sectors achieve ambitious climate goals, which are essential in the broader energy transition. Our financing plays a key role in enabling sustainable projects and innovations. A prime example of such financing is our sustainability-linked loan to the Port of Amsterdam (Port Authority). This EUR 60 million loan is linked to sustainability goals, encouraging the port authority to take concrete steps to reduce CO₂ emissions.

In addition, we are the main financier of regional transport in the two major metropolitan areas of the Netherlands: the Amsterdam Transport Region (VRA) and the Rotterdam-The Hague Metropolitan Region (MRDH). Together, VRA and MRDH account for approximately 28% of bus transport in the Netherlands. Throughout the Netherlands, approximately 39% of buses are now emission-free (24% in MRDH and 74% in VRA). These customers are therefore well on their way to emission-free public transport, and BNG is contributing with its financing, which is used to purchase these emission-free buses. This makes us an important partner for these transport operators in transforming their bus fleets to be completely emission-free, and we support the sector-wide commitment to make bus transport completely zero-emission by 2030.

Besides focusing on green investments, such as electric buses and sustainable infrastructure, we also recognise the importance of "gray investments" to keep the mobility industry operational. While the transition to sustainable mobility is essential for reducing the CO₂ footprint, existing systems must continue to function reliably during this transition. Our role as a financier is therefore twofold: we stimulate the energy transition and ensure continuity in the mobility sector.

Spatial planning

With the ambition to build over 900,000 homes by 2030, area development is more relevant and important than ever. This challenge requires significant investments in both new housing developments and the redevelopment of existing (business) sites. We fulfill a trusted role as a public sector financier and provide the financial basis to make large-scale projects possible. The challenge with area development is that major investments in infrastructure, public space, and amenities are required before homes or business locations reach their final location. Therefore, we work closely with public partners such as provinces, municipalities, and Regional Development Agencies (ROMs). We also deploy our expertise in Public-Private Partnerships (PPPs) where this offers added value. In 2025, we financed a wide range of projects in the field of area development. For example, in the Amersfoort region, we refinanced the new phase of a development site for EUR 100 million through a public-private partnership (PPP). We also financed the redevelopment of a port site for EUR 14 million in collaboration with a regional development company. Furthermore, we are actively involved in the planning phase of area developments throughout the Netherlands. Our projects range from development sites for housing to the redevelopment of business parks. These investments not only contribute to a livable residential environment but also strengthen the economic capacity of regional governments. By future-proofing infrastructure and facilities, we support the broader ambitions of the Netherlands regarding sustainability and resilience.

3.1 Solid foundation in money and capital markets

Developments in 2025

In 2025, we raised EUR 16.6 billion in long-term funding with an average maturity of 6.9 years. Despite market volatility, partly due to geopolitical tensions, BNG has good access to funding with medium and long-term maturities on the capital market throughout the year. Our triple A ratings play a crucial role in this regard. The total amount of funding raised is in line with the average for recent years, but the premiums were higher on average than the previous year. Part of the funding raised is, again, composed of several large syndicated bond issues, the so-called benchmarks. This year, we made three new benchmark issues in EUR and three new benchmark issues in USD, underscoring our ambition to maintain a robust and liquid benchmark curve for both currencies. We also issued two large bonds denominated in CHF and were active in GBP and AUD. We also underscored our presence in Asian markets by returning to the Chinese yuan. This is in line with our aim to achieve a high level diversity in our investors, both in terms of geography and type. The principal investor interest in 2025 confirms that we are achieving this diversity successfully.

Importance of ESG bonds

Demand for ESG bonds continued to be strong in 2025. Since our first issue in 2014, we have now issued more than EUR 38 billion in ESG bonds. We do so through sustainability issues for municipalities and through social issues for housing associations. The issues are covered by our Sustainable Finance Framework, according to which the bond income is used to finance municipalities and housing associations. Under this framework, municipal budgets and expenditure by housing associations are linked to the green and social bond categories of the International Capital Market Association (ICMA) and the Sustainable Development Goals (SDGs) of the United Nations. Our ambition is to ensure that a substantial part of our funding is raised through ESG bonds. This proportion has grown sharply in recent years: while in 2020 it was still 14% of the total bond issue, in recent years it was from 30% to over 40%. This year, we issued a significant volume of EUR 5.5 billion in ESG bonds (33%), both through new issues and by increasing existing bonds.

Keyfigures for funding

3.2 Financial results

Results and return

Over the 2025 reporting year, BNG recorded a net profit of EUR 172 million. This is EUR 122 million less than in 2024. This result was also reflected in a lower return on equity of 3.5%, compared with the return on equity for the previous year (6.4%). A lower interest result, a negative result on financial transactions, higher total operating expenses and impairments contributed to the decline in net profit.

BNG achieved an interest result of EUR 496 million. This result is EUR 40 million lower than the result for 2024. Due to changes in the interest rate curve, customers have borrowed with shorter maturities. This has resulted in lower margins on new loans granted. We have also applied a deliberate pricing strategy, using part of the profit to give discounts back to our customers. Higher margins on funding have led to an increase in interest expenses. Furthermore, in 2025, we decided to start phasing out the non-strategic portfolio. In 2025, a number of transactions were settled, which led to a decrease in interest income.

In 2025, compared to the previous year, the commission result decreased by EUR 7 million to EUR 23 million. This decrease is due to one-off fee income in 2024 that was related to treasury activities. Commission income from payment transaction commissions invoiced to customers remained stable.

The result on financial transactions amounts to EUR 31 million negative (in 2024: EUR 15 million negative). The non- effective portion of hedge accounting yields a negative result of EUR 44 million (2024: EUR 6 million negative). The vast majority of our derivatives and assets and liabilities are involved in hedge accounting. We use hedge accounting to eliminate an accounting mismatch. This was 99.2% effective in 2025. The realised sales results amounted to EUR 6 million negative (2024: EUR 18 million negative) and relate to sales in the liquidity portfolio. We have a liquidity portfolio of EUR 16 billion to absorb shocks in liquidity. Managing this portfolio involves regularly selling and buying bonds to keep it liquid. The negative sales results that must be recognised directly in the result under IFRS are offset by new liquid bonds with high returns in the coming years. The other unrealised market value changes yield a result of EUR 19 million positive (2024: EUR 9 million positive) and are caused by market volatility that affects the valuation of financial instruments.

The consolidated operating expenses for BNG amounted to EUR 173 million on balance. These have increased by EUR 21 million compared to 2024. This is the result of the inclusion of a restructuring provision of EUR 15 million. This reorganisation provision is necessary to achieve the objectives of the Route to More Added Value. This will enable us to strengthen our execution capabilities, collaborate in a chain-oriented manner, invest in leadership and professionalise. In addition, staff costs have increased as a result of the collective labour agreement and investments have also been made in the strengthening of the current IT infrastructure. On the other hand, the resolution fund did not call for additional contributions as in 2024.

The result from the impairments on financial assets in 2025 is EUR 41 million negative (2024: EUR 35 million positive). These impairments relate in particular to the solar energy sector. These items were provided in the years 2018 to 2020 with Sustainable Energy Transition Incentive (SDE) subsidies. This scheme did not provide sufficient compensation for negative energy prices, causing these projects to run into difficulties. Most of these items have been classified as non-strategic items. The bank’s total provisions for expected credit losses increased by EUR 41 million to EUR 98 million by the end of 2025.

The effective tax burden for 2025 was 28.2%, at a nominal corporate income tax rate of 25.8%. The bank levy amounted to EUR 36 million in 2025, EUR 5 million higher than in 2024. This increase was caused by the fact that current and long-term debts were higher at year-end 2024 than in the year before.

The balance sheet total for BNG in 2025 was EUR 116 billion, which is EUR 12 billion lower than in 2024. This is due, among other things, to the repayment of short-term funding. As a result, the balance sheet item Debt securities has decreased by EUR 9 billion.

The size of the long-term loan portfolio is EUR 95.7 billion, of which EUR 7.7 billion is subject to solvency requirements. The increase in the portfolio by EUR 2.7 billion compared to the end of 2024 is almost entirely free of solvency requirements. In 2025, EUR 11.2 billion in new long-term loans and advances were granted, which is EUR 0.5 billion less than in 2024. The increase in the portfolio is particularly due to high demand in the housing sector. The housing sector portfolio increased by EUR 3.1 billion to EUR 54.0 billion in 2025.

BNG maintains a target of at least 90% solvency-free exposures in the total loan portfolio. The target was achieved at 92.0% in 2025. In addition, we aim for a success rate of at least 60% on solvency-free long-term lending to local authorities, housing associations and healthcare institutions. In 2025, 61% of loan applications were granted by us and the target of 60% was met.

Liquidity ratios remain strong, with a net stable funding ratio of 143% in 2025 (139% in 2024) and a liquidity coverage ratio of 159% (217% in 2024). These ratios are also well above the minimum levels and reflect our prudent risk management.

At year-end 2025, BNG’s equity stood at EUR 4.9 billion. Of this amount, EUR 0.3 billion is additional Tier 1 capital. The bank’s solvency ratios remain strong. The Common Equity Tier 1 ratio is 42%. In 2024, this figure was 40%. At the end of 2025, the leverage ratio was 14%, which is 2% higher than the 12% at year-end 2024. The CET1 and leverage ratios are well above the minimum values imposed by the regulator.

Dividend

A dividend of EUR 79 million for 2025 will be proposed at the Annual General Meeting (EUR 140 million in 2024). In line with our policy, this is 50% of the net profit, adjusted for the payout on the additional Tier 1 capital.

3.3 Financial outlook

As in previous years, BNG's funding policy will continue to be focused on ensuring permanent access to the money and capital markets at the terms and volumes required and at the lowest possible rates. BNG expects to raise approximately EUR 15 to 17 billion in funding in 2026. Over the next year, we again intend to raise a substantial part of its long-term funding from ESG bonds.

We do not expect to pay a contribution to the Single Resolution Fund in 2026. The fund has been fully paid up since 2023 and requests for it to be supplemented are only made in the event of a bankruptcy of a European bank.

BNG is expected to remain financially strong in 2026, as well. Strong capitalisation, healthy profitability combined with a high market share and good funding conditions are also providing a solid financial foundation for the future.

The total amount of net profit is subject to uncertainty because we cannot forecast the development of unrealised market value adjustments. We are unable to reliably estimate the net profit for 2026 for that reason.

Our impact-driven strategy responds to this. We aim to achieve net-zero CO₂e emissions within our value chain by 2050. In doing so, we are focusing primarily on making our lending more sustainable, with specific reduction targets for 2025 and 2030. In addition, we are also taking measures within our own business operations, such as the use of renewable energy, when renovating our office and policy regarding business travel and lease cars.

Responsible financing for a sustainable society

Climate change entails significant risks, such as physical damage from extreme weather conditions and transition risks from the transition to a sustainable economy. An example of this is the depreciation of buildings that do not meet the sustainability requirements. Through strategic cooperation, we are supporting our clients in their transition to a more sustainable economy, while also working actively to limit risks.

Although we only have an indirect influence on our clients’ emissions, we encourage sustainability by means of targeted financing, strategic discussions and conditions that encourage sustainability. Examples of this are the financing of the heat supply in the Westland region and the provision of green loans aimed at promoting sustainability among housing associations.

We are actively contributing to the energy transition by financing renewable energy, such as wind and solar energy, energy-efficient buildings, electric mobility and CO₂e storage infrastructure. Network operators play a crucial role in this, which is why we also support investments in expanding and strengthening the energy network.

Financed emissions

We are aiming for a 25% reduction in CO₂e emissions from financed emissions in 2026 compared to 2018. Based on the measurement year 2024, a reduction of 25.5% has been achieved compared to 2018. This means we are well on track to achieve our reduction target for 2025. Since 2018, we have been measuring the CO₂e emissions caused by our financing. This is based on the method developed by the PCAF (the Partnership for Carbon Accounting Financials). The outcome of this measurement and the methodology and data used are described in detail in our report ‘Greenhouse Gas Emissions of BNG’s Assets’, which can be found on our website. In this annual report, we will provide an update on the financed emissions associated with the outstanding long term loans as at 31 December 2024. Chapter 9.1 of this annual report explains the most important elements of the methodology and data.

In our ‘Going Green’ climate plan, we have set targets for our financed emissions. The short-term objectives of BNG were validated by the Science-Based Targets Initiative (SBTi) in September 2025. Every year, we report on the progress made on these targets in our Climate Progress Report, which we publish as a separate document at the same time as this annual report.

Absolute financed emissions originating from our entire loan portfolio decreased from 2,417 kt CO₂e in 2023 to 2,363 kt CO₂e in 2024 (-2.2%). This decrease is mainly attributable to the decrease in emissions in the Care sector, which is caused in particular by a change in methodology¹. The coverage ratio of our measurement remained virtually unchanged from 99.6% in 2023 to 99.7% in 2024. The loan portfolio also grew by 4.4% from EUR 87.8 billion in 2023 to EUR 91.7 billion in 2024. This resulted in 26.0 tCO₂e per financed million euros, a decrease of 6.5% compared to 2023 (2023: 27.8 tCO₂e/EUR million).

In our Climate Progress Report, we look more closely at the client groups that we finance within this sector. If we limit ourselves to the sectors we measure from 2018, these will generate 18.8 tCO₂e per financed million euros, a decrease of 3.6% compared to 2023². Only the sectors that we have been measuring since 2018 have been included for the calculation of the KPI on a percentage decrease of the absolute scope 1 and 2 emissions. These relate to housing associations, municipalities, provinces, water boards, healthcare, education and drinking water companies.The absolute emission measurement for scope 1 and 2 for these sectors is 835 ktCO₂e in 2024, 840 ktCO₂e in 2023 and 1,121 ktCO₂e in 2018. This represents a decrease of 0.6% in 2024 compared to 2023 and 25.5% compared to 2018.

In the previous year, we mapped out the financed emissions for our bond portfolio for the first time. These are bonds that we have purchased from governments, supranational and multilateral development banks, municipalities and companies in the Public Infrastructure and Energy sector. Emissions were able to be measured for 62% of this portfolio in 2024.

These results are explained in more detail in the Climate Progress Report.

1. For the Healthcare, Education and Municipalities sectors, the methodology has been adjusted or different source data has been used; see Chapter 9.1 for more details. These adjustments have been applied retroactively to the 2018 and 2023 emissions. For Healthcare, it was not possible to apply this to all items in 2018 and 2023.
2. The base year for the Housing Associations, Municipalities, Provinces, Water Boards, Care and Education sectors is 2018. The base year for Drinking Water Companies is 2020.

In addition to our external impact, we aim to achieve CO₂e neutrality and the responsible use of materials within our own operations. We report our scope 1, 2 and 3 emissions annually in accordance with the Greenhouse Gas Protocol (GHG).

