Our strategy

During 2025, we concluded the execution of our strategy 2021-2025: 'Better for each other – from promise to impact'. This strategy had two main pillars aimed at strengthening our distinctive capabilities: to be the bank with the strongest customer relationship and to have a substantial and measurable positive impact on society. While significant progress was made against the core ambitions of the 2021-2025 strategy, economic circumstances and customer needs continued to evolve. This prompted the development of a new strategy with a strong focus on simplification and growth.

On 13 November 2025, we announced our new strategy 'Simplify and Grow', building on our successful first year of transformation. We aim to achieve growth through our core activities: mortgages, savings, and payments, and enhance the effectiveness and efficiency of business operations, internal processes, and systems.

Building on the strong ASN Bank brand and our distinctive social profile, the new strategy sets out three priorities: 

We aim to grow in mortgages, savings, and payments through simple products that meet customer needs, positioning ourselves as a sympathetic challenger. Franchise partners and intermediary channels remain crucial for mortgage distribution, while we work to make savings more attractive.

Improving the customer experience is central to achieving this growth. Customers expect fast, accurate service; digital where possible, personal where it matters. ASN Bank aims to broaden its customer base also in the Randstad, where we are opening flagship stores in Utrecht, Rotterdam, and Amsterdam.

ASN Bank remains committed to contributing to a sustainable and fair future for everyone. Our priority is increasing our impact on society. As an accessible bank we remain committed to provide solutions for challenges in the Dutch society such as sustainability, housing accessibility and financial wellbeing.

Simpler, faster, smarter remains our guiding principle. Simplification is essential for becoming a healthy, cost-efficient bank with an eye for people and society. Having completed the first transformation phase focused on the "front end" in 2025, we now shift attention to "back end" improvements in 2026 and 2027.

We will move to a clear, improved and appropriate product range. More standardisation means less complexity and therefore lower costs. Our technology requires modernisation; we will replace outdated systems and standardise where possible, while investing in reliable data, future-proof IT platforms, and pragmatic AI applications. Customers will experience these improvements through enhanced, faster services including a unified app, simplified processes, and shorter turnaround times.

We will also continue strengthening our anti-financial crime processes and risk management. While we have made significant progress in remediation and addressing past backlogs, compliance costs remain elevated due to temporary external staffing requirements.

The strategy is primarily focused on simplification and growth, with ambitious commercial and financial targets. The proposed streamlining is expected to result in total annual structural cost savings as of 2027 of approximately € 150 million, of which € 70 million are to be realised as of 2026 and an additional € 80 million as of 2027. These savings are expected to be partly offset by higher temporary costs related to the implementation of the transformation programme, wage inflation and additional remediation costs to combat financial crime and deficiencies in risk management.

Under the new strategy, the financial ambitions are:

• Cost-income ratio of 50%-55%

• Return on Equity of 8%-10%

• Common Equity Tier 1 capital ratio of at least 17%, and

• Leverage ratio of at least 4.5%

In addition to financial ambitions, ASN Bank also has non-financial targets¹: 

• At least 1.5 million primary customers

• Leading Net Promotor Score

• Reducing CO2 emissions to net zero by 2050, and

• Employee engagement score of at least 8

For a more detailed explanation of these KPIs, see the Section Our strategic objectives.

1. For the measurement methodology of this KPI, refer to the Section Definitions of strategic KPIs in this report.

Transformation programme (In scope of CSRD)

In the second half of 2024, we launched a transformation programme designed to simplify our organisation by consolidating to a single retail brand, optimising our distribution model, and streamlining operations. This transformation programme aims to enhance efficiency and adaptability in response to regulatory requirements, technological developments, economic shifts, and evolving customer needs. The programme is progressing according to plan.

Our transformation achieved significant progress across three key pillars:

1. Single retail brand: ASN Bank: We launched the new ASN Bank by merging our four retail brands and changing the entity name from ‘de Volksbank N.V.’ to ‘ASN Bank N.V.' We successfully migrated 2.3 million ASN Bank and SNS customers on 1 July 2025, bringing our total customer base including former RegioBank and BLG Wonen customers to 3.03 million. RegioBank customers and franchisees successfully transitioned on 1 December 2025, with BLG Wonen partnerships in the intermediary channel scheduled for 2026.
   

2. Optimised distribution model: We implemented our strategy combining mobile-first banking with a nationwide branch network. We have transferred our own SNS branches to the franchise partners. We rebranded former SNS shops to the new ASN Bank style on 1 July, and former RegioBank branches successfully transitioned to ASN Bank on 1 December, resulting in a total of 325 branches across the Netherlands now displaying the ASN logo on their facades. We launched a flagship store in Utrecht on 8 December, Rotterdam and Amsterdam locations are planned for 2026.
   

3. Simplified organisational model: Since 1 July 2025, we operate under a streamlined structure designed to increase clarity, responsiveness, and cost-efficiency while maintaining focus on operational excellence and customer service. In line with our announcements, over 700 FTEs left the organisation. An additional ambition with a second round of job cuts, affecting 850-950 FTEs in 2026, was announced in November 2025. Through our Social Plan, we support these colleagues by developing their employability and assisting them in finding new positions.

The simultaneous execution of our transformation and remediation programmes affects our FTE and cost development. With the transformation, we aim to reduce the structural cost base, while at the same time temporary FTEs and costs are required to cover remediation work, focusing on anti-financial crime and risk management-related topics. To provide insights in both developments, the table below shows a breakdown of FTEs and operating expenses into a structural and a temporary component.

At the end of 2024, we announced a reduction in the number of FTEs by 700-750 based on the reference point for the number of jobs of 4,500 as at 30 June 2024. At year-end 2025, the reported number of FTEs of 4,192 still included 327 FTEs who left the bank on 1 January 2026. As per this date, the total number of FTEs amounted to 3,865, of which 3,484 structural FTEs, confirming that our year-end 2024 announced ambition has been fully realised.