In 2023, we started renovating our office building on Koninginnegracht. The building will be preserved further and will meet the highest energy efficiency standards after delivery (energy label A++). During the renovation period, we are using temporary accommodation that runs partly on gas, which has led to a temporary increase in scope 3 emissions. Nevertheless, the electricity supply remains completely green. We will return to our renovated and more sustainable office building in the beginning of 2027.

Scope 1 & 2

By 2025, the targets for scope 1 and 2 of our own business operations will have been validated by SBTi. These targets concern: a 100% reduction in absolute CO₂e emissions and BNG will continue to purchase only renewable electricity until 2030.

Our lease policy changed last year, which means that employees will only be able to lease electric cars in the future. As a result, we will see a decrease in our Scope 1 emissions for this category in the coming years. Due to the expiry of lease contracts for cars with a combustion engine, our Scope 1 emissions will be zero from 2029. At year-end 2025, there were no longer any diesel-powered lease cars and two-thirds of the lease cars were fully electric.

Scope 3

Our policy on business travel has changed. For journeys of up to 750 kilometres, train travel will in principle be the standard from 2024 onwards. This will be reflected in the CO₂e emissions from our air travel. This year, for the first time, we have mapped out the emissions from our employees' commuting. In 2026, we will make our mobility policy even more sustainable and investigate how we can further facilitate and encourage employees to make sustainable choices. Starting this year, on the advice of SBTi, we are reporting the electricity consumption of electric lease cars under scope 3, as we have no influence on the electricity mix of charging points outside BNG. This item was reported under scope 2 last year.

5.1 Employees

Strategic priorities

Our HR policy is focused on realising the strategic course "Road to More Added Value" by strengthening executive effectiveness, supply chain-oriented collaboration, and sustainable employability. By investing in leadership, expertise, and entrepreneurship, we make our strategy concrete through the development and deployment of our people. Our HR policy seamlessly aligns with the corporate strategy, using our core values as the foundation for our daily actions and collaboration. In 2025, we therefore added the core value "entrepreneurial," in line with the Route to More Added Value. This new value emphasises a new way of working, with greater executive effectiveness and proactivity. Our core values "expert, connecting, optimistic, and enterprising" form a solid foundation for our policy.

Our strategy needs to be tightened up with concrete and measurable objectives. Each quarter, we reported on progress and impact through identified KPIs. These quarterly reports are an important way to show successes and take further steps. In the fourth quarter of 2025, we developed the ambitions for our strategic objective further in programme plans for 2026 and targets through to 2028.

Delivering added value is a lasting objective and a driving force that is visible in our culture, results and growth. The KPIs for this objective are now also anchored in the Performance Management System, through which joint results targets for management will be integrated across the bank by 2026.

Personnel policy and reorganisation

Our human resources policy focuses on creating an inclusive, sustainable and fair working environment. This policy is based on our human rights policy, which applies to lending, liquidity management and procurement. It promotes equal opportunities and fair pay, regardless of gender, race, religion or employment relationship.

In 2025, we implemented important policy updates to strengthen our human resources strategy. In cooperation with the works council, for example, we have implemented a new job centre, consisting of seventeen job families, which promotes internal flow. This gives employees more insight into the knowledge, skills and competences required for development within or outside their job family. This transparency contributes to engagement and growth and supports management in strategic workforce planning.

The Road to More Added Value strategic course of action revolves around a sharper focus and a new way of working. We are taking measures to future-proof the organisation in order to reinforce this course of action. One of these measures is the reorganisation, which is taking place in two phases: first the top structure, then the broader organisation. The RfA (request for advice) for the top structure (phase 1) was completed in the summer of 2025. The RfA for the rest of the organisation (phase 2) was submitted in December 2025 and will be completed in the first quarter of 2026. The implementation of the new organisation will take place in the second quarter of 2026. For this reorganisation, we have taken a restructuring provision of over EUR 15 million.

Personal growth

We invested fully in the development of our employees again in 2025. We stimulated more internal mobility and saw a growing use of our learning and development platform, which is a part of the ‘Unlimited Learning’ concept. This concept reflects our ambitions to continuously support employees in their personal and professional growth. The BNG Academy was introduced in 2025, offering a mix of mandatory e-learning modules and tailor-made learning tracks on specific themes, such as onboarding. These provide an overview of learning activities for each position or role that will help our employees to develop their knowledge, skills and conduct. Each employee sets themselves personal development goals for the coming year through our Performance Management system. To strengthen talent development, we continued the Personal Leadership Journey in 2025. This process built on previous leadership initiatives, for which forty employees had been selected based on their development potential.

Diversity and inclusion

Diversity and inclusion took centre stage in 2025. In line with the SER Charter Diversity signed in 2024, the action plan has been submitted and we are monitoring this annually. As part of this plan, we established an ambassador group that actively works to promote diversity and inclusion within the organisation. These efforts received additional support from a range of events, including the initiatives during Diversity Day and workshops such as “Unconscious bias” and “Dilemma training”. These events contributed to raising awareness and engagement among employees. The results of our Pulse Survey in the last quarter of 2024 and 2025 provided important insights into social safety. We shared the team results across all teams and discussed actions and improvements together. In addition, we have identified a number of bank-wide topics in 2025 that we will work with on a structural basis in 2026.

Recruitment, selection and onboarding

We optimised our recruitment and selection activities in 2025. We are reinforcing our presence on social media and deploying our employees as ambassadors through the referral programme. 9 new employees have been recruited via the referral programme. The time needed to fill vacancies (time to hire) increased in the first half of 2025, but decreased in the second half. We have increasingly filled vacancies through internal flow, recommendations and our own recruitment efforts. As a result, the share of external agencies in our recruitment activities continued to decrease. We have improved our onboarding programmes in 2025 to integrate new employees more quickly, regardless of their employment relationship. These programmes help them feel connected to our organisational culture. They contribute to a smooth start and reinforce the sense of involvement in BNG as an attractive employer.

As at 31 December 2025, our workforce consists of 503 in-house staff (measured in FTEs). The number of external staff stands at 124 FTEs as at 31 December 2025. This represents a decrease of 45 FTEs compared with the figure as at 31 December 2024. The externally hired staff consist of individuals on self-employed contracts and seconded staff, who are primarily working on strengthening and modernising our IT organisation. The decrease in the number of externally hired staff in 2025 is due to the transition from external to internal staff and the completion of IT projects.

Sustainable employability and green employment conditions

Sustainability is an essential aspect of our human resources policy. We are inspired in this instance by the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. This is reflected in sustainable employment relationships, ‘green employment conditions’ and sustainability of our mobility and lease policies. To promote the sustainable employability of employees, we offer facilities such as a sports budget, bicycle plan and vitality leave. These contribute to the vitality and long-term commitment of our employees. Absenteeism was 4.35% in 2025, higher than in 2024 (4.0%). This higher rate of absenteeism is mainly due to higher absenteeism in the fourth quarter. Long-term absenteeism is largely medically related.

Key figures HR

Remuneration policy

BNG is a member of the Employers’ Association for Banks (WVB) and applies the Collective Labour Agreement Banks. Of all BNG employees, 95% are covered by the Dutch Collective Labour Agreement Banks (CAO Banken).

Based on the agreements in this CLA, salaries and salary scales were increased by 4% on 1 January 2025 and then by 1% on 1 July 2025. In addition to many other schemes, the collective labour agreement also includes a parental leave scheme that can be detailed further by the organisation.

BNG has a parental leave scheme where the first four weeks of the partly paid parental leave (a total of nine weeks can be taken) can be topped up to a maximum of 100% of the salary. Thirteen employees (10 men and 3 women) made use of the scheme in 2025. All employees whose parental leave ended returned to their jobs.

The Collective Labour Agreement Banks also has a vitality scheme. Based on a number of criteria and with retention of part of their salary, employees can take two months’ leave. Eleven employees made use of this scheme in 2025. In addition, the vitality scheme has a so-called 80-80-100 scheme, in which the employee works 80% hours at 80% salary but retains 100% pension accrual. Within BNG, two employees participated in this scheme.

All employees participate in the ABP pension scheme. As the employer, BNG contributes 70% to pensions, while the employee contributes 30%. All figures mentioned are as of the end of 2025.

BNG aims for a restrained remuneration policy that corresponds with our identity and strategy. We want the remuneration policy to discourage taking more risk than is acceptable. The remuneration policy must also not lead to incentives for dishonest behaviour. Employees and members of the Executive Committee and Supervisory Board do not receive variable remuneration.

The Supervisory Board monitors the bank’s remuneration policy. The general principles of the remuneration policy for Executive Committee and employees have been approved by the Supervisory Board. Each year, the implementation of the remuneration policy is reported to the Supervisory Board and the Supervisory Board assesses whether the policy meets the principles for a restrained remuneration policy. For that purpose, Risk Management carries out a risk analysis for various components of the remuneration policy.

The Annual General Meeting adopts the remuneration policy for the statutory members of the Executive Committee and the remuneration scheme for members of the Supervisory Board. In 2025, the salary of the highest-earning member of the Executive Committee was 3.72 times the median salary of employees at BNG (3.87 in 2024). The average salary (wage bill) increased by 8.7% compared with 2024. The salary of the highest-paid ExCo member increased by 7.8% in 2025. The remuneration policy and the remuneration report are published on the website. The remuneration of Executive Committee and Supervisory Board members in 2025 is reported in the financial statements.

5.2 Compliance

Governance

Risks that threaten the integrity of BNG are described as the bank's compliance risk. We divide this risk into four sub-risks that relate to financial economic crime, behaviour, fraud and regulatory compliance. Managing these risks is the responsibility of the entire bank. As an independent second-line compliance function, the Compliance department provides support in this regard based on a compliance cycle. This cycle is in line with the generic risk management cycle of BNG and is laid down in the Compliance Charter..

Compliance cycle

Developments in 2025

In 2025, BNG focused on improving the demonstrability of the management of compliance risks. This creates a more complete and objective view of the risks. Where we identify gaps in our risk picture, we perform further analysis, including the Systematic Integrity Risk Analysis (SIRA). We also identify opportunities for improvements and tightening in our risk management. We will discuss the main developments in 2025 for each sub-risk below.

Financial and economic crime

An important condition for our integrity is that BNG is not involved directly or indirectly in money laundering, terrorist financing, sanction violations, bribery or corruption. The client integrity policy forms the basis for mitigating this risk. Based on this policy, we assess counterparts in the international money and capital markets, clients in the Dutch public domain and other relationships. In addition, we use this policy as a foundation for our transaction monitoring programme, which allows us to detect unusual transactions.

The Anti-Money Laundering and Terrorist Financing Act (Wwft) and the Sanctions Act (SW) form important frameworks in this policy for client integrity. In 2025, BNG made qualitative improvements to the implementation of this policy and the systems used in the implementation of the policy.

Bribery or corruption are fundamental offences that lead to money laundering. Managing these risks in relationships is part of the due diligence process for these relationships. Within BNG, we screen our employees and have a code of conduct to which employees commit. We assess the inherent risks of corruption or bribery as limited both in our commercial processes and in our internal processes. Therefore, BNG does not specifically offer of anti-corruption training. We also did not register any incidents of corruption in 2025.

Conduct risk

Conduct risk includes the risk of actions by BNG, its employees or its relations that are contrary to our standards, legal requirements or social standards. Our code of conduct is the starting point for managing this risk. This code gives employees direction in their actions and is an important building block in the integrity of BNG.

New employees (internal and external) go through an onboarding programme when they start work with us. In this training, they are given an explanation of the code of conduct, take the banker's oath and the second-line compliance function provides an introduction to the regulations that employees must comply with. In addition, new employees must take in-depth training courses to mitigate conduct risks in the first weeks after commencement of employment.

Employees who are already employed can always consult the policy internally. Through additional training courses, intranet reports, stand-ups, management focus and employee surveys, BNG monitors whether employees remain aware of the standards of conduct that we agree upon with each other. Managers, HR and Compliance are ready to provide consultancy or answer questions about this policy. In addition, employees can report potential irregularities via an incident process, a complaints procedure or a reporting procedure. In this way, we bear responsibility for the integrity of BNG jointly.

In the case of clients, counterparties and other third parties, the code of conduct is the starting point. BNG wants to support positive social transitions and promote ethical action among these stakeholders. The code of conduct is the starting point in a supplementary policy that is aimed at these external stakeholders. These stakeholders can also provide feedback on BNG's actions, for which there is a complaints procedure (link).

BNG did not receive reports or identify incidents in which conduct risks with a significant impact materialised in 2025.

Fraud risk

We monitor fraud risk as a separate sub-risk due to the nature of this risk and the impact that a fraud incident can have on confidence in BNG or the financial sector as a whole. This risk includes both internal fraud by employees and external fraud directed against BNG or our business relations. We ensure the detection and settlement of fraud cases through our separate fraud risk management framework. Developments in existing or new fraud risks form part of the SIRA.

BNG did not identify any cases of internal fraud or external fraud against BNG in 2025. We detect signs of external fraud at or through our relationships using management measures, such as transaction monitoring. Here too, the number remained limited in 2025 and these signals were reported, where necessary. Fraud in payment transactions continues to be a focus point for financial institutions in 2025. BNG’s clients are less susceptible to fraud in payment transactions due to the nature of their business and the fact that this type of fraud is often directed against consumers.

Regulatory compliance risk

Finally, BNG has defined the risk of breaches of laws and regulations as a separate risk. The new regulatory compliance risk management policy provides a framework for identifying and reporting on compliance risks. We identify material compliance risks through analyses and monitoring within the compliance cycle. Information from first-line monitoring, audit reports and discussions with the supervisory authorities provide input into this analysis and monitoring.

A number of new or amended laws entered into force in 2025 and the volume of legal obligations remains extensive. In 2025, BNG prioritised activities that manage regulatory compliance risks more highly. Implementing the obligations under the Digital Operational Resilience Act (DORA) has been given absolute priority in this regard. These activities not only reduce the regulatory compliance risk, but also reduce the operational risks of BNG in this area.

Data security is a component of DORA. As a result, these activities also increase the maturity of BNG in its compliance with the General Data Protection Regulation (GDPR).

The Capital Requirements Regulation, BCBS239 and the Wwft/SW remain important legislative files with regard to regulatory compliance risks arising from other regulations. The Instant Payments Regulation and the Artificial Intelligence Act were added in 2025. BNG remains committed to compliance with all obligations based on a risk-based approach. If structural solutions for compliance require additional time to implement, BNG uses temporary mitigating measures.

BNG remained in close contact with regulators in 2025 about regulatory compliance risks. These contacts include informal discussion, as well as formal information requests, notifications and inspections. We did not receive any fines or penalties and were not involved in any legal proceedings due to non-compliance. There were also no outstanding fines or sanctions from previous years.

Customer privacy

BNG attaches great value to the privacy of persons, employees, applicants and other data subjects associated with clients.

We took steps to increase our level of privacy maturity in 2025:

• We have set up a Privacy Office to further strengthen the privacy framework.

• The Privacy Policy has been revised and supplemented with a range of guidelines and procedures.

• At the launch of our new website, we implemented a cookie consent mechanism and a cookie statement, in accordance with the instructions of the Dutch Data Protection Authority (DPA) for clear cookie banners.

Data breaches

Under the GDPR, BNG must register data leaks internally and, depending on the severity, report them to the DPA and data subjects. A data breach is a security incident, in which personal data is accidentally or unlawfully destroyed, lost, modified, provided, made accessible or temporarily unavailable. We registered 29 data breaches in 2025 (2024: 23). Only two of them were reported to the AP (as many as in 2024). One report was later withdrawn, as further investigation revealed that there was no risk to data subjects. The data breach reported concerned access rights set incorrectly, which meant that data was too widely accessible internally. There was no unauthorised external access. There were no data leaks requiring reporting to data subjects.

Rights of data subjects

In 2025, BNG introduced a new procedure that provides frameworks for handling requests from data subjects to exercise their privacy rights under the GDPR. BNG received one request in 2025: a removal request from an applicant. In addition, BNG did not receive any complaints about breaches of the privacy of data subjects.

5.3 Risk Management

Identifying, analysing and managing risks is inherent in our activities. We manage and control risks through an extensive Risk Management Framework (RMF), which integrates risk management in all our business activities, from strategic planning to daily operational activities. This is aimed at safeguarding and maintaining the bank's secure risk profile and protecting our reputation. Taking balanced risks that are adjusted to the risk appetite is essential for our managed business operations.

Risk Management Framework

The RMF is the set of policy documents that outline the risk management principles at BNG. The framework brings together a range of elements that play a role in our risk management. Our RMF is shown in the overview below.

Risk-related committees

The Executive Committee determines the risk management frameworks with the approval of the Supervisory Board. The Asset & Liability Committee (ALCO), Credit Committee (CC), Credit Policy Committee (CPC), Credit Committee Treasury (CCT), Sustainability Banking Committee (SBC), Non-Financial Risk Committee (NFRC) and Client Acceptance and Review Policy Committee (CARPC) make decisions on the risk management of the bank. The Supervisory Board (SB) and, in particular, the Risk Committee (RC) of the SB, evaluate the risk management. This is an important part of his supervisory role.

See the overview of risk-related committees beside:

The purpose and powers of the Risk Management and Compliance departments are laid down in the Risk Management Charter and Compliance Charters respectively. Risk Management and Compliance are is represented in the risk-oriented ExCo committees and takes part in meetings held by the SB’s Risk Committee. The Compliance and Risk Management department heads are accountable to the CRO, the ExCo and have a reporting line to the SB.

A summary of the roles of the Exco committees per risk type is set out in the table:

1. ESG risks that fall specifically in a traditional risk category are subject to the same risk governance. For example, ESG risks related to credit risks are handled by the sub-committee of the Executive Committee that monitors credit risks.

BNG uses the 3LoR model as its governance framework for risk management. Each line has a specific role and defined responsibilities in managing and controlling risks. The figure below shows the allocation of departments within BNG to the three lines.

The responsibilities in the second line are fulfilled by three Risk Management departments and Compliance, which operate independently of the first line. The purpose and powers of the Risk Management and Compliance departments are laid down in the Risk Management and Compliance Charters respectively.

• Integrated Risk Management (IRM) is responsible for oversight of bank-wide risks, including strategic and reputational risk. The IRM department is responsible for, among other things, the bank-wide Risk Management Framework and underlying policy, drawing up the Risk Appetite Statement (RAS) in line with the risk taxonomy and cascading the RAS to Key Risk Indicators (KRIs), integrated risk reporting, coordination of Pillar 3 reporting, and monitoring and advising on prudential laws and regulations.

• Financial Risk Management (FRM) subdivided into the following sub-departments:

  • Asset Liability Management (ALM): The ALM department is responsible for market and liquidity risk and carries out the coordination of the ICAAP and ILAAP and the recovery plan and coordinates the bank-wide stress testing.

  • Credit Risk Management (CRM) CRM is responsible for credit risk at portfolio and client level from the second line. The tasks include providing a second-line challenge and an opinion on credit proposals and reviews of individual clients, financial counterparties and investments.

  • Model Risk Management (MRM) is responsible for model risk as a subcategory of operational risk and carries out the model management, including model governance and validation of the bank's models.

• Non-Financial Risk Management (NFRM): The NFRM department is responsible for monitoring all operational risks (including IT-related risks) and provides support in identifying, qualifying, and quantifying operational risks in regular business activities and change programs. NFRM is also responsible for bank-wide coordination of the investigation and follow-up of operational incidents.

• Compliance: The Compliance department is responsible for monitoring compliance risks, monitors compliance with rules, laws and internal policies and promotes the integrity of the organisation, its clients, its employees and the markets in which BNG operates. See 5.2 Compliance for further details.

Risk Appetite Statement and taxonomy

Risk Appetite

The Risk Appetite Statement (RAS) describes the risk appetite that we accept to achieve our strategic objectives.  It defines the risk management principles within BNG and sets limits on all different types of risk.

The risk appetite is described qualitatively for BNG relevant risk types and elaborated in key risk indicators with defined limits. The risk appetite is evaluated annually and adjusted if necessary, to keep it in line with current developments and BNG’s strategic objectives.

The Executive Committee, after discussion and approval by the Supervisory Board, determines the RAS and ensures that our operational activities remain within the risk parameters identified with the support of the risk departments.

Taxonomy

The main risks that apply to BNG are recorded and described in the risk taxonomy. A distinction is made between financial risks, non-financial risks, strategic risks, ESG risks and reputational risks. Where applicable, main risks (level 1) and sub-risks (level 2) have been defined within these categories. The diagram below shows the relevant risks, without indicating the scale of the risk for each type. The overview shows that ESG risk and strategic risk are spread across financial and non-financial risks and that reputational risk is always the result of not managing other risks correctly.

The BNG’s risk taxonomy is shown as follows:

Explanation of the main risks

This section examines the main risk categories that BNG has included in its risk taxonomy. If these risks materialise, they may have a material impact on BNG’s reputation, the achievement of its strategic objectives or on the bank’s financial results. A brief description is included for all major risks of the definition, the risk appetite, the way in which BNG deals with this risk and the most important developments.

Strategic risk

Strategic risks are defined as risks that affect or are created by the bank’s business strategy and strategic objectives. This concerns risks resulting from internal and external causes that could prevent us from successfully achieving our strategic objectives. The Executive Committee and the Supervisory Board have formulated a number of strategic preconditions within which we must operate in order to be of added value to our clients, shareholders and other stakeholders.

Organisational structure

Strategic risks are inherent in the bank’s strategic plans and may also be influenced by external factors. The strategic risks are usually closely related to other risk types. How we deal with strategic risks is detailed in the organisational strategy and annual plansof the individual departments.

These risks matter are also addressed in the stress test programme and are covered in the Capital Management Plan (as part of the mandatory internal capital adequacy assessment process (ICAAP)).

The identification of strategic risks is part of the strategic decision-making process and of strategic risk assessment methodologies. Appropriate measures are taken to mitigate strategic risks where possible. Monitoring and reporting on strategic risks is an integral part of the periodic risk management cycle.

Developments 2025

Geopolitical developments in 2025 are an important focus for BNG. The impact of these developments on BNG appears limited for the time being, but is being closely monitored and analysed. Where necessary, BNG has conducted ad hoc risk assessments to determine whether additional measures were needed to deal with these developments and limit the risk to the bank.

Environmental, Social and Governance (ESG) risk

BNG considers Environmental, Social, and Governance (ESG) risk to be a factor for traditional risk categories. These factors relate to the negative effects of the environment and climate (E), society (S), and governance (G) on the bank's financial performance, continuity, and reputation. We focus in particular on climate and environmental risks. We consider social and governance factors to be less material for the bank. This is because BNG’s exposure is mainly located within the Netherlands and the Netherlands has good institutions and governance practices.

Identification, assessment and management of ESG Risks

BNG uses the ESG Risk Identification & Materiality Assessment (ESG RI&MA) to identify the significant ESG risks to which BNG is or may be exposed. In the materiality assessment, we assess how ESG risks affect traditional risks, such as credit risk, market risk or operational risk. By identifying the material ESG risks, we ensure the integration of ESG risk into our existing risk management.

Internal ESG rating

The ESG factors that are assessed as material in the sector analyses form the basis for the assessment of ESG-related credit risks at the individual client level.

We use an ESG rating to measure ESG risk at the client level. This includes the ESG risk drivers established by the RMAs.

The ESG rating, together with the regular credit rating, forms part of the individual credit assessment process and, thus, contributes to the risk appetite. It also provides input into the ICAAP process and into climate-related stress tests and scenario analyses.

ESG assessment and management

The risk assessment based on the ESG rating forms the basis for the client view of ESG risks. Critical ESG outcomes are discussed with the client in order to make them open to discussion. The focus here is on the efforts of the client to get within the path to acceptance. This can lead to the creation of performance targets. These targets may, for example, be linked to the reduction of energy consumption or CO₂ emissions. In an extreme case, when the ESG risks are assessed as being too high, this may lead to rejection of the credit application or a transfer to high risk for credit reviews. This approach ensures that climate and environmental risks are taken into account fully in our credit policy, which contributes to a responsible and future-proof loan portfolio.

KPIs and Reporting

To measure the performance of our clients on sustainability, our focus is on emissions and energy consumption KPIs (Key Performance Indicator), where we focus on the (committed) CO₂ reduction targets.

We mainly use independent emissions data sources for this purpose. In this way, it is possible to compare clients according to factors relevant to the sector, including emissions related to the building. Divergent values are identified within the ESG risk reports, after which they are discussed with the client based on the regular periodic credit assessment process.

Organisational structure

ESG risk management is an integral part of the RMF, and the tasks and responsibilities are assigned in accordance with risk governance and the 3 LoR policy. The impact of ESG factors on the bank in terms of lending to customers, assets within the portfolios, and positions with financial counterparties is identified and managed. Decision-making regarding ESG risks takes place at board level and in the existing committees, including the CC, CPC, ALCO, and NFRC. The SBC determines and oversees our integrated sustainability policy. This includes both our long-term environmental and social contribution and the identification of material ESG risks that may negatively impact our performance. To help it implement the strategic sustainability objectives, the SBC is supported by two other bodies. The Sustainability Task Force (STF) consists of representatives from the most relevant departments within the bank. The ESG Regulatory Change Framework (RCF) Task Force identifies upcoming ESG legislation and its impact on the bank.

Developments 2025

We are continuing to refine our ESG risk management framework, while anticipating new regulations such as the CRR3/CRD6 Directive. Our focus is on improving our data quality further, expanding our scenario analyses and strengthening our commitment with clients to jointly mitigate ESG risks. In addition, the bank is working on expanding and deepening its understanding of the physical risks and their further integration into the risk management framework. Through this holistic approach to ESG risk management, we aim to enhance our resilience, protect our stakeholders and contribute to a sustainable future.

The focus of ESG risk on climate and environmental risks will be developed further by the CRR3/CRD6 and EBA Directives for the social and governance components.

Reputation risk

Reputation risk is the risk that BNG's market position could deteriorate due to a negative reputation among stakeholders:

• Internally caused reputational risk: the risk that BNG's reputation could be negatively affected by the impact of other (poorly managed) risks.

• Externally caused reputational risk: the risk that BNG's reputation could be negatively affected by altered external expectations that are not well managed in the strategic process (strategic positioning risk).

Organisational structure

As part of the risk management cycle, reputational risk is periodically analysed and reported in the integrated risk report and discussed with the Executive Committee and the Supervisory Board.

Credit risk

Credit risk is the risk that a borrower or a financial counterparty will fail to meet its contractual obligations or will not do so on time. This risk is divided into three subcategories:

• Counterparty risk: The risk that a borrower or counterparty fails to meet payment obligations arising from a financial transaction at the time they are due.

• Concentration risk: The risk of credit losses from exposure to a group of borrowers or counterparties with comparable characteristics.

• Settlement risk: The risk of loss if a party to the settlement of a contract (or group of contracts) does not meet the agreed conditions.

ESG risks as a part of credit risk

ESG risks are an integral part of credit risk. The way in which a counterparty deals with environmental, social and governance aspects within its business operations has a direct influence on its creditworthiness. A higher ESG risk score may result in a lower credit rating, as these factors materially affect a company’s financial stability and future prospects. ESG criteria are, therefore, an essential part of the credit analyses and rating methodologies. When managing ESG risks as part of credit risk, the focus is on transition and physical risks. The material ESG credit factors are determined per sector in the Risk ESG Identification and Materiality Assessment (ESG RIMA).

Creation and mitigation of credit risk

Credit risk arises from a range of activities, including lending to the public sector, hedging currency and interest rate risks through derivative transactions with financial counterparties, money market liquidity management operations and investments in interest-bearing securities of issuers.

The credit risks arising from lending are usually mitigated by government guarantees via the WSW (Social Housing) and Wfz (Care) guarantee funds, which are guaranteed by the Dutch State via backstop arrangements. Focusing our lending on the Dutch public sector, which is inherent in the business model, entails concentration risk.

Settlement risk arises in the settlement of foreign currency issue transactions with financial counterparties. Due to the size of these transactions, the settlement risk may potentially be high. To mitigate these risks, arrangements are made with counterparties on the maximum size of individual settlements, in accordance with the applicable internal limits. Large settlements are processed in sub-steps, with the next part being provided only after the previous part has been settled. Settlement dates for new transactions with counterparties are also spread over time to avoid unnecessary concentrations in one day.

Monitoring and assessment

The credit risk of a borrower or counterparty is determined periodically based on a credit assessment. Internal credit assessments are carried out annually for all borrowers to evaluate their creditworthiness and take appropriate measures where necessary. In addition to the periodic credit assessment process, ongoing monitoring of the financial performance of borrowers takes place, including by monitoring early warning indicators and unlikeliness to pay indicators.

For financial counterparties and investments, external credit assessments and investor report data are also included in the assessment. Four external rating credit rating agencies approved within the Eurosystem are used for this purpose.

Developments in 2025

Our loan portfolio remained stable in 2025, partly thanks to a tightened customer strategy and a further decline in the “Financial Restructuring and Recovery portfolio”. We have continued to focus on integrating climate and ESG risks into our credit assessments and reports, in line with increasing social and regulatory requirements.

Market risk

Market risk is the risk of loss of profit and capital as a result of fluctuations in market prices. There are various forms of market risk: interest rate risk, currency risk, fluctuations in credit and liquidity spreads and volatility risk.