Total FTEs also included 381 temporary FTEs covering remediation work, focusing on anti-financial crime-related topics. These temporary FTEs, comprising of internal and external FTEs, are expected to support ASN Bank until year-end 2027 and are largely provisioned for in our AFC remediation programme.

On 13 November 2025, we announced an additional planned reduction of 850-950 FTEs, partly by cutting external staff and not filling vacancies. This reduction is driven by the further streamlining of the organisation and is expected to occur in phases throughout 2026.

Total operating expenses in 2025, excluding incidental items and levies of € 809 million, consisted of € 741 million structural costs and € 68 million temporary costs. Temporary costs relate mainly to remediation work for anti-financial crime and risk management and our transformation programme.

Structural costs in 2025 were positively influenced by realised transformation-related cost savings of around € 35 million. This equates to € 70 million on an annualised basis, which will be fully reflected in 2026 financial figures. Realised cost savings in 2025 were offset by the impact from wage inflation and higher IT costs.

The achieved structural cost reduction in 2025 is visible in the structural cost base in the second half of 2025, which decreased by € 31 million compared to the first half of 2025 to € 355 million.

The anticipated additional FTE reduction by 850-950 FTEs will result in additional annual cost savings as of 2027. This will only be partly visible in 2026 figures due to a phased execution of the reduction. The future structural cost base will be impacted by ongoing wage inflation, which will partly offset structural cost savings.

Overall, the proposed streamlining is expected to result in total annual structural cost savings as of 2027 of approximately € 150 million, of which € 70 million are to be realised as of 2026 and an additional € 80 million as of 2027.

Our strategic objectives

Our strategic objectives are presented and discussed in more detail below.

In 2025, the customer-weighted average NPS¹ decreased to -7 (year-end 2024: +4). Key drivers for the decline were a greater than expected impact from the transformation and rebranding, the reduction of branches and mandatory customer re-identification procedures. In our new strategy, we are targeting the highest NPS position among the major systemic Dutch banks. At year-end 2025, we ended in joint second position, driven by the transformation impact.

In 2025, the number of active multi-customers¹ rose by 46 thousand to 1.28 million (year-end 2024: 1.23 million), mainly as a result of new current account and savings account customers.

In our new strategy, we replaced our customer KPI ‘Active multi-customers’ with KPI¹ ‘Primary customers’, targeting at least 1.5 million. At year-end 2025, the number of primary customers was 1.40 million (year-end 2024: 1.37 million).

The total number of customers was virtually stable at 3.03 million (year-end 2024: 3.10 million). With the transition from four brands to one retail brand, ASN Bank, we adjusted our customer base by applying the single customer calculation, which resulted in a one-time reduction of approximately 150,000 customers. This does not represent a loss of actual customers, but rather the de-duplication of multi-brand customers.

As of 31 December 2025, we formally concluded our KPI climate-neutral balance sheet¹, with 100% well above the 75% target. The climate-neutral balance sheet included 959 kilotonnes (kt) of CO₂e emissions (year-end 2024: 991 kt) and 963 kt of avoided emissions (year-end 2024: 1,000 kt).

The climate-neutral balance sheet KPI is succeeded by the net zero¹ by 2050 KPI. Net zero is a widely used concept, with a more uniform way of measuring emissions and setting targets. Because of this, the emissions deviate from the climate-neutral balance sheet. The net zero KPI includes all relevant operational and financing activities of ASN Bank. This is the first year we can report progress on this KPI. The net zero KPI included 798 ktCO₂e emissions at year-end 2025, compared to 839 ktCO₂e emissions at year-end 2024.

We replaced our People KPI ‘Genuine attention’ with ‘Employee engagement’¹. This KPI is measured on an annual basis via our Employee Listening Survey. In previous years, employee engagement was already measured with a set of four questions, resulting in a score of 1-10. Going forward, employee engagement will be measured using a new set of questions, resulting in a 1-10 score, with a target of at least 8. For comparison purposes, employee engagement in 2025 was measured using both the previous and new question sets, both resulting in a score of 7.6, compared to 7.3 in 2024 using the previous set.

In 2025, our cost/income ratio (C/I ratio) moved to 71.7%, compared to 87.2% in 2024. Adjusted for incidental items, the C/I ratio stood at 66.0% (2024: 58.5%), higher than our 2025 target of 57-59% as operating expenses in 2025 included substantial temporary costs, mainly related to our transformation programme and the remediation of anti-financial crime (AFC) and risk management related topics. We have set our new C/I ratio target on 50-55%.

In 2025, we achieved a 6.3% Return on Equity (RoE), compared to 3.2% in 2024. The RoE adjusted for incidental items². amounted to 7.6% compared to 10.5% in 2024. This decrease was mainly driven by a decrease in total income, reflecting the changed external interest rate environment. Going forward, we expect to achieve our RoE target of 8-10%, supported by our transformation programme.

At year-end 2025, ASN Bank's CET1 capital ratio (CRR 3) decreased slightly to 19.8% (year-end 2024: 20.4% CRR 3). The leverage ratio was stable at 5.1% (year-end 2024: 5.1%). Both ratios remained well above our planning targets of at least 17.0% and 4.5%, and well above regulatory minimum requirements. For more information on the capital and leverage ratios, refer to the Section Capital management.

ASN Bank has set a target range of 40%-60% of net profit for regular dividend distribution. For the financial year 2025 we propose a dividend amount of € 124 million, which corresponds to a pay-out ratio of 50% of the net profit attributable to the shareholder. For the 2024 financial year, ASN Bank decided in its General Meeting of Shareholders (GSM) in April 2025 to retain the net profit.