• Interest rate risk: the risk of loss of profit or capital due to unfavourable movements in interest rates.

• Currency risk: the risk of loss of profit or capital due to unfavourable fluctuations in exchange rates.

• Credit and liquidity spreads risk: the risk of loss of profit and capital due unfavourable spread fluctuations.

• Volatility risk: the risk of loss of profit or capital due to unfavourable movements in the implied volatility of market interest rates or exchange rates. This risk applies only to interest rate instruments that operate under a principle similar to that of options (for example, caps and floors).

The most recent Risk Identification & Materiality Assessment concluded that there are no material ESG factors relating to market risk and its sub-risks. For credit and liquidity spread risk, we nevertheless capitalise on ESG factors, because capital is based on historical movements of these spreads, where ESG factors are included. 

Risk appetite

We are applying a prudent approach to managing market risks:

• The bank hedges interest rate risk positions in the banking book with interest rate swaps. The bank models the equity in such a way that the required return of the shareholders is achieved^1[1], which is an ongoing investment in 10-year paper of the Dutch State;

• We fully hedge against risks arising from value adjustments of financial instruments that may result from the change in an index, such as inflation, with index-related derivatives.

• The bank hedges currency risk with cross-currency swaps and foreign exchange swaps.

Developments 2025

During the reporting year, the bank's market risk profile was characterised by increased volatility in credit and liquidity spreads. This led to manageable, unrealised losses in the capital position and the associated risk measurements.

Interest rate risk remained within the established limits, with the short-term interest rate position (0–1 year) being actively managed. In combination with further improvements in governance and model development, market risk remained controlled and within the established risk appetite.

Liquidity risk

Liquidity risk is he risk of loss of profit or capital due to the possibility that the bank is at any time unable meet its payment obligations without incurring unacceptable costs or losses. Liquidity risk can be broken down further into various subcategories (short and long term):

• Short-term risk: the risk that the bank will not be able to raise sufficient funds to meet its payment obligations.

• Funding capacity risk: the risk that, as a consequence of its funding capacity, the bank will not be able to raise sufficient funds to meet its funding requirement over the long term, which would jeopardise the continuity of its business operations.

• Refinancing risk: The risk that, as a consequence of our own creditworthiness or changing market conditions, the bank will have to raise financing or refinancing on the basis of unfavourable financing spreads that will jeopardise future profits.

Within the liquidity risk, the bank focuses on the transition and physical risks within the sub-risks of liquidity risk as far as ESG factors are concerned. The bank has established that the ESG risk is not material for the short-term liquidity risk.

Risk appetite

In order to meet our payment obligations at all times, including in stressful situations, we pursue a prudent liquidity policy and the bank accepts liquidity risks at short notice only if there are sufficient liquidity buffers in return. The bank has a substantial liquidity buffer for this purpose.

The public sector largely consists substantially of institutions with a long investment horizon. This means that loans often have very long maturities. up to several decades in some cases. As there are no acceptable funding rates available for these long maturities, the bank attracts funding for somewhat shorter maturities and we accept a funding mismatch. This mismatch is monitored daily and is subject to strict liquidity and capital limits.

Limits or warnings apply for a range of liquidity risk measures, such as the liquidity gap analysis, liquidity stress scenarios, the Liquidity Coverage Ratio (LCR), the NSFR (Net Stable Funding Ratio) and Contingency Funding Plan (CFP) triggers.

Liquidity risk instruments

As a bank, we want to maintain continuous access to money and capital markets, together with the continuous maintenance of attractive, varied and sufficiently large issuance programmes for investors, because we want to meet the credit demand of our clients – even in difficult times.

In addition, liquidity buffers are required, so that we have access to liquidity in stressful times. The liquidity buffer is mainly formed from a cash position at the ECB, level 1 high-quality liquid interest-bearing securities (which are explicitly held for liquidity purposes and known as the liquidity portfolio) and the ECB eligible interest-bearing securities and loans deposit with the ECB . The management of the size and composition of the liquidity portfolio is one of the liquidity measures taken to meet the external requirement for anLCR of at least 100%. The bank also holds a large amount of collateral in the ECB deposit, allowing it to obtain short-term financing immediately. Since we, as a bank, can deposit ECB eligible interest-bearing securities and loans as collateral with the ECB, this collateral can be extended further in cases of prolonged stress. The size of the buffers is tested in the liquidity stress tests, which are monitored monthly. Furthermore, the financing plan and the related planned liquidity gap are tested in unfavourable normative stress scenarios for the LCR and NSFR ratios.

Most of the funding is obtained from international capital markets. We distinguish between short-term and long-term financing. We maintain a number of issuance programmes that allow access to funding at competitive levels at any time. We are committed to proactive relationship management with investors who support these efforts. The main currencies for the bank are the euro and the US dollar.

We are aware of a number of funding sources. We use the following resources for short-term financing (money markets):

• Commercial paper: The bank has a European commercial paper programme (ECP) of EUR 20 billion and a US commercial paper programme (USCP) of USD 20 billion. Under normal market conditions, a significant margin is maintained between the maximum size allowed by the programme and the actual use by the bank.

• Unsettled repo transactions with interbank parties under a Global Master Repurchase Agreement (GMRA), where the bank's liquidity portfolio is used as collateral.

• Deposits from institutional money market parties.

We have the following programmes available for long-term financing (capital markets):

• a debt issuance programme (DIP) of EUR 110 billion. This is our most important source of funding. ESG bonds are also issued under this programme.

• AUD 15 billion Kangroo-Kauri programme specifically for the Australian and New Zealand markets. ESG bonds are also issued under this programme.

• Namen-Schuld-Verschreibungen (registered debt securities, NSV), bond issues under German law.

• private loan agreements under various legislations.

We may also use the following alternative sources of funding:

• European Central Bank financial instruments.

• ‘Global’ loans from the European Investment Bank and the Council of the European Development Bank.

• guaranteed investment contracts (GICs).

We do not enter into transactions with private individuals.

We have a funding plan, in which the desired funding mix is described in detail. Part of the funding plan is the annual issue in benchmark size to maintain a“BNG curve” in the market. These large-scale issues by an issuer with a creditworthiness linked to the Dutch State ensure that we have a secure profile among investors, allowing us to maintain access to investors, even in times of market stress. The actual realisation of this desired funding mix or the reason for deviating from this is monitored and evaluated by the ALCO, by means of a funding plan drawn up by Treasury and reviewed on a quarterly basis.

Developments 2025

During the reporting year, the bank's liquidity risk remained under control, with good access to money and capital markets throughout the year. Although there was volatility in the financial markets and geopolitical uncertainties, no limits or targets were exceeded and there were no structural tensions in the liquidity position. The development of the liquidity gap remained within the established framework, partly due to active management of the maturities of new turnover and the timely attraction of long-term funding. The refinancing risk also remained within the established risk appetite. Through continuous monitoring, robust stress tests and the use of contingency indicators, the liquidity risk remained within the established risk appetite.

Operational risk

Operational risk is defined as the risk of loss of income or capital resulting from deficiencies of internal processes, people and systems, or from external events. Operational risk includes various level 2 risks, including risks relating to processes, technology, information security, data management, third parties, legal affairs and business continuity. Within operational risk, we focus on transition and physical risks in terms of ESG factors.

Risk appetite

Operational risks are inherently linked to the business operations of BNG. Although BNG is committed to a high standard of quality and reliability in its business operations, measures to mitigate operational risks are taken based on a balance between costs and economic income. In view of the great importance of BNG’s reputation, the bank applies and monitors qualitative limits to strengthen its risk management framework.

Given its role as a system bank, BNG is not prepared to accept high or critical operational and security risks, nor medium-sized operational and security risks that are expected to materialise once every three years or even more frequently.

With regard to ESG‑risk, BNG takes into account increased process risks, data management risks, model risks and legal risks that may arise from non-timely compliance with internal and external requirements (e.g. as a result of missing ESG‑data). The risk of external ESG‑related events that may have an impact on BNG is also estimated.

Non-Financial Risk Management instruments

We use a range of tools to manage operational risks, including:

• Key Risk Indicators: The bank’s risk appetite for operational risk results in a risk tolerance that is primarily focused on reputation and internal business operations. The bank’s exposure to operational risk is measured using Key Risk Indicators (KRIs) with set limits. The KRIs relate to all categories of operational risk. The measured KRIs are compared with the risk appetite and reported to the NFRC on a quarterly basis in the operational risk report.

• Risk Control Self-Assessments (RCSAs): The RCSAs are performed on the business processes, with the second line playing a facilitating, but also challenging, role. The inherent and residual risks identified and the corresponding management measures are assessed at least annually, based on probability and impact scales. The RCSA results provide the input for our monitoring programmes, including the periodic testing of the effectiveness of the most important control measures.

• Incident management: We record all operational incidents that occur and investigate the root causes of incidents with a medium or high or critical impact. The process owners must carry out this investigation and initiate remedial actions. In order to prevent similar incidents in the event of future incidents, the process owner examines together with the 2^nd line whether adjustments are necessary in the process, the systems and/or the working method. Incidents are reported to the NFRC, the Executive Committee and the Supervisory Board’s Risk Committee.

• Scenario analysis: A scenario analysis of operational risks is performed annually. These scenarios also provide input to substantiate the economic capital allocation for operational risk.

Developments in 2025

In 2025, it was established that three focus areas have not yet reached the desired level of maturity. In order to achieve this, improvement programmes have been launched with intensive management focus and periodic reporting. These focus areas are as follows:

ICT risk²: A secure and stable IT landscape is essential for the continuity of our services and the trust of our clients. BNG applies an integrated approach to managing ICT risks that is aimed at ensuring the confidentiality, integrity and availability of information. This approach includes clear responsibilities within the organisation and guidelines for suppliers and other parties with whom data is exchanged. In 2025, further steps were taken to modernise our IT environment and the IT risk framework, taking into account the requirements of the DORA Regulation and other relevant regulations. BNG continues to invest in secure and future-proof digital infrastructure. New technological developments, including artificial intelligence, are monitored carefully and, where appropriate, integrated to enhance the robustness of the IT landscape.

Process risk: Efficient and effective business operations are necessary to achieve the objectives of BNG. Continuous improvement and optimisation of internal work processes is a top priority. BNG launched several initiatives in 2025 that make a concrete contribution to this and, at the same time, aim to reduce operational costs. Through a chain-wide approach, processes are simplified, more robust and, where possible, automated. The quarterly management review based on measurable results gives focus to this and thus facilitates effective cooperation throughout the entire organisation.

Data management risk: Effective data management is an essential part of BNG’s strategic objectives. It forms the basis for innovation, further digitisation and compliance with laws and regulations. In addition, good data management supports timely and reliable reporting on both existing and emerging risks, including on ESG aspects. BNG is working continuously on strengthening its data management capabilities, so that BNG demonstrably meets the requirements of RDARR and BCBS 239. The focus is on the accuracy and completeness of data, a broader application of data-driven work within the organisation and a further improvement of the availability and management of data by means of appropriate systems and processes.

1. The component of the required return that is related to the Euribor.
2. ICT Risk has an impact on the following BNG risk taxonomies: 1) Technology Risk, 2) Information Security Risk (incl. Cyber Risk), 3) Third Party Risk, 4) Business Continuity Risk.

5.4 Digitalisation, IT and cybersecurity

Cloud migration and infrastructure modernisation

This year, we were able to take advantage of the digital workplace and the integration platform that were implemented successfully, with which we can link applications flexibly. In addition, we have brought payment transactions back to our own organisation and started renewing the payment transaction system. Steps have also been taken towards further cloud adoption, in which we have prepared components from our IT landscape for migration or have already successfully transferred them. This modernisation ensures greater scalability, better performance and a future-proof infrastructure in line with our strategic ambitions.

Resilience to complex threats

The cyber threat landscape is becoming increasingly complex. Technological developments, such as the malicious use of AI, and geopolitical tensions, are increasing the threat. This requires a coherent approach to prevention, monitoring and response.

Within BNG, the Security department is working on strengthening digital resilience, both within its own organisation and across the entire chain. The focus is on testing measures, crisis and communication management and practising a number of scenarios together with IT partners.

In the event of an increased threat or special circumstances, cooperation with external parties will be intensified further. An example of this is the coordination in the run-up to the NATO summit in 2025, in which, among other things, we worked together with the municipality of The Hague.

In addition to technical improvements, such as the faster identification of deviant behaviour, investments have also been made in organisation-wide awareness. Through joint exercises and a clear division of roles, the bank can respond quickly and effectively to cyber incidents.

Compliance and cooperation in the chain

In order to comply with increasingly stringent regulations, such as the Digital Operational Resilience Act (DORA) and the NIS2 Directive, we have tightened our processes further and made them more professional. In July 2025, we launched the Fortica transformation programme, a bank-wide initiative aimed at strengthening our IT risk management sustainably and making our (chain) organisation future-proof.

With project Fortica, we are working on a distinctly higher level of operational resilience. We are improving governance, streamline processes and modernise our technological infrastructure. Thanks to this integrated approach, we will meet the highest internal and external standards, while at the same time aligning well with the needs of our public customers who rely on our continuity and reliability.

Innovation and AI

We are focussing on small, concrete AI applications that can be deployed quickly within the organisation and offer immediate value, such as automatic analysis or support for daily tasks. A working group is investigating the AI initiatives which have the most potential and are both easy and secure to apply. This allows us to innovate step by step without risks to privacy or intellectual property. Collaboration and knowledge sharing are important, such as during the Servicenow Agentic AI Hackathon Event, where we are converting ideas into smart IT solutions with colleagues and partners.

Artificial intelligence offers great opportunities to make our processes more efficient, faster and more error-proof. Applications such as automated data processing, predictive models and smart employee support can lead to improved service and lower operational costs. As an organisation that values quality and reliability, we recognise the potential of AI to strengthen lending processes, risk assessments and customer contact.

At the same time, the use of AI brings new challenges and risks, especially for a bank operating under strict European supervision. Systemic banks are subject to high standards of reliability, transparency, explainability and operational risk management. This means that the introduction of AI must be carried out carefully, step by step and with robust controls. It requires a conservative approach, in which innovation is given room to flourish, but never at the expense of stability, compliance and the security of our services.

6.1 Corporate structure

History

In 1914, the Association of Dutch Municipalities (VNG) established the Municipal Credietbank. This bank gave municipalities the financial clout they needed to tackle social problems at a time of high levels of poverty and pressing social-societal issues. The Municipal Credietbank grew into BNG. This original mission – contributing to societal solutions – is still at the heart of our activities. 

We provide financing to the public sector on competitive terms and for all maturities. We are continuing to support our clients in difficult times, as well. Until now, we have always succeeded in doing so. More than 90 per cent of our loans go to or are guaranteed by government agencies. These loans, referred to as solvency loans, have a risk weighting of 0 per cent. We also take care of payment transactions for our clients. Thanks to the shareholding by Dutch governments and our focus on solvency loans, clients and partners see us as a safe bank. We have the highest external credit ratings (Moody's: Aaa; Fitch Ratings: AAA; S&P Global: AAA). This provides us with a strong funding position on international money and capital markets. This position allows us to attract short and long-term funding at low prices in different currencies. As a result, we offer our clients loans at low lending rates.

Business model

Governance structure

Our two-tier governance structure is comprised of a Supervisory Board (SB) and an Executive Committee (ExCo). The Executive Committee has, at the moment, five directors, three of whom form the statutory board. On 7 May 2026, the ExCo will be expanded to include a sixth director, namely a CIO. The Supervisory Board appoints and dismisses the members of the Management Board. The Executive Committee constitutes the management body with an executive function as defined in the Capital Requirements Directive (2013/36/EU). It is responsible for the day-to-day management, the general course of affairs and the continuity of BNG. The Executive Committee has set up committees to provide consultancy or carry out specific tasks.

These committees are:

• Asset & Liability Committee

• Credit Policy Committee

• Credit Committee

• Treasury Credit Committee

• Non-Financial Risk Committee

• Integral Portfolio Committee

• Sustainable Banking Committee

• Client Acceptance & Review Policy Committee (“Policy CARC”)

The regulations of the Management Board/Executive Committee and their committees can be found on our website.

The Supervisory Board is the supervisory body as indicated in the Capital Requirements Directive. The Supervisory Board supervises the policy of the Executive Committee and the general course of affairs within the organisation. The members of the Supervisory Board are appointed and dismissed by the General Meeting. The Supervisory Board has four committees that prepare the decision-making process:

• Audit Committee

• Risk Committee

• HR Committee

• Remuneration Committee

The regulations of the Supervisory Board and its committees have also been published on our website.

ESG policy governance

The CEO is accountable for the strategy, including the ESG strategy. Management takes care of the implementation of this. The Strategy & Sustainability department and the Executive Committee Sustainable Banking Committee (SBC) prepare proposals for changes in the purpose, strategy, ESG policy and ESG objectives. The Executive Committee decides on these proposals. The SBC ensures that BNG has, implements it and reports on an integrated sustainability policy. ESG factors with an impact on an existing risk are managed by the relevant ExCo committee. The Strategy & Sustainability department reports each quarter on the progress of the strategy, including the material topics. Measuring the impact that BNG has through its clients is part of the ESG policy. This task lies with the Strategy and Sustainability department. We report annually in our annual report on the impact on society through our clients. More information is provided in Chapter 4 of this report.

Stakeholders

Our principal stakeholders are clients, investors, shareholders and employees. We invest in long-term relationships by engaging with them regularly. We do this through consultations, regional meetings, sector meetings and investigations. These dialogues give us insight into their expectations and the value we can create for them. Stakeholders’ responses are used to improve our products, services and processes. For municipal clients, we organise annual meetings on current topics. We also make substantive contributions to meetings concerning real estate in the healthcare, education, municipal and housing association sectors. We are a member of the Dutch Banking Association (NVB), the European Association of Public Banks (EAPB), the European Banking Federation (EBF), the International Securities Dealer Association (ISDA) and the International Capital Market Association (ICMA).

Subsidiaries and associates

BNG Gebiedsontwikkeling B.V. is the only BNG subsidiary specialising in risk-based participation in land development, process design and process guidance for municipalities and other public or semi-public organisations. In March 2018, the SB of BNG Area Development and the then Executive Board of BNG decided no longer to engage in new activities and projects within BNG Area Development. The projects within the existing portfolio will, therefore, be completed in the coming years.

6.2 Composition of the management body and organisation

In 2025, there were two changes in the composition of the Executive Committee. At the beginning of 2025, Jaco van Goudswaard (COO) and Cindy van Atteveldt (CRO) announced that they would leave the bank. Irene van Oostwaard (former head of Internal Audit at BNG) was appointed CRO on 4 March 2025 and Amir Arooni was appointed acting COO on 1 April 2025 for a one-year period. Furthermore, Olivier Labe was reappointed for the third time to 1 May 2027.

In the context of the renewed BNG organisation, Norbert Siegers started as a quarter maker on 5 January 2026 and will take on the role of COO on 7 May 2026.

The internal risk management and control systems are an important point of attention within BNG. The Risk Governance Framework forms the basis for all risk management activities within our bank. It clarifies the principles behind the internal control and risk management system. The Risk Appetite Statement describes the risks we wish to accept in order to achieve our objectives. The various risks attendant on the bank’s activities are discussed each year in BNG’s Annual Report. The process owners or department heads responsible for the primary and key supporting processes annually issue an ‘In Control Statement’ to the Executive Committee, in which they highlight the risks in relation to the risk appetite, the management of risks and any deficiencies in this respect. All process owners or department heads provide ‘in control’ information in their quarterly reports. In the annual plans, they also explain how they aim to fulfil their responsibility of meeting the bank’s risk appetite. At various times during the year, the second line reports to the Executive Committee on compliance with the Risk Appetite. This overall framework is closely linked to the bank’s Capital Management Policy, which is periodically reviewed and discussed with the supervisory authority.

Audits by the Internal Audit Department (IAD) focus on independently determining the structure and function of the internal risk management and control systems. The external auditor audits the financial statements and evaluates internal control in respect of the financial reporting insofar as relevant to an efficient and effective audit of the financial statements. The findings of the IAD and the external auditor are reported to the Executive Committee and to the Supervisory Board. The head of the IAD and the external auditor attend the meetings of both the Audit Committee and the Supervisory Board where the financial statements are discussed.

The annual report provides sufficient insight into deficiencies in the operating effectiveness of BNG’s internal risk management and control systems. The aforementioned systems provide a reasonable degree of certainty that the financial reporting contains no inaccuracies of material importance. These systems alone are of course incapable of providing absolute assurance as to the achievement of the company’s objectives and the prevention of all misstatements, instances of fraud and non-compliance with laws and regulations. A detailed explanation is provided in the ‘Risk’ section of the notes to the financial statements. The consolidated financial statements have been prepared on the basis of the going-concern principle. No material risks or uncertainties were identified that could hinder continuity for a period of twelve months following the preparation of the report.

In the opinion of the Management Board under the Articles of Association, the financial statements provide a true and fair view of the assets, liabilities, financial position and profit or loss for the year of BNG and its consolidated subsidiaries. The annual report provides a true and fair view of the bank’s position, and the current balance sheet reflects performance during the reporting year and the expected developments of BNG and its consolidated subsidiaries. Figures belonging to these subsidiaries have been included in the consolidated financial statements. The Annual Report also describes the material risks facing BNG.

The Hague, 20 March 2026

Management Board under the Articles of Association

Philippine Risch (CEO)
Olivier Labe (CFO)
Irene van Oostwaard (CRO)

8.1 Foreword

Over the past year, the world changed rapidly due to the new leadership in the United States and geopolitical tensions. Fluctuations in the financial markets affected the playing field for international lending. However, this was not a major obstacle for BNG. Thanks to our strong position, we remained resilient and were able to fulfil our role very well in these challenging times. In doing so, we underlined our stability and reliability in a dynamic market.

Our loan portfolio has developed strongly over the past year. Despite the pressure on our net interest income and rising costs, which are partly due to investments in IT and organisation, we have managed to achieve our investment objectives. Thanks to our sound liquidity and a strong capital position, we were able to attract financing and make it available on favourable terms this year, as well.

Investing in social challenges

The Netherlands has many opportunities to invest in social areas, such as housing, energy, infrastructure, high-tech innovation and defence. The public domain works closely with public and private financiers to enable and accelerate these investments.

A clear investment structure is essential. The recent announcement of the merger of Invest NL and Invest International into a single national investment institution highlights the strong level of cooperation within the Dutch financing landscape. This new institution will focus on investments with higher risk, while BNG will continue to focus on low risk financing, preferably with a guarantee profile. In this context, we welcome the decision in Brussels to make it possible to secure the financing of medium-sized rental homes. This strengthens our position and actually helps us to advance the investment task for housing construction.

Future-proof organisation

With the arrival of CEO Philippine Risch, a restructuring of BNG was initiated in 2025. After a thorough introduction to the organisation, she presented a sharpened strategy in April. The central theme is the transition from a traditional, column structure to a chain-oriented form of cooperation. This new facility increases the effectiveness, efficiency and governability of BNG.

This trend is accompanied by necessary cost reductions and a gradual reduction in staff numbers until 2029. At the same time, there is still room for attracting new talent in line with the competencies required for the new way of work.

Changes have also taken place within the Executive Committee. During the year, Cindy van Atteveldt (Chief Risk Officer) and Jacco van Goudswaard (Chief Operating Officer) left the organisation to take on a new challenge elsewhere. The Supervisory Board is grateful for their commitment and contribution. Irene van Oostwaard will succeed Cindy van Atteveldt as Chief Risk Officer and Amir Arooni will provisionally take on the role of Chief Operating Officer. We are excited about the experience and energy that they bring.

Strengthening our IT

One of the priorities is to strengthen and restructure the IT organisation. IT was largely outsourced to one external party until the end of 2024. A strategic change has been chosen to reduce this dependence and spread IT services more and partly bring them back in house. With this approach, we also aim to improve the effectiveness and efficiency of our IT and optimise risk management.

An important milestone is the removal of the processing of payment traffic to our own organisation. At the same time, we have started to renew the outdated payment system. The transition to the new system, scheduled for 2026, is proceeding according to schedule.

Social and green added value

ESG is a central starting point in our organisation and our client relationships, in which environmental awareness and action are an essential theme. BNG is actively taking measures to reduce its own ecological footprint and that of its clients. A good example is our office building on the Koninginnegracht in The Hague, which is undergoing a large-scale and sustainable renovation. The work has been delayed due to market conditions, but we are looking forward to a modern and inspiring working environment with an A+++ energy label.

In discussions with the Executive Committee, the Supervisory Board has devoted considerable attention over the past year to stimulating clients on ESG themes. The aim is to create more social and green added value. Forms of financing, such as sustainability bonds and a pilot with green loans, emphasise this ambition. In 2025, we also entered into a dialogue with a housing association and the Social Housing Guarantee Fund to deepen cooperation.

Building success together

We express our great appreciation for the hard work, commitment and passion of the Executive Committee, all BNG employees, suppliers and partners. Their commitment makes the difference and forms the basis of our success. With confidence and a strong sense of connection, we look forward to the challenges and opportunities that the future brings.

On behalf of the Supervisory Board,

Huub Arendse, Chair

The Hague, 20 March 2026

8.2 Composition of the Supervisory Board and committees

The Supervisory Board is composed of seven members and has extensive knowledge and experience of the markets relevant to BNG. The following pages list the main position or most recent main position held by each member of the Supervisory Board. The relevant other positions of the supervisory directors are also included in this annual report. A register with all of the ancillary positions reported has been published on the website. All of the Supervisory Board members are independent within the meaning of the best-practice provisions of the Dutch Corporate Governance Code.

The Supervisory Board monitors the policy of the Executive Committee, the way in which the Executive Committee implements the strategy and oversees general affairs within the company. The Supervisory Board focuses on both long term sustainable value creation for BNG clients and for the society. The Supervisory Board also monitors the effectiveness of the internal risk management and control systems, as well as the integrity and quality of the financial and non-financial reporting. Depending on the situation, the Supervisory Board fulfils the role of supervisor, employer or adviser for the Executive Committee.

The Supervisory Board has four committees, namely the Audit Committee, the Risk Committee, the HR Committee and the Remuneration Committee. The committees prepare decisions for the Supervisory Board and report verbally and in writing to the Supervisory Board. In addition, the relevant committees advise the Supervisory Board whether approval of the Supervisory Board is required.

BNG has an onboarding programme for new members of the Supervisory Board. This programme will be made specific to each new member, as knowledge and experience will change. The purpose of the onboarding is to ensure that the new members have sufficient knowledge of BNG, its strategy and activities, so that the new members can fulfil their role.

In 2025, the attendance rate for the Supervisory Board meetings reached 86% (2024: 100%) and for committee meetings 96% (2024: 96%). The combined attendance rate for all meetings was 91% (2024: 98%).

8.3 Activities of the Supervisory Board

The Supervisory Board met eight times in 2025. The ExCo is present at the meetings with the exception of the "private session" that precedes the meetings. The regular topics are financial information, (commercial) developments in the various client segments, IT, Risk, Compliance, operational progress, the budget, progress on implementation of the funding plan, corporate governance and HR-related topics. Finally, this year the renovation of the office at the Koninginnegracht and the reorganisation – including the expansion of the Executive Committee with a sixth director, the CIO, and the reclassification of several divisions within the bank – were a periodic item on the agenda of the Supervisory Board.

The Supervisory Board has reviewed and approved the Annual Report 2025 and the financial results for 2025. PwC audited the report and the financial statements. We convene the General Meeting (AGM) to approve the annual figures and to grant discharge to the Executive Committee and the Supervisory Board for execution and supervision respectively in 2025.

In addition, the following topics were discussed at the Supervisory Board meetings in 2025:

• ‘Route to More Added Value’ strategy

• The Annual Report on the Climate Action Plan and the Sustainability Policy 2025.

• Update on CSRD progress and update on the Double Materiality Analysis (DMA)

• Progress on strategic projects, including DORA and IT Risk

• Annual Report 2024, dividend proposal for 2024 and Pillar 3 report

• The impact on BNG of the revision of the Dutch Corporate Governance Code in 2025, in particular the new Risk Management Statement.

• Establishment of the 2025 half-year figures

• Determination of the Risk Appetite Statement 2026 (RAS); the system of limits, targets and information figures. The risk definitions were also established.

• The remuneration report 2024 and the risk analysis govern remuneration policies for BNG and BNG GO.

• SIRA 2024

• SREP letter 2025 from the ECB

• The (re-calibration) of the 2025 Budget and the 2025 Funding Plan, as well as the multiannual commercial plan, including a competitive analysis. In addition, the Supervisory Board adopted the 2026 Funding Plan.

• Fill the CIO vacancy and vacancy for the Head of IAS

• Status of non-strategic exposures and the solar energy portfolio

• Developments regarding a new payment system and the selection of a new supplier

• Developments arising from ECB supervision and the On-site investigations of the supervisory authority

• Update on the Debt Issuance Programme (DIP) 2025

• Definition of the external KPIs for a period of three years (2026-2028)

• The BNG Shareholder Contact Policy

• Approval of the biennial update of the Rules of Procedure of the Supervisory Board as well as the Rules of Procedure of the Supervisory Board committees

• The results of the periodic employee survey

The Supervisory Board received the information necessary to perform its duties. In addition, the Supervisory Board received information from the external auditor, with whom a confidential meeting also took place twice per year. Employees from the organisation regularly attend topic briefings, which also introduces the Supervisory Board to senior management. This is important for the purposes of internal succession planning. In addition, there is an annual topic lunch with the entire Works Council, during which we discuss a current subject.