1. For the measurement methodology of this KPI, refer to the Section Definitions of strategic KPIs in this report.
2. For the definition and the explanation of incidental items and adjusted net result, see the Section Reconciliation of alternative performance measures in this report.

Operating expenses

Total operating expenses decreased by € 266 million to € 874 million (-23%) as a result of a € 306 million lower negative impact from incidental items. In 2025, operating expenses were negatively impacted by incidental items totalling € 69 million, consisting of an addition to the restructuring provision related to the transformation programme. Operating expenses in 2024 included € 375 million incidental items, consisting of restructuring charges related to the transformation programme and provisions related to the AFC remediation programme, the settlement of legal proceedings and two administrative fines.

Total operating expenses, excluding incidental items, increased by € 40 million to € 805 million (+4%), despite a € 15 million decrease in regulatory levies. Regulatory levies reflected a reversal of € 4 million in 2025 compared to a charge of € 11 million in 2024. Levies in the reporting period consisted of a € 9 million refund of a prior year’s contribution to the Single Resolution Fund (SRF). This was partly offset by a € 5 million contribution to the Deposit Guarantee Scheme. Levies in 2024 were entirely linked to the ex-ante DGS contribution.

Total operating expenses, excluding incidental items and regulatory levies, went up by € 55 million to € 809 million (+7%) due to € 73 million higher other operating expenses, partly compensated by € 15 million lower staff costs and € 3 million lower depreciations.

Staff costs decreased by € 15 million as reductions in structural FTEs resulting from the transformation outweighed the impact of wage inflation and an increase in temporary FTEs covering remediation work on anti-financial crime and risk management-related topics. The total reported number of FTEs dropped by 165 to 4,192 compared to year-end 2024, with structural FTEs declining while temporary FTEs increased. Total reported FTEs at year-end 2025 included 343 FTEs which were provisioned for and left the bank on 1 January 2026 effectively. As per this date, total number of FTEs amounted to 3,849.

Other operating expenses, excluding regulatory levies, increased by € 73 million. Of this amount € 16 million was linked to a non-recurring gain in 2024 for an adjustment in recoverable VAT in previous years. In addition, consultancy costs increased, mainly related to our transformation programme and addressing deficiencies in risk management, while IT and marketing costs also increased.

The adjusted cost/assets ratio increased to 108 bps, compared to 105 bps in 2024. This increase was wholly attributable to higher operating expenses, while average assets were higher as a result of loan growth.

Impairment charges (releases) on financial assets

Total impairments on financial assets were a release of € 32 million, compared to a release of € 51 million in 2024. For a more detailed description of loan loss provisioning, refer to the Section Credit risk.

For residential mortgages, the bank recorded an impairment release of € 38 million, compared to a release of € 48 million in 2024. The release in 2025 was mainly attributable to lower modelled provisions due to the implementation of an enhanced IFRS 9 Expected Credit Loss (ECL) model and a € 7 million decrease in the management overlay. The new model shows lower expected credit losses (ECL) compared to the previous model, primarily because of lower loss given default (LGD) rates driven by positive house price developments, methodological improvements in modelling and the incorporation of more recent and enhanced data.

The release in 2024 was mainly related to a decrease in the modelled provision, driven by an improved macroeconomic outlook and higher house prices at the time, which also led to a shift of mortgages to lower Loan-to-Value (LtV) buckets.

Incurred credit losses (write-offs) on residential mortgages were negligible (zero bps) in both reported periods, reflecting the strong underlying credit quality of our portfolio.

Impairment charges on consumer loans amounted to a small charge of € 1 million (2024: nil), reflecting the small size of the portfolio and a virtually unchanged credit quality.

Impairment charges on SME loans consisted of a release of € 3 million compared to a release of € 7 million in 2024. The reversal in 2025 was driven by a decrease in the number of defaults within stage 3 and arrears within stage 2. The release in 2024 was partly driven by the full release of the management overlay for SME customers who might be affected by high inflation. The credit quality of the SME loan portfolio remained sound and incurred credit losses were very limited.

Impairment charges on other corporate and government loans consisted of a charge of € 10 million compared to a charge of € 5 million in 2024, in both periods consisting of impairments on certain individual corporate loans as a result of increased credit risk.

Slightly decreased credit spreads resulted in a release of € 1 million on loans to banks in both reporting periods. Impairments on investments were also a release of € 1 million in 2025 (2024: nil).

Taxation

ASN Bank recognised € 109 million in corporate income tax, corresponding to an effective tax rate of 28.9% (2024: 34.2%), above the statutory rate of 25.8%. This was the result of the interest deduction limitation on borrowed capital (thin capitalisation rule), partly offset by the tax impact from interest expenses related to Additional Tier 1 capital securities that are recognised directly in shareholders' equity.

In 2024 the higher effective tax rate was also the result of two administrative fines that were not tax deductible.

Risk management framework

ASN Bank applies the COSO¹ Enterprise Risk Management (ERM) Framework. The Risk Management Framework (RMF) enables ASN Bank to properly apply all COSO ERM elements, and serves as a generic tool for both the first line and second line. The RMF ensures consistent terminology and provides a compatible methodology for the identification, assessment, measurement, monitoring, management and reporting of key risks.

In 2025, ASN Bank undertook several important steps to further strengthening its RMF, updating the bank's policy management approach (House of Policies), enhancing the risk management cycle (RMC) and refining its issue management processes.

The risk management cycle is designed to support evaluation of the effectiveness of the design and operation of the internal risk management and control system.

The RMC, as the central part of the RMF, provides a methodology for a sound internal risk management and control system, describing the necessary instruments, and using consistent terminology. It is designed to support the evaluation of the design and effectiveness of the internal risk management and control system.  