This year, a visit was made to the Eigen Haard housing association during the annual ‘outside meeting’ – a meeting in which Supervisory Board and Executive Committee discuss the challenges they face with several customers in a segment. In addition to an explanation and dialogue about Eigen Haard’s strategy, a visit to one of its projects was planned. It is a great opportunity to see first-hand what activities are being made possible with the resources of BNG.

In addition, the Executive Committee and the Supervisory Board took part in three continuing education sessions. The regulatory landscape ECB and the WSW guarantee system were topic areas, as well as a DORA boardroom training. The Supervisory Board members also discussed the Standard Pricing model in an in-depth session.

Twice per year, two members of the Supervisory Board contact representatives of the Ministry of Finance as part of the government’s 50% interest in BNG. Regular discussions are also held with the supervisory authority about, among other things, the SREP (Supervisory Review and Evaluation Process) and ‘on site’ investigations.

The Supervisory Board values structural self-evaluation to learn from and become more effective. In addition to evaluation at the end of a meeting, one self-evaluation is carried out per year. This is carried out once every three years by an external party. This took place in 2025. The Supervisory Board discussed the outcome of this self-assessment in a private session in 2025, and a follow-up to the findings will be provided in 2026. The general picture that emerged from the self-evaluation is positive and an encouragement to continue on the path taken. The Supervisory Board intends to focus even more explicitly on putting the strategy into practice and to monitor the progress of projects more actively. In addition, the Supervisory Board will continue bilateral consultations with individual Executive Committee members. The Supervisory Board has asked the Executive Committee to give extra attention to succession planning and fleet planning in the HR Committee and to pay attention to cultural and behavioural elements.

The Supervisory Board is also responsible for the evaluation of the functioning of the ExCo and the assessment of the ExCo members. This is done using individual performance and development targets for each ExCo member. Discussions on the individual targets took place with all Executive Committee members in 2025.

There were no situations in which there was a conflict of interest. In order to maintain a focus on this, this is determined at the start of each meeting.

8.4 Audit Committee

Composition and engagement

The Audit Committee consists of Karin Bergstein (chair), Constant Korthout, Leonard Geluk (until 1 July 2025) and Huub Arendse as of 1 July 2025. The committee supports and advises the Supervisory Board on the design and operating effectiveness of the internal risk management and control systems, the internal and external audit process, material considerations regarding financial and sustainability reporting and material risks and uncertainties of the company and its affiliated company.

Working method

In addition to the members of the Audit Committee – including the chair of the Risk Committee – the CEO, CFO and the CRO, the head of IAS, the head of Finance & Control and the external auditor participate in the meetings of the Audit Committee. The chair of the Supervisory Board was present at the discussion of the annual report and half-yearly report and on 1 July 2025 – with the resignation of Leonard Geluk – he has temporarily taken over the vacant position in the committee. The Audit Committee holds a private session with the external auditor and the head of IAD prior to some of the meetings. Prior to the regular meetings, the chair shall speak separately with the head of IAS and with the external auditor. The Audit Committee met four times in 2025 and in two joint meetings with the Risk Committee.

The Audit Committee discussed the financial statements and the 2025 Annual Report and gave the Audit Committee positive advice on the approval of the financial statements and the management statement included in the Annual Report. The committee also provided a positive consultancy on the proposal to make a dividend of 50% of the net profit for 2025 available for distribution.

Recurring topics in 2025

In preparation for the discussion by the full Supervisory Board, the Committee dealt with the following recurring topics.

• During the year under review, the committee was informed of key trends, developments and prospects in the areas of business, profitability, solvency, capital, liquidity and funding, as well as progress on non-financial KPIs (so-called DSs) through quarterly reports. In discussing the quarterly reports, the committee paid particular attention to competitiveness and standard pricing, the interest result, costs, financial transaction results and GRI reporting. With the transition to the Route to More Added Value, the committee also discussed the form and content of the accounting for each value chain. 

• Specifically, the Commercial Multi-Year Plan, Financial Multi-Year Plan and the budget were discussed in terms of content.

• The mid-year report 2025, after discussing the findings of the external auditor, the committee issued a positive recommendation to the Supervisory Board.

• The Pillar 3 Disclosure report for 2024 was discussed and submitted to Supervisory Board with positive consultancy. At the beginning of November, the Supervisory Board approved the publication on the BNG website of the interim report 2025 and its provision to the supervisory authority.

• The Audit Committee follows the work of the IAD during each meeting. The most important findings of the IAD and their follow-up are also discussed.

• The Committee frequently discussed the management of the IT General Controls (ITGCs).

• The 2026 Funding Plan was submitted to the Supervisory Board with a positive recommendation.

Key points for attention

• The Audit Committee has been informed to report on the basis of the GRI for the financial year 2025. In addition, the Committee has no objection to continuing this reporting standard for the financial year 2026 and, thus, to applying an unchanged reporting methodology for 2026. In addition, the committee discussed the report on progress on the impacts, risks and opportunities of the material themes (DMA) and the external KPIs that are directly linked to them. The Committee presented the external KPIs for the period 2026-2028 to the Supervisory Board with positive advice.

• Prior to discussing the financial statements in the full Supervisory Board, the Audit Committee also discussed its board report on the financial statements with the external auditor. The audit scope, materiality and key audit issues were of interest: loan provisions, the value of financial instruments and the ITGCs.

• The determination of the provisions for loans and debtors is a key audit matter, because BNG's loan portfolio contains not only guaranteed, but also unguaranteed loans. The calculation of the provisions is complex and also requires judgement. The Audit Committee was informed of the calculation methods used and the results and the manner in which the external auditor formed an opinion on them. Based on the discussion and taking into account an acceptable range in the uncertainties, the AC agreed with the Management Board that the provisions reported give a true and fair view of the credit risks in the loan portfolio.

• The valuation of financial instruments is a key audit matter, because market information is not available on all instruments or because the models used are complex. Regarding the first category, the Audit Committee discussed with the external auditor how it challenged and assessed the assumptions and method used. Regarding the second category, the external auditor explained to the Audit Committee the independent valuation of a number of positions that it had performed. The AC has been informed that the system used has not changed and has been assessed as adequate. The AC discussed the adjustment of the presentation of the result in relation to derivatives, with the aim of providing a better insight.

• The Committee was informed about the On Site Inspection on Market Risk and the application of the voluntary deduction in accordance with Article 3 of the CRR, in particular.

• The IT general controls are also a key audit matter. With a view to auditing the financial statements, the Committee also directs its attention to the reliability and continuity of automated data processing. In the year under review, the Audit Committee paid specific attention to projects aimed at improving IT controls, data governance and data quality.

• The Committee was informed about the On-site Inspection on Market Risk and, in particular, the application of the voluntary deduction under Article 3 of the CRR.

• After discussion with the external auditor – the Committee took note with approval of the audit plan for 2025 and the audit engagement as laid down in the engagement letter for 2025.

• The Audit Committee was periodically informed in detail about the content of the funding plan and the progress of the funding programme. The Committee also received a report on the course of the non-strategic exposures.

• The Committee paid extensive attention to the progress of ongoing strategic projects relating to Identity & Access Management and RDARR. The Committee was also informed about the implementation of CRRIII and CRD6. Furthermore, the Audit Committee was informed about the follow-up of the findings of the IAS, the external account and the supervisory authority.

• The ILAAP and ICAAP were discussed in a joint meeting with the Risk Committee, after which the Capital Adequacy Statement and the Liquidity Adequacy Statement were approved.

• The Audit Committee was informed of the progress made in the transition of the audit activities from Pwc to EY.

• The committee issued a positive opinion on the proposed appointment of the Head of IAS.

• Finally, the Audit Committee gave positive advice on the biennial update of the Audit Committee Regulations.

8.5 Risk Committee

Composition and engagement

The Risk Committee is composed of Constant Korthout (chair), Marlies van Elst, Karin Bergstein and Femke de Vries. The Risk Committee prepares the decision-making process for the Supervisory Board on the way in which the company and its affiliated company have structured its risk management and the management of all of the different risks and risk areas in mutual connection. The Risk Committee periodically discusses, among other things, the functioning of the internal risk management and control systems, the internal risk governance framework and the risk management organisation.

Working method

In addition to the members of the Risk Committee, the CRO, CEO, the head of Financial Risk Management, the head of Non-Financial Risk Management, the head of Integrated Risk Management and the head of Compliance participate in the meetings of the Risk Committee. Depending on the subject, the chair of the Supervisory Board, the COO, the CCO and the head of IAD also participate in the meeting.

At least once per year, the chair of the Risk Committee speaks additionally and separately to the head of Risk Management (Financial and/or Non-Financial), or to the head of Compliance. In addition, meetings are held between the chair of the Risk Committee and the CRO and the head of Compliance, prior to the meetings of the Risk Committee. The Risk Committee met five times in the reporting year, and also twice in a joint meeting with the Audit Committee. Prior to each meeting, the RC holds a ‘private session’ with the committee members.

Recurring topics

In preparation for the discussion by the full Supervisory Board, the Committee dealt with the following recurring topics.

• The Committee discussed the 2025 annual plans for Financial Risk Management, Integrated Risk Management and Non-Financial Risk Management. The 2025 charters for Risk Management and Compliance were also discussed.

• Every quarter, the Risk Committee discussed the Integrated Risk Report, a report on Financial, Integrated and Operational Risk and Compliance, including the opinion and advice of the CRO column. The Integrated Risk Report reports on compliance with the Risk Appetite; it also reflects the bank's risk positions and reports on the most important events from a risk perspective. Further details are provided on the development of the credit, market and liquidity-based risks, as well as the bank’s operational and strategic risks. Climate & Environmental Risks is an increasingly important issue. Compliance reports on Financial Economic Crime, Conduct (Privacy risk), Fraud and on compliance with existing laws and regulations, as well as on the preparation and implementation of new laws and regulations.

• The Committee is informed of the risks in the area of money laundering and the financing of terrorism, including the management of both types of risk.

• The Risk Committee has been informed extensively about a new approach to the Risk Appetite Statement (RAS), the system of limits, targets and information figures that forms the basis for the Risk Report. In response to this, the Committee discussed Operational Risk, Strategic Risk and Sustainability Risk. On the basis of this new set-up, the Committee prepared the annual adoption of the RAS 2026 by the Executive Committee and recommended it positively.

• The Compliance and Risk Section in the 2024 Annual Report were discussed by the Committee and submitted to the Supervisory Board for approval with positive consultancy.

• The Risk Committee discussed the outcome of the Systematic Integrity Risk Analysis (SIRA) 2024 and found that the SIRA has become embedded in the organisation. It is important that all of the action points remain well in view and are carried out as planned. In addition, the Committee discussed the SIRA at Financial & Economic Crime (FEC) and the scenarios and business rules, in particular.

• The Committee discusses developments with regard to the supervisory authority in its meetings every quarter. This concerns the annual Supervisory Review and Evaluation Process (SREP) 2025, but also the On Site Inspections and the broader dialogue with the supervisory authority. The outcomes and key points for attention and their possible follow-up will be discussed in more detail in the meetings of the Risk Committee.

Key points for attention

• The Risk Committee was informed in a comprehensive manner of BNG's cyber security threat landscape. The various threats and the relationship between the threat analysis and the Risk Control Self-Assessment were discussed.

• The committee discussed the state of play regarding privacy within BNG, including the most important gaps and the safeguarding of privacy within BNG (governance) on the basis of an action plan.

• The Risk Committee also approved the proposal to transfer the role of the Wwft policymaker from the CEO to the CCO, including the associated tasks and responsibilities. 

• The committee paid extensive attention to the progress of ongoing strategic projects in relation to, among other things, payment transactions and IT Risk.

• In general, the Risk Committee discussed the functioning and legal context of the WSW guarantee system. In particular, the committee discussed in-depth sessions on transaction monitoring, including business rules, the implementation of DORA and finally a deep dive on refinancing risk and excess returns.

• Finally, the Risk Committee gave positive advice on the biennial update of the Risk Committee Regulations.

8.6 HR Committee

Composition and engagement

The HR Committee consists of Huub Arendse (chair), Marja Elsinga, Femke de Vries and Leonard Geluk (until 1 April 2025). The HR Committee's responsibilities include the recruitment and selection of members of the Supervisory Board and statutory members of the ExCo, the periodic evaluation of the performance of the Supervisory Board and the ExCo as a whole and the assessment of the performance of individual statutory members of the Supervisory Board and the ExCo. The HR Committee also supervises the broader HR policy of BNG and the Diversity & Inclusion policy for the Supervisory Board and the Executive Committee. The HR Committee prepares the Supervisory Board's decision-making and supports the Supervisory Board in its role as employer.

Working method

In addition to the members of the HR Committee, the CEO and the head of HR participate in the meetings of the HR Committee. The HR Committee met four times in 2025.

Recurring topics

• A recurring topic in the meetings was the progress of the HR strategy, on which BNG reports quarterly in the HR Dashboard. As a result, the employee satisfaction survey (ENPS), the lead time for filling vacancies, Diversity & Inclusion KPIs and absenteeism due to illness were discussed. In the second half of the year, the committee discussed a new HR Dashboard to bring the report more into line with the tasks of the committee.

• The HR Committee discussed the outcomes of the periodic employee satisfaction survey extensively, in particular the results on results on enthusiasm, social safety, diversity & inclusion and the eNPS.

• The committee discussed the completion of the vacancies that will arise in 2026 as a result of the early retirement of Leonard Geluk and the retirement of Marlies van Elst and prepared the filling of both vacancies.

• The Continuing Education Executive Committee and Supervisory Board programme was discussed and submitted to the Supervisory Board for approval with input from the committee. The annual self-assessment of the Supervisory Board was also prepared.

• Finally, in the context of the new organisation of BNG, the committee dealt with the expansion of the ExCo with the CIO function and the related search as of Q2 2026. In line with this, we also discussed the term of office of Amir Arooni that applies to the acting COO role he holds.

Special topics

The committee discussed the (progress of) the reorganisation in the context of the Route to More Added Value and the reorganisation of a positive recommendation to the Supervisory Board. The HR Vision and Strategy BNG 2026-2028 was also discussed. In addition, the committee set up in-depth sessions for 2026 in order to be able to discuss a specific topic in greater depth. Finally, the HR Committee gave positive advice on the biennial update of the HRC and RemCie regulations.

8.7 Remuneration Committee

Composition and engagement

The Remuneration Committee is composed of Femke de Vries (Chair), Huub Arendse, Marja Elsinga and Leonard Geluk (until 1 April 2025). The Remuneration Committee is responsible for preparing the decision-making in the Supervisory Board concerning the remuneration of the Supervisory Board, the ExCo and identified staff, including decisions about remuneration that have consequences for risk management within the company. As is the case for the activities of the HR Committee, this primarily centres around the employer role of the Supervisory Board.

Working method

In addition to the members of the Remuneration Committee, the CEO and the head of HR participate in the meetings of the Remuneration Committee. The Remuneration Committee met once in 2025.

Recurring topics

• The committee discussed the implementation of the remuneration policy for the ExCo and the employees for 2024 and advised the Supervisory Board positively on its approval.

• The committee also took note of the outcome of the annual risk analysis of the controlled remuneration policy. This did not reveal any points for attention on which decision-making by Supervisory Board was necessary or desirable; the remuneration policy contributes to effective risk management and does not invite taking more risk than is acceptable.

• The committee advised the Supervisory Board positively on the Remuneration Report (published on the website). In it, the SB reports on the remuneration policy of the ExCo and the employees and on the implementation of the remuneration scheme for the SB.

Special topics

• The Remuneration Committee has been informed of the progress and status of the Future-oriented Job Centre process.

9.1 Reporting principles

Guidelines and definition of the reporting used

Legislation and reporting guidelines

Legislation and reporting guidelines BNG prepares the annual report in accordance with Section 2:391 Dutch Civil Code and the EU directives “Annual financial statements, consolidated financial statements and related reports of certain types of companies” (2013/34/EU) and is in accordance with the GRI Standards (Sustainability Reporting Guidelines of the Global Reporting Initiative). The report provides an overview of the principal developments and the performance of BNG in 2025, and shows how the bank deals with opportunities, risks and uncertainties. The Annual Report is based on the topics designated as material by the ExCo and stakeholders.

Defining the scope of the Annual Report

Non-financial information for the 2025 calendar year is included in the 2025 annual report. This is done to inform stakeholders about the public role of BNG in relation to its mission, strategy and objectives. The information in this report relates to BNG Bank N.V., including its subsidiaries. There were no (potential) acquisitions in 2025. The performance of suppliers, sources of funding, clients and other parties in the chain is not included in the figures.

Codes and guidelines observed 

BNG endorses a number of codes of conduct and international conventions and guidelines. BNG undertakes to comply with the Dutch Banking Sector Agreement on international responsible business conduct regarding human rights (2016). As of 2020, and pursuant to the latter agreement, BNG has applied the Equator Principles, a Risk Management Framework for determining, assessing and managing environmental and social risk in projects. Along with other financial institutions, BNG has committed to the Climate Agreement in 2019. BNG endorses the future-oriented banking package of the Dutch Banking Association (NVB), which brings together the Social Charter, the Dutch Banking Code and a set of rules of conduct associated with the banker’s oath. Through this, the banking sector explicitly states how strives for service-orientated and sustainable banking. BNG adheres to the recommendations under the UN Global Compact, the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises, and has implemented these recommendations in its relevant procedures. These codes and guidelines contribute to the successful conduct of due diligence investigations, in which the precautionary principle is also applied.

Under the law, BNG is not obliged to apply the Dutch Corporate Governance Code (the ‘Code’). With only public authorities as shareholders, BNG voluntarily applies the provisions of the Code as adopted in 2022 (the ‘2022 Code’), among other things by bringing its working methods into line with the Code as much as possible. This is in line with the Central Government Participation Policy Memorandum. BNG will use 2026 to assess the impact of the updated Code, as adopted in 2025 (the ‘2025 Code’) on BNG as an unlisted company in order to implement it in an appropriate manner, specifically with regard to the introduction of the amended statement on risk management as included in the 2025 Code. BNG reports on its compliance with the principles and best practices of the Code on its website.

Data collection

The quantitative and qualitative information in this annual report was collected on the basis of desk research and through interviews. Sources of data include staff records, financial reports, incident registration, and the registration of reports from internal confidential counsellors and the Compliance Officer. Information was provided by the Compliance, Finance & Control, HR, Risk Management, Security and Treasury & Capital Markets departments. In addition, interviews were conducted with employees of the departments of Business Strategy & Control, Relationship Banking and Lending. BNG follows the GRI Standards for the quality of the data included in this annual report. The non-financial data in this report relates to 2025. Where possible, data and results are also reported for previous years.

Management cycle

The ExCo is responsible for strategy, company objectives, content and implementation of policy. Senior management, which reports directly to the ExCo, is responsible for achieving the objectives in accordance with the policy frameworks and for measuring performance. The ExCo monitors policy implementation and the achievement of objectives on the basis of monthly or quarterly reports. This takes place on the basis of reports prepared by senior management, heads of department and control functions. Where necessary, adjustments are made on the basis of progress against the objectives. Performance against the objectives set is externally reported in the annual report. In turn, the ExCo and senior management evaluate policy as well as the designated objectives in preparation for the annual management cycle. The lessons drawn from the evaluation are incorporated into the subsequent management cycle and reported to the Supervisory Board. New policy and procedures are assessed in terms of coherence with existing policy and procedures, and implemented by means of work meetings and publication on the intranet. The policies, procedures and support systems of BNG and its subsidiaries are subject to internal audits.

Reporting on sustainability

An important objective of the European Commission resulting from the European Green Deal is to promote the financing of sustainable activities. To achieve this, legislation and regulations have been published, with which (financial) institutions are increasingly required to comply. The CSRD (Corporate Sustainability Reporting Directive) is European legislation that requires companies to report extensively on sustainability, including environmental, social and governance issues. In February 2025, the European Commission presented the so-called Omnibus I package. The package contains a directive that provides for substantive changes of, inter alia, the CSRD. The most important change for BNG is that the reporting obligation for 2025 and 2026 has been postponed by two years due to the stop-the-clock scheme. In addition, a political agreement was reached in the European Parliament on 16 December 2025 to limit the CSRD reporting obligation to companies with more than 1,000 employees and a net turnover of more than EUR 450 million. BNG does not meet these criteria and, therefore, falls outside the CSRD reporting obligation. A decision on whether to report voluntarily on sustainability based on the CSRD will only be made by the Executive Committee once the regulations have been finalised. 

BNG, therefore, is continuing to apply the GRI (Global Reporting Initiative) standard as the basis for the sustainability reporting in the 2025 annual report. This standard provides a structured framework that allows us to report transparently on our impact on the environment, society and governance (ESG). In order to respond even more effectively to the specific information needs of our stakeholders, we are combining the GRI guidelines with elements that are important to our organisation.

The EU Taxonomy was drawn to define sustainable activities in a uniform manner. BNG endorses the objective of the EU Taxonomy. Because of the public nature of the bank, we are playing an important role in the transition to a more sustainable society. At the same time, the EU Taxonomy does not seem to be properly applicable to BNG’s business model as a public bank. BNG’s clients are mainly government institutions or institutions affiliated to the government (including housing associations), to which balance sheet financing is provided. The vast majority of these clients do not fall within the scope of the EU Taxonomy and, therefore, fall outside the scope of the activities that can be classified as green for the purposes of determining the Green Asset Ratio (GAR). The GAR for BNG for the 2025 financial year is, therefore, expected to be very low.

To be able to report on its implementation of the EU Taxonomy on a voluntary basis, BNG relies on the willingness and capacity of borrowers to provide information voluntarily. Many clients (sectors) were only be able to do so in 2025 to a very limited extent or not at all yet. BNG is discussing with the various sectors how and to what extent this can be implemented in the future.

Principles and methods used in determining the CO₂e emissions of the loan portfolio

Methodology

The PCAF methodology was used to calculate the greenhouse gas emissions caused by our loan portfolio. This is what BNG has been doing since the annual report of 2019, in which calculations were made about the financed emissions from our lending in 2018. The methodology uses estimates and assumptions that are subject to uncertainties regarding external data.

Based on the general principles of the PCAF, BNG uses the following principles in its working method:

• where possible, the seven greenhouse gases from the Kyoto Protocol have been included in the calculation and converted to their CO₂ equivalents;

• absolute emissions are expressed in metric tonnes of CO₂ equivalents (tCO₂e);

• relative emissions are expressed in metric tonnes of CO₂ equivalent per million euros (tCO₂e/EUR million);

• to calculate the greenhouse gas footprint of BNG's loan portfolio, emission factors were used to calculate the emissions per tonne of greenhouse gas emissions. The emission factors from CO2emissiefactoren.nl were used. This list of emission factors was developed by the Dutch government, SKAO, Stimular, Connekt and Milieu Centraal.

• the attribution method is used. This means that we only report our share of the client’s emissions. This share is determined by comparing the financing provided by BNG with the balance sheet total of the client or project. This share is also called the attribution factor. The emissions of the client that are to be allocated to BNG are calculated by multiplying the attribution factor of that client (or the project) by the total emissions of that client. To calculate the attribution factor, all types of financing provided (both shares and loans) must be taken into account in the calculation. Any deviations from this must be explained;

• in principle, the scope 1, scope 2 and relevant parts of scope 3 activities of the client are involved in the emission calculation. When this approach is deviated from, the reasons for this must be explained;

• in order to monitor the development in the financed emissions, it is important that the annual emissions data reported is consistent and comparable. The methodology for the emissions calculation is still under development. Continuous improvement of data availability and/or methodological progress will allow more accurate calculations in the future. In the event of a change in the methodology whereby the emissions are no longer comparable between years, BNG will, if possible, recalculate the emissions for both the penultimate year and the basis year (2018) on the basis of the new methodology;

• ‘follow the money’ is the starting point in the CO₂e emissions of financial assets. Funding should be monitored as far along the chain as possible to mitigate the impact of CO₂e emissions on the economy. This means that BNG also tries to calculate scope 3 emissions for clients and other assets.

• The methodology used in the current provision is based on a number of reporting standards: The Greenhouse Gas Protocol, A corporate accounting and reporting standard, revised edition, The harmonised approach for the financial sector in the Netherlands and The global GHG accounting & reporting standard. The general reporting requirements and recommendations are:

• Principles: GHG calculations and reporting by financial institutions should be based on the following principles: relevance, completeness, consistency, transparency and accuracy.

• Objective: The reporting by a financial institution should be aligned with its specific business objectives; for example, to identify and manage climate-related transition risks or to achieve a specific emission reduction target.

• Frequency: Financial institutions shall disclose the report at least annually and at a fixed time in accordance with the financial accounting cycle. Financial institutions should ensure that the timing chosen gives a representative picture of the issues for that reporting year and should disclose transparently whether major changes close to (before or after) the reporting date have affected the results.

• Recalculation and significance thresholds: Financial institutions should, in accordance with the requirements of the GHG Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard, establish a basic recalculation policy to define the circumstances under which a recalculation of (reference year) financed emissions is necessary to ensure the consistency, comparability and relevance of reported greenhouse gas emissions data over time. As part of this recalculation policy for reference year emissions, financial institutions should identify and disclose the significance threshold that triggers reference year emission recalculations.

• Reporting form: Financial institutions should include issue data in publicly available reports, such as annual and semi-annual reports, website articles or other publicly available sources that are considered appropriate by the financial institution.

• Past performance: Where appropriate and relevant to their business objectives, financial institutions should disclose their financed emissions for several similar time periods, e.g. years.

As of reporting year 2024, we are reporting avoided emissions. Avoided emissions concern activities that reduce CO₂e emissions without falling directly within BNG control. The net avoided emissions reported only cover sustainable solar and wind energy projects financed by BNG. The calculation of avoided emissions is based on the total energy production of these projects multiplied by the applicable grey electricity emission factor in 2024. This concerns the gross avoided emissions. Net avoided emissions are the gross avoided emissions minus the emissions generated during the production, installation, maintenance and disassembly of the solar panels and wind turbines.

Data used

Owing to the availability of data, reported financed CO₂e emissions are based on data from the year prior to the bank's reporting year. The emission calculation for the reporting year 2025 is, therefore, based on the bank’s outstanding loans as at year-end 2024. Data for 2024 was used to calculate the emissions linked to these loans.

An emission calculation was made for 99.7 per cent of the loan portfolio. The graphic in Chapter 4 ‘COe emissions for 2024 linked to the loan portfolio’ shows per segment the percentage of the portfolio that is included in the emission calculation. BNG aims for a 100 per cent coverage of the loan portfolio in the near future. Since reporting year 2024, we have been mapping CO₂e emissions for virtually all of our loans to public infrastructure companies, joint schemes and other public institutions. Public infrastructure companies include, for example, air and sea ports, network operators and waste processing companies. Consequently, this portfolio is diverse and mainly includes non-property-related emission sources. As a result, we were unable to adopt the same approach as in the other sectors. Where possible, we used emission data from clients’ annual reports. As many clients do not yet report their emissions, we have calculated a share of the emissions using a sectoral approach. This approach has a lower PCAF data quality score than that of the other sectors. In the coming years, we will work on improving data quality for the emission measurements of these clients.

The financed emissions of BNG are calculated by the research agency Het Pon & Telos. Our clients’ emissions are derived from or calculated on the basis of public data from, among others, three network managers (Enexis, Liander and Stedin), Statistics Netherlands (CBS), the Land Registry, the Inspectorate for the Environment and Transport (ILT), CBIG, the Department for Implementation of Training (DUO), Vivet (CBS, Kadaster) and sustainability reports from the financed institutions. In most cases, the emission factors of www.CO2emissiefactoren.nl were used.

Every year, BNG, together with Het Pon & Telos, tries to improve the methodology further, for example, by changing the calculation method or using alternative data sources.

The following changes in method were made for the reporting year 2025:

Municipalities/education: The national ratios for energy use of social real estate were used for scope 1 and 2 emission calculations that were made available by Vivet (CBS, Kadaster).

Healthcare: This year, the methodology of emission calculation for the healthcare sector has been changed to improve data quality. This was done by using the publicly available data from the Environmental Barometer for as many healthcare institutions as possible. This data comes directly from the institutions themselves. Not all healthcare institutions publish sustainability data on the Environmental Barometer. Therefore, a combination of methods was used to achieve the results. The aim is to increase the use of the Environmental Barometer in the coming years.

For more detail on the data used per customer segment please refer to the PCAF BNG 2025 report on the website.

Data quality

The PCAF platform has drawn up an assessment framework per asset class for the quality of the data, based on which it is given a score. This score runs from 1 to 5, with 1 being the highest score. The PCAF BNG 2025 report describes the PCAF data quality score per component of the emissions calculation. For example, the data quality per segment can differ for the scope 1, 2 and 3 emission calculation. By means of a weighted average, these different quality scores are combined into one PCAF data quality score per segment. These can be found in the visual in Chapter 4 'CO₂e issues 2024 linked to the loan portfolio' and in the last table in this paragraph.