The ExBo has assessed the effectiveness of the internal risk management and internal control system in relation to operational, compliance and reporting risks during the past financial year. The basis for this assessment is the overall risk mitigation for strategic risks, financial risks and non-financial risks. With respect to internal control over for financial reporting, the bank relies on the outcome of the evaluation of high rated issues, operational incidents, and identified deviations from the proper functioning of the internal control system. These evaluations have resulted in defined areas of attention for 2025 including mitigating measures.  

The bank used different approaches for risk mitigation during 2025:

• For the mitigation of strategic risks, a Strategic Risk Assessment was performed to identify strategic and emerging risks and to define actions to mitigate these risks at both strategic and operational organisation levels. The top risks were assessed and aligned with the risk taxonomy and aligned with the risk appetite to the potential impact of any such top risks.

• For the mitigation of financial risks, the bank used additional processes and instruments to mitigate, such as the Financial Risk Assessment and regular monitoring and comparison with RAS limits. Consistent with their mandates, responsible risk committees (Credit Committee, ALCO and ExBo) can decide on measures to steer the risk position towards risk appetite when necessary.

• For the mitigation of non-financial risks, significant effort was put into the improvement of several key processes and instruments, such as the issue management process, the financial and IT key control frameworks, the risk assessment approach and the control testing standard. We will continue with the improvements in 2026.

1. The Committee of Sponsoring Organizations of the Treadway Commission, www.coso.org

Risk governance

The bank’s risk governance is based on the three lines model. In this model, the first line, i.e. the business, is responsible for setting up and executing its own processes and for the identification and assessment of the risks involved. The business units measure the risks against the defined risk appetite and report on relevant risks. The second line, consisting of the risk management and the compliance function, supports the first line, sets the frameworks, gives advice and monitors if the business units take their responsibility. More specifically, the compliance function monitors how ASN Bank complies with laws and regulations and internal policies on integrity. The third line, the audit function, independently assesses the effectiveness of the first and second line.

The ExBo is ultimately responsible for risk management within the organisation. Various risk committees support the ExBo in fulfilling this task.

The Supervisory Board is charged with the supervision of the ExBo and in that role is advised by the Audit Committee, the Risk & Compliance Committee, the Selection, Nomination & Remuneration Committee and the ESG Committee, for more information on risk committees, see Section Leadership and governance in the Annual Report 2025.

The bank’s risk management function is an integral, but independent, part of the organisation. On the one hand, the risk management function informs, challenges, takes positions and gives solicited and unsolicited advice, and on the other hand it is essential that they listen to and liaise with stakeholders. They take into consideration all stakeholders and try to find solutions that do justice to the various stakeholder interests and contribute to the realisation of the strategy.

The compliance function oversees ethical employee conduct within the organisation. The Ethics Committee enables such oversight.

The compliance function develops and executes an integrity awareness plan for all employees on an annual basis. This plan includes ongoing training and communication initiatives such as workshops, e-learning courses, intranet publications and dilemma-management.

The bank has five risk committees and three business committees. Each risk committee is chaired by an ExBo member and is responsible for the monitoring and steering of exposures in one or more risk type of the risk taxonomy. Business committees address questions that involve aspects of various risk types and are chaired by an ExBo member. The third line has a standing invitation for all risk and business committee meetings but has no voting rights. Both types of committees are made up of officers who represent the business and manage the risks, and officers from the risk management function and/or compliance function, who monitor risks and the risk-related response.

Decision-making related to, or with impact on, risk management follows the lines of risk governance and is assessed against risk guidelines. If risk limits are exceeded, or if the risk appetite is not otherwise observed, risk committees will discuss the issue and take subsequent remedial actions. A risk committee may escalate and present a point of discussion to the ExBo. The risk management function regularly facilitates a complete self-assessment for all risk committees and business committees, defining areas for improvement where necessary.

Risk Taxonomy

ASN Bank has a process in place to identify risks that are material. The risks are included in a comprehensive internal risk inventory. All risks that may have a material impact on our strategic objectives and viability are included in the bank’s risk taxonomy, clustered into three categories:

• Strategic risks,

• Financial risks and

• Non-financial risks.

ASN Bank carries out regulated and supervised activities that may be impacted by developments. These developments and related risks may prevent us from achieving our strategic objectives. For more details on our strategic objectives, see the Section Our strategy in the Annual Report 2025.

ASN Bank annually carries out a Strategic Risk Assessment (SRA), which identifies and assesses the most important risks in relation to its strategy. Refer to the Section Strategic risks for an overview.

We assess the material risks and will adjust the risk taxonomy when necessary. If so, we will take measures to align our strategy and risk appetite to the potential impact of any such top risks.

Risk Appetite Framework

The Risk Appetite Framework (RAF) is an integral part of ASN Bank's Risk Management Framework and the structured approach the bank uses to define, communicate and manage the amount of risk it is willing to take in pursuit of its strategic objectives. It defines Risk Appetite governance and presents the approach and methodology by which the risk appetite is identified, measured, determined, allocated, supervised, communicated and reported. The Risk Appetite Framework outlines the bank’s appetite for all key risks.

The Supervisory Board, supported by its relevant committees, is responsible for setting and overseeing the bank’s risk appetite, ensuring an effective internal control environment is operated by the ExBo.

Key elements of the ASN Bank's Risk Appetite Framework are:

• Risk Appetite Statement: expresses the amount and type of risk which the organisation is generally willing to accept in order to meet its strategic and financial objectives. It reflects the bank’s mission, vision and values.

• Risk Limit Framework: is imposed to express the banks risk appetite and to facilitate prudent allocation of such risk appetite to individual risk takers or group of risk takers. The Risk Limit Framework consists of measurable metrics (key risk indicators) to monitor the Risk Profile and to communicate the boundaries to senior management.