The weighted average data quality of the portfolio improved slightly from 2.8 in 2023 to 2.7 in 2024. The greatest positive impact on the data quality score was caused by the method change for the Healthcare sector as described above.

The table below shows the loan portfolio and the part of it has been included in the emission calculations.

The following table shows the absolute and relative financed issues of the credit portfolio and the data quality.

1. For an explanation of data quality, see the following table.

For more detailed information on the PCAF data quality score per component of the emissions calculation, please refer to paragraph 2.3 of the PCAF BNG 2025 report.

9.2 Supplementary information on material topics

Process for determining material impacts, risks and opportunities

The double materiality analysis was carried out using a four-step process:

1. Identifying the value chain and key stakeholder relationships in the value chain.

2. Stakeholder interviews and desk research to draw up a long list of ESG topics.

3. Carrying out the double materiality analysis.

4. Governance and approval by the Executive Committee (ExCo) and Supervisory Board.

Step 1 Our value chain

In the double materiality analysis, we identify impacts, risks and opportunities related to our value chain, both the upstream and downstream. As a financial institution, our loan portfolio is the most important segment with an impact on sustainability issues, because we contribute to the economy and social development through financing. The analysis focuses primarily on direct contractual relationships, such as business and public customers.

Our value chain includes suppliers, investors, employees, regulators, ESG rating agencies, shareholders, customers and society. We distinguish between:

• Upstream: Supply chain: parties that enable our activities, such as suppliers, investors and regulators.

• Own business operations: our employees and internal processes.

• Downstream: parties that benefit from our services, such as customers, shareholders and society.

Value chain

Step 2 Stakeholder interviews and desk research for drawing up a long list of ESG topics

Feedback was collected through surveys, interviews and workshops and analysed for consistency, relevance and substantiation.

Step 3 Performing the double materiality analysis

Impacts, risks and opportunities were identified and scored for each topic. Impacts were assessed in terms of magnitude, scope, reversibility and probability. Financial materiality was assessed in terms of the magnitude and probability of risks and opportunities, including dependencies on natural, human and social resources. Risks were analysed within existing risk categories, including transition and physical climate risks. Opportunities were defined as developments that could strengthen the business model or strategic objectives.

Step 4 Governance and approval

The methodology and results of the double materiality analysis have been approved by relevant governance bodies, including the Sustainability Task Force, the Sustainable Banking Committee, with approval by the ExCo and the Supervisory Board.

According to the GRI, the previously identified material themes served as important input in determining the material themes within our double materiality analysis (DMA). While the GRI themes provide a broad overview of strategic and societal priorities, the DMA makes these topics concrete and measurable in line with the ESRS requirements.

This means that subjects such as market leadership in the public domain, sustainability, data security, organisational efficiency and social involvement have been translated into specific DMA themes that reflect the social impact, risks and opportunities of BNG in the short, medium and long term. For example, broad GRI priorities have been fleshed out in themes such as affordable and available funding, climate change, sufficient and affordable housing and in-house staff.

In this way, the DMA ensures that our material sustainability topics are directly aligned with our core activities and social role, while being in line with the requirements of the CSRD/ESRS.

DMA scoring method

BNG uses external data sources, internal information, voluntary reports and statutory disclosures to assess the impacts, risks and opportunities of its activities and value chain.

Impact materiality

For impact materiality, we assess both the positive and negative impacts, which can actually or potentially occur. In doing so, we look at:

• Scale: how large or serious the impact is;

• Scope: how many people, sectors or areas are affected;

• Recoverability: the extent to which negative impacts can be repaired.

In addition, we assess the probability of an impact occurring in the short, medium and long term.

Financial materiality

Financial materiality is determined on the basis of the possible financial consequences for BNG. We look at the magnitude and probability of these effects, for example through dependencies of natural, social and human resources, business relationships, and reputation. Data indicators are supplemented by the opinion of sector and risk specialists.

Risks and opportunities

In the case of risks, we combine negative impacts, dependencies and external context factors to determine whether these are material for our portfolio. Where possible, we use internal data and scenario analyses. For opportunities, we look at potential financial and non-financial benefits, such as new funding opportunities, cost savings or reputational benefits. In doing so, we also assess the extent to which BNG itself invests in order to take advantage of these opportunities.

Scoring and thresholds

The analyses lead to a combined score on a scale of 1 (very low) to 5 (very high). A sustainability issue is considered material if, based on this scoring, it is assessed as ‘significant’ or ‘critical’ according to the conversion matrix applied.

Material topics

The table below shows the progress of the material topics from 2024 to 2025.

Policy and actions

The table below shows the policy and actions relating to the material subjects.

Definitions color score KPIs 2025

9.3 Glossary

Asset & Liability Committee (ALCO): The Asset & Liability Committee manages and monitors the bank's liquidity, market, refinancing and solvency risks.

Bond: Negotiable evidence of participation in a loan, with a fixed nominal value on which interest, usually fixed, is paid. The loan is repaid at the end of the term.

CEO: Chief Executive Officer, chair of the ExCo and the statutory board.

CCO: Chief Commercial Officer, member of the ExCo.

CFO: Chief Financial Officer, member of the ExCo and the statutory board.

Compliance: Complying with laws and regulations and working according to the standards and rules that an institution has drawn up itself.

Compliance Risk: The risk of insufficient compliance with or recognition of companyvalues, codes of conduct, generally accepted social norms and values, laws and regulations, and supervisory requirements. Compliance risk includes integrity risk and regulatory compliance risk.

Compliance Management Framework (CMF): Policies, working conditions, roles and responsibilities to ensure that BNG properly complies with applicable laws and regulations, thereby reducing and manageable the risk of financial or reputational loss due to insufficient compliance with laws and regulations.

COO: Chief Operating Officer, member of the ExCo.

Corporate governance: Corporate governance is the system of principles and best-practice provisions regulating relations between the Executive Committee, the Supervisory Board and the Annual General Meeting. The Dutch corporate governance model is characterised by the two-tier board structure, which provides for a Supervisory Board with supervisory duties and a managing body with executive management duties.

Credit Committee STMP: The Credit Committee for statutory market partners is tasked with taking individual credit decisions within the Credit Committee's mandate.

Credit Committee Treasury: The Credit Committee Treasury is mandated to set and manage the credit policy of financial counterparties and to approve individual agreements with financial counterparties.

Credit Policy Committee STMP: The Credit Policy Committee for statutory market partners is mandated to establish and manage the credit risk policy for statutory market partners and to monitor the implementation of this policy.

CRO: Chief Risk Officer, member of the ExCo and the statutory board.

Customer Due Diligence Policy (CDD): A policy to ensure that banks know and monitor their clients well in order to prevent and combat financial and economic crime. This policy enables banks to fulfil their important gatekeeper function, the aim of which is to prevent funds obtained through financial and economic crime from gaining access to the financial banking system.

ESG (Environmental, Social, Governance): A set of environmental, social and governance criteria used, among other things, to assess sustainability and social impact in terms of risks and opportunities, to shape a sustainability strategy and to guide lending and investment decisions.

ESG bond: Bonds issued by BNG under its Sustainable Finance Framework. These comprise two types of ESG bonds: social bonds and sustainability bonds. BNG uses social bonds to finance housing associations and sustainability bonds to finance local authorities. The expenditure of local authorities and housing associations is linked to the UN SDGs and the ICMA categories for the use of proceeds.

ESG rating (internal): This is the rating that BNG gives to clients as part of the identification, assessment and management of ESG risks.

Executive Committee (ExCo): BNG’s management body in its executive function.

Full-time equivalent (FTE): A unit to measure the scope of an employment contract or the workforce. Within BNG, one FTE represents one employee with a full-time working week of 36 hours.

Funding: Raising short-term and long-term capital in various currencies in international money and capital markets.

Global Reporting Initiative (GRI): Sustainability guidelines for reporting on economic, social and environmental performance.

Integral Portfolio Committee (IPC): The Integral Portfolio Committee's task is to maintain an overview, insight into and to monitor the manageability of BNG's total change portfolio.

Integrated Reporting: Reporting framework originating from the International Integrated Reporting Council (IIRC) resulting in an integrated report covering value creation: the external environment influencing the organisation, the incoming and outgoing resources and the way that the organisation interacts with the external environment. The value creation model is used to record the results.

Leverage ratio: The ratio between a bank's Tier 1 capital and the adjusted balance sheet total.

Liquidity risk: The risk of losses to earnings and capital due to the possibility, at any given time, that the bank will not be able to fulfil its payment obligations without incurring unacceptable costs or losses. Liquidity risk comprises of short-term liquidity risk and long-term liquidity risk (or refinancing risk).

Loans subject to solvency: Loans for which regulations require a certain amount of equity to be held as a buffer against the risk of non-repayment.

Long-term lending: The provision of loans with a term of more than one year.

Market leader in the public domain: BNG wants to be market leader in the public domain by financing governments and public/social organisations. The scoring percentage for new long-term loans is higher than 60% in 2025. This is calculated as the volume of actually concluded long-term loans divided by the volume of loans that clients requested a quotation for.

Market risk: The risk of losses to earnings and capital due to the fluctuation of market prices. Market risk includes the interest rate risk, exchange risk and fluctuations in credit spreads and liquidity spreads.

Material topics: Topics identified using the 'materiality analysis' which are sufficiently important to be reported on in the Annual Report.

Materiality analysis: Process in which it is determined with input from stakeholders which topics, known as 'material topics', are sufficiently important to be reported on in the Annual Report.

Net promoter score (NPS): In order to calculate the NPS, BNG asks how likely it is that a client recommends the bank to a colleague or relation. Clients can answer with a score on a 0-10 scale, with the following distribution: promoters (9 or 10); passives (7 or 8); detractors (0-6). NPS is calculated as the percentage promoters minus the percentage detractors.

Non-Financial Risk Committee: The Non-Financial Risk Committee (NFRC) supports the ExCo on issues that fall under operational, compliance and security risks, including the impact that ESG factors may have on this risk.

Operational risk: The risk of losses of earnings or capital due to shortcomings of internal processes, people and systems, or as a result of external events. Operational risk comprises process risk, people risk, model risk, IT risk, data management risk, outsourcing risk, legal risk, business continuity risk and external event risk.

Promotional loan: A loan granted directly or via an intermediary credit institution, by a credit institution under public law or an entity established by the central, regional or local government of a member state, on a non-competitive, not-for-profit basis, in order to promote the policy objectives of the central, regional or local government of a member state of the European Union.

Rating: Rating of the creditworthiness of banks, the ability of banks to meet their obligations. The assessment is carried out by independent credit rating agencies, such as the recognised credit rating agencies Moody's, Fitch and Standard & Poor's.

Return on equity (ROE): Calculated by dividing the net profit minus the distributed dividend on additional Tier 1 capital divided by the aggregate of the equity minus the additional Tier 1 capital and the unrealised reserves at the start of the financial year. The unrealised reserves are the revaluation reserve, the cash-flow hedge reserve, the own credit adjustment and the cost of hedging reserve.

Risk Appetite Framework (RAF): Includes policy, processes, controls and systems used to determine, communicate and monitor the bank’s risk appetite, including the Risk Appetite Statement, risk limits and an overview of the roles and responsibilities of those who supervise the implementation and monitoring of the framework.

Risk Appetite Statement (RAS): Description of the risks that the bank wishes to accept in order to achieve its objectives.

Risk Management Framework (RMF): Consists of overarching policy on general and specific risk-related topics: risk governance, risk appetite framework and specific risks, and is tailored to the specific company profile. The framework forms part of the Internal Governance Framework.

Scope 1: Direct CO₂ emissions caused by fuels that the institution itself purchases and consumes. This concerns emissions from the institution's own buildings and transport and production-related activities.

Scope 2: Indirect CO₂ emissions in the business operations of the institution. This concerns the consumption of electricity and heat, physically generated elsewhere.

Scope 3: Other indirect CO₂e emissions for which the institution does not itself handle procurement, as well as direct emissions beyond the institution's direct control. This includes, among other things, the commuting by employees of the institution without lease cars and the consumption by external parties from which the institution procures services (such as air travel).

Scoring percentage: The volume of actually concluded long-term loans divided by the volume of loans that clients requested a quotation for.

Social impact: BNG’s impact on social issues, translated into SDGs.

Solvency-free loans: Loans for which no equity is required because they are considered to be (virtually) free of credit risk. Loans to or under guarantee from the Dutch government are considered to be (nearly) free of credit risk.

Stakeholders: Groups or individuals who can reasonably be expected to be significantly affected by the institution's activities, products or services and/or whose actions affect the ability of the institution to implement its strategies or achieve its objectives.

Strategic risk: The risk that an organisation’s strategic decisions result in losses of earnings and capital due to changes beyond its control with regard to political climate, regulatory developments, reputation, business climate and ESG.

Supervisory Board (SB): BNG’s management body in its supervisory function.

Sustainable Banking Committee (SBC): The SBC's mission is to ensure that BNG has, implements and reports on an integrated sustainability policy.

Sustainable Development Goals (SDGs): 17 sustainability goals aimed at ensuring peace and prosperity for people and the planet, now and in the future. These goals are endorsed by all member states of the United Nations in 2015.

Sustainable Finance Framework: Framework in line with which various types of sustainable financial instruments can be issued, such as bonds, loans, commercial papers and deposits.

Sustainable financing (in general): Financing in the form of balance sheet or project financing for the purpose of achieving public sector social policy objectives that are in line with the United Nations Sustainable Development Goals (SDGs), such as the realisation of affordable housing, investments in climate-proof living environments and the energy transition, and making social real estate more sustainable. BNG also provides specific sustainable financing products, such as green loans to housing associations aimed at making social and mid-range rental housing more sustainable, and sustainability-linked loans.

Three Lines of Responsibility model: Risk management framework that spreads responsibility for operational risk management across three roles. Line management in the first line is the owner of and directly manages risks. The second line supervises the first line, determines policy, defines risk tolerance limits and ensures that these are observed. The third line, consisting of internal audit, provides independent assurance of the first two lines.

Time to hire: The lead time for recruiting internal staff for a permanent position.

Value creation and the value creation model: Value creation models in integrated reporting provide stakeholders with an understanding how the business model of a company create value on the short-, medium- and long term.

10.1 Consolidated financial statements

Consolidated balance sheet

Consolidated income statement

The references refer to the notes to the consolidated financial statements. The notes to the consolidated financial statements are an integral part of the consolidated financial statements.

Consolidated statement of comprehensive income

Consolidated cash flow statement

Consolidated statement of changes in equity

BNG has not recognised any results from minority interests in the consolidated equity which is attributable to third parties. With the exception of Additional Tier 1 capital, the entire equity is attributable to the shareholders.

Notes to the consolidated financial statements