• Risk Appetite setting and calibration: Risk Appetite is set at an aggregated bank-wide level across the different risk categories. The Risk Appetite Framework provides the principles for cascading this risk appetite down into the organisation. The strategic risk assessment and materiality assessment acts as the starting point for the yearly review, setting and calibration of the Risk Appetite.

• Risk Appetite monitoring and reporting: To validate that the bank remains within the set risk appetite of the defined risk categories it reports the risk profile of ASN Bank monthly via the KRIs and accompanying limits to the applicable Risk Committees. On a monthly basis the Level 1 Risk Appetite Statement KRIs are submitted to the Executive Board via the Integrated Risk Report reflecting the exposure of the bank to the set risk appetite. Risk Appetite escalation and breach management aligns with escalation for economic capital and recovery & resolution planning.

Areas of attention

During 2025, ASN Bank implemented multiple improvements in the RMF, as a deliverable of the Risk & Compliance Transformation programme. A new House of Policies was designed, the RAS process updated, and a new risk reporting cycle was in place.

The bank has updated its methodology enhancing requirements for risk appetite setting and calibration and clarifying roles and responsibilities in relation with risk appetite. Additionally, the bank improved the governance cycle including risk appetite review and approval in (Risk) committees and the ExBo.

Also, the bank aligned its risk committee structure to the new ASN Bank organisation as described in the paragraph Risk Committee Structure.

At the end of every year, the bank executes an internal review of all identified deviations to a proper functioning of the internal control system. These deviations are translated into areas of attention, which are ultimately reviewed by the ExBo for their overall impact and required actions.

Below is an overview of the areas of attention, resulting from our internal risk assessments, including mitigating measures.

The bank is continuously improving the risk culture by establishing and translating a healthy and mature risk culture into effective behaviour throughout the entire organisation in an integrated and comprehensible manner.

During 2025, many improvements in the renewed Risk Management Framework were implemented as part of the Risk & Compliance Transformation programme. A new House of Policies was designed, the Risk Appetite Statement process updated, Regulatory Change process (including installation of a Regulatory Change Board) and a new risk report and cycle is set in place. The risk management organisation has also been strengthened by focusing on additional knowledge and experience, where necessary from outside the organisation. Further mitigating measures focused on strengthening risk awareness and behavioural alignment, including bank wide masterclasses on the business model, regulatory environment and key risks, complemented by interactive, values-based discussions to support risk informed decision making.

For 2026, we will further strengthen the culture, further interventions have been planned as part of our company wide corporate culture. In addition, we will continue to operationalise and improve the risk and compliance management processes within the first and second line following the roll-out of the defined road maps. We will also focus on the improvement of Control testing, Risk reporting, implementation of the Model Risk Management Framework, setting up the Independent Validation Unit, and regulatory monitoring.

The evolution towards a risk mature organisation will require ongoing management attention and perseverance.

The control framework for Data risks is being improved. While the necessary data capabilities are defined, further strengthening awareness, knowledge, and skills related to data throughout the organisation requires continued attention.

To address the identified need to further strengthen data awareness, knowledge and skills across the organisation, the Data Management Risk policy was updated and is translated to underlying standards and controls. Implementation of this policy is supported by a newly developed data Target Operating Model which clarifies data related roles, responsibilities and accountabilities across business units and data domains. This operating model serves as a foundation for embedding data governance requirements into daily activities and supports targeted training and capability development.

For 2026, the bank is fully focused on realising being in control for BCBS 239 for financial and non-financial reporting, in line with the roadmap planning.

The bank is continuing to strengthen its alignment with regulatory requirements and supervisory expectations, with particular focus on credit risk models. Initiatives are underway to further enhance model quality, data and methodological foundations, and governance across the relevant domains.

These improvements are expected to reinforce the accuracy and robustness of parameters used for RWA and provisioning, support a more risk sensitive capital framework, and enhance the quality and depth of insight into the bank’s underlying risk profile.

The execution of the Path to Green (P2G) for model risk focuses on implementing structural enhancements in the Data & IT processes and addressing findings The execution is monitored in the Model Governance Committee (MGC). The Model Risk Management House of Policies is approved in accordance with internal governance. The implementation will further strengthen the model risk management framework and enhance the governance and effectiveness of the model life cycle.

Ensuring alignment with applicable laws and regulations remains a key priority for the bank. Ongoing initiatives focus on the implementation and embedding of regulatory requirements across areas such as AML, data protection (GDPR), climate risk, data management, and risk and provisioning models, including IFRS 9.

Regulatory risks are mitigated through an operational Regulatory Change Management process, including active engagement initiatives such as roadshows. Legal is closely involved in all supervisory files, ensuring timely interpretation and application of regulatory requirements.

In addition, first line compliance and activity reporting is aligned and subject to review by the second line, with further refinement of this process ongoing.

In the area of Wwft and Sanctions Act compliance, the bank is continuing to strengthen the effectiveness of customer due diligence and ongoing monitoring processes. At the reporting date, these processes are operational, but their execution requires further enhancement to fully meet our obligations and supervisory expectations.

AFC risks are mitigated through strengthened governance and oversight. During 2025, the Chief Financial Crime Officer (CFCO) role was established and embedded in the Executive Board, reinforcing senior management accountability for AFC matters. In addition, the AFC budget has been structurally integrated into the standard investment and operational planning (IP/OP) process.

Planned AFC remediation actions for 2025 have been realised. The remediation plan has been evaluated and translated into an operational roadmap for 2026. Compliance is further embedding its second line role through the Quality Management Framework, enhancing ongoing oversight and challenge.

The bank is developing further insight into its privacy-related risks. Data cleansing and data retention remain an ongoing area of attention into 2026, alongside continued focus on the security of personal data exchanges.

Privacy risks are mitigated through a structured roadmap that is actively being implemented. Further embedding and alignment with the ISO privacy framework is planned for 2026, supporting continued strengthening of privacy controls.

In the current reality we are aware of the continuous threat of a possible cyber-attack. Also, we face the risk that our IT systems are unable to keep up with market and supervisory developments, which could lead to unrealised strategic priorities.

These risks are mitigated through continuous strengthening and transformation of the IT landscape, focusing on resilience, security and flexibility. Modernisation of the IT environment remains a strategic priority for 2026, further enhancing the bank’s ability to deliver high quality services and respond to regulatory and market developments.

Supervisory actions

At the end of January 2025, De Nederlandsche Bank (DNB) imposed a fine of € 5 million for shortcomings in the bank’s organisation and operations to comply with the Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en financieren van terrorisme - Wwft). At the same time, DNB also imposed a fine of € 15 million for shortcomings in risk management as a result of not complying with the sound business operations-related requirements under the Financial Supervision Act (Wet op het financieel toezicht - Wft).

The bank is currently in the process of strengthening its risk management and ensuring sound business operations, to comply with Wwft and Wft requirements. This means that:

• A risk transformation programme was initiated to improve our risk management processes. As from July, required remediations have been incorporated in the improvement planning of the restructured risk management organisation. The risk management organisation has also been strengthened by focusing on additional knowledge and experience, where necessary from outside the organisation. We are fully committed, and have set to work, to sustainably and adequately address the identified deficiencies in risk management to comply with laws and regulations. The bank is prioritising improved monitoring, reporting and tightened escalation mechanisms.

• With effect from 1 February 2025, a renewed AFC organisation has been implemented. The bank introduced a simplified organisational structure across all three lines with clear mandates and responsibilities to manage and mitigate the AFC risks that the bank is potentially exposed to. We are committed to a healthy risk culture and managing our customer portfolio within the boundaries of our risk appetite.

• During 2025 ASN Bank has made substantial progress in reducing AFC risks by:

  • Advanced in-depth insights in AFC risks as part of our SIRA 2024 and the necessary requirements to further mitigate these risks.

  • Reduction in operational backlogs for transaction monitoring and customer due diligence.

  • Further improvements in sanctions screening processes and systems.

  • Start of large-scale customer data remediation and customer risk reassessment.

  • Development of AFC standards and risk frameworks in line with market practices.

For more detailed information on the Anti-financial crime (AFC) remediation, see Section Anti-financial crime in the Sustainability statements in the Annual Report 2025.

Overall, we have made good progress in strengthening our remediation efforts in anti-money laundering and risk management. We maintain a continuous dialogue with our supervisory authorities on the progress of all ongoing improvements.

Risk culture and awareness

A strong risk culture identifies, manages and controls relevant risks in line with the bank's vision, risk appetite and customer needs, all within the applicable legal frameworks. It shapes management and employees’ day-to-day decisions and fosters an atmosphere of open communication and constructive challenge which is a prerequisite for effective risk management and risk awareness. We aim for the envisaged risk culture to be endorsed by the entire organisation. This starts by using the bank’s RMF policy that describes our overall risk management governance.

In 2025, a new vision on risk culture was developed and rolled out, intended to strengthen the risk culture within ASN Bank. Multiple initiatives were rolled out to raise risk awareness and provide guidance towards desired behaviour like 'whole system in the room' workshops  to strengthen cooperation between first and second line and dilemma management. Additionally, all employees are expected to include a goal regarding risk awareness in their performance cycle.

In January 2025, we measured the perceived integrity and risk culture within ASN Bank with an employee survey. This survey included the main elements from ASN Bank risk culture model and EBA requirements. The results showed that employees experience an improvement in certain areas of the risk culture, mainly in leading by example (2025: 74.8%; 2023: 73.6%) and feasibility (2025: 78.3%; 2023: 77.6%). Commitment (94%), discussability (80%) and accountability (77%) remained at the same level whereas transparency (2025: 65.2%; 2023: 66.9%) and enforcement (2025: 80.3%; 2023: 83%) showed a small decline.

Risk awareness is the ability to spot risks that could impact the organisation. We raise risk awareness among our employees by helping them identify, assess and respond better and more consciously to (potential) risks. We do this by providing training courses, workshops and e-learning programmes as well as by sharing risk awareness-related success stories and lessons learned with our employees. This risk awareness framework is carefully maintained and continuously improved, and new rules and regulations are embedded into the different policies that are accessible to employees in the policy framework. We encourage a critical consideration of the risk-return ratio by focusing on the interests of our customers, society, our employees and the shareholder.

Internal code of conduct

We expect our employees to show good corporate behaviour. They are guided in this by our Code of Conduct: ‘Common Sense, Clear Conscience’, which focuses on moral dilemmas and how to deal with them. A well-spread network of confidential counsellors offers staff the opportunity to raise concerns about malpractices.

Remuneration policy

ASN Bank pursues a remuneration policy based on the strategy of building strong customer relationships and increasing its social impact. We do not grant any variable remuneration to discourage employees from taking undesirable risks that may give priority to short-term individual interests over long-term collective objectives. For more detailed information on our remuneration policy, see Section Remuneration report in the Annual Report 2025.

Stress testing

In addition to monitoring our risk indicator-based risk appetite, we use stress tests to gain insight into the sensitivity to changes in the underlying causes and the interrelationship of risks. Several times a year, we calculate a severe yet plausible macroeconomic scenario to determine its effects on aspects such as our profitability, capital and liquidity position. In 2025, we also performed a climate stress test to gain insight in the impact of climate change resulting from both physical and transitional climate-risk drivers. We carry out different types of stress tests to reveal potential vulnerabilities.

For the use of stress tests in relation to credit risk, market risk, liquidity risk and capital adequacy, see the related sections in the Annual Report 2025. For more information on the continued development of climate stress testing, see Section Sustainability risk - Areas of focus and activities.

Business risk

Business risk is defined as the risk that the ASN Bank's profitability deviates from limits that may negatively impact the viability of the bank’s business model and sustainability of the bank’s strategy. Business risk-sub types are:

• Business model risk and

• Transformation risk

Business model risk is defined as the risk that the profitability of ASN Bank deviates from limits that may have a negative impact on the viability of the bank’s business model and sustainability of the bank’s strategy.

Net interest income in 2025 decreased, driven by lower net interest income on cash management activities, due to less volume year-on-year and the decline in the ECB deposit facility rate.

In 2025, both the mortgage and savings market grew. Despite a competitive domestic market, the commercial interest income on residential mortgages increased, driven by portfolio growth in combination with a stable portfolio margin in basis points (bps). Commercial interest income on savings remained virtually stable.

In these markets, we managed to reduce ASN Bank’s excess liquidity as loan growth outpaced the increase in retail deposits. As a result, our loan-to-deposit ratio improved, which makes us less sensitive to future changes in short-term interest rates. In the coming year, we will continue our efforts to optimise our balance sheet.

Total operating expenses, adjusted for incidental items, in 2025 consisting of restructuring charges for our transformation programme and, in 2024 also for a provision related to our anti-financial crime (AFC) remediation programme, increased due to higher consultancy costs. These costs mainly related to our transformation programme and addressing deficiencies in risk management, and to higher IT costs. In addition, expenses in 2024 included a non-recurring gain related to an adjustment in recoverable VAT in previous years. These elements were partly offset by lower regulatory levies and lower staff costs.

Staff costs decreased, despite pressure from (wage) inflation and an increase in temporary FTEs covering remediation work, focusing on anti-financial crime and risk management-related topics. The decrease in staff costs was driven by structural cost savings from our transformation programme. Transformation-related cost savings of around € 35 million were realised, this equates to the € 70 million cost savings on an annualised basis, as announced at the end of 2024.

The next phase of the transformation will lead to an expected FTE reduction of 850–950 throughout 2026. This additional FTE reduction is anticipated to result in an additional annual structural cost saving of approximately € 80 million as of 2027.

ASN Bank has drawn up a Financial Plan & Budget for the 2026-2030 period. This plan sets mission-driven objectives for growth and improvement and includes efficient capital management. At the same time, it carves out a path with actions to achieve our financial objectives.

For more information on ongoing and future actions refer to Section Strategy and performance in the Annual Report 2025.

Transformation risk is defined as the incapability to (rapidly) transform the business in response to changes in the market such as the entry of new competitors, the development of new industry-changing technologies, regulatory requirements or shifts in overall market conditions that may negatively impact the viability and sustainability of the bank’s business model.

We achieved significant progress on our transformation, including the successful brand merge,  which led to  cost savings of € 70 million on an annualised  basis through migrating 2.3 million customers, streamlining the branch network, and reducing the number of FTE.   
Two primary transformation risks are:  1) the ability to sustain the pace of execution and  2) the possible transformation delays. The first risk is driven by the magnitude and scope of simultaneous changes across multiple domains and organisational complexity. The second risk is due to increased interdependencies between changes across systems, processes, and organisational structures in 2026.  

To mitigate these risks,  ASN Bank established a Transformation Office, which has proven effective in delivering risk mitigation through strengthened governance structures. 

The transformation is a centrally orchestrated process and continuously manages activities, sequences the various transformation initiatives, and flags bottlenecks to ensure optimal delivery. Risk management is embedded as a core practice, to assure strong daily customer service and prevents transformation to interfere with the ongoing remediation efforts.

Reputational risk

Reputational risk is the risk that ASN Bank becomes subject to negative public opinion due to internal or external events that may negatively impact the bank’s ability to attract and retain (the support of) customers, employees, society, counterparties, shareholders and supervisory authorities. This may be caused by internal and/or external events and/or developments, which may subsequently result in the loss of stakeholder support and motivation and a direct or indirect financial loss.
Reputational risks may be related to our own conduct in events that are subject to the public's attention, but also to policy decisions, our day-to-day actions and issues regarding products, or the actions of individual employees. External developments may also affect reputational risk as they may change stakeholder expectations of ASN Bank.
The Corporate Communications department actively manages issues at sector and bank level by monitoring and mitigating current and upcoming internal and external events that may result in reputational damage for the bank and its brands. In addition, ASN Bank's Crisis Communication Plan (CCP) includes (press) policies, communication strategies and key messages for various crisis communication scenarios. The CCP is tested and updated annually. ASN Bank measures reputation scores on a quarterly basis. They are conducted by RepTrak, the leading global reputation research company. Since the transition to one brand on 1 July, reputation was measured for ASN Bank, RegioBank and BLG Wonen in the third quarter of 2025, and from the fourth quarter of 2025 onwards is measured exclusively for ASN Bank.

2025 marked many changes. From the rebranding to one brand 'ASN Bank', the closing of SNS branches in March, to the reduction of over 700 FTEs, and the announcement in November of the new strategy and an additional reduction of 850-950 FTEs throughout 2026.

In 2025, the customer-weighted average NPS decreased to -7 (year-end 2024: +4). Key drivers for the decline were a greater than expected impact from the transformation and rebranding, the reduction of branches and mandatory customer re-identification procedures. In our new strategy, we are targeting the highest NPS position among the major systemic Dutch banks. At year-end 2025, we ended in joint second position, driven by the transformation impact.

The above-mentioned developments did not lead to significant fluctuations in the bank's 2025 reputation scores. The RepTrak research shows that ASN Bank still outperforms on relevant reputational drivers such as conduct, products and services and citizenship. As a result ASN Bank holds the top position in the Dutch banking industry, as well as on ESG-related themes.

Sustainability risk (In scope of CSRD)

Sustainability risk is the risk of financial and/or reputational damage as a result of Environmental, Social and Governance (ESG) developments. Developments related to sustainability risk are elaborated on in Section Sustainability risk.

Management and control

Operational risk management aims to minimise operational losses at reasonable cost while meeting regulatory requirements, with risk appetite and supporting risk indicators captured in the Risk Appetite Statement (RAS).

Operational risk governance is anchored in the three lines model: the business owns and manages risks and controls; the independent risk management and compliance functions set the frameworks, advise, monitor and challenge; and the internal audit function independently assesses the effectiveness of the first and second line.

The Executive Board (ExBo) is ultimately responsible for managing and controlling non-financial risks. The Supervisory Board (SB) supervises, advises, challenges and supports the ExBo in its management of non-financial risks, specifically via the Risk & Compliance Committee (R&CC). ASN Bank has a risk taxonomy and related controls in place to identify, closely monitor and report on the risks. The non-financial risk committee (NFRC) reviews and assesses non-financial risks monthly, based on ASN Bank's risk appetite. Further oversight committees are described in the Section Risk governance.

For Pillar 1 capital purposes, operational risk requirements are calculated using the standardised approach. The outcome provides input to the internal capital adequacy assessment process (ICAAP). For ongoing measurement and management, ASN Bank uses a risk control framework to monitor control effectiveness, evaluates and monitors issues and incidents, and applies (key) risk indicators (KRIs) to measure exposures against appetite.

In the first half of 2025, the CRO domain completed a 2nd line improvement programme, which resulted in enhanced risk management framework and processes (e.g. policies, risk appetite process, integrated risk reporting).

Operational risk

For operational risk, the most important sub-risks and developments of 2025 are highlighted below, specifically: people risk, technology, information security and data management risks, as well as third party risks. ASN Bank acts on the other risk types in line with the Risk Management Framework (RMF) of the bank.

Compliance risk

We define compliance risk as the risk that ASN Bank fails to comply with laws, or the spirit of any such laws, additional regulations, self-regulation and any relevant codes of conduct.

The compliance function continuously monitors compliance with laws, regulations and internal policies. The taxonomy of compliance risk distinguishes five sub-risks:

• External fraud risk

• Internal fraud risk

• Conduct risk

• Financial crime risk

• Regulatory compliance risk

We ensure better identification and management of compliance risks by means of tools, such as regulatory technology, compliance management dashboards and new privacy tooling.

The bank conducted an ESG materiality assessment in 2025; the results for compliance risk are included in the Section Sustainability risk.

Below, we describe the most important compliance risk-related developments in 2025.

Model risk

Model risk is the risk that the use of models has a negative impact on society, customers, employees of the bank, or the financial position of the bank. Model risk arises from errors in the development, implementation, use, or interpretation of models, leading to inaccurate, non-compliant, or misinterpreted model output.

Model risk governance and maintenance are an ongoing process involving many discussions and iterations with the ECB, DNB and the JST. We have paid considerable attention to improving compliance with regulatory capital and provisions-related regulations, especially with respect to the residential mortgage portfolio.

The active model versions (including those for regulatory capital and the IFRS 9 provisioning for our residential mortgages) are part of our internal ongoing validation cycle in accordance with regulatory requirements and internal policies. In December 2025, model risk remains outside our risk appetite, as further improvement is required on key aspects such as data, IT infrastructure and (credit) processes, as well as in the implementation of the newly approved model risk management framework. To sufficiently mitigate this model risk in our regulatory capital model we continue to hold additional capital (a self-imposed capital add-on, SIA) with clear focus on strengthening our management and use of models.

In 2025, we have finalised the new iteration of our regulatory capital models and provisioning models for our residential mortgage portfolio. The regulatory capital models are currently undergoing a supervisory approval process. The IFRS 9 ECL model was upgraded and internally approved, for more information, see the Section Provisioning methodology.

Risk profile

Over the past years the credit risk of ASN Bank’s portfolios decreased due to the strong economic situation of the Netherlands. The unemployment rate is low, salaries increased, house prices increased, and the customer interest rates are favourable. As a result the number of customers in arrears or in default remains low. Portfolio developments are in line with ASN Bank’s strategy to increase market share and fit well within the risk appetite of the bank.

Also throughout 2025, interest-only mortgages had our continued attention. We explored additional de-risking measures for interest-only mortgages in the Netherlands. ASN Bank implemented processes to gather information on customers' intention to repay their interest-only mortgage and the affordability of the mortgage at maturity, aligning with ECB guidance. These measures may result in further scrutiny of the future loan volume development, impairment charges and capital.

For Other corporate and government loans, ASN Bank faced a deteriorated financial situation of multiple Sustainable Finance loans. Besides the windmill parks and solar energy parks, ASN Bank also invested in several innovative projects for which the business cases appeared to be less sound than initially projected at origination. ASN Bank placed selected loans on the watchlist and holds higher individually determined provisions for these loans. In 2025, a non-performing loan with a significant exposure was unwound. ASN Bank will continue to closely and actively manage this portfolio from a risk perspective. ASN Bank held appropriate credit provisions for the problem loans during 2025.

The risk profiles for SME loans, Other retail loans and Private placement loans did not significantly change throughout 2025. The portfolio volumes grew only slightly in 2025, the loan sizes are small, and these portfolios are both in absolute and relative terms less material on ASN Bank’s balance sheet.

Additional credit risk